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HomeMy WebLinkAboutNC0021253_201 FACILITIES PLAN_19941018 e NPDES DOCUMEMT SCANNING COVER SHEET NPDES Permit: NCO021253 Havelock WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Engineering Alternatives Analysis 201 Facilities Plan Instream Assessment (67B) Speculative Limits Permit History Document Date: October 18, 1994 Mix1m document is printed on reuse paper-ignore say content oa the reverse aide DIVISION OF ENVIRONMENTAL MANAGEMENT Water Quality Section/instream Assessment Unit October 18, 1994 MEMORANDUM TO: Monica Swiha FROM: Farrell Keo Betsy Johnso THROUGH: Carla Sande Ruth Swanek SUBJECT: Revisions to Havelock 201 Facilities Plan and Environmental Assessment Havelock WWTP NPDES No. NCO021253 Craven County The Instream Assessment Unit has reviewed the 201 Wastewater Facilities Plan for the Town of Havelock Waste Water Treatment Plant revised September 1994. The plan has been amended to include relocation to the Neuse River upon expansion above the permitted 1.9 MGD. There are a number of discrepancies in the present value analysis and Table E-1 in the revised document. Staff from the Construction Grants Section have spent considerable time reviewing the numbers with us and Black&Veatch has provided revised calculations for the present value analysis. These revisions should be included in the final 201 plan and the corrections to Table E- 1 made. Based on the new calculations and Table E-1, it appears that Alternate 3A is the least cost option, closely followed by Alternative 4, discharge to the Neuse River. The Environmental Assessment indicates that discharge to the Neuse would likely have lower impact than continued discharge to Slocum Creek. Again I reiterate that continued discharge to Slocum Creek is not an environmentally sound option. However, since the analysis now considers relocation for future expansion as part of Alternatives 3A and 3B these options will be considered. The Technical Support Branch strongly recommends Alternative 4 since it is within 5%of the cost of Alternative 3A and meets the goals of the Neuse Basin plan sooner. We would also like to take this opportunity to note that inflow and infiltration have been ongoing problems for this facility for many years. The sections of our regulations that apply to sewer collection systems, Title 15A- subchapter 2H -section .0208 authorizes our review and Permit preparation of sewer systems and expansions. Section .0219 outlines the minimum design requirements: included in this section are loading specifications, minimum velocities, infiltration rates, and manhole spacing requirements. Please rate that within this section (.0219), and infiltration rate of 100 gallons per day per inch of pipe diameter per mile is designated as acceptable. The rate quoted in this report, 3,000 gpdim is three-fold the acceptable level. In addition, please be advised of section .0217(a) (11)which describes routine maintenance and rehabilitation of existing wastewater collection systems which would not require a change in the NPDES permit. We have included a copy of the regulations along with this letter for review between yourself and the Town of Havelock's consulting engineer. For questions regarding this section,please contact Ms. Carolyn McCaskill at(919) 733-5083. Finally,the letters to the US Fish &Wildlife and Corps of Engineers should be revised to indicate that the Town has received a permit for a discharge of 1.9 MGD to Slocum Creek, not 2.25 MGD as indicated previously. In addition, the revised letters should indicate that the Town plans to relocate the discharge to the Neuse River upon expansion above 1.9 MGD. Thank you for this opportunity to review and comment. If you have questions or concerns, please call. cc: Don Safrit, Asst. Chief TSB Dave.Goodrich;P&E� Construction Grants Section Washington Regional Office pp 9199A t ti 2 DIVISION OF ENVIRONMENTAL MANAGEMENT Water Quality Section October 24, 1994 MEMORANDUM TO: Monica Svahart FROM: Don Safril/P.E. Assistant Ghiaf- rf3 Technical Support p THROUGH: Steve Tedder, Chief :I SUBJECT: Revisions to HavelL14011 Facilities Plan and Environmental Assessment Havelock WWTP '� NPDES No. NCO021253 Craven County The Instream Assessmem Unit has reviewed the 201 Wastewater Facilities Plan for the Town of Havelock Waste Water Treatment Plant revised September 1994, The plan has been amended to include relocation to the Neuse River upon expansion above the permitted 1.9 MGD. There are a number of discrepancies in the present value analysis and Table E-1 in the revised document. Staff from the Construction Grants Section have spent considerable lime reviewing the numbers with us and clack & Veatch has provided revised calculations for the present value analysis. These revisions should be included in the final 201 plan and the corrections to Table E- 1 made. Based on the new calculations and Table E-1, it appears that Alternate 3A is the least ® cost option, closely followed by Alternative 4, discharge to the Neuse River. The Environmental Assessment indicates that discharge to the Neuse would likely have lower impact than continued discharge to Slocum Creek. Since the analysis now considers relocation Sor future expansion as part of Alternatives 3A and 3B these options will be considered. The Technical Support Branch strongly recommends Alternative 4 since it is within 5% of the cost of Alternative 3A and meets the coals of the Neuse Basin plan sooner. We would also like to take this opportunity to note that inflow and infiltration have been ongoing problems for this facility for many years. The town should be encouraged to address all excessive 1/1 where economically practical. Finally, the letters to the US Fish & Wildlife and Corps of Engineers should be revised to indicate that the Town has received a permit for a discharge of 1.9 MGD to Slocum Creek, not 2.25 MGD as indicated previously. In addition, the revised letters should indicate that the Town plans to relocate the discharge to the Neuse River upon expansion above 1.9 MGD. Thank you for this opportunity to review and comment. If you have questions or concerns, please call. Don Safrit, Asst. Chief TSB Dave Goodrich, P&E Construction Grants Section Washington Regional Office North Carolina Division of Environmental Management Water Quality Section/ Rapid Assessment Group September 16, 1994 MEMORANDUM To: Greg Nizich From: �Farrell-Keo I-? Through: Carla Sanderson I i Subject: Havelock Waste Water Treatment Plant NC0021253 monitoring requirements Permits and Engineering has recently requested our recommendations on changing the monitoring requirements for Havelock WWTP. The option of dropping the monitoring requirements for chromium and lead and changing the monthly monitoring requirements for copper, nickel, zinc, and aluminum to a quarterly monitoring requirement has been reviewed and the following represents the Technical Support Branch position. Our review has indicated that chromium and lead monitoring can be dropped. All of the submitted values for these parameters over the last twelve months have been below the detection level. Our recommendations for copper and zinc will still include NPDES Permit monthly monitoring. Both of these parameters exceeded the allowable discharge quantity based on the State Action Level standards. This requirement follows our current Standard Operating Procedure, (SOP) which will be up for possible revision during the tri-annual review. We do concur with Havelock's request for a quarterly monitoring requirement on aluminum. This parameter also exceeded the allowable discharge quantity. The aluminum allowable discharge quantity was based on the EPA criterion for continuous concentration of 87 µg/l. Since the state of North Carolina has not adopted this criterion, allowing quarterly monitoring should not pose a conflict with any existing policies in the Water Quality Section. Finally, our review of the data submitted by the City of Havelock indicates that Nickel should be limited rather than monitored. The Technical Support Branch recommends that this requirement be changed in the NPDES Permit to reflect a limit. The following outlines our recommendation in brief: Pam Recommendation Chromium delete NPDES requirement Lead delete NPDES requirement Copper monitor monthly per NPDES Permit Zinc monitor monthly per NPDES Permit Aluminum monitor quarterly per NPDES Permit Nickel limit at 88.0 µgil in NPDES Permit cc: Don Safrit, Asst Chief TSB August 1893 through July 1994 Feast,ft.. Havelock WVITP Per.m.ee. Chromium Psr m xvr. Copper [AI] NPDESO. NCO021253 Slu d. 50 Pyt Snn4N- 7 µqt Ow(3r00). 1.50 m 0 rurroo(ws). 0.00 eie n BDL-12DL '012 OL RESULTS n BDL-12DL 'H 12 DL RESULTS AVC(y. 100.00% 1 2.5 Sid Dev. 0.0 1 43 Shot Dev. 24.2 2 2.5 Mean 2.5 2 34 Mean 39.4 FINAL RESULTS 3 2.5 C.V. 0.0 3 47 C.V. 0.8 Chromium Medmum V.I . 2.5 4 2.5 4 52 Max.Prod Cw 0.0 .� 5 2.5 - 5 37 Allowable Cw 50.0 . e 2.5 Mutt Factor- 0.0 a 66 Wit Factor- 2A 7 2.5 Max.Value 2.5 µ91 7 25 Max.Value 86.0 uO Copper [AI] MwUmem Velw Beo B 2.5 Max.Prod Cw 0.0 Pev a 78 Max.Prod C% 2/0.8 PW Max.Prod Cw 240A 8 2.5 Allowable Cw 50.0 Pel a 28 Allowable Cw 7.0 µyl Allowable Cw 7.0 10 2.5 16 28 11 2.5 0 5 Lead Maxinum V.IIM 2.5 12 2.5 12 10 Max.Prod Cw 0.0 ' I 13 13 Allowable Cw 25.0 14 14 15 15 Nickel eladmen VA .. 55.0 Is 1e Max.Prod!Cw 110.0 17 17 Allowable Cw BS.O 1B Is is /8 Zinc [AL] Mednum V.I . 87.0 20 20 Max.Prod CW 208.8 "" 21 21 Allowable Cw 50.0 22 22 23 23 Aluminum• Madnum VNw 208.0 24 24 Ms..Prod Cw 412.0 25 25 Allowable Cw 67.0 id 26 26 27 27 w14N4 Augua11993 through July 1994 i Piwnww- Lead PararrWw- Nickel P..w- Zkic [ALI P..w. Aluminum• EPA crisdon LALI S1nMw. 25 994 Standard- 88 P94 sune.n. 5o yg4 sradwd. 87 VAN n BDL-12DL •H 12 DL RESULTS n BDL-/2DL 'H 12 DL RESULTS n BDL-12DL 'H 12 DL RESULTS n BDL-12DL 'H 12 DL RESULTS 1 2.5 Sid Dev. 0.0 1 28 Sid Dev. 13.4 1 74 Sid Dev. 25.1 1 206 Sid Dev. 55.7 2 2.5 Mean 2.5 2 13 Mean 29.8 2 70 Mean 48.8 2 190 Mean 130.3 3 2.5 C.V. 0.0 3 36 C.V. 0.4 3 56 C.V. OS 3 168 C.V. 0.4 4 2.5 4 25 4 73 4 116 5 2.5 5 30 5 60 5 82 6 2.5 Mu4 Fedor- 0.0 a 53 Murt Factor- 2.0 a 39 MuB Factor- 2.4 a 25 MUN Factor- 2.0 7 2.5 ' Max.Value 25 µyl 7 20 Max.Value 55.0 IV 7 19 Max.Value 87.0 y9A 7 104 Max.Value 206.0 µpA a 2.5 Max.Prod CA 0.0 W a 34 Max,Prod CA 110.0 y91 5 87 Max.Prod CA 200.8 yqA a 58 Max.Pmd CA 412.0 y9A 9 2.5 Allowable Cw 25.0 µyl 9 23 Allowable Cw 88.0 y9A 9 29 Allowable Cw 50.0 yaw 9 172 Albxacle Cw 07.0 µgA 10 2.5 10 55 10 5 10 120 11 2.5 11 27 11 36 11 152 12 2.5 12 13 12 35 12 170 13 13 13 13 14 14 14 14 15 15 15 15 16 16 to 16 17 17 17 17 to 16 18 1a 10 10 19 19 20 20 20 20 21 21 21 21 22 M 22 22 23 23 23 ?J 24 24 24 24 25 4 25 n 26 26 26 26 27 27 27 27 a14w DIVISION OF ENVIRONMENTAL MANAGEMENT September 6, 1994 MEMORANDUM aka To: Carla Sanderson Instream Assessment Unit k From: Greg Nizic<60 l6s% r� NPDES Permits Group Subject: Effluent Monitoring Data Evaluation Permit# NC0021253 City of Havelock Craven County A request was received from the City of Havelock to drop their monitoring requirements for chrouium and lead, and to reduce monitoring for copper, nickel, zinc and aluminum to quarterly. I have attached monitoring data that the city submitted. Let me know if other information is required. Enclosures CITY OF HAVELOCK Post Office Drawer 368 Havelock, N.C. 28532 A'�OHPoPATCU IY] August 12, 1994 ,-0 -. X7• m Ms. Colleen Sullins, P.E. , Supervisor NPDES Permits Group Division of Environmental Management Zi DEHNR s s P.O. Box 29535 -m< Raleigh, NC 27626-0535 y '2 rn .. p Dear Ms. Sullins: i In reference to the letter accompanying our NPDES permit dated June 30, 1993, I am submitting the following information. The first attachment is part of a letter dated May 13, 1993 requesting that the monitoring of metals be reduced to quarterly following the collection of one year of satisfactory monthly data. The second attachment is a copy of the cover letter , dated June 30, 1993, for the City ' s NPDES permit. Item 6 requires monthly monitoring for one year after which the City may request a reduction in monitoring frequency regarding metals. At this time, the staff has collected data for twelve months and has found that chromium and lead are always below detectable levels. The nickel average for the twelve months is less than 30 ug/I with the highest value thus far being only 55 ug/l . The City's average concentrations for chromium, copper, lead and zinc in the effluent were all less than 50 ug/l . The average concentration for aluminum was less than 130 ug/l . Please review the data concerning the metals in the effluent to determine if monthly monitoring is necessary. The City herein requests deletion of monitoring requirements for chromium and lead and a reduction from monthly to quarterly monitoring for copper, nickel , zinc and aluminum in NPDES permit #NC0021253. If you have questions or comments please call Susan Rexrode at (919) 444-6421 . Thant: you for your cooperation in reviewing this matter. Sincerely, Susan Rexrode WwTP Superintendent enclosure Phone (919) Fax (919)447-0126 City of Havelock Monitoring Data re: Metals NPDES permit # NCO021253 Date Aluminum Chromium Lead Copper Nickel Zinc ug/1 ug/1 ug/1 ug/1 ug/l ug/1 08/1993 206 <5 <5 43 28 74 09/1993 190 <5 <5 34 13 70 10/1993 168 <5 <5 47 36 56 11/1993 116 <5 <5 52 25 73 12/1993 82 <5 <5 37 30 60 01/1994 <50 <5 <5 86 53 39 02/1994 104 <5 <5 25 20 19 03/1994 58 <5 <5 78 34 87 04/1994 172 <5 <5 28 23 29 05/1994 120 <5 <5 28 55 <10 06/1994 152 <5 <5 <10 27 36 07/1994 170 <5 <5 10 13 35 DIVISION OF ENVIRONMENTAL MANAGEMENT Water Ouality SectionAnstream Assessment Unit July 28, 1994 N MEMORANDUM C TO: Monica Swihart ^v FROM: Farrell Keough ,�1 ^ �� Betsy Johnso� ` THROUGH: (Cads_-Sanderson cup ip� Steve Bevington Ruth S ZCS frit Don afrit►��� SUBJECT: Havelock 201 Facilities Plan and Environmental Assessment Havelock WWTP NPDES No. NCO021253 Craven County The Instream Assessment Unit reviewed the 201 Wastewater Facilities Plan for the Town of Havelock waste water treatment plant dated June, 1994.The 201 plan lists two Odriving factors' for the need for funding: 1. increase in wastewater flows due to Cherry Point's expansion 2. rigorous effluent limits set by DEM. Instream Assessment is concerned that the water quality impacts from continued discharge to Slocum Creek are being overlooked. Instream Assessment, has three major concerns with this proposed expansion: 1. continued increases in wastef low to Slocum Creek 2. water quality violations in Slocum Creek 3. more stringent than state-of-art technology needed to protect water quality in Slocum Creek Since 1987, wastewater treatment plant expansions to Slocum Creek have been discouraged due to water quality violations. These water quality problems(low dissolved oxygen levels, stratification, algal blooms, metals accumulation in fish,...) have been exacerbated by the tidal nature of Slocum Creek which receives zero freshwater inflow and limited tidal exchange with the Neuse River. As a result, effluent is trapped in the lake-like embayment such that there is no assimilative capacity,within this waterbody. The Neuse River Basin Plan states that the existing discharges to Slocum Creek are encouraged to relocate to the Neuse River and no new ouffalls will be permitted. In addition, the state's antidegradation policy prohibits new or expanded discharges to zero flow streams. However,through much negotiation, Havelock received permit limits for a proposed expansion to 1.9 MGD in 1993. Due to the documented water quality problems in Slocum Creek and the lower reaches of the Nauss River Basin,the recommended limits were based on the Best Available Technology and are some of the most restrictive in the State; however, these limits do not protect water quality, in Slocum Creek. Because of these factors,the Technical Support Branch cannot support any further expansions at this facility with continued discharge to Slocum Creek. The rigorous limits set by DEM were in response to numerous water quality violations in Slocum Creek due to effluent discharges. There is a great deal of historical water quality information available on Slocum Creek which documents these violations. There is quite a bit of self-monitoring data on Slocum Creek(collected by both Havelock and USMC-Cherry Point)and there have also been special studies and bloom investigations by DEM. Given all the available water quality information and previous negotiations, Technical Support is concerned that this 201 plan pursues funding for continued expansion in Slocum Creek above the recently permitted 1.9 MGD. In a letter to the Marine Corps Air Station (MCAS) dated March 25, 1992 and copied to DEM, Havelock acknowledges that continued discharge to Slocum Creek is unlikely to be allowed for more than four or five years. Yet this 201 plan pursues remaining in Slocum Creek. In a meeting with DEM on October 22, 1992, Havelock stated that 1.9 MGD was the top wasteflow for Havelock, Havelock had no room for additional growth in the town, and Havelock had actually lost developable land due to new wetlands regulations. The Marine Corps recently assured DEM that there would be no increase in wastef low at either the base or Havelock's discharges due to the base expansion. Yet, the 201 plan makes reference to the City's population being 'directly related to the number of persons, both military and civilian, assigned to the Cherry Point Marine Corps Air Station.' The 201 plan also indicates that Havelock can house an additional 9000 persons. The 201 plan does not meet the goals of the Neuse River Basin Plan which reiterates DEM's position that Havelock and USMC-Cherry Point coordinate efforts for wastewater treatment and disposal through discharge to the Neuse River. The 201 plan repeatedly asserts that permit limits have been given for 2.25 MGD. In section H, entitled Environmental Assessment,two letters are copied; one to the U.S. Fish and Wildlife and the other to Department of the Army which imply incorrect information. The letter states that Black& Veatch have undertaken a study in which'...the City is planning to expand the WWTP to a capacity of 2.25 million gallons per day. The existing discharge point will not be changed. We[Black& Veatch as representatives of the City of Havelock] have obtained effluent limits from the Division of Environmental Management (DEM) which require that advanced treatment and nutrient removal be provided.' The Technical Support Branch wants to make it clear that we have not given limits for, nor do we support an expansion in discharge by the City of Havelock for 2.25 MGD. As stated above, we recommended very stringent limits including nutrient removal for an expansion in discharge of up to 1.9 MGD, but with many concerns as to consistent achieveability. DEM also stated that any expansion above 1.9 MGD would not be permitted. In Section D, Alternatives, each of the attematives should address the capability for future expansion. The 201 plan incorrectly states that Havelock has received permit limits for 2.25 MGD. The assumption that the permit limits for 1.9 MGD will remain at 2.25 MGD is inappropriate. No future expansion will be permitted due to the zero flow policy,the lack of assimilative capacity in Slocum Creek, and inability of a wastewater treatment plant to remove pollutants in order to meet water quality standards in Slocum Creek. The EA should document all the water quality information listed above. Also,the EA should mention the proposed change in water quality classification for Slocum Creek. Additionally,we would request more extensive review and elaboration upon secondary impacts of the expansion. We would request that the Appendices attached be re-compiled in typewritten rather than handwritten format. The figures were used to support many of the statements throughout this document and are crucial for the review,therefore a clear, concise presentation of them is imperative. We would like to reiterate that this 201 plan's selection of alternative 3A for expansion at the existing discharge site is not consistent with DEM's goals for the Nauss River Basin and that permit limits for expansion to 2.25 MGD have not been approved. Treatment more advanced than current state-of- the-art technology will be required to protect water quality. Therefore,Technical Support does not support an expansion of the WWTP unless the discharge is relocated to the Neuse River. Thank you for this opportunity to review and comment. If you have questions or concerns, please call. cc: Steve Tedder, Water Quality Section Cheif Dave Goodrich, P&E Washington Regional Office 2