NC0029980_Fact Sheet_20180717

Fact Sheet
NPDES Permit No. NCOO2998O
Permit Writer/Email Contact Qais Banihani, [e-mail]:
Date: Month 17, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
N Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2' species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
MillerCoors LLC
Applicant Address:
863 E. Meadow Dr., Eden, NC 27289
Facility Address:
863 E. Meadow Dr., Eden, NC 27289
Permitted Flow:
5.2 MGD
Facility Type/Waste:
Industrial
Facility Class:
IV
Treatment Units:
Bar screen, grit chamber, neutralization, equalization, aeration
basins/secondary clarifiers and polishing lagoons
Pretreatment Program (Y/N)
N
County:
Rockingham
Region
Winston - Salem
Briefly describe the proposed permitting action and facility background: The MillerCoors LLC, herein
called MillerCoors or Permittee, applied for an NPDES permit renewal. The Permittee's 5 -year NPDES
permit expired on April 30, 2017. This facility is a brewing and packing facility for malt beverages. The
process includes brewing, fermenting, aging and packing. Wastewaters generated during the process are
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treated in a 5.2 MGD activated sludge wastewater treatment facility. MillerCoors ceased all manufacturing
activities as of September 2016 and implemented facility closure work. The final flow cessation date was
in April 2017. However, the facility requested to retain its NPDES permit in June 2017.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — Dan River
Stream Segment:
22-(39)a
Stream Classification:
C
Drainage Area (mi2):
1735
Summer 7Q10 (cfs)
369
Winter 7Q 10 (cfs):
608
30Q2 (cfs):
738
Average Flow (cfs):
1648
IWC (% effluent):
2.1
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes- State wide Mercury TMDL implementation
Subbasin/HUC:
03-02-03; 03010103
USGS Topo Quad:
B20NW
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of January 2014 through April 2017.
Table 1. Effluent Data Summary Outfall 001
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Permit
Parameter
Units
Average
Max
Min
Limit
Flow
MGD
1.28
4.24
0.11
MA 5.2
MA 1,648.0DM
BOD
lb/d
181.49
2,222.0
11.0
3,990.0
MA 2,429.0DM
TSS
lb/d
308.19
4,579.0
14.0
5,855.0
NH3N
mg/l
0.99
16.5
< 0.1
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DO
mg/l
6.21
29.0
0.2
Average
Temperature
° C
20.88
35.0
3.0
Min
PH
SU
8.42
9.0
7.5
6.0:S pH <
9.0
Total Zinc
µg/1
118.38
1050
18
TN
mg/l
9.60
41.0
< 0.2
TP
mg/l
369.0
14,400
0.27
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring
Coalitions established in several basins that conduct instream sampling for the Permittee (in which case
instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposedfor this permit
action: The current permit requires instream monitoring for Dissolved Oxygen (DO) and Temperature. A
review of instream data from June 2014 through September 2016 indicates that the DO standard of 5 mg/L
was maintained. Data collected is within normal parameters for DO and temperature. Instream data is
summarized in tables 2 and 3. This draft permit maintains the same instream monitoring requirements.
Table 2: Upstream Instream Data (June 2014 - September 2016)
Table 3: Downstream Instream Data (June 2014 - September 2016)
DO
m /L
DO
Temperature
m /L
°C
Average
7.57
8.02
Max
8.5
9.0
Min
6.7
7.0
Table 3: Downstream Instream Data (June 2014 - September 2016)
DO
m /L
Temperature
°C
Average 23.41
23.79
Max 28.0
28.0
Min 18.0
18.0
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): NO
Name of Monitoring Coalition: NA
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5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported no limit
violations from June 2012 to March 2018.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): Since 2013, the facility passed 17 of 17 quarterly chronic toxicity tests
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
on July 2017 reported that the facility operations were found to be shut down and no flow is anticipated.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: NA
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/l (summer) and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The facility does
not have chlorination; therefore, no TRC limit. The NH3-N allowable concentration for summer and winter
exceeded 35 mg/L; therefore, monitor only. There are no proposed changes.
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Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of '/2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between January 2014
and April 2017. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria: NA
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but
the maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was <50% of the allowable concentration: Total Zinc
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: A chronic WET limit at 2.1% effluent will continue on a
quarterly frequency.
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Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will receive
an MMP requirement. Industrials are evaluated on a case-by-case basis, depending if mercury is a pollutant
of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL
value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/1
Describe proposed permit actions based on mercury evaluation: Mercury is not a pollutant of concern for
this facility and the permittee did not test any mercury for this renewal. There are no proposed changes.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: NA
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or OR W) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H. 010 7(c) (2) (B), 40CFR 122.4 7, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: brewing and packing
List the federal effluent limitations guideline (ELG) for this facility: NA
If the ELG is based on production or flow, document how the average production/flow value was calculated:
NA
For ELG limits, document the calculations used to develop TBEL limits: NA
If any limits are based on best professional judgement (BPJ), describe development: The last waste load
allocations was completed in 1996. Limits for BOD and TSS were based in proposed effluent guidelines.
The guidelines were never finalized and the limits were modified in 2003 based on BPJ. The BOD
monthly and daily limits were based on concentrations of 38 mg/1 and 92 mg/1 respectively. TSS monthly
and daily limits were based on concentrations of 56 mg/1 and 135 mg/1 respectively. Current permit limits
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are 1648 lb/day monthly average and 3990 lb/day daily maximum for BOD and 2429 lb/day monthly
average and 5855 lb/day daily maximum for TSS.
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review
Sections 402(0)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): Yes
If YES, confirm that antibacksliding provisions are not violated: Based on RPA, no monitoring will be
required for Total Zinc.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(0) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
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11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
A. Table 4. Current Permit Conditions and Proposed Changes 5.2 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 5.2 MGD
No change
15A NCAC 213 .0505
BODS
MA 1,648 lbs/d
No change
Based on 2003 BPJ
DM 3,990 lbs/d
TSS
MA 2,429 lbs/d
No change
Based on 2003 BPJ
DM 5,855 lbs/d
NH3-N
Weekly
No change
WQBEL. Based on protection of
State WQ criteria (WLA). 15A
NCAC 2B.0200
DO
Daily
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
Temperature
Daily
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
Total Zinc
Monthly
Remove monitoring
No reasonable potential (RP) found
in RPA
Total Nitrogen
Monitor Only - Monthly
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
Total Phosphorus
Monitor Only - Monthly
No change
WQBEL. State WQ standard, 15A
NCAC 213.0200
Toxicity Test
Chronic limit, 2.1 %
No change
WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 213.0200
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
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13. Public Notice Schedule:
Permit to Public Notice: 05/29/2018
Per 15A NCAC 2H .0109 & .0 111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes
If Yes, list changes and their basis below:
Winston-Salem regional Office (WSRO) did make a comment on the draft renewal permit due to the fact
that the facility has been unoccupied for more than 1.5 years and it requires significant maintenance prior
to any future discharge. WSRO requested to add a condition that pre -startup inspection be conducted
before restarting the discharge.
In response, the following text has been added to the Supplement to Permit Cover Sheet: "At the
time of this permit renewal, the facility has been unoccupied for more than a year and a half. The
wastewater system is not operational, and will require significant maintenance prior to any future
discharge.
The permittee shall notify the NC DEQ Winston-Salem Regional Office (WSRO) at least 30
days prior to any planned restart of this treatment facility. WSRO staff approval is required prior
to any future discharge from this system."
15. Fact Sheet Attachments (if applicable):
RPA Spreadsheet Summary
Dissolved Metals Implementation/Freshwater or Saltwater
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