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HomeMy WebLinkAboutNC0044024_Fact Sheet_20180905FACT SHEET FOR EXPEDITED PERMIT RENEWALS This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Basic Information for Expedited Permit Renewals Permit Writer / Date Brianna Young 9/5/18 Permit Number NCO044024 Facility Name / Facility Class Highway 52 WTP / PC -1 Basin Name / Sub -basin number Yadkin Pee -Dee River / 03-07-13 Receiving Stream / HUC UT to Little Long Creek / 0304010504 Stream Classification / Stream Segment C / Index: 13-17-31-1 Does permit need Daily Maximum NH3 limits? N/A Does permit need TRC limits/language? Already present Does permit have toxicity testing? IWC (%) if so Yes; IWC = 100% (capped at 90%) Does permit have Special Conditions? No Does permit have instream monitoring? Yes — added upstream hardness in renewal Is the stream impair d on 303(d) list)? No Any obvious compliance concerns? No Any permit mods since lastpermit? No New expiration date 2/28/2023 Comments on Draft Permit? Yes; see below Facility Overview: City of Albemarle operates a conventional water treatment plant with a potable design flow of 12 MGD. In September 2013, the Permittee began sending all the WTP wastewater via a gravity sewer to the local POTW but has requested the current NPDES permit be renewed to maintain the outfall as a backup when the POTW cannot accept any portions of the WTP wastewater. Two (2) discharge occurred between December 2014 and December 2017 (occurred in February 2016) and the monthly average was 0.799 MGD. Since September 2013 there have been episodic discharges. Only partial monitoring was completed during episodic events. Compliance History (February 2013 and February 2018): • 1 NOD for pH limit violation • 1 NOV for TSS limit violation • 1 NOV each monitoring violations for copper, iron, pH, and TSS • No recent toxicity data available from aquatic tox group Page 1 of 3 RPA: Two (2) discharge occurred between December 2014 and March 2018 (both occurred in February 2016) and monthly average was 0.799 MGD. • Copper — Reasonable potential to exceed WQS based on a limited dataset; Limits added with monthly monitoring • Fluoride — No reasonable potential to exceed WQS based on a limited dataset; Monitoring reduced to quarterly but being maintained as facility indicated fluoride has the potential to be discharged and historical data indicates predicted max > 50% allowable Cw • Zinc No reasonable potential to exceed WQS based on a limited dataset, but predicted max > 50% allowable Cw; Monitoring reduced to quarterly NCG59 General Permit Eligibility: • Limits added for total copper; therefore, the facility is not eligible for the NCG59 • Limited toxicity data available; therefore, the facility is not eligible for the NCG59 • Conclusion: Facility is not eligible for the NCG59 Chances from previous permit to draft: • Added eDMR footnote in A(1) and language as A(3) • Updated outfall map • Added regulatory citations • Added parameter codes in A(1) • Added units of measure in A(1) • Updated language on Supplement to Permit Cover Sheet per 2012 WTP guidance • Removed Weekly Average column from A(1) as it is no longer required per the current WTP strategy • Removed flow limit from A(1) per 2009 WTP strategy • Reworded pH limits in A(1) to match current NPDES formatting • Added turbidity monitoring per 2009 WTP strategy o No indication why this was removed in 2009 permit 0 2009 permit renewal predated revised WTP strategy, therefore turbidity monitoring restored in this renewal based on current WTP strategy • Monitoring increased to weekly for TSS, pH, and TRC per 2012 WTP guidance • Removed monitoring for calcium and magnesium in A(1) per 2009 WTP strategy • Removed monitoring for manganese in A(1) as there is no longer a WQS and facility does not discharge into a water supply • Removed monitoring for iron in A(1) as there is no longer a WQS, the facility indicated in the renewal application that iron sulfate/ferrous sulfate does not have the potential to be discharged, and iron was monitor only in the previous permit • Monitoring for fluoride and zinc reduced to quarterly based on RPA Page 2 of 3 • Limits added for copper based on RPA • Removed monitoring for ammonia nitrogen as the facility indicated that ammonia nitrogen/chloramines did not have the potential to be discharged in renewal application and per 2009 WTP strategy • Added quarterly hardness monitoring in A(1) per current WTP guidance • Added Monitor & Report for WET testing in A(1) per 2012 WTP guidance • Updated flow footnote (now #2) in A(1) • Updated #2 and #3 footnotes about TRC in A(1) into one footnote (now #3) using current language • Removed footnote #4 in A(1) stating "Zinc should be monitored if a Permittee uses zinc orthophosphate as a corrosion inhibitor" as monitoring is required since the facility indicated in the renewal application that zinc has the potential to be discharged • Removed footnote #5 in A(1) stating "Facilities using chloramination will be required to monitor ammonia nitrogen on a quarterly basis" since monitoring is no longer required • Removed footnote #6 in A(1) stating "Parameters should be monitored in conjunction with toxicity test" as this is no longer required • Removed footnote #7 stating "Fluoride monitoring applies if the facility backwashes with fluoridated, finished water" as monitoring is required since the facility indicated in the renewal application that fluoride has the potential to be discharged • Updated tox footnote in A(1) • Toxicity test in A(1) and A(2) changed from chronic 7 day test to acute 48 hour test per October 2012 memo from aquatic toxicology unit as facility only discharges episodically o Per Susan Meadows from ATU (email 3/1/18): I have been talking with Wes Bell (MRO) and Roberto Scheller (current inspector for this facility) about this them. Roberto conducted a compliance inspection in 2017 for this facility. The permit is being kept open for emergency conditions, 99.9% of the time this will be reported as "no discharge". So, as far as Tox goes, I have no problem with 48 hr. Acute. It would make the most sense to run the acute in an emergency or under sporadic conditions. Comments received on draft permit: • Wastewater Operator Certification Group (Maureen Kinney via email to MRO 6/28/18): This permit appears to be a PC -2 facility and may need to be reclassified. o MRO response (Wes Bell via email 6/28/18): The only treatment this wastewater would receive is dechlorination. Normally, all WTP wastewater goes to the City's WWTP, the discharge outfall is for emergencies only. All the other listed treatment chemicals (besides sodium bisulfite — dechlor chemical) are for the potable water treatment process, not the wastewater treatment process. The WTP wastewater currently goes into an EQ tank and then metered into the City's collection system. Page 3 of 3