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
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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
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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
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