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HomeMy WebLinkAboutWQ0005135_Response to NOV-2020-DV-0338_20200831i , f; l u Most Important j. zoL DEQIDWR Justin Dawkins Director of Operations — Paper Manufacturing vonDrehle Cordova Operations Justin.Dawkins@vonDrehle.com August 27, 2020 Mr. Honeycutt Environmental Specialist Division of Water Resources, NCDEQ 225 Green Street, Suite 714 Fayetteville, NC 28301 Dear Mr. Honeycutt: AUG 3 12020 r—AYETTCVII� �ONALOFFICb, This letter and its attachment are in response to the Notice of Violation & Intent to Assess Civil Penalty that we received from J. Trent Allen, Regional Supervisor at the Water Quality Regional Operations Section of NCDEQ. As stated in the NOV, our Cordova facility had a discharge during the early morning hours of Thursday, July 9, 2020, which we reported to NCDEQ as soon as your office opened on the morning of July 921. The discharge was ceased as soon as possible and was repaired with a temporary cap. Once we received the proper supplies to replace the pipe and cap, we did so with schedule 80 couplings, pipe, and cap. We have a plan to install a protective barrier around the stub pipe in this area per your recommendation and it should be completed by September 4th, 2020. In addition to the physical repairs that were made to repair the ruptured cap and pipe, we solicited Geosyntec Consultants to aide us in evaluating the effect of the discharge and give us a professional opinion about it — prior to issuing our press release about it. Following receipt of the NOV, we also asked Geosyntec to confirm that our estimate of the volume of the discharge was correct. The attachment is their formal evaluation with supporting documentation. von Drehle values the professional relationship that we have formed with you and your team and hope that we can continue to demonstrate our desire to be environmentally responsible. Please let me know if there is any additional information or questions that we can assist with on this matter. Sincerely, Justin Dawkins Director of Operations — Paper Manufacturing vonDrehle Cordova Operations Geosyntec consultants Geosyntec Consultants of NC, PC VIA ELECTRONIC -MAIL Mr. Justin Dawkins Director of Operations- Paper Manufacturing von Drehle Corporation 126 1" Street Cordova, NC 28330 Subject: 9 July 2020 Krofta Release Calculations von Drehle facility, Cordova, NC INTRODUCTION Geosyntee Consultants of NC, PC. 201 N Front Street, Suite 501 Wilmington, NC 28401 PH 910.726.3652 N w .geosyntec.com 27 August 2020 Geosyntec Consultants of NC, PC ("Geosyntec") has prepared this Technical Memorandum for von Drehle Corporation ("von Drehle" or "Client") to document our calculations and conclusions completed prior to and in support of the Notification of Discharge of Partially Treated Wastewater published by von Drehle in the Richmond Observer on 14 July 2020 (the "Notice"). UNDERSTANDING AND SCOPE OF WORK We understand that a discharge of partially treated wastewater into Little Carr Creek occurred at von Drehle Corporation's facility in Cordova, North Carolina (the "Facility") due to a crack in a PVC cap between 2:00 A.M. and 7:00 A.M. on 9 July 2020 (the "Discharge"), at which time the discharge ceased. We understand that this wastewater had already been treated by the Facility's Krofta dissolved air floatation equipment (the "Krofta"). von Drehle estimated the total volume of water released to Little Carr Creek to be between 1,000 and 2,000 gallons. Prior to publication of von Drehle's Notice, Geosyntec conducted screening of parameters that are routinely measured in Krofta effluent and/or are required by the Facility's discharge permit against Title 15A of the North Carolina Administrative Code (NCAC) subchapter 02B surface water standards ("213 Standards") for Class C Freshwater to evaluate which parameters should be included in mixing and dilution calculations. Geosyntec conducted mixing engineers I scientists I innovators Mr. Justin Dawkins 27 August 2020 Page 2 and dilution calculations to evaluate, based on the estimated volume of the Discharge, its potential effect on water quality in Little Carr Creek relative to Class C Freshwater 2B Standards. Geosyntec provided the results of this analysis to von Drehle by conference call and a follow up email on 14 July 2020, prior to publication of the Notice. The following information was used for the calculations: • Historical wastewater quality data supplied by von Drehle; • Analytical results for samples of the Discharge water collected by von Drehle (Attachment A); • The site observations, pipe and fracture information, and duration (five hours) of the Discharge supplied by von Drehle; • The base flow rate in Little Can Creek (152 cubic feet per second (cfs) or 68,000 gallons per minute (gpm)) supplied by Grimes Engineering, P.C. to von Drehle; and • North Carolina 15A NCAC 02B Water Quality Standards for Class C Freshwater (effective 1 November 2019). ESTIMATION OF DISCHARGE QUANTITY REACHING LITTLE CARR CREEK Von Drehle received the North Carolina Department of Environmental Quality's ("DEQ") 7 August 2020 Notice of Violation and Intent to Assess Civil Penalty on 14 August 2020. Thereafter, von Drehle asked Geosyntec to confirm the accuracy of von Drehle's original estimate of the volume of the Discharge. The discharge occurred due to leakage of Krofta effluent through a non -displaced crack across the face of a 6-inch diameter Schedule 40 PVC male threaded pipe plug that was installed in the end of a tee fitting that was oriented at 90 degrees vertical to a horizontal 6-inch diameter Schedule 40 PVC pipe. The plug arrangement also included a rubber membrane covering the entire area on the inside of the male plug. This membrane was observed to be intact after removal of the PVC plug. Information provided from the Facility includes: • Estimated width of the crack = 1/32 inch engineers I scientists I innovators Mr. Justin Dawkins 27 August 2020 Page 3 • Estimated length of the crack = 6 inches • Estimated observed height of vertical waterspout emanating from the crack = 5 feet • Duration of discharge event = 5 hours • Volume of water recovered by von Drehle = 550 gallons The height of the waterspout was assumed to be equivalent to the velocity head of the water exiting the crack, given by the following equation: Where: H = Height of waterspout, 5 feet (ft) v = velocity of water exiting crack, feet per second (ft/s) g = acceleration due to gravity, 32.2 feet per second per second (f ls') Solving for velocity and substituting values yields the following: v= VH 229=,I5ftx2x32.2f =17.9 St Flow can be computed by multiplying the velocity by the area of the crack. The area of the crack is estimated below: A = l x w = 6 inches x 32 inch = 0.1875 inches' z A = 0.1875 inches' x 144 inches' = 0.0013 ft' Flow is computed as follows: Q=vxA=17.9ftx0.0013ft'=0.0233 f 3 s s engineers I scientists I innovators Mr. Justin Dawkins 27 August 2020 Page 4 3 Q = 0.0233f tt x 7.48gallons x 60 s = 10.46 gallons s f t3 minute minute Volume released over a 5-hour period is estimated as follows: gallons minutes V = Q x t = 10.46 minute x 5 hours x 60 hour = 3,138 gallons Subtracting the volume recovered by von Drehle: VDischarge = V — 550 gallons = 3,138 gallons — 550 gallons = 2,588 gallons Therefore, a likely estimate for volume of the discharge reaching Little Carr Creek is 2,588 gallons and von Drehle's initial estimate of 1,000 to 2,000 gallons was a good approximation of that volume. As shown below, the additional 588 gallons of partially treated wastewater does not alter our original conclusion that the Discharge did not cause a violation of the Class C 2B Standards in Little Carr Creek. SCREENING OF DISCHARGE WATER QUALITY DATA AGAINST CLASS C 2B FRESHWATER STANDARDS Table 1 summarizes screening of available water quality parameters in the Discharge water against parameters with Class C 2B Standards to identify parameters that are routinely measured in the Krofta effluent that also have 2B Standards. The following parameters measured in Krofta effluent were identified as having Class C Freshwater 2B Standards: • Cadmium; • Chromium; • Lead; • Nickel; • pH; • Temperature; engineers I scientists I innovators Mr. Justin Dawkins 27 August 2020 Page 5 • Turbidity; and • Zinc. MIXING CALCULATIONS AND COMPARISON TO CLASS C 2B FRESHWATER STANDARDS Table 2 presents the results of mixing calculations completed to estimate the possible contribution of the Discharge to changes in water quality in Little Carr Creek. As shown in the table, the smaller volume of the Discharge (2,588 gallons) compared to the large volume of flow through Little Carr Creek (20.4 million gallons) during the 5-hour discharge window, resulted in negligible changes to water quality within Little Carr Creek. The estimated upstream copper and lead were above the water quality standard but were unaffected by the addition of the Discharge. This was the result of the background water quality assumption used for copper and lead. Each of the other estimated in - stream concentrations were below their respective acute and chronic water quality standards. An example mixing calculation for BOD is provided below. Calculations for other parameters were conducted similarly: BODmix = BODDischarge X VDischarge + BODstream X Vstream VDischarge + VStream Where: BOD,,,ix=BOD after mixing of Discharge with Little Carr Creek flow, milligrams per liter (mg/L) BODDlschng = BOD in the Discharge water from the Krofta, mg/L VDiscbe p = Volume of Krofta Discharge, gallons BODstream = Upstream BOD in Little Carr Creek, mg/L Vstre. = Volume of flow in Little Carr Creek during Discharge Period, gallons Substituting values for the variables: 2,110 Mg x 2,588 gallons + 1 � x 20,400,000 gallons mg BODmix = 2,588 gallons + 20,400,000 gallons — 1.27 L engineers I scientists I innovators Mr. Justin Dawkins 27 August 2020 Page 6 It can be seen from the example calculation that even though the BOD in the Discharge was significantly higher than the upstream BOD concentration in Little Carr Creek, the resulting change in concentration was very small due to the large amount of dilution that occurred during the time of the Discharge. CONCLUSIONS Based on the calculations and analysis provided in this memorandum, it is Geosyntec's opinion that the Discharge did not cause violations of the North Carolina water quality standards in Little Carr Creek. engineers I scientists I innovators Alt Prepared by: Todd DeJournett, Ph.D., P.E.MN,FL,1. r,MT Senior Engineer, Geosyntec Consultants Reviewed by: Joseph G. Cleary, BCEE, P.E.NY,NI, Puerto Rico Senior Consultant Reviewedby: ICaitlyn Rhonehouse, P.E.NC Principal, Geosyntec Consultants of NC, PC PROFESSIONAL ENGINEER SIGNATURE I, Kaitlyn Rhonehouse, a Licensed Engineer for Geosyntec Consultants of NC, P.C., do certify that the information in this report is correct and accurate to the best of my knowledge. Geosyntec Consultants of NC. P.C. is licensed to practice engineering in North Carolina. The certification number (Firm's License Number) is C-3500. � C111/11 0 ?r y 4 SEAL 9r- 43 b ; {1548 1. �GI` NVrj Jytu� /i//,tRH0V0 Kaitlyn Rhonehouse, PE Principal Engineer North Carolina P.E. License No. 043548 Expiration Date: 31 December 2020 Geosyntec Consultants of NC, PC 201 N Front Street, Suite 501 Wilmington, NC 28401 Telephone: (910) 726-3652 engineers I scientists I innovators REFERENCES USGS, 1983. Water Quality of North Carolina Streams. United States Geological Survey Water Supply Paper 2185-E. USGS, 1952. Water Resources for the Yadkin -Pee Dee River Basin, North Carolina. United States Geological Survey Water Supply Paper 1415. engineers I scientists I innovators TABLES engineers I scientists I innovators $ d z z � � z a z AAA �353 F ° 2 a' ° g z° 4 °a m @ 3 y¢y Ha yq �A Z g 3sa a z r L pp a 69 yygg 3 E gy _ E `o py En° � o°Lyny e � 2 n 2 `a" S�^3 og 2g �= s � Y �o „ se `o a I v$ a 3 ���gQBv@g�osa cvc gr c aa•23 XE 2 a C g b u F 3 m � ��g52�o�s2o;$ „8„+33'so Y EE �8osasr?ye=s n $ �n 5 1O $ a c e o Be�P.gsg C 3 tpc I i N U �;U e gCg8 V M O °o V, u a � U a' b o 0 N U m � a a � 8 r y 3 v, O � q m 3 h w c F V � � v � N F a a a 3 W n O a� i i 33.5 C e d 5 $ O a L. � � a 0 U V U Attachment A engineers I scientists I innovators MICROBAC° Microbac Laboratories, Inc. - Fayetteville CERTIFICATE OF ANALYSIS KOG0151 Von Drehle Corporation Project Name: Spill Mr. Chris Fowler Project / PO Number: N/A 126 First Street Received: 07/09/2020 Cordova, NC 28330 Reported: 07/17/2020 Analytical Testing Parameters Client Sample ID: Effluent, composite Sample Matrix: Aqueous Collected By: Wright Lab Sample ID: KOG0151-01 Collection Dale: 07/09/2020 14:24 *" DEFAULT GENERAL METHOD """ Result RL Units Dilution Note Prepared Analyzed Analyst SM 2540 D-2011 Total Suspended Solids 118 30.5 mg/L 12 07/13/20 0857 JDW SM 5210 B-2011 BOD 2110 2.00 mg/L 1 07/09/201837 07/14/20 1703 MT Inorganics Total Result RL Units Dilution Note Prepared Analyzed Analyst SM 4500-H+ B-2011 pH at 25 °C 7.4 1.0 S.U. 1 H 07/16/20 1427 TBM SM 5220 0-2011 COD, Total 5580 10.0 mg/L 07/14/20 0928 07/15/20 0941 MT Analyses Subcontracted to: Microbac Laboratories Inc., - Marietta, OH Metals Total by ICPMS Result RL Units Dilution Note Prepared Analyzed Analyst EPA 200.8, Rv. 5.4 (1994) Cadmium <0.00120 0.00120 mg/L 2 D1 07/15/20 0931 07/15/20 1653 JYH Chromium <0.0200 0.0200 mg/L 5 D1 07/15/20 0931 07/16/20 1459 JYH Copper 0.0133 0.0100 mg/L 5 01 07/15/20 0931 07/16/20 1459 JYH Lead <0.00200 0.00200 mg/L 2 D1, J 07/15/20 0931 07/15/20 1653 JYH Nickel 0.0200 0.00800 mg/L 2 D1 07/15/20 0931 07/15/20 1653 JYH Zino 0.176 0.0600 mg/L 2 D1 07/15/20 0931 07/15/20 1663 JYH Definitions DI: Dilution was performed due to matrix interference. H: Analyse was prepared and/or analyzed outside of the analytical method holding time J: The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample. MDL: Minimum Detection Limit mg/L: Milligrams per Liter RL: Reporting Limit S.U.: Standard Units Microbac Laboratories, Inc. 2592 Hope Mills Rd I Fayetteville, NC 28306 1910.864.1920 p I www.microbac.com Page 1 of 3 Microbac Laboratories, Inc. - Fayetteville CERTIFICATE OF ANALYSIS KOG0151 Project Requested Certification(s) Microbac Laboratories Inc., - Marietta, OH 583 NC Dept. of the Environment and Natural Resources Report Comments Reviewed and Approved By: Samples were received in proper condition and the reported results conform to 1� I �. applicable accreditation standard unless otherwise noted. The data and information on this, and other accompanying documents, represents only the sample(s) analyzed. This report is Incomplete unless all pages Indicated in the footnote am Brittany Smith present and an authorized signature is included. The services were provided under and Administration subject to Microbac's standard terms and conditions which can be located and reviewed at <httos://w w.microbac.com/standartlderms-conditions>. Reported: 071171202017:32 Microbac Laboratories, Inc. 2592 Hope Mills Rd I Fayetteville, NC 283061 910.864.1920 p I www.microbac.com Page 2 of 3 . 0 \ ON 2 S 2 � 0 k § k 0 k ) / k 4 LIJ § k + \ z»«\�`d k\ .§Ake} 0 2§U§ in� ( � § m k k b mz'@lNA' #mo 2 'is wow 4g U3 * < a e e! < .� k % | x . } k § + § § § ; ■ m 2 � ) /| / ,| a « co |(! }.uj ±2 -, � 2 2 ) | u q § §I§ (6 Z ) k � � � � , ! , ! A| CID! 00 * £ 2 ! ! ! � OD I ' ! �! | ! ƒ ƒ ( ! ! | !