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.