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HomeMy WebLinkAboutNC0058084_Fact Sheet_20200813FACT SHEET FOR EXPEDITED PERMIT RENEWALS This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Basic Information for Expedited Permit Renewals Permit Writer / Date Brianna Young 8/13/2020 Permit Number NCO058084 Facility Name / Facility Class GoughEcon WWTP / WW-1 Basin Name / Sub -basin number Catawba / 03-08-34 Receiving Stream / HUC UT to Catawba River / 030501011405 Stream Classification / Stream Segment WS-IV, B; CA / I I - 122 Does permit need Daily Maximum NH3 limits? Already present Does permit need TRC limits/language? Already resent Does permit have toxicity testing? IWC (%) if so N/A Does permit have Special Conditions? No Does permit have instream monitoring? Yes - Temperature Is the stream impaired on 303 d list)? Yes — PCB fish tissue advisory Any obvious compliance concerns? Yes — fecal coliform and ammonia nitrogen exceedances Any permit mods since lastpermit? None New expiration date 6/30/2025 Comments on Draft Permit? None Section 1. Facility Overview: Gough Econ, Inc. operates manufacturing facility that produces light sheet metal products, with wastewater generated by bathrooms onsite. The facility has a permitted wastewater discharge of 0.0012 MGD. The facility generates an intermittent discharge (2-3 days per week for 8 hours). The treatment system consists of a septic tank, dosing tank, sand filter, recirculating tank with pump, mushroom fountains, tablet chlorine contact tank, tablet dichlorination tank, cascade and effluent pipe. Section 2. Compliance History (June 2015 — June 2020): • 1 NOD for fecal coliform daily max exceedance • 3 NOVs for fecal coliform daily max exceedances • 1 NOD for ammonia nitrogen monthly average exceedance • 3 NOVs for ammonia nitrogen monthly average exceedances • 1 enforcement case for ammonia nitrogen monthly average exceedance • 1 NOV for late/missing DMR Page 1 of 7 303(d) listing: J ICATAWBA RIVER (Lake Wylie below elevation 570) 1-95 bridge to the upstream side of Paw Creek Arm of Lake Wylie, Catawba River Classification WS-IV,B;CA Length or Area 601 llnits FW Acres Previous AU Number ment Criteria Status Reason for Rating Parameter of Interest Category ding Criteria Fish Consumption Advisory PCB Fish Tissue Advisory (Advisory, FC, NC) IF Section 5. Changes from previous permit to draft: • Updated eDMR footnote inA(1) and language in A(2) • Updated outfall map • Added facility grade in A(1) • Added receiving stream characteristics on the Supplement to Permit Cover Sheet Section 6. Changes from draft to final: • eDMR language updated in A(2) Section 7. Comments received on draft permit: • None NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as approved. Table 1. NC Dissolved Metals Water Oualitv Standards/Aauatic Life Protection Parameter Acute FW, µg/1 (Dissolved) Chronic FW, µg/1 (Dissolved) Acute SW, µg/1 (Dissolved) Chronic SW, µg/1 (Dissolved) Arsenic 340 150 69 36 Beryllium 65 6.5 --- --- Cadmium Calculation Calculation 40 8.8 Chromium III Calculation Calculation --- --- Chromium VI 16 11 1100 50 Copper Calculation Calculation 4.8 3.1 Lead Calculation Calculation 210 8.1 Nickel Calculation Calculation 74 8.2 Silver Calculation 0.06 1.9 0.1 Page 2 of 7 Zinc I Calculation I Calculation 190 1 81 Table 1 Notes: 1. FW= Freshwater, SW= Saltwater 2. Calculation = Hardness dependent standard 3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative concerns (as are all human health standards for all metals). It is still necessary to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC 213.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life protection). Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC 02B .0211 Subparagraph (11)(d) Metal NC Dissolved Standard, µg/l Cadmium,Acute WER* {1.136672-[ln hardness](0.041838)} e'l0.9151 [ln hardness]-3.14851 Cadmium, Acute Trout waters WER*{1.136672-[lnhardness](0.041838)} e'l0.9151[lnhardness]-3.62361 Cadmium,Chromc WER* {1.101672-[ln hardness](0.041838)} e'l0.7998[ln hardness]-4.4451 } Chromium III, Acute WER*0.316 e^{0.8190[lnhardness]+3.7256} Chromium III, Chronic WER*0.860 e^{0.8190[lnhardness]+0.6848} Copper, Acute WER*0.960 • e^{0.9422[ln hardness]-1.700) Copper, Chronic WER*0.960 • eA10.8545[ln hardness]-1.702) Lead,Acute WER*{1.46203-[ln hardness](0.145712)) • eAll .273[ln hardness]-1.4601 Lead, Chronic WER* { 1.46203-[ln hardness](0.145712)) • eAll .273 [ln hardness]4.705 } Nickel, Acute WER*0.998 e^{0.8460[ln hardness]+2.255} Nickel, Chronic WER*0.997 e^{0.8460[ln hardness]+0.0584} Silver, Acute WER*0.85 • eAll .72[ln hardness]-6.59} Silver, Chronic Not applicable Zinc, Acute WER*0.978 e^{0.8473[ln hardness]+0.884} Zinc, Chronic WER*0.986 e^{0.8473[ln hardness]+0.884} General Information on the Reasonable Potential Analysis (RPA) The RPA process itself did not change as the result of the new metals standards. However, application of the dissolved and hardness -dependent standards requires additional consideration in order to establish the numeric standard for each metal of concern of each individual discharge. The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness and so must be calculated case -by -case for each discharge. Page 3 of 7 Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The discharge -specific standards must be converted to the equivalent total values for use in the RPA calculations. We will generally rely on default translator values developed for each metal (more on that below), but it is also possible to consider case - specific translators developed in accordance with established methodology. RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and the critical low -flow values for the receiving stream. If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level), then the Division may remove the monitoring requirement in the reissued permit. 1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the following information: • Critical low flow of the receiving stream, 7Q 10 (the spreadsheet automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993 • Effluent hardness and upstream hardness, site -specific data is preferred • Permitted flow • Receiving stream classification 2. In order to establish the numeric standard for each hardness -dependent metal of concern and for each individual discharge, the Permit Writer must first determine what effluent and instream (upstream) hardness values to use in the equations. The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any hardness data and contacts the Permittee to see if any additional data is available for instream hardness values, upstream of the discharge. If no hardness data is available, the permit writer may choose to do an initial evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively. If the use of a default hardness value results in a hardness -dependent metal showing reasonable potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and upstream hardness samples over a period of one week. The RPA is rerun using the new data. Page 4 of 7 The overall hardness value used in the water quality calculations is calculated as follows: Combined Hardness (chronic) = (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q 10, cfs *Avg. Upstream Hardness, mg/L) (Permitted Flow, cfs + s7Q 10, cfs) The Combined Hardness for acute is the same but the calculation uses the IQ 10 flow. 3. The permit writer converts the numeric standard for each metal of concern to a total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have been developed using federally approved methodology. EPA default partition coefficients or the "Fraction Dissolved" converts the value for dissolved metal at laboratory conditions to total recoverable metal at in -stream ambient conditions. This factor is calculated using the linear partition coefficients found in The Metals Translator: Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation: Cdiss = 1 Ctotal 1 + { [Kpo] [SS(1+a)] [10-6] } Where: ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used, and Kpo and a = constants that express the equilibrium relationship between dissolved and adsorbed forms of metals. A list of constants used for each hardness -dependent metal can also be found in the RPA proeram under a 4. The numeric standard for each metal of concern is divided by the default partition coefficient (or site -specific translator) to obtain a Total Recoverable Metal at ambient conditions. In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is dissolved to the same extent as it was during EPA's criteria development for metals. For more information on conversion factors see the June, 1996 EPA Translator Guidance Document. 5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration (permit limits) for each pollutant using the following equation: Ca = (s7Q 10 + Qw) (Cwgs) (s7Q 10) (Cb) Page 5 of 7 Qw Where: Ca = allowable effluent concentration (µg/L or mg/L) Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L) Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L) Qw = permitted effluent flow (cfs, match s7Q 10) s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human health through the consumption of water, fish, and shellfish from noncarcinogens (cfs) * Discussions are on -going with EPA on how best to address background concentrations Flows other than s7Q 10 may be incorporated as applicable: IQ 10 = used in the equation to protect aquatic life from acute toxicity QA = used in the equation to protect human health through the consumption of water, fish, and shellfish from carcinogens 30Q2 = used in the equation to protect aesthetic quality 6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern. Data entered must have been taken within four and one-half years prior to the date of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper concentration of each pollutant. The Predicted Max concentrations are compared to the Total allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable potential to violate the water quality standard, and a permit limit (Total allowable concentration) is included in the permit in accordance with the U.S. EPA Technical Support Document for Water Quality - Based Toxics Control published in 1991. 7. When appropriate, permit writers develop facility specific compliance schedules in accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. 8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be compared against water quality standards for chromium III and chromium VI. 9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted into all permits with facilities monitoring for hardness - dependent metals to ensure the accuracy of the permit limits and to build a more robust hardness dataset. 10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included: Page 6 of 7 Parameter Value Comments(Data Source Average Effluent Hardness No RPA necessary (mg/L) N/A Total as, CaCO3 or Ca+M Average Upstream Hardness No RPA necessary (mg/L) N/A [Total as, CaCO3 or (Ca+Mg)] 7Q 10 summer (cfs) N/A No RPA necessary 1 10 cfs N/A No RPA necessary Permitted Flow MGD N/A No RPA necessary Page 7 of 7 the TI),artotte (96seruer charlotteobserver.com LakeN Z I N E n Carolina Brideos CL"T AFFIDAVIT OF PUBLICATION Amount# Ad Number ld.nhficatian 145583 1 0004694441 1 Public Notice North Carolina Environmental Management Commission/N Attention: Wren Thedford NCDENR/DWQ/POINT SOURCE 1617 MAIL SERVICE CENTER RALEIGH, NC 276991677 PUBLIC NOTICE North Carolina Environmerrcel Management commatuarNPDES unit 1617 Mail Ser me Center Raleigh, NC 27699-1617 Notice of Insert to Issue a NPDES Wastewater Permit 14Co05a09a Gough Econ W WTP The North Caroline Environmental Management Commission proposes to laws a NPDES wastewater da perm N to tha persons) Fstetl below. Wns[en comments regarNng the proposed permit will be am ted umil 30 al Y after the publish date of this irome. The Dino for of the NC Division of Water Resources (DWR) may hold a public hearing should Mare be e si Aicant Eegme o1 public Interest. Please mail comments antl/or intormetion requests to D Rat the above aWress. Interested parsons may vistt the DWR at 512 N. Salisbury Sheet Raleigh, NC to review inbrmason on Me. Addilpnel iMormaOan on NPDES permits antl Mis no- 6ce may be lound on our webs@.:Mpgidm.nc.gov/eboWmvisiona/watar-msourc Mater-res nurses -as in reFxastewatwmnchMpfte wastewater/pubic-no ms,m by calling (919) 707- 3601. GW9h Emn, Inc. has applied Mr renewal of permit NC005fal for Me Gough Eton, Inc W WrP in MecldenbuM iDwr Thu permihed discharge is 00012 MGD crested wastewater to an unnamed tributary to the (atewba River in the Catawba River Basin. This discharge may af- feq tutors allotions inthis portion 0e Catawba River Basin.LPa69aaa1 ca North Carolina } SS Mecklenburg County } Before the undersigned, a Notary Public of said County and State, duly authorized to administer oaths affirmations, etc., personally appeared, being duly sworn or affirmed according to law, cloth depose and say that he/she is a representative of The Charlotte Observer Publishing Company, a corporation organized and doing business under the laws of the State of Delaware, and publishing a newspaper known as The Charlotte Observer in the city of Charlotte, County of Mecklenburg, and State of North Carolina and that as such he/she is familiar with the books, records, files, and business of said Corporation and by reference to the files of said publication, the attached advertisement was inserted. The following is correctly copied from the Insertions) Published On: July 10, 2020 c� 0(�-t lix�VD Chem Foster. Regional Office Associate In Testimony Whereof I have hereunto set my hand and affixed my seal on the 9th day of July, 2020 Electignic Notary Public State of North Camtina Young, Brianna A From: Cook, Clinton Sent: Tuesday, August 11, 2020 10:11 AM To: Young, Brianna A Subject: RE: Draft NPDES permit NC0058084 to public notice Attachments: NC0058084 PWS memo (Cook).pdf Brianna, I appreciate the opportunity to review the subject draft permit and have attached an electronic copy of the memorandum describing my response. Please also note that the nearest downstream raw water intake for a public water system is associated with the City of Belmont and is located approximately 1.9 miles downstream. If you have any questions or need any additional information, please let me know. Thanks, Clint Clinton O. Cook, PE Regional Engineer Division of Water Resources — Public Water Supply Section North Carolina Department of Environmental Quality 704 663 1699 office 704 663 6040 fax clinton.cook(cDncdenr.gov Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Young, Brianna A Sent: Wednesday, July 8, 2020 9:44 AM To: Cook, Clinton <clinton.cook@ncdenr.gov> Subject: Draft NPDES permit NC0058084to public notice Good morning Clinton, Attached is the draft NPDES permit NC0058084 for the Gough Econ, Inc. WWTP that has been submitted to public notice. Please fill out the attached form and return it to me by August 7tn Thank you, Brianna Young Environmental Specialist II Compliance and Expedited Permitting Branch Division of Water Resources Department of Environmental Quality Office: 919-707-3619 Brianna.Young@ncdenr.gov Mailing address: 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. ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director MEMORANDUM To: Clinton Cook NORTH CAROLINA Environmental Quality July 8, 2020 NC DEQ / DWR / Public Water Supply Mooresville Regional Office From: Brianna Young Compliance and Expedited Permitting Unit Subject: Review of Draft NPDES Permit NCO058084 Gough Econ, Inc. WWTP Mecklenburg County Please indicate below your agency's position or viewpoint on the draft permit and return this form by August 7, 2020. If you have any questions on the draft permit, please contact me at 919-707-3619 or via e-mail [brianna.young@ncdenr.gov]. §§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§ RESPONSE: (Check one) ❑Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Px� Concurs with issuance of the above permit, pfovided the following erditiors are et:* * I have no appreciable expertise in implementation of the Clean Water Act requirements and have minimal understanding of the information provided. As a result, I have no basis for opposing the permit. F-1 Opposes the issuance of the above permit, based on reasons stated below, or attached: r ��' Date. 8/11 /2020 Signed. D E Q North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 N(1HTH f:Ai(1!_INA � n ­ro emoreowmen'e wQ� i 919,707,9000 MONITORING REPORT(MR) VIOLATIONS for: Report Date: 06/18/2C Page 1 of 2 Permit: nc0058084 MRS Betweei 6 - 2015 and 6 - 2020 Region: % Violation Category:% Program Category: Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO058084 FACILITY: Gough Econ Inc - Gough Econ WWTP COUNTY: Mecklenburg REGION: Mooresville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 06-2015 001 Effluent Chlorine, Total Residual 06/30/15 2 X week ug/I 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 07-2015 001 Effluent Chlorine, Total Residual 07/03/15 2 X week ug/I 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 09-2015 001 Effluent Chlorine, Total Residual 09/02/15 2 X week ug/I 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 07-2019 001 Effluent Chlorine, Total Residual 07/29/19 2 X week ug/I 17 24 41.2 Daily Maximum No Action, BPJ Exceeded 08-2019 001 Effluent Chlorine, Total Residual 08/02/19 2 X week ug/I 17 19 11.8 Daily Maximum No Action, BPJ Exceeded 08-2019 001 Effluent Chlorine, Total Residual 08/13/19 2 X week ug/I 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 08-2019 001 Effluent Chlorine, Total Residual 08/16/19 2 X week ug/I 17 20 17.6 Daily Maximum No Action, BPJ Exceeded 11 -2019 001 Effluent Chlorine, Total Residual 11/01/19 2 X week ug/I 17 22 29.4 Daily Maximum No Action, BPJ Exceeded 01 -2020 001 Effluent Chlorine, Total Residual 01/03/20 2 X week ug/I 17 18 5.9 Daily Maximum No Action, BPJ Exceeded 04-2016 001 Effluent Coliform, Fecal MF, MFC 04/26/16 2 X month #/100ml 400 411 2.8 Daily Maximum Proceed to NOD Broth, 44.5 C Exceeded 08-2016 001 Effluent Coliform, Fecal MF, MFC 08/09/16 2 X month #/100ml 400 2,419.6 504.9 Daily Maximum Proceed to NOV Broth, 44.5 C Exceeded 01 -2018 001 Effluent Coliform, Fecal MF, MFC 01/10/18 2 X month #/100ml 400 1,553.1 288.3 Daily Maximum Proceed to NOV Broth, 44.5 C Exceeded 10-2019 001 Effluent Coliform, Fecal MF, MFC 10/21/19 2 X month #/100ml 400 579.4 44.8 Daily Maximum Proceed to NOV Broth, 44.5 C Exceeded 06 -2016 001 Effluent Nitrogen, Ammonia Total (as 06/30/16 2 X month mg/I 2 2.13 6.5 Monthly Average Proceed to NOV N) - Concentration Exceeded 01 -2018 001 Effluent Nitrogen, Ammonia Total (as 01/31/18 2 X month mg/I 4 5.82 45.6 Monthly Average Proceed to NOV N) - Concentration Exceeded 05-2018 001 Effluent Nitrogen, Ammonia Total (as 05/31/18 2 X month mg/I 2 2.35 17.5 Monthly Average Proceed to NOV N) - Concentration Exceeded MONITORING REPORT(MR) VIOLATIONS for: Report Date: 06/18/2C Page 2 of 2 Permit: nc0058084 MRS Betweel 6 - 2015 and 6 - 2020 Region: % Violation Category:% Program Category: % Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO058084 FACILITY: Gough Econ Inc - Gough Econ WWTP COUNTY: Mecklenburg REGION: Mooresville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 09 -2018 001 Effluent Nitrogen, Ammonia Total (as 09/30/18 2 X month mg/I 2 2.08 3.8 Monthly Average Proceed to NOD N) - Concentration Exceeded 11 -2018 001 Effluent Nitrogen, Ammonia Total (as 11/30/18 2 X month mg/I 4 5.32 33 Monthly Average Proceed to N) - Concentration Exceeded Enforcement Case Monitoring Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 10-2015 001 Effluent Temperature, Water Deg. 10/31/15 5 X week deg c Frequency Violation No Action, BPJ Centigrade 06 -2016 001 Effluent Temperature, Water Deg. 06/04/16 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 03 -2017 001 Effluent Temperature, Water Deg. 03/04/17 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 10 -2019 001 Effluent Temperature, Water Deg. 10/05/19 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 10 -2019 001 Effluent Temperature, Water Deg. 10/12/19 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 10 -2019 001 Effluent Temperature, Water Deg. 10/19/19 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 10 -2019 001 Effluent Temperature, Water Deg. 10/26/19 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 11 -2019 001 Effluent Temperature, Water Deg. 11/02/19 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error 01 -2020 001 Effluent Temperature, Water Deg. 01/04/20 5 X week deg c Frequency Violation No Action, Facility Centigrade Reporting Error Reporting Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 05-2017 07/01/17 Late/Missing DMR Proceed to NOV ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. David Risley Gough Econ Post Office Box 668583 Charlotte, North Carolina 28266 Dear Mr. Risley: NORTH CAROLINA Environmental Quality 27 March 2019 Subject: Notice of Deficiency Compliance Evaluation Inspection Gough Econ WWTP NPDES Permit No. NCO058084 Mecklenburg County Tracking #: NOD-2019-PC-0076 Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on March 21, 2019, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. This report is being issued as a Notice of Deficiency (NOD) due to the following: 1) Failure to properly maintain the sand filter (solids removal); 2) Failure to repair the metal support structure for the tablet chlorinator; 3) Failure to properly document effluent results and meter calibrations/verifications for all sampling events; 4) Failure to properly report effluent data on the Discharge Monitoring Reports (eDMRs); These are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215 as detailed in the Sand Filter (Low Rate)/Summary, Disinfection -Tablet and Record Keeping/Summary Sections of the attached report. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State that may result from the violations. It is requested that a written response be submitted to this Office by April 17, 2019, detailing the actions taken to address all above -noted violations. hi responding, please address your comments to the attention of Mr. Wes Bell. North Carolina Department of Environmental Quality I Division of Water Resources ece�- DEQ �� Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROLINA o,g.aE""'°" bl°"'niv 704,663.1699 Mr. David Risley Page Two 27 March 2019 The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bellgncdenr.gov. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 15 1 3 I NCO058084 111 12 I 19/03/12 I17 18 I C I 19 I G I 201 21111111IIIIIIIIIIIIIIIIII1IIIIII IIIIIIIIIII f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 70 71 [.. I 72 l-1 L �, � 73 L_LJ74 751 1 1 1 1 LU80 LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oermit Number) 09:32AM 19/03/12 15/07/01 Gough Econ WWTP 9400 N Lakebrook Rd Sr Exit Time/Date Permit Expiration Date Charlotte NC 28214 12:30PM 19/03/12 20/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Steven L Lam bert/ORC/704-546-2602/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted David P Risley,PO Box 668583 Charlotte NC 28266/President/704-399-2306/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Wes Bell DocuSigned by: MRO WQ//704-663-1699 Ext.2192/ 3/26/2019 �Piy �e& A61696D90CC343T Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger Division of Water Quality//704-2; EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 3/27/2019 AlaccsalAFvazs... Page# NPDES yr/mo/day Inspection Type (Cont.) NCO058084 I11 12, 19/03/12 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: Only one effluent total residual chlorine (TRC) result was reported for the weeks of 4/22/18, 10/28/18 and 12/23/18. The inspection verified that the above -noted monitoring violations were transcription errors and therefore, revised eDMRs will be submitted and mailed in to the Division. The Permittee and ORC must ensure that all eDMRs are accurate and complete prior to submittal. The records reviewed during the inspection were organized and readily accessible; however, there were several instances of either the pH and TRC effluent results or the meter calibrations/verifications not being properly documented as required by the subject Permit [Part II, Section D(6) Records Retention & D(7) Recording Results]. The Permittee and ORC must ensure that all data is properly documented and maintained. SAND FILTERS (LOW RATE) SECTION cont'd: Ponding was observed during the recirculation process and the ORC indicated that the entire sand bed is submerged during a discharge event from the dose tank. Extensive ponding for extended periods of time can negatively impact the aerobic biological treatment processes. The Permittee and ORC must ensure that the sand bed is consistently raked of solids, spent sand is replaced when needed, and the sand bed is not submerged for extended periods of time. In addition, the Permittee and ORC must also ensure that no short-circuiting of the initially dosed wastewater (bypasses the recirculation process) occurs during a discharge event. Page# Permit: NCO058084 Inspection Date: 03/12/2019 Owner - Facility: Gough Econ WWTP Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Is the facility as described in the permit? ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ 0 ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The last compliance evaluation inspection was performed by DWR staff on 9/12/16. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? ❑ 0 ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration ❑ Dates of analysis Name of person performing analyses Transported CM Are DMRs complete: do they include all permit parameters? ❑ 0 ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ M ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Discharae Monitorina Resorts (eDMRs) were reviewed for the period January 2018 throuah December 2018. Effluent ammonia monthly average violations were reported in January, May, September, and November 2018. An effluent fecal coliform daily maximum violation was also reported in January 2018. The Division has previously addressed these limit violations through the issuances of either a Notice of Deficiency (NOD) or Notice of Violation (NOV). See "Summary" Section for additional comments. Page# 3 Permit: NCO058084 Owner - Facility: Gough Econ WWTP Inspection Date: 03/12/2019 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: On -site field analyses (dissolved oxygen, pH, temperature, TRC) are performed under the Gough Econ's field laboratory certification #5083. Statesville Analytical Holdings, LLC (Certification #440) has also been contracted to provide analytical support for all effluent parameters except field. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ representative)? Comment: The subiect Dermit reauires effluent arab samDles. The ORC and staff must ensure that effluent samples are collected during a representative discharge event. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Septic Tank (If pumps are used) Is an audible and visual alarm operational? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ■ ❑ Page# 4 Permit: NCO058084 Owner - Facility: Gough Econ WWTP Inspection Date: 03/12/2019 Inspection Type: Compliance Evaluation Septic Tank Yes No NA NE Is septic tank pumped on a schedule? 0 ❑ ❑ ❑ Are pumps or syphons operating properly? 0 ❑ ❑ ❑ Are high and low water alarms operating properly? ❑ ❑ M ❑ Comment: The septic tank is pumped by a contracted company (Rays) once every two years. Sand Filters (Low rate) Yes No NA NE (If pumps are used) Is an audible and visible alarm Present and operational? ❑ ❑ M ❑ Is the distribution box level and watertight? 0 ❑ ❑ ❑ Is sand filter free of ponding? ❑ 0 ❑ ❑ Is the sand filter effluent re -circulated at a valid ratio? ❑ ❑ 0 ❑ # Is the sand filter surface free of algae or excessive vegetation? ❑ 0 ❑ ❑ # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) ❑ ❑ 0 ❑ Comment: The dosing tank (single bell siphon), distribution box and recirculation tank (single pump) were operational and in service. Excessive accumulation of solids was observed on the sand bed. These solids should be removed and properly disposed. See "Summary" Section for additional comments. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? Yes No NA NE ■ ■ ❑ ❑ ❑ ❑ ❑ ❑ 1 Is the level of chlorine residual acceptable? M ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑ Comment: The tablet chlorinator was severely tilted to one side due to structural issues with the metal supports. The support structure must be repaired as soon as possible. Please be advised that the subject permit requires the permittee to properly operate and maintain all facilities and systems of treatment and control at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation and Maintenancel. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ 0 ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Page# 5 Permit: NC0058084 Owner - Facility: Gough Econ WWTP Inspection Date: 03/12/2019 Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Comment: Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 4 Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ❑ 0 ❑ Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? ❑ ❑ 0 ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Instantaneous effluent flows are based on the bucket and stop watch method. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The facility was not discharging at the time of the inspection. Page# 6 ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Gough Econ, Inc. Attn: David P. Risley, President & CEO PO Box 668583 Charlotte, NC 28266 Subject: Permit Renewal Application No. NCO058084 Gough Econ WWTP Mecklenburg County Dear Applicant: NORTH CAROLINA Environmental Quality June 16, 2020 The Water Quality Permitting Section acknowledges the June 11, 2020 receipt of your permit renewal application and supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting branch. Per G.S. 15OB-3 your current permit does not expire until permit decision on the application is made. Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a timely manner to requests for additional information necessary to allow a complete review of the application and renewal of the permit. Information regarding the status of your renewal application can be found online using the Department of Environmental Quality's Environmental Application Tracker at: https://deg.nc.gov/permits-regulations/permit-guidance environmental -application -tracker If you have any additional questions about the permit, please contact the primary reviewer of the application using the links available within the Application Tracker. Sincerely, IA Wren Thedford Administrative Assistant Water Quality Permitting Section ec: WQPS Laserfiche File w/application North : arD ra Department of Environmental Quetity I Dtvs*n of Water Fesouroes Mooresv a Regona Off ce 1 610 East Center Avenue, Suite 301 1 A'aoresv e, NortI,:&ro na 2S115 704£62-1588 irDOUGH ECON,INC. BULK MATERIALS HANDLING SOLUTIONS June 8, 2020 Mr. Wren Thedford NC DENR / DWQ / NPDES Unit 1617 Mail Service Center Raleigh, N.C. 27699-1617 Subject: Permit Renewal Application Package NPDES Permit NCO058084 Gough Econ Inc. Mecklenburg County Dear Mr. Thedford, RECEIVED/NCDEn, �rR JUN z 2020 Non-D'schar, - P'�iitin 9r 9 Unit Please accept our apologies for applying late to renew our permit. In the past we have always received a notification from the state reminding us about the renewal is coming up. However, we did not receive anything until June 3. When an email from Charles Weaver came in telling us that our permit expires June 30, 2020. Please see attached our renewal application for the waste treatment permit referenced above. There have been no modifications made since our last permit was issued. The application asks for a narrative description of our sludge management plan. We hire the services of a licensed waste company to pump out the septic tank and remove sludge when instructed to do so by our ORC, Mr. Steven Lambert. If you should have any questions or need additional information please do not hesitate contact our ORC/Steven Lambert via phone or email or 704-657-8847 by email Steven Lambert mslambeil@yadtel.net. Respectfully Submitted, gh Ec Davt P. Risley President & CEO Cc: Steven Lambert — ORC o:\wpdata\dpr\wastetreatment\NPDESpermit renewal 2020.doc Gough Econ, Inc. P.O. Box 668583 Charlotte NC 28266-8583 Tel. 704.399.4501 Fax 704.392.8706 NPDES APPLICATION - FORM D For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD Mail the complete application to: N. C. DENR / Division of Water Resources / NPDES Program 1617 Mail Service Center, Raleigh, NC 27699-1617 NPDES Permit INCO058084 If you are completing this form in computer use the TAB key or the up - down arrows to move from one field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type. 1. Contact Information: Owner Name David P. Risley Facility Name Gough Econ Inc Mailing Address P.O. Box 668583 City Charlotte State / Zip Code N.C. 28066-8583 Telephone Number (704)399-4501 Fax Number (704)392-8706 e-mail Address DRISLEY@GOUGHECON.COM 2. Location of facility producing discharge: Check here if same address as above ❑ Street Address or State Road 9400 N. Lakebrook Rd. City Charlotte State / Zip Code N.C. 28214 County Mecklenburg 3. Operator Information: Name of the firm, public organization or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Steven Lambert - Certified Waste Treatment Operator Mailing Address 154 Sunflower Rd. City Statesville State / Zip Code N.C. 28625 Telephone Number (704)657-8847 cell Fax Number (704)392-8706 e-mail Address Steven Lambert <mslambert@yadtel.net> 1 of 4 Form-D 9/2013 NPDES APPLICATION - FORM D For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD 4. Description of wastewater: Facility Generating Wastewater(check all that apply): Industrial X Number of Employees 45 Commercial ❑ Number of Employees Residential ❑ Number of Homes School ❑ Number of Students/Staff Other ❑ Explain: Describe the source(s) of wastewater (example: subdivision, mobile home park, shopping centers, restaurants, etc.): Manufacturing facility (light sheet metal products) Wastewater generated by restrooms. Number of persons served: 45 S. Type of collection system X Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer) 6. Outfall Information: Number of separate discharge points 1 Outfall Identification number(s) 001 Is the outfall equipped with a diffuser? ❑ Yes X No 7. Name of receiving stream(s) (NEW applicants: Provide a map showing the exact location of each outfall): Unnamed tributary to catawba river in the catawba river basin 8. Frequency of Discharge: ❑ If intermittent: Days per week discharge occurs Continuous 2-3 X Intermittent Duration: 8 hrs. approx.. 9. Describe the treatment system List all installed components, including capacities, provide design removal for BOD, TSS, nitrogen and phosphorus. If the space provided is not sufficient, attach the description of the treatment system in a separate sheet of paper. System consists of a septic tank, dosing tank, sand filter, recirculating tank with pump, mushroom fountains, chlorine contact (tablet), dichlorination tank (tablet), cascade and effluent pipe. Facility is designed to provide acceptable parameter concentrating at .0012 MGD. Phosphorus is not monitored. Original design limitations as set forth by NC Debt of Natural Resources in 1983: Parameter Limitation Flow 0.0012 MGD BODs 24 mg/L NH3 18 mg/L TSS 30 mg/L Fecal Coliform 1000/ 100 ML Effluent D.O. : 5 mg/L PH : 6.0-8.5 s.u. 2 of 4 Form-D 9/2013 NPDES APPLICATION - FORM D For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD 3 of 4 Form-D 9/2013 NPDES APPLICATION - FORM D For privately -owned treatment systems treating 100% domestic wastewaters <1.0 MGD 10. Flow Information: Treatment Plant Design flow .0012 MGD Annual Average daily flow .00037 MGD (for the previous 3 years) Maximum daily flow .00072 MGD (for the previous 3 years) 11. Is this facility located on Indian country? ❑ Yes X No 12. Effluent Data NEW APPLICANTS: Provide data for the parameters listed. Fecal Coliform, Temperature and pH shall be grab samples, for all other parameters 24-hour composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average. If only one analysis is reported, report as daily maximum. RENEWAL APPLICANTS: Provide the highest single reading (Daily Maximum) and Monthly Average over the oast 36 months for naram.eters currentlu in uour nerm.it. Mark other naram.eters "NIA"_ Parameter Daily Maximum Monthly Average Units of Measurement Biochemical Oxygen Demand (BOD5) 27 3.76 mg/L Fecal Coliform 1553 4.99 #/ 100 ml Total Suspended Solids 13 1.1 mg/L Temperature (Summer) 31 22 Degrees C. Temperature (Winter) 19 7 Degrees C. pH 7.0 6.9 S.U. 13. List all permits, construction approvals and/or applications: Type Hazardous Waste (RCRA) UIC (SDWA) NPDES PSD (CAA) Non -attainment program (CAA) Permit Number NCO058084 14. APPLICANT CERTIFICATION Type NESHAPS (CAA) Ocean Dumping (MPRSA) Dredge or fill (Section 404 or CWA) Other Permit Number I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. David P. Risley President 8s CEO Printed name of Person Signing Title ,tip' - ?i - Signature of Apr Date North Carolina General Statute 143-215.6 (b)(2) states: Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) 4 of 4 Form-D 9/2013