NC0043532_Email (SOC limits)_20191210

Strickland, Bev
From: Denard, Derek
Sent: Tuesday, December 10, 2019 1:30 PM
To: Basinger, Corey; Scheller, Roberto; Hennessy, John
Subject: West Stanley WWTP BOD & NH3-N limits for expanded flow
Attachments: 4532factsheet2018.pdf
For the expanded flow to 1.2 MGD, I found discussion of the new limits for BOD and Ammonia. In 2005 speculative limits
were given based on a QUAL2E model. For the 2018 renewal, David Hill added the expansion page for 1.2 MGD with
these new limits. See the section titled Oxygen -Consuming Waste Limitations on pages 4 and 5 of the attached fact
sheet.
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denarda-ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Fact Sheet
NPDES Permit No. NCO043 532
Permit Writer/Email Contact David Hill, [e-mail]:
Date: April 17, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑ Renewal
N Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Stanly County/West Stanly WWTP (formerly Oakboro WWTP)
Applicant Address:
1000 North First Street, Albemarle, NC 29001
Facility Address:
24939-B Barbee's Grove Road, Oakboro, NC 28129
Permitted Flow:
0.9 MGD/Expansion 1.2 MGD
Facility Type/Waste:
MINOR Municipal; 100% domestic (Upon Expansion MAJOR
Municipal)
Facility Class:
Class 3
Treatment Units:
Bar Screen, Activated Sludge/Aeration, Disinfection
Pretreatment Program (Y/N)
N
County:
Stanly
Region
Mooresville
Briefly describe the proposed permitting action and facility background: Stanly County has applied for
an NPDES permit renewal for 0.9 MGD, and for a modification to rerate the existing facility to
expand in the future to 1.2 MGD, for the West Stanly WWTP (formerly Oakboro WWTP) in
February 2014. The application included the required EAA for the expansion. This facility serves
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as a regional facility for a population of 6,400 residents for the communities of Oakboro, Stanfield,
and Locust.
The facility has a primary Outfall 002 and an emergency Outfall 001, each outfall impacts different
receiving streams. Discharge from Outfall 002 requires the operation of effluent pumps to transfer
the treated wastewater via a pressure sewer to Rocky River. Discharge from Outfall 001 is an
emergency gravity overflow from the effluent pump station to Long Creek. Mechanical issues that
have resulted in the historical episodic discharge from the emergency overflow will be resolved as
part of the expansion design/constructions. Upon expansion to 1.2 MGD the facility's Outfall 001
will be no longer be considered as an active discharge.
This segment of the Yadkin -Pee Dee River that receives the discharge from Outfalls 001 and 002 is
downstream from High Rock Lake. West Stanly is an active member of the Yadkin -Pee Dee River
Basin Association.
A speculative letter was issued in 2005 for a proposed expansion to 1.2 MGD for this facility based
on a QUAL2E model prepared for Rocky River and Mallard Creek. The speculative limits are still
valid and will be applied in this permit.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001— Long Creek
Outfall 002 - Rocky River
Stream Segment:
11-17-31
13-17
Stream Classification:
C
C
Drainage Area (m12):
192.5
965
Summer 7Q10 (cfs)
3.3
29
Winter 7Q10 (cfs):
5.8
51
30Q2 (cfs):
-
-
Average Flow (cfs):
183
920
IWC (% effluent):
30% at 0.9 MGD
4.6% at 0.9 MGD
6.0% at 1.2 MGD
303(d) listed/parameter:
Yes, the segment is listed in
the 2016 303(d) for Copper
impairment
Yes, the segment is listed in
the 2016 303(d) for Copper
and Zinc impairments IR
Category 5e
Subject to TMDL/parameter:
Yes- State wide Mercury TMDL implementation.
Subbasin/HUC:
Yadkin -Pee Dee; 03040105
USGS Topo Quad:
G17NE
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3. Effluent Data Summary
Effluent data for Outfall 002 is summarized below for the period of March 2016 through November 2017.
Table 1. Effluent Data Summary Outfall 002
PermitLimit
Parameter
Units
Average
Max
Min
Flow
MGD
0.456
2.41
0.24
MA 0.9
BOD summer
mg/l
5.89
56.0
< 2
WA 13.5
MA 9.0
WA 27.0
BOD winter
mg/l
15.23
383.0
< 2
MA 18.0
WA 9.0
N113N summer
mg/l
1.08
13.2
0.04
MA 3.0
NH3N winter
mg/l
2.64
33.8
< 0.04
WA 18.0
MA 6.0
TSS
mg/l
15.67
973.0
< 2.5
WA 45.0
MA 30.0
6.0>pH<9.0
pH
SU
6.87
7.5
6.0
(geometric)
Fecal coliform
#/100 ml
399
> 8600
< 1
WA 400
MA 200
DO
mg/l
8.77
14.6
5.9
DA >5.0
TRC
µg/l
20.1
479
< 10
DM 28.0
Temperature
° C
17.77
26.7
6.1
TN
mg/l
20.43
35.2
5.2
TP
mg/l
2.74
4.78
0.2
Total Copper
mg/l
10.5
14
< 10
Total Zinc
mg/l
Only two values: 54, 82
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
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4. In stream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen and
temperature. West Stanly is a member of the Yadkin -Pee Dee River Basin Association and as such
instream monitoring was waived. Currently there are no instream monitoring stations active
downstream of either outfall.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): Yes
Name of Monitoring Coalition: Yadkin -Pee Dee River Basin Association
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): During Oakboro
ownership, February 2010 to February 2014, there were 29 limit violations. Oakboro paid $1,363 in
fines. Since the transfer of ownership to Stanly County in March 2014 the facility has had 53 limit
violations (BOD, ammonia, TSS, fecal coliform) and paid $10,480 in fines.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 20 of the last 20 quarterly chronic toxicity tests (14 undercurrent
permittee Stanly County). As a minor facility, no second species testing is required.
Summarize the results from the most recent compliance inspection: The last facility inspection
conducted in 2016 reported that the facility was having operational issues from high influent BOD
and NH3-N loading, and visible effluent clarity issues, as the result of a recently accepted
wastewater stream from Enterprises Rendering. Acceptance of the Enterprise Rendering
wastewater was terminated by the Permittee at the direction of The Mooresville Regional Office.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
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(e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed. Limitations for 0.9
MGD to Outfall 002 for BOD and NH3-N are based on a Streeter Phelps model (Level B) for
instream DO protection. No changes are proposed from the previous permit limits.
In 2005 a QUAL2E model was prepared for Rocky River and Mallard Creek applying a 1.2 MGD
discharge from this facility. The resulting limits are defined in Table 1.2 MGD and will be applied
to Outfall 002:
Table 2. 1.2 MGD
Effluent Characteristics
Monthly
Average
Weekly
Average
Minimum Limit
BOD, yearround
10.0 m L
15.0 m L
NH3-N, yearround
4.0 m L
12.0 m L
DO, yearround
6.0 m L, daily average
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: There are no
proposed changes for the current 0.9 MGD flow.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of/2 detection limit for "less than" values; and 4) stream flows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between May 2013 and
November 2017. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: None
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Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was >50% of the allowable concentration: Bis(2-
ethylhexyl)phthalate and cyanide will be monitored quarterly for the emergency outfall
001. Though they didn't exhibit reasonable potential, copper and zinc will be monitored
quarterly based on BPJ due to stream impairments.
No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: Total phenolic compounds.
POTW Effluent Pollutant Scan Review: The effluent pollutant data summarized in the renewal
application were evaluated for additional pollutants of concern.
o The following parameter(s) will receive awater quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: None
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: None
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: Will continue quarterly testing chronic WET limit at
4.6% effluent for 0.9 MGD and will add testing for a chronic Wet limit at 6.0% effluent
concentration for expansion to 1.2 MGD.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/l
Describe proposed permit actions based on mercury evaluation: The single mercury analysis that was
submitted showed no detect but was not applicable as it did not use test Method 1631E. A special
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condition will be added to this permit that will require at a minimum that one effluent mercury
measurement using test method 1631E must be submit in conjunction with the next permit renewal.
If the facility expands prior to the next renewal multiple mercury measurement will be submitted as
part of the required effluent pollutant scans.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within thispermit: NA.
Other WOBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H. 0107( c) (2) (B), 40CFR 122.47, and EPA May 2007 Memo: If applicable, describe any
water quality standards variances proposed in accordance with NCGS 143-215.3(e) and 15A NCAC
2B. 0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Municipals
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l
BODS/TSSforMonthly Average, and 45 mg/l forBODS/TSSfor Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BODS/TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
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If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results:
Based on the projected population growth in the facility's service area demand will exceed the
current 0.9 MGD capacity by 2026. The EAA to evaluate several alternatives as well as expansion
of the existing permitted facility to add 0.3 MGD capacity is summarized below:
Table 3. EAA summary results.
System
Description of Proposed System
Present Worth Cost
Land
Estimatedwill need 220 acres of land for a lagoon and irrigation area. The
$18.2 million
Application
current treatment works willbe upgraded to meet the additional0.3 MGD.
Reuse
Estimatedthe additional treatment, operatingcost, andstorage required for
$14 million
0.3MGD conjunctive reuse.
Expansion
Estimatedthe capitalupgrades to expandthe existingplant
$9.3 million
NPDES
Discharge
The Division concurred with the Permittee that the expansion of the existing facility was the best and
most economical approach.
9. AntibackslidingReview:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
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12. Summary of Proposed Permitting Actions:
Table 4. Current Permit Conditions and Proposed Changes 0.9 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.9 MGD
No change
15A NCAC 2B .0505
BOD5
Summer:
No change
WQBEL. Based on protection of DO
MA 9.0 mg/l
standard. 15A NCAC 2B.0200
WA 13.5 mg/l
Winter:
MA 18.0 mg/1
WA 27.0 m /l
NH3-N
Summer:
No change
WQBEL. Based on protection of
MA 3.0 mg/l
State WQ criteria. 15A NCAC
WA 9.0 mg/1
2B.0200
Winter:
MA 6.0 mg/l
WA 18.0 m /l
TSS
MA 3 0. 0 mg/l
No change
TBEL. Secondary treatment
WA 45.0 mg/l
standards/40 CFR 133 / 15A NCAC
2B .0406
Fecal coliform
MA 200 /100ml
No change
WQBEL. State WQ standard, 15A
WA 400 A 00ml
NCAC 2B .0200
DO
> 5.0 mg/, daily average
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH
6.0 - 9.0 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Nitrogen
Monitor Only
No change
15A NCAC 2B.0500 et seq.
Total Phosphorus
Monitor Only
No change
15A NCAC 2B .0500 et seq.-
Conductivity
Monitor 3/week
Remove
Not required. The town lacks any
industrial dischargers.
Toxicity Test
Chronic limit, 4.6%
No change
WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Temperature
Monitor Only
No change
WQBEL. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Total Copper
2/Month Monitoring
Quarterly Monitoring
WQBEL. 15A NCAC 2B.0200, no
reasonable potential but receiving
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streams are impaired for this
parameter under old standard.
Total Zinc
Quarterly Monitoring
Quarterly Monitoring
WQBEL. 15A NCAC 2B.0200, no
reasonable potential but receiving
streams are impaired for this
parameter under old standard.
Cyanide
No requirement
Quarterly monitoring
WQBEL. 15A NCAC 2B.0200 and
reasonable potential to violate WQS
at emergency outfall 001
Bis(2-ethylhexyl)
No requirement
Quarterly Monitoring
WQBEL. EPA NRWQC and
phthalate
reasonable potential to violate WQS
at the emergency outfall 001 at
0.9MGD
Mercury
Different requirement
Add special condition
15A NCAC 2B .0500 et seq.
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Table 5. Proposed New Conditions for expansion 1.2 MGD
Parameter
Expansion Permit
Proposed Condition
Basis for Condition
Flow
MA 1.2 MGD
New
15A NCAC 2B .0400 et seq., 02B
.0500 yet seq.
BOD5
Year round:
New
WQBEL. Based on protection of DO
MA 10.0 mg/l
standard. 15A NCAC 2B.0200,
WA 15.0 mg/1
limit based on QUAL2E Model
NH3-N
Year round:
New
WQBEL. Based on protection of
MA 4.0 mg/1
State WQ criteria. 15A NCAC
WA 12.0 mg/1
213.0200, limit based on QUAL2E
Model
DO
> 6 mg/l, daily average
New
WQBEL. State WQ standard, 15A
NCAC 213.0200, limit based on
QUAL2E Model
Toxicity Test
Chronic limit, 6.0%
New
15A NCAC 2B. 0200 et seq., limit
effluent
based on IWC%
Effluent Pollutant
Provide 3 seasonal scans
New
40 CFR 122, G.S. 143.215(b)
Scan/2°d Species
and 4 seasonal 2nd
Tests
species test
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
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13. Public Notice Schedule:
Permit to Public Notice: 05/02/2018
Per 15A NCAC 2H .0109 & .O111, The Division will receive comments for a period of 30 days
following the publication date of the public notice. Any request for a public hearing shall be
submitted to the Director within the 30 days comment period indicating the interest of the party
filing such request and the reasons why a hearing is warranted.
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): NO
If Yes, list changes and their basis below: NA
15. Fact Sheet Attachments (if applicable):
RPA Spreadsheet Summary
Dissolved Metals Implementation/Freshwater or Saltwater
Page 11 of 11