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
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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
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• 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.
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