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HomeMy WebLinkAboutDEQ-CFW_00004339A) Type of permits or plans most familiar with: [ Individual Ponmdu(l,26X) Municipal WW'I'Ps boJu*Cria|\yW7Pe Private !00%domostic WW?Pe Groundwater ramuodla1ioodischarges Water Treatment Plant discharges Version 5-31-2011 Q.Geucral Pennits(1,?4l} l} Non -contact cooling water, boiler cooling tower, condensate, hydroelectricdumn DGroundwater omediation(for 3)Sand dredging 4}Fish/Seafood packing &dos,fiabbuzua 5) Single family residence Primary customer: (emmples:commercial facility, residential, local government, farmers) [ -1-n-di-vidual Pori -nits L-2-6-8 (Table A. contains a list of all Wastewater NPDES individual Dermittees) l. MunicipalWW`7Ye[10Olarge and major >1 MGD'14small and major <1MGDM11ofm 'oro=14smeU*B7|mrQa have Pretreatment Programs), 123 minor municipals < 1 MGD] aEvaluation of111 PnatroatmontPOTVVa Majors Thirty major PmtroaUnont Municipalities were reviewed to assess the impact of the proposed dissolved metal standards onthe facilities NPDEGeffluent limitations. The impact dimnoumnodbelow specifically refers &uthe total metal effluent limitations put inthe PonmiUoo'eorPOTW'nNPDEGpermit. |norder hrassess the full impact onthe POTVVe'the Pretreatment unit used these effluent numbers to determine allowable influent metal concentrations to each Pretreatment POTVV. Once allowable influent concentrations were determined, any additional impact on the POTVVcould be oeaoanod based on possible allocations (metal loadings) available to the POTW's significant industrial users (SlUs). Simply, ifthe influent allocations did not change, there would bnnoimpact tothe G|Us. |fthe metal allocations decreased and significantly affected SIU allocations, the POTW or the industry would have to take mitigative action(s) or pursue options that might help increase the allowable influent loading (ie. WER, moving the outfall to a larger stream, etc.). A copy of the total metal limitations that would beput inthe 3OPretreatment POTVVo NPDEGpermits based onthe proposed regulations are supplied in Table B` Pretreatment POTVVEffluent limitations. NPDEGeffluent limitations calculated based onthe proposed standards showed animpact un5ufthe 3OPretreatment POTWs. These five POTWs would receive additional effluent limitations as a result of the proposed rules and 2 of the five facilities (OJY6)would possibly have topemuomitigative measures. Extrapolating these numbers tothe 111 Pretreatment POTVVewmu|dmnan1SFaci|iUoa(1OJ96)wmu|dmcoivoaddiUona||imitaUonsand7-8tani|iUoawmu|dborequimdk>tako possible mitigative action. To evaluate the type of mitigative measures the facilities might take to meet the standards specifications on the two POTWs'expected to exceed standards are listed below: Additional Effluent limits toboput inthe NPDE8permit: reduce Pblimit to77ug/L chronic and 195ug/L acute (current effluent max 15, avg. 3. 1) reduce Nilimit N78un/L and chronic /095acute Additional Effluent limits tobeput inthe NPOESpermit reduce Pblimit to8ug/L chronic and 21Oug/L acute (current effluent max 33, avg. 10) reduce CUlimit to1.5un/Lchronic and Ei1 xo8aoute (current effluent max 4.Iavg13) Hamby Creek WWTP can analyze and minimize the sources of the pollutants Nseek reductions of Pb and Ni, evaluate the possibility ofperforming aWEIR for site specificstandards, nrconsider possibletreatment alternatives. The City of Lexington can have its laboratory sample s8lower PQLn for Pb so the average discharge oflead will meet the chronic limit but potential for violations still exist. Source reductions would be the best alternative for Lexington as an initial approach to the problem. 11111 lilivill r i i Note that in many cases the proposed limits determined for Pb and Cd were less than the PQL's and current sampling results also show these metals in the wastewaters at less than the PQLs. Therefore, until sampling techniques are improved it is not clear whether the facilities are actually meeting their calculated limitations or whether additional mitigative measures will be necessary. b. Evaluation of 123 minor municipals < 1 MGD Eight of the 123 minor POTWs were reviewed and it does not appear that the proposed standards will have an impact on these facilities. c. Evaluation of 63 majors without pretreatment programs (> 1 MGD) 160 major POTWs — 97 major Pretreatment POTWs = 63 majors without pretreatment programs > 1 MGD I reviewed the list of non -Pretreatment POTWs — majors. Six of the 48 facilities reviewed currently have a limit for Cd, Pb or Ni in their permit. Therefore, Cd, Pb, or Ni concentrations were reported at levels showing reasonable potential to violate WQS when the permit was last renewed. It is reasonable to assume that since the new criteria will result in lower concentration limits for all three metals; these same facilities are likely to be impacted by the adoption of the dissolved metals standards. My best estimate is (6/4 * 100) or 1 .5% of the non -Pretreatment POTWs — majors will be impacted by the adoption of the new standards. 2. Privately Owened 100%domestic WWTPs {AII Minors —Total 4861 Privately owned includes County school WWTPs = 466 Plus 14 State and 6 Federal facilities These facilities receive 100% domestic wastewater and metals are not expected to be in their wastestream. None of these facilities are expected to be affected by the proposed standards. Note that in many cases the proposed limits determined for Pb and Cd were less than the PQL's and any current sampling results also show these metals in the wastewaters at less than the PQLs. Therefore, until sampling techniques are improved it is not clear whether any of the facilities sampling for these metals are actually meeting their calculated limitations or whether additional mitigative measures would be necessary. Table C. State and Federal Facilities considered as privately owned - 100% domestic WWTPs State 14 Facilities Odom Correctional Institute NCO027642 NC Department of Correction WWTP 100% Domestic < 1 MGD NCO030180 NC Department of Correction NCO032166 Appalachian r • (Division of Parks NCO031160 Recreation) NCO029190 NC Department of •• s NCO028606 NC Department of Transportation NCO028614 NC Department of •• s NCO029726 NC Department of Correction NC DENR/Division of Forest NCO040339 Resources NCO024805 NC Department of Transportation NCO027685 NC Department of Correction Blanch Youth Center WWTP Surry County Rest Area 1-77 Rest Area Iredell County 1-77 Rest Area Yadkin County Guilford Correctional Center WWTP B.H. Corpening Forestry Training Center Haywood County Rest Area Avery Correctional Center 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD 100% Domestic < 1 MGD DEQ-CFW 00004340 T[i£OOi@| R2Vi£VV FiSC@| Note Evaluation for NP[)ESWvW P£[[OitS Blue Ridge Youth Center NC0073962 NCDepartment ofCorrection VVVVTP 1OO96Domestic <1MGD Betsy Jeff Penn 4H NCO078271 NCState University Educational Center VVVVTP 1OOY6Domestic <1MGD NCDENR(Division ofParks & The Summit atHaw River NCO046019 Recreation) State Park VVVVTP 1OO96Domestic <1MGD Federal GFmci|itiws NCO020478 USDA UGForest Goniun NC0072729 UGD| National Park Service NCO020450 USDA UGForest Service NCO020486 USDA UGForest Service U8Army / Military Ocean Terminal NCO029122 Sunny Point Jackrabbit Mountain Recreation Area VVVVTP Lake PowhatonRecreation Area Mount Pisgah VVVVTP Sliding Rock Recreation Area North Mills River Recreation Area Military Ocean Terminal / Sunny Point VA State 1 Facility NC0039420 Virginia DOT Virginia DOT71-77 Rest Area 3. Industrial WW7Pe /OO Majors Total -Industrial Pmnaaa &Common:ial ) Privately owned =03 Plus 3 Federal Facilities Major Permits — Process & Commercial Wastewaters 100%Domestic <1MGD 100%Domestic <1MGD 1OO96Domestic <1MGD 1OOY6Domestic <1MGD 100%Domestic <1MGD 100%Domestic <1MGD 100%Domestic <1MGD All three of the Federal facilities listed below have metals in their wastewaters. The last two facilities, NCO003O2Sand NCO003816, are new and we do not have much data on their wastewaters. However, it does appear that NCO003816 which is located in Tidal waters, will violate the proposed and lower saltwater standard for lead. Table D.Federal |ndusthalVVVVTPa Majors Federal 3 Facilities Department of the Army NCO003864 Directorate nfPublic Works NCO063029 UGMarine Corps Camp L jouno U8MICAS Cherry Point (MCALFNCO003816 Atlantic) - Industrial Process &Commercial Camp LejounoAdvanced WWTp Industrial Process & Commercial Cherry Point WWTP 4. Industrial WW?Po|l0|Minors Total ' Industrial Process QCommercial] Privately owned = 15 Plus 5 State and 5 Federal facilities Ill 1111111 Jill III III I lilt It ell. Minor Permits — Process & Commercial Wastewaters Industrial Process &Commercial OEQ-CFVV_00004341 Table E. State and Federal Industrial WWTPs - Minors NCD025305 UNC-ChapelHill NCO027626 NC Department of Correction NCO041386 NCDepartment ofCommerce NCO056065 NCDepartment ofTransportation NCO035904 NCDepartment ofCorrection Federal 5Fmci|itiaa NCO027332 Tennessee Valley Authority NCO027359 Tennessee Valley Authority NCO027341 Tennessee Valley Authority NCO089051 MCBCamp L joune NCO088079 MC8Camp L jouno UNC Cogeneration Facility Caledonia WWTP VVanohoeoHarbor Project Marine Maintenance facility McCain Correctional Hospital WWTP Chatuge Hydro Plant Hiwa0000Hydro Plant Fontana Hydro Plant bejouneBorrow Pits 2and 3 Lejeune Borrow Pit 10 5. Groundwater remedlation discharges JAR Minors ' Total 88] Privately owned — 35 Plus 3State facilities Anavmwofal|thegmundwaterremodiaUonsiteoohown1hs815of\he3Rfao|iUoahavomota|oinUheirwetenwatom.VVhi|e most of the sampling data for the metals are < the PQLs the proposed limitations for these facilities would be < the PQLs as well. Most of these facilities discharge to zero low flow streams and no hardness data is available to accurately assess the impact nfthe new standards. It is likely that the proposed standards will affect groundwater remediation facilities that have CdorPblevels greater than detection. Since source reduction ionot analternative these faci|Uieowill have k>provide costly treatment or persue a WEIR to potentially comply with the proposed standards. Assume some percent will have topomuemitigative measures. Approx. Softhe facilities with metals intheir discharge contain Cd, Pb, Cr or Ni in their wastewaters. A listing of all Groundwater remediation permittees is attached in Table E. and the facilities with metals in their wastewater discharge are identified. Groundwater remediaUnnsites are considered to have complex wastewaters so toxicity testing is put in these permits unless aquatic toxgrants permission toremove the requirement. Thirteen ofthe 15sites identified above aeshowing metals in their wastewaters have WET testing in their permits. Aquatic tox, allowed two facilities to remove the requirement. Table F. SCu[o Gronndvvu[orroonoJhmLioo discharges - minors State 4 Facilities NCDepartment of NCO085979 Transportation NCDepartment of NCO087628 Transportation NCO088129 North Carolina State University Rosman Maintenance Facility Asphalt Testing Site #O University - Lot 86 GmundweterRomediaUon GmundwaterRamodiaUon 6. Water TraotnxeuiPlant discharges t3major, 217 Municipal & Privately Owned =3|G Plus 8State owned Tmb|eG. State Water Treatment P1uuts-minor State 3 Facilities NCO044423 Appalachian State University Appalachian State VVTP Water Treatment Plant N00074524 Western Carolina University Western Carolina University VVTP Water Treatment Plant NCO077500 NCDepartment ofTransportation Ferry Division VVTP Water Treatment Plant Water Treatment Plants (WTP) are divided into four groups based on the type of treatment used to produce potable water. There are 11OConventional Water Treatment Plants, 47Gmonuandfao|Ums, 19Reverse Osmosis nrmembrane treatment facilities, and 39 WTPs using Ion exchange. According to DWQ's WTP Strategy these facilities monitor for the following RO'nfor As, Cu, °Zn'and Fe |Emfor Cu, °Zn' Pb. Fe and Mn Conventional for Cu, °Zn' Fe, Mn' and Al Gneenaand fur^Zn. Fe. and Mn °Znisonly monitored ifused inthe treatment process The proposed metal standards primarilyaffect the limits onCd'Pb. Niand Cr. A review ofthe metals above shows that most ofthese feo|desare not expected 0ndischarge Cd'Pb, NiorOrintheir effluent wastewaters except Ion exchange VVTPswhich have been noted tohave lead intheir effluent. Aawith all permits there are always exceptions Uuthe monitoring requirements if additional pollutants are found in the permittees discharge. All WTPs currently sampling for Cd, Pb, and/or Ni were reviewed and are listed below. An expected,given the VVTP strategy parameters identified ebnve, no conventional or gneenaand VVTPuwere found sampling for Cd' Pb. or Ni. Eight out of1SRO'sare currently sampling for nickel and/or lead. One ROfacility was identified an possiblybeing impacted bvthe proposed standards. The Roclanthe WTP currently has a lead limit of 25 ug/L which will be reduced to 8.1 ug/Lwhen the chronic standards are adopted for saltwater. Uiucurrently discharging lead atamax concentration of1O ug/Land would therefore potonUoUyvio|atothepmpoeodna|kwater|oodstandondof8.1 ug/L. |tcan not boconcluded that any other RO WTP in saltwater will be impacted by the proposed lead standard for saltwater since several other RO's in the same saltwater stream classification are not showing potential k>violate the atanadrd (Kill Devil &Ogdon). Note, the Tyrell County RO showed reasonable potential to exceed the proposed freshwater nickel water quality standard ofR.2ug/Lbut itshows reasonable potential hrviolate the current standard ofR.3ug/Lmawell. NnROVVTPaare expected to be impacted by the proposed nickel standards since the difference between the current and proposed standards are Four out of11 Ion Exchange URWTPs sampling for lead infreshwater are showing potential toboimpacted by the proposed freshwater chronic lead standard (high|igh0ad). There are atotal of15|Efacilities infreshwater aoifwoassume 30Y6are affected (4K11°1OO)than 3O96of1Oequals 0Ion Exchange facilities potentially being impacted bvthe proposed freshwater chronic lead standard. Two out of16Ion Exchange WTPs sampling for lead in saltwater are showing potential toboimpacted bythe proposed saltwater chronic lead standard (high|ighted). There are atotal of22|Efacilities infreshwater noifwmassume 12.5Y6are affected (V10°1OO)than 12.5Y6of23equals 3Ion Exchange facilities potentially being impacted bvthe proposed saltwater chronic lead standard. Ovena|, approximately8out of21Tur4%ufthe VVTPmare expected &uboimpacted bvthe proposed standards. Faciflity Permit # WTP Type Stream Class IWC N Cd, Plb, or Ni showing RIP Max reported effl. Conc. New std. vs current Cedar Island Ferry Terminal NCO077500 RO SA; ORW tidal Ni - chronic 8.2 / 8.3 ug/L Camden County WTP NCO086681 RO SIB tidal none Some Ni 8.2 / 8.3 ug/L Kill Devil Hills NCO070157 RO SIB Tidal none Snow Hill Subdivision NCO088617 Egreensand C 100 none Pine Street WTP NCO072699 IE SC tidal none Glenda Drive WTP NCO072702 IE SA; HQW tidal none Brown Blvd. WTP NCO078131 IE SC; Sw; NSW tidal none Pamlico County NCO088323 IE SC; NSW; Sw tidal Pb - chronic 133 ug/L 8.1 / 25 ug/L Atlantic Beach WTP NCO044806 IE SA; HQW tidal Plb - chronic 22 ug/L 8,11 / 25 ug/L West Carteret WTP NCO077143 I E SA; HOW tidal none Laurel Road WTP NCO086975 I E SA; HQW tidal none Town of Oriental WTP NCO088447 I E SA; HWQ; NSW tidal none Richard WTP NCO084808 Egreensand SC; NSW tidal Hill Road WTP NCO087041 Egreensand SB; NSW tidal none Town Kershaw WTP NCO088331 Egreensand SC; NSW tidal None It. General Poonitn(L74|) The proposed regulations are not expected 0uimpact any ofthe wastewater NPDEGGeneral Permits.