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HomeMy WebLinkAboutNC0089206_Draft Permit_20200908 • ROY COOPER Governor MICHAEL S. REGAN Secretary y S. DANIEL SMITH • ;; • Director NORTH CAROLINA Environmental Quality September 8, 2020 Gary Myers, Safety and Environmental Manager Plaze Incorporated 105 Boldt Lane St. Claire, Missouri 63077 Subject: DRAFT Review of NPDES Permit NC0089206, Grade PCNC Claire Sprayway Remediation Project Mecklenburg County,NC Dear Mr. Myers: The Division of Water Resources (DWR or the Division)received your application to renew the subject permit on April 7, 2020. Please review the attached renewal draft carefully to ensure your understanding of its limits and monitoring conditions, and to correct errors, if any. Concurrent with this notification, the Division will solicit public comment on this draft by publishing a notice in newspapers having circulation in the general Mecklenburg County area, as required by the NPDES Program. Please submit your written comments(if any),to my attention, NCDEQ/DWR/NPDES no later than October 9,2020(approximately 30 days after receiving this document). We welcome your written comments,but they are not mandatory. Renewal Changes: The Division understands that you have made no significant alterations to treatment processes since last renewal. Based on monitoring data submitted,we note that many chlorinated hydrocarbon databases for contaminants of concern do not show reasonable potential to exceed their respective surface water-quality Standards. Therefore, in keeping with NPDES Permitting Guidance, we have relaxed the monitoring frequency for these from Monthly to Quarterly. In addition, we have removed their permit limits [see permit section A. (1.)]. Finally, we have revised and updated permit texts and the site location map. Monthly Report Submittals: Federal regulations require electronic submittal of all program reports and Monthly Discharge Monitoring Reports(DMRs); see Permit Condition A. (3.). Our records show that you have successfully registered for the Electronic Discharge Monitoring Report(eDMR)program. If you have filled out and submitted to DWQ an Electronic Signature Agreement, you are no longer required to submit DMR hardcopy as back-up to the eDMR. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617-919.707.9000 Gary Myers Plaze Incorporated Draft Permit Review Page 2 of 2 Following the mandatory 45-day Public Comment period, the Division will review all pertinent comments, if any, and take appropriate action prior to issuing an NPDES permit final. If you have questions,please email the undersigned at [ioe.corporon@a,ncdenr.gov]. In support of mandated emergency response to Covid 19,much of NC state government currently functions remotely, therefore correspondence via email is preferred. Respectfully, oe R. Co oron, .G. DEQ/D /NPDES Permitting Enclosure:NPDES Permit NC0089206(ren wal draft) ec: DWR/MRO, NPDES Program Files DWR/OCU,Maureen Kinney Whole Effluent Toxicity(WET)Test WET requirement is a Quarterly Chronic Toxicity Pass/Fail test using Ceriodaphnia at 90%. (No changes recommended).RPA was not conducted for this renewal because all databases for parameters of concern reported"not detected"above laboratory PQL. Limits Considering that previously identified Contaminants of Concern(COCs)were not detected during the previous permit cycle,the Division has removed permit limits,per NPDES Permitting Guidance. We have also relaxed the sampling frequency from Monthly monitoring to Quarterly [see section A. (1•)]. Compliance: WET testing all"pass"last 11 Quarters. Proposed Schedule of Issuance Draft Permit to Public Notice: September 7,2020(est.) Permit Scheduled to Issue: November 16,2020(est.) Permit Effective Date: January 1,2021 (est.) NPDES UNIT CONTACT If you have questions regarding any of the above information or on the attached permit, please email Joe R.Corporon,P.G. [joe.corporon@ncdenr.gov]. i ;/ Name: Date: 01 Sep2020 Joe R. orporon .G. Fact Sheet for Renewal Sep2020 NPDES NC0089206 DENR/DWQ/NPDES FACT SHEET FOR NPDES PERMIT RENEWAL NPDES Permit NC0089206 Facility Information Applicant/ Plaze Incorporated/ Facility Name Claire Sprayway Remediation Project Facility Contact: Gary Myers, Safety and Environmental Manager Applicant Address 105 Boldt Lane, St.Claire,Missouri 63077 Facility Address 2100 North Church Street,Charlotte,NC 28206 Permitted Flow (MGD) 0.050 Type of Waste Treated Groundwater/Treated Vapors Facility Class PC-1 County Mecklenburg Facility Status Renewal Regional Office MRO Stream Characteristics Receiving Stream UT to Little Sugar Creek Stream C Classification Drainage Area(sq. mi.) NA Drainage basin Catawba Summer 7Q10 (cfs) 0.0 Subbasin 03-08-34 Winter 7Q10 (cfs) NA State Grid G15NE 30Q2 (cfs) NA USGS Topo Quad Charlotte East Average Flow(cfs) NA Permit Writer Joe R. Corporon IWC (%) 100%-Storm-drain Date 01 Sep2020 discharge=zero-flow receiving stream conditions. 303(d) Listed Yes-Impaired for Copper in the 2018 final 303(d)list. adalfOrir History Summary--Plaze Incorporated (Plaze or the Pennittee) applied for a discharge permit for a treatment system designed to remediate groundwater at their former Claire Sprayway facility in Charlotte. Groundwater was found to contain numerous volatile organic compounds including the metals and cleaning solvent [1,1,1-Trichloroethane(TCE) and associated decomposition products], 1,1-dichloroethene(DCE), and fuel-related Toluene (APP;Pace Analytical,pg. 10 of 16). These and similar contaminate plumes containing chlorinated solvents are believed to have originated offsite. There has been significant work to determine the scope of contamination of groundwater. Past attempts to remediate the contamination have failed. The renewal application includes data from several monitoring wells. These analyses document a list of 22 compounds and concentrations detected. Three of the compounds have no listed Water Quality Standards, so are not included as contaminants of concern. Groundwater and Vapor Treatment System—Treatment by air-stripping to removal trichloroethane(TCA),dichloroethene(DCE),and other volatile organic compounds from groundwater to achieve applicable surface water-quality Standards.Ground Water Remediation via monitoring and extraction wells are constructed entirely underground; air stripping facilities are aboveground in a treatment building. Fact Sheet NPDES Permit NC0089206 Page 1 The dual-phase extraction system consists of ten(10) [to be modified as needed] recovery wells, each equipped with an automated,pneumatically actuated total fluids recovery piped to a manifold leading to the water treatment system. The water flows to a low-profile air stripper for treatment, discharges via a sampling port,then discharges to the City of Charlotte's storm sewer system. Each well is connected to a blower providing vapor extraction at screened intervals within recovery wells. Extracted vapors from the wells connect to a manifold, condensed in a knockout drum, then filtered; final treatment vented to the atmosphere. The groundwater(3,000 to 5,000 gallons per day)is treated with air stripper discharging treated effluent to an outfall storm-drain(City of Charlotte).The storm sewer discharges to an unnamed tributary to Little Sugar Creek, eventually discharging aboveground to Little Sugar Creek. Table 2 --Discharge—Annual Flow Summaries in Million Gallons per Day(MGD) YEAR n MAX MIN AVE SUM 2016 361 0.231 0.004 0.032 11.45 2017 349 0.200 0.0003 0.250* 8.74 2018 290 0.269 0.0032 0.021 6.09 2019 244 0.233 0.003 0.020 4.91 2020 144 0.013 0.0003 0.004 0.452 *Flow considered for RPA but all POCs=ND. Table 3 --Parameters of Concern Summary (ug/L) PERAMETER n MAX MIN AVE Comments PCE 35 < 2 — — Not detected TCE 35 2.5 0.65 2 1,1 DCE 34 <2 — — Not detected 1,2 DCA 35 <2 < 1 1.2 Not detected TSS 44 25.9 2.5 4.0 — Naphthalene 35 <5 < 1 2.6 Not detected Toluene 35 <2 < 1 1.9 Not detected WET 16 — — All pass (TGP3B) 1,1,1 TCA 35 2.3 0.76 1.95 — Fact Sheet for Renewal Sep2020 NPDES NC0089206 Permit NC0089206 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1 All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,please visit the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." 5. Records Retention [Supplements Section D. (6.)1 The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Permit NC0089206 A. (3.) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS [G.S. 143-215.1 (b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit(Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.) Records Retention • Section E. (5.) Monitoring Reports 1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)l The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. The eDMR system may be accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr. If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the following address: NC DEQ/Division of Water Resources/Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 See"How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: • Sewer Overflow/Bypass Event Reports; Permit NC0089206 • Pretreatment Program Annual Reports; and • Clean Water Act(CWA) Section 316(b)Annual Reports. ➢ NPDES Electronic Reporting Rule—Phase 2 Extension. EPA is proposing to extend the Phase 2 deadline from December 21,2020 until at least December 21, 2023. The current compliance date will be extended if the implementation date is extended as a final regulation change in the federal register. The permittee may seek an electronic reporting waiver from the Division(see"How to Request a Waiver from Electronic Reporting"section below). by 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program)that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: https://www.federalregister.gov/documents/2015/10/22/2015- 24954/national-pollutant-discharge-elimination-system-npdes-electronic-reporting-rule Electronic submissions must start by the dates listed in the"Reporting Requirements"section above. 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty(60)days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time,monitoring data and reports shall be submitted electronically to the Division unless the permittee re-applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr Permit NC0089206 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq.,02B .0500 et seq.;Grade PCNC [15A NCAC 08G .0302] Beginning on the effective date of this permit and lasting until expiration,the Permittee is authorized to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT MONITORING REQUIREMENTS PARAMETER LIMITATIONS Monthly Daily Measurement Sample Type Sample Average Maximum Frequency Location Flow I 0.05 MGD Continuous Recording Effluent Total Suspended Solids 30.0 mg/L 45.0 mg/L Monthly Grab Effluent 1,1,1-Trichloroethane Quarterly Grab Effluent 1,1 -Dichloroethane Quarterly Grab Effluent 1,1 -Dichloroethene Quarterly Grab Effluent Naphthalene Quarterly Grab Effluent Tetrachloroethene Quarterly Grab Effluent Toluene Quarterly Grab Effluent 1,2-Dichloroethane Quarterly Grab Effluent Trichloroethene Quarterly Grab Effluent Chronic Toxicity 2 Quarterly Grab Effluent Footnotes: 1. Flow may be measured using a totalizing flow meter. 2. Chronic Toxicity(Ceriodaphnia)limit at 90%with testing in January,April,July and October [see A. (2)]. 3. Quarterly samples for monitored parameters shall coincide with the chronic toxicity test. Condition: The Permittee shall discharge no floating solids or foam visible in other than trace amounts. A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0200 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90 %. The permit holder shall perform at a minimum, Quarterly monitoring using test procedures outlined in the"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," (Revised December 2010, or subsequent versions) or"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised December 2010, or subsequent versions). The tests will be performed during the months of January, April, July, and October. These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during Permit NC0089206 representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple-concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-December 2010, or subsequent versions). All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT- 3 (original) is to be sent to the following address: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, NC 27699-1621 Or, results can be sent to the email, ATForms.ATB(aincdenr.gov. Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity(AT) test form indicating the facility name,permit number, pipe number, county, and the month/year of the report with the notation of"No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re-opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0089206 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Plaze Incorporated is hereby authorized to discharge wastewater from a facility located at the Claire Sprayway Remediation Project 2100 North Church Street, Charlotte Mecklenburg County to receiving waters designated as an unnamed tributary(UT)to Little Sugar Creek in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective , 2020. This permit and the authorization to discharge shall expire at midnight on June 30, 2025. Signed this day , 2020. S. Daniel Smith, Director Division of Water Quality Permit NC0089206 By Authority of the Environmental Management Commission PART I SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Plaze Incorporated is hereby authorized to: 1. continue to operate a dual phase [liquid &vapor] groundwater remediation system [permitted liquid flow 0.050 MGD] generating condensed vapors and treated groundwater(average total liquid discharge 3,000 to 5,000 gallons per day)utilizing • liquid phase - ten (10) each [or as modified] groundwater recovery wells; pneumatically automated for total fluids recovery; each well evacuated via a pump, pipe and manifold to the water treatment system; • low-profile air stripper(liquid phase final treatment) • flow meter, sample port and appurtenant piping to outfall storm-drain system (City of Charlotte). • vapor phase- each well fitted for vapor extraction from screened intervals at discrete depths; • vapors flow to a"knock-down"tank for condensing and venting • air filter(final treatment) for discharge to the atmosphere; these facilities located at the Claire Sprayway Remediation Project, 2100 North Church Street, Charlotte, Mecklenburg County; then 2. discharge from said treatment works (liquid phase) via Outfall 001, a the location specified on the attached map, into an unnamed tributary(UT) to Little Sugar Creek, a Class C waterbody located within subbasin 03-08-34 [HUC 0305010301], of the Catawba River Basin.