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HomeMy WebLinkAboutWQ0005906_Final Permit_20011130State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Gregory G. Thorpe, Ph.D., Acting Director November 30, 2001 MR. ROBERT C. Amos, PLANT MANAGER E.I. DUPONT DE NEMOURS AND COMPANY POST OFFICE Box 800 KINSTON, NORTH CAROLINA 28502-0800 I� N/ Z, 0 2 NCDENR FORTH CAROLINA DEPARTMENT OF FNVIRONMENT AND NATURAL RESOURCES Subject: Permit No. WQ0005906 E.1- DuPont de Nemours and Company Kentec Facility Groundwater Remediation and Disposal Facilities Lenoir County Dear Mr. Amos: In accordance with your permit modification application package received on September 7, 2001 as well as the additional information received on November 19, 2001 and November 27, 2001, we are forwarding herewith Permit No. WQ0005906, dated November 30, 2001, to E.I. DuPont de Nemours and Company for the construction and continued operation of the subject groundwater remediation and disposal facilities. This permit has been modified to approve the construction and operation of an infiltration gallery for the disposal of groundwater being -remediated under the Corrective Action Plan for the Kentec Facility that was originally prepared on July 11, 1991 for Groundwater Incident No. 6334. It is believed that the use of the infiltration gallery will shorten the time required for completing the groundwater remediation activities without causing a migration of contaminated groundwater into currently unaffected areas. As such, the infiltration gallery is now proposed to be the primary disposal method for remediated groundwater; however, the option to "pump and haul" the remediated groundwater is still being retained in this issuance of this permit. This permit shall be effective from the date of issuance until February 28, 2003; shall void Permit No. WQ0005906, issued on May 1, 1998; and shall be subject to the conditions and limitations as specified therein. Please take time to review this permit thoroughly, as some of the conditions may have been added or amended since the last issuance of this permit. Of special interest is the fact that hydrogen peroxide is no longer used in the Ultrox F-325 to assist in the oxidization of the contaminants present in the groundwater to be remediated. For this reason, the hydrogen peroxide feed system has been removed from the description of the required groundwater remediation and disposal facilities. Note that, should hydrogen peroxide be needed once again to achieve stipulated groundwater remediation efficiencies, a formal modification of this permit must be submitted to and approved by the Division of Water Quality prior to installation and operation of the feed system_ Finally, as always, pay particular attention to the monitoring requirements in this permit. Failure to establish an adequate system for collecting and maintaining the required operational information will result in future compliance problems. If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes. and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made ,this permit shall be final and binding. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-5063 Fax (919) 733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper One set of approved plans and specifications is being forwarded to you. If you have any questions concerning the conditions listed in Section IV. (i.e., Groundwater Requirements) of this permit., please contact Mr. David L. Goodrich of the Division of Water Quality's (Division) Groundwater Section at (919) 715-6162. If you need any additional information concerning other sections of this permit, please contact Ms. Shannon Mohr Thornburg at (919) 733-5083, extension 353. Sincer .,,2 Gregory J. Thorpe, Ph.D. cc: Mr. Andrew F. Alcazar, E.I. DuPont de Nemours and Company Mr. Mark B. Robinson, P.E., URS Corporation Lenoir County Health Department Washington Regional Office, Water Quality Section Washington Regional Office, Groundwater Section Central Office, Groundwater Section Technical Assistance and Certification Unit Non -Discharge Compliance/Enforcement Unit NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH GROUNDWATER REMEDIATION AND DISPOSAL FACILITIES PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations PERMISSION IS HEREBY GRANTED TO E.I. DuPont de Nemours and Company Lenoir County FBI ; WIN , construction and continued operation of 20,000-gallon per day groundwater remediation and disposal facilities to serve E.I. DuPont de Nemours and Company's Kentec Facility, with no discharge of wastes to surface waters, pursuant to the permit modification application package received on September 7, 2001 as well as the additional information received on November 19, 2001 and November 27, 2001, and in conformity with the project plans, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural Resources and considered a part of this permit. The approved groundwater remediation facilities shall be capable of treating up to 11,520 gallons per day of contaminated groundwater and shall consist of the following minimum components: approximately 2,605 linear feet of six-inch groundwater interceptor piping for removal of groundwater from the surficial aquifer; two simplex pump stations, each equipped with a one -horsepower pump and.high-water alarms, for collection of groundwater and its conveyance to treatment; a sand filter and a fiber pre -filter for the removal of solids and iron precipitates from the groundwater; a 600-gallon tank equipped with a transfer pump for equalization of the groundwater and its pretreatment with ozone; two fiber filters for final pre-treatment polishing of the groundwater; a metering system for measuring groundwater flow; an Ultrox F-325 including a 14-pound ozone generator and a catalytic ozone decomposer for the oxidation of contaminants present in the groundwater with ozone and ultraviolet light; a 350- gallon tank equipped with a transfer pump for post -equalization of the groundwater and its conveyance to additional treatment; two 165 pound activated carbon units for final polishing of the groundwater; two 16,000- gallon tanks equipped with a transfer pump for the storage of the remediated groundwater and its conveyance to final disposal (i.e., through pump and haul activities); one 1,000-gallon tank for the storage of the remediated groundwater and its conveyance to final disposal (i.e., through the infiltration gallery); and all associated piping, valves, electrical and instrumentation/control systems, and other related appurtenances required to make complete and functional remediated groundwater disposal facilities The approved disposal facilities shall consist of the following minimum components: facilities to recycle up to 2,000 gallons per day of remediated groundwater in the Kentec Facility for reuse in the parts cleaning process; facilities to collect, transport via railcar, and dispose of up to 20,000 gallons per day of remediated groundwater in wastewater treatment facilities serving E.I. DuPont de Nemours and Company's Kinston, NC Plant (i.e., NPDES Permit No. NC0003760), also known as "pump and haul" activities; and the facilities to discharge up to 8,640 gallons per day of remediated groundwater into one 4,625-square foot infiltration gallery approximately 18.5 feet wide, 250-feet long, and one foot deep; and all associated piping, valves, electrical and instrumentation/control systems, and other related appurtenances required to make complete and functional remediated groundwater disposal facilities This permit shall be effective from the date of issuance until February 28, 2003; shall void Permit No. WQ005906, issued on May 1, 1998; and shall be subject to the following specified conditions and limitations: 1. PERFORMANCE STANDARDS Construction of the new groundwater remediation and disposal facilities (i.e., those approved with this permit modification) shall be scheduled and performed so as not to interrupt the service provided by and the proper operation of the existing groundwater remediation and disposal facilities (i.e., those previously approved under this permit) nor result in an overflow, bypass, or discharge of remediated groundwater to the surface waters of the State. 2. Upon completion of construction and prior to operation of this permitted groundwater remediation and disposal facilities, a certification must be received from a professional engineer certifying that the facilities have been installed in accordance with this permit, the approved plans and specifications, and other supporting materials. yIf° the facilities are completed in phases and partiallycertified, you pp g track further to be shall retain the responsibilit to tra construction approved under the same permit and shall provide a final certificate of completion once the entire_ _project has been completed. Mail the certification to the NCDENR-DWQ, Non -Discharge Permitting Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617. The Water Quality Section of the Division of Water Quality's (Division) Washington Regional Office, telephone number (252) 946-6481, shall be notified at least 48 hours in advance of operation of the installed groundwater remediation and disposal facilities so that an in -place inspection can be made. Such notification to the regional super -visor shall be made during normal office hours (i.e., from 8:00 a.m. until 5:00 p-m.) on Monday through Friday, excluding State Holidays. 4. This permit shall become voidable if the soils fail to adequately assimilate the wastes and may be rescinded unless the groundwater remediation and disposal facilities are installed, maintained, and operated in a manner which will protect the assigned water quality standards of the surface waters and groundwater. 5. In the event that the groundwater remediation and' disposal facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those actions that may be required by the Division, such as the construction of additional or replacement groundwater remediation and/or disposal facilities. 6. The issuance of this permit shall not relieve the Permittec of the responsibility for damages to surface water or groundwater resulting from the operation of the groundwater remediation and disposal facilities. In addition, the Permittee shall be liable for any damages cause by a spill or failure of the pump and haul activities. 7. Any residuals generated from the groundwater remediation and disposal facilities shall be disposed in accordance with North Carolina General Statute § 143-215.1 and in a manner approved by the Division. 8. Diversion or bypassing of the untreated groundwater from the groundwater remediation and disposal facilities shall be prohibited. When the option to pump and haul remediated groundwater is exercised, the collected remediated groundwater shall be treated in the wastewater treatment facilities serving E.I. DuPont de Nemours and Company's Kinston., NC Plant (i.e., NPDES Permit No. NC0003760) prior to being discharged into the receiving stream. II. OPERATION AND MAINTENANCE REQUIREMENTS The groundwater remediation and disposal facilities shall be properly maintained and operated at all times. ` 2. Upon classification of the groundwater remediation and disposal facilities by the Water Pollution Control Systems Operators Certification Commission (WPCSOCC), the Permittee shall employ a certified operator to be in responsible charge (ORC) of the facilities. The operator shall hold a certificate of the type and grade at least equivalent to or greater than the classification assigned to the facilities by the WPCSOCC. The Permittee shall also employ a certified back-up operator of the appropriate type and grade to comply with the conditions of 15A NCAC SG .0202. The ORC of the facilities shall visit Class I facilities at least weekly and Class U, III, and IV facilities at least daily, excluding weekends and holidays; shall properly manage and document daily operation and maintenance of the facilities; and shall comply with all other conditions of 15A NCAC 8G .0202. The facilities shall be effectively maintained and operated as a non -discharge system to prevent the discharge of wastes resulting from the operation of the groundwater remediation and disposal facilities. 4. The Permittee shall provide for the maintenance of an audible and visual high-water alarm on all pumping and storage facilities associated with the groundwater remediation and disposal facilities. 5. No wastes other than remediated groundwater from E.I. DuPont de Nemours and Company's Kentec Facility shall be disposed of in the permitted disposal facilities. 6. When the option to pump and haul remediated groundwater is exercised, the remediated groundwater a shall not exceed the following limitations: Monthly Average Maximum Parameter Railcar Concentration Railcar Concentration 1,1-Diebloroethane 14 µg/L 21 µg/L 1,1-Dichloroethene 14 µg/L 21 µg/L 1.4-Dioxane 200 µg/L 200 µg/L a The Corrective Action Plan for the Kentec Facility, dated July 11, 1991, states that the facilities are capable of producing concentrations of 1,1-Dichloroethane, I,1-Dichloroethene, and 1,4-Dioxane of seven micrograms per liter, seven micrograms per liter, and 100 micrograms per liter, respectively. 7. When the option to pump and haul remediated groundwater is exercised, remediated groundwater shall be collected in a 20,000-gallon railcar, and each shall be sampled and analyzed to determine compliance with Condition II. 5. prior to being introduced into any primary components at the wastewater treatment facility serving E.I. DuPont de Nemours and Company's Kinston, NC Plant. The introduction rate of remediated groundwater shall not exceed 20,000 gallons in a 24-hour period. III. MONITORING AND REPORTING REQUIREMENTS 1. Any monitoring deemed necessary by the Division to ensure surface water and groundwater protection shall be established and an acceptable sampling reporting schedule shall be followed. 2. When the option to pump and haul remediated groundwater is exercised, an accurate record of the pump and haul activities shall be maintained by the Permittee. The following minimum information shall be documented: a. Date remediated groundwater is removed, b. Name of the facility from which remediated groundwater is removed, c. Name of the facility receiving the remediated groundwater, d. Volume of remediated groundwater removed, and e. Analytical results of remediated groundwater sampling stipulated in Condition H. 5. and Condition II. 6. The record of the pump and haul activities shall be submitted monthly to the Water Quality Section of the Division's Washington Regional Office on or before the fifteenth day of the month following the activities being reported. Mail the record to the NCDENR-DWQ, Washington Regional Office, 943 Washington Square Mall, Washington, NC 27889. 3, Noncompliance Notification: The Permittee shall report by telephone to the Water Quality Section of the Division's Washington Regional Office, telephone number (252) 946-6481, as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence at the groundwater remediation and disposal facilities that results in the treatment of significant amounts of contaminated groundwater that are abnormal in quantity or characteristic, such as the dumping of the contents of a basin or tank, the known passage of a slug of hazardous substance through the facility, or any other unusual circumstances; b. Any process unit failure, due to known or unknown reasons, that renders the groundwater remediation and disposal facilities incapable of adequate remediation: and disposal, such as mechanical or electrical failures of pumps, aerators, compressors, etc.; c. Any failure of a pumping station, sewer line, or other facility resulting in a bypass directly to surface waters without treatment of all or any portion of the waste influent to such station, line, or facility; or d. Any time that self -monitoring information indicates that the groundwater remediation and disposal facilities are not in compliance with any of the specified permit limitations. Persons reporting such occurrences by telephone shall also file a written report in letter form within five days following first knowledge of the occurrence. This report shall outline the actions taken or proposed to be taken to ensure that the problem does not recur. IV. GROUNDWATER REQUIREMENTS 1. System Performance Requirements: a. The groundwater remediation facilities shall consistently achieve at least 95 percent of the contamination present in the influent groundwater or the Groundwater Quality Standards stipulated in 15A NCAC 2L (i.e., whichever is higher) prior to discharge into the infiltration gallery. If the facilities fail to achieve this performance standard consistently, additional groundwater remediation facilities or changes in operation may be required. 27.. Operational Requirements: a. Prior to the operation of the infiltration gallery, a piezometer shall be installed near the center of the infiltration gallery to monitor the elevation of the water table. The water level in the piezometer shall be measured and recorded every 12 hours for the first week after start-up, every week for the next three weeks, every month for the next three months, and every three months thereafter for the life of the infiltration gallery. b. The infiltration gallery shall be operated above the water table at all times. No re -mediated groundwater shall be discharged to the infiltration gallery if the water table rises to within one foot of the bottom of the infiltration gallery. c. The groundwater remediation and disposal facilities shall be inspected weekly. If it is determined that the facilities are malfunctioning, all repairs shall be made as soon as possible and reported to the Groundwater Section of the Division's Washington Regional Office at telephone number (252) 946-6481 within 48 hours. All components of the facilities shall be properly weatherproofed to prevent freezing and failure of the facilities. 3. Sampling Requirements: a. The groundwater influent to and effluent from the groundwater remediation facilities shall be sampled. monthly for the following parameters: 1,1 Dichloroethane pH 1,1-Dichloroethene Water Level 1,4-Dioxane b. Shallow groundwater monitoring wells MW-I, MW-3, MW-4A, MW-6, MW-7A, MW-8, MW- 10A, MW-11A, MW-14A, and MW-15 as well as deep groundwater monitoring wells MW-4B, MW-7B, and MW-14B shall be sampled every January and July for the following parameters: 1,1-Dichloroethane pH 1,1-Dichloroethene Water Level 1,4-Dioxane Shallow groundwater monitoring wells MW-9 and MW-12 shall be sampled on a schedule to be prescribed by the Groundwater Section of the Division's Washington Regional Office after review of the results from each sampling event. Sampling shall be for the following parameters: 1,1 Dichloroethane pH 1,1-Dichloroethene Water Level 1,4-Dioxane Water levels in the groundwater monitoring wells shall be measured prior to sampling the groundwater for the remaining parameters. The depth to water in each well shall be measured from the surveyed point on the top of the casing, which shall be surveyed relative to a common datum. c. Surface water monitoring location SW-11 shall be sampled every January and July for the following parameters: 1,1-Dichloroethane 1,4-Dioxane 1,1-Dichloroethene d. EPA Method 601 shall be used for the analyses of 1,1-Dichloroethane and 1, 1 -Dichloroethene, and EPA Method 8260B shall be used for the analysis of 1,4-Dioxane. The detection limit for all parameters shall be at or below the groundwater quality standards stipulated in 15A NCAC 2L or the lowest practical limit possible by the laboratory. Any parameters detected above the Method Detection Limit (MDL), but below the PQL of 0.5 µg/L shall be qualified (i.e., estimated) and reported. e. Any laboratory selected to analyze parameters shall be Division -certified for those parameters required_ 4. Documentation and Reporting Requirements: a. The results of the sampling and analysis shall be received on the most -recent version of "Groundwater Quality Monitoring: Compliance Report Form" (i.e_, GW-59 Form) with copies of the laboratory analyses attached by the Division's Groundwater Section on or before the last working day of the month following the sampling month. 5 5. 91 b. All reports shall be mailed to the following addresses: NCDENR-DWQ and NCDENR-DWQ Groundwater Section Groundwater Section Permits and Compliance Unit Washington Regional Office 1636 Mail Service Center 943 Washington Square Mall Raleigh, NC 27699-1636 Washington, NC 27889 Updated blank reporting forms may be downloaded from the web site for the Division's Groundwater Section at http://gw.ehnr.state.nc.us/ or requested from one of the two addresses Iisted above. c. The Pertnittee shall retain records of all monitoring information, including calibration and maintenance records, continuous monitoring data, and reports required by this permit for at least three years from the date of sample measurement, report, or applications. Records of this monitoring information shall include, but shall not be limited to, the following: i. Date, exact place, and time of sampling or measurements; ii. Individual who performed the sampling or measurements; iii. Date of performance of analyses; iv. Analytical techniques or methods used; and v. Results of such sampling, measurements, and analyses. d. The Perinittee shall report any monitoring or other information that indicates: i. Any contaminant may cause an endangerment to an underground source of drinking water, ii. Any non-compliance with a permit condition due to a malfunction of the groundwater remediation and disposal facilities; or iii. Any cause of fluid migration outside the injection zone or area. The information shall be provided to the Groundwater Section of the Division's Washington Regional Office verbally within eight hours, telephone number (252) 946-6481, and as a written submission within five days of the occurrence. The written submission shall contain a description of the noncompliant event and its cause as well as the period of noncompliance, including exact dates and times. If the noncompliant event is not corrected and is expected to continue, steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliant event shall be provided to the Groundwater Section of the Division's Washington Regional Office in a timely manner. e. Sixty days prior to closure of the infiltration gallery, the Permittee shall request a rescission of the permit from the Division. Applicable Boundaries: a. The COMPLIANCE BOUNDARY for the disposal system shall be as specified by regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The Compliance Boundary for a disposal system individually permitted after December 31, 1983 shall be established at either (1) 250 feet from the waste disposal area or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An exceedance of groundwater quality standards at or beyond the Compliance Boundary shall be subject to immediate remediation action according to 15A NCAC 2L A106(d)(2). b. In accordance with 15A NCAC 2L, a REVIEW BOUNDARY shall be established around the disposal system midway between the Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of groundwater quality standards at the Review Boundary shall require remediation action in accordance with 15A NCAC 2L .0106(d)(1). The pump and haul activities shall be maintained as an option for the disposal of remediated groundwater at all times. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided. V. INSPECTIONS Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to ensure proper operation of the groundwater remediation and disposal facilities. 2. The Permittee or his designee shall inspect the groundwater remediation and disposal facilities to prevent malfunctions and deterioration, operator errors and discharges which may cause or lead to the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall maintain an inspection log or summary including at least the date and time of inspection, observations made; and any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall be maintained by the Permittee for a period of three years from the date of the inspection and shall be made available upon request to the Division or other permitting authority. Any duly authorized officer, employee, or representative of the Division may, upon presentation of credentials, enter and inspect any property, premises or place on or related to the groundwater remediation and disposal facilities at any reasonable time for the purpose of determining compliance with this permit, may inspect or copy any records that must be maintained under the terms and conditions of this permit, and may obtain samples of groundwater, surface water, or leachate. VI. GENERAL CONDITIONS 1. This permit may be modified or revoked and reissued to incorporate any conditions, limitations, and monitoring requirements that the Division deems necessary in order to protect the environment and public health adequately. 2. This permit shall become voidable unless the groundwater remediation and disposal facilities are constructed in accordance with the conditions of this permit, the approved plans and specifications, other supporting data, and in a manner that has been approved by the Division. In addition, the option to pump and haul remediated groundwater shall not be exercised unless the agreement between E.I. DuPont de Nemours and Company and CSX Transportation, Inc. or Conoco Transportation for the transport of the remediated groundwater by railcar is in full force and effect. 3. This permit shall be effective only with respect to the nature and volume of wastes described in the application and other supporting data. 4. This permit shall not be transferable. In the event there is a desire for the groundwater remediation and disposal facilities to change ownership or there is a name change of the Permittee, a formal permit modification request shall be submitted to the Division accompanied by documentation from the parties involved and other supporting materials as may be appropriate. The approval of this request shall be considered on its merits and may or may not be approved_ 5. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statute § 143-215.6A through § 143-215.6C. 6. The issuance of this permit does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (i.e., local, state, and federal) which have jurisdiction, including, but not Iimited to, applicable river buffer rules in 15A NCAC 2B .0200, erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCGOl0OOOO, and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC 2H .0500. 7. A set of approved plans and specifications for the groundwater remediation and disposal facilities shall be retained by the Perxnittee for the Iife of the facilities. The annual administering and compliance fee shall be paid by the Pennittee within 30 days after being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205 (c)(4). 9. The Permittee, at least six months prior to the expiration of this permit, shall request its extension. Upon receipt of the request, the Division shall review the adequacy of the groundwater remediation and disposal facilities described therein and, if warranted, shall extend the permit for such period of time and under such conditions and limitations as it may deem appropriate. Permit issued this the "irtieth day of November, 2001. NORTH LINA ENV;RP11MENTAL MANAGEMENT COMMISSION �regory J. Thorpe, Ph.D., Acting Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number WQ0005906 Pernrzit No. WQ0005906 November 30, 2001 ENGINEER'S CERTT ICA.TION Partial Final I, , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the facilities, Project Dame .location and County for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation of the construction such that the construction was observed to be built within substantial compliance and intent of this permit, the approved plans and specifications, and other supporting materials. 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