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HomeMy WebLinkAboutNC0089915_technical correction_20210125ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality January 25, 2021 Mr. Brian Long, Plant Manager The Chemours Company / Fayetteville Works 22828 NC Highway 87 West Fayetteville, NC 28306 Subject: NPDES Permit NC0089915 Technical correction /parameter codes Fayetteville Works Bladen County Grade PC -II WPCS Dear Mr. Long: The Division has received questions from your facility's staff regarding the parameter codes used for data entry in the Division's eDMR system. In addition, some parameter codes were inadvertently omitted from your original permit. This permit modification provides the correct parameter codes for outfall 003, as well as updated sampling frequencies as described in the previous permit modification issued on December 14, 2020. This permit modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). Insert the attached pages into your permit and discard the old pages. The new pages take effect February 1, 2021. This modified permit includes the following changes to the existing permit: ➢ Parameter codes for each parameter have been added to simplify and clarify data entry. ➢ Monitoring frequencies have been updated as per the 12/14/2020 permit modification ➢ Footnotes have been re -numbered and edited for clarity. If any parts, measurement frequencies or sampling requirements contained in this modification are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11617 Mall Service Center I Raleigh, North Carolina 27699-1617 919.707.9000 This permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by any other Federal, State, or Local governmental regulation. If you have any questions concerning these changes, please contact Dr. Sergei Chernikov [sergei. chernikov@ncdenr. gov]. Sincerely, s, e�V S. Daniel Smith, Director Division of Water Resources cc: NPDES Unit (Laserfiche) Permit NC0089915 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — OUTFALL 003 [15ANCAC 02B .0400 et seq., 02B .0500 et seq.] Facility Physical -Chemical Grade II [15A NCAC 8G .0306] Beginning on the February 1, 2021 and lasting through the expiration date, the Permittee is authorized to discharge from Outfall 003 (treated surface water, groundwater, and stormwater) Such discharges shall be limited and monitored by the Permittee as specified below: PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Sample Frequency Type Sample Location1 Flow 50050 1.58 MGD Continuous Recording Effluent Total Monthly Flow 82220 Monitor and Report (MG/month) Monthly Recording or Calculation Effluent Temperature (°C) 00010 See footnote 2 Weekly Grab Effluent, U & D BOD, 5-day, 20°C C0310 30.0 mg/L 45.0 mg/L Monthly Composite Effluent TSS C0530 30.0 mg/L 45.0 mg/L Monthly Composite Effluent Dissolved Oxygen, mg/L 00300 Weekly Grab U & D Turbidity 00700 Daily Grab Influent & Effluent PMPA3 52624 0.054 pg/L 0.054 pg /L Weekly Grab Influent & Effluent PMPA3 QM624 Monitor and Report (pounds/month) Monthly Calculation Effluent PMPA3 QY624 Monitor and Report (pounds/year) Annually Calculation Effluent HFPO-DA3 52612 0.06 pg/L 0.06 Ng /L Weekly Grab Influent & Effluent HFPO-DA3 QM612 Monitor and Report (pounds/month) Monthly Calculation Effluent HFPO-DA3 QY612 Monitor and Report (pounds/year) Annually Calculation Effluent PFMOAA3 52613 0.85 pg/L 0.85 pg/L Weekly Grab Influent & Effluent PFMOAA3 QM613 Monitor and Report (pounds/month) Monthly Calculation Effluent PFMOAA3 QY613 Monitor and Report (pounds/year) Annually Calculation Effluent PFAS compounds, ng/L See A. (5.) Grab See A. (5.) Total Phosphorus, mg/L C0665 Monthly Composite Effluent Total Nitrogen, mg/L C0600 (NO2+NO3+TKN) Monthly Composite Effluent Conductivity 00094 Monthly Grab Upstream, Downstream Page 3of12 Permit NC0089915 PARAMETER CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Chronic Toxicity TGP3B See footnote 4 Quarterly Composite Effluent pH 00400 Between 6.0 and 9.0 Standard Units Weekly Grab Effluent Mercury (Method 1631E) COMER Monitor and Report (ng/L) Quarterly Grab Effluent Total Selenium 01147 Quarterly Composite Effluent Total Silvers 01077 0.48 pg/L5 2.01 pg/L Monthly Composite Effluent Total Cobalts 01037 23.9 pg/L 23.9 pg/L Monthly Composite Effluent Total Cadmium, pg/L 01027 Quarterly Composite Effluent Total Copper, pg/L 01042 Quarterly Composite Effluent Total Cyanide, pg/L 00720 Quarterly Composite Effluent Total Lead, pg/L 01051 Quarterly Composite Effluent Total Thallium, pg/L 01059 Quarterly Composite Effluent Total Hardness [as CaCO3] 00900 (mg/L) Quarterly Composite Grab Effluent Upstream7 Footnotes: 1. Influent: influent to the Old Outfall 002 Wastewater Treatment System. Note the Outfall 003 concentration limitations do not apply to the influent. Influent sampling is required to calculate the HFPO-DA and PFMOAA percent removal. Effluent: Outfall 003 (effluent from the Old Outfall 002 Wastewater Treatment System). U: upstream monitoring shall be at the Permittee's Cape Fear River Water Intake. D: downstream at the boat ramp approximately 4500 feet downstream at Prospect Hall Landing. As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements for conventional parameters (DO, temperature, and conductivity) as stated above are waived. Should your membership in the agreement be terminated, you shall notify the Division immediately and the instream monitoring requirements specified in your permit shall be reinstated. 2. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.8°C and in no case cause the ambient water temperature to exceed 32°C. 3. The Permittee shall remove indicator parameters HFPO-DA, PFMOAA, and PMPA at an efficiency of 99% in order to reduce PFAS loading to the Cape Fear River. The effluent limits listed above are Technology Based Effluent Limits ("TBELs") calculated to ensure a minimum of 99% removal efficiency. In addition to complying with these effluent limits the Permittee must demonstrate compliance with the 99% removal efficiency requirement by calculating monthly removal efficiency for HFPO-DA, PFMOAA, and PMPA pursuant to condition A. (6.). The Permittee may request revision of the 99% removal efficiency requirement upon a demonstration that influent concentrations of PFAS have been reduced to such a level that 99% removal is no longer technically feasible. However, notwithstanding any such revision, Chemours shall continue to operate the Treatment System at optimal efficiency. 4. Chronic Toxicity (Ceriodaphnia) P/F @ 12.5%; testing shall be performed quarterly during February, May, August, November; see A. (2.) of this permit. Page 4 of 12 Permit NC0089915 5. Sufficiently sensitive test methods shall be used to analyze for Silver. The Division shall consider all effluent Silver values reported below the PQL to be in compliance with the Monthly Average Silver limit. As of the effective date of this permit, DWR recommends a target PQL of 1.0 µg/L for Silver. 6. After 12 months of sampling the facility can apply for a reduction in sampling if all the sampling results demonstrate concentrations below detection levels. The facility shall be employing the sufficiently sensitive test methods. 7. The permittee shall sample instream hardness upstream of the facility's discharge. The sample shall be representative of the hardness in the stream. If the permittee is a member of the Monitoring Coalition Program, sampling for instream hardness may be waived as long as the Monitoring Coalition agrees to sample hardness at the nearest upstream location, at a minimum frequency of quarterly, and the permittee has obtained approval from DWR -NPDES Permitting Unit that the upstream station being monitored by the coalition is representative of the receiving stream for this discharge. The permittee is responsible for submitting instream hardness test results with its DMRs as results are received from the coalition. If coalition membership is cancelled or the Monitoring Coalition terminates instream hardness sampling at the approved station, the permittee will immediately notify the Division and resume sampling for instream hardness, upstream of its discharge, as required in Section A. (1.). THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. The facility shall develop a Dam (collection system) Operation and Maintenance Plan (Plan) to ensure maximum dry weather flow (- 610 gpm) in the channel is consistently captured and treated. Similar efforts shall be applied at the sumps/dams or other devices that will be used to capture water from the seeps. The Plan shall be provided to the DEQ no later than October 18, 2020 for review and approval. Upon approval, the Plan becomes an integral part of the permit. The facility shall complete and submit EPA Form 2C for this Outfall no later than March 30, 2021. From time -to -time the Middle Cape Fear River has experienced flooding conditions which are documented to cause a significant increase in water levels below Lock and Dam #3, consistent with the location of proposed Outfall 003. During these events a backwater condition propagates upstream in the "Old Outfall 002 Stream". Historical observation indicates that the Old Outfall 002 Stream levels can rise significantly (consistent with the flooded Cape Fear River levels) and would be expected, at times, to be equal to or significantly greater than the invert elevation of the treatment system intake dam and associated pumping system. During these flooded backwater conditions elevated sediment load and reduced flow velocity gradients are expected to cause significant sediment deposition within the collection dam and pumping structure. The sediment load may cause failure of the pumping and treatment system during the flooded backwater condition. Requirement for treatment shall be suspended during these force majeure flooding events and be allowed 48 hours after the backwater stream level falls below the invert of the intake collection dam to safely maintain the influent collection structure and re- initiate collection and treatment. The triggering Cape Fear River flood elevations; event documentation and notification requirements; and procedure for treatment cessation and safe restart shall be included in the approved Dam Operation and Maintenance Plan. Whenever treatment is suspended under this condition, the permittee shall document the flooding in the DMR for that month including the time of flooding above the intake invert, when the water recedes below the intake invert, and time that treatment resumes. Page 5 of 12 Weaver, Charles From: Chernikov, Sergei Sent: Monday, January 25. 2021 8:31 AM To: Weaver, Charles; 'Fields, Dianne L'; Brantley. Mari.. Subject: RE: 52620 vs. 52624 - solved Looks good to me. Thank you, Charles! Sergei Chernikov, Ph.D. Environmental Engineer 111 Industrial NPDES Permitting Unit NEW Tel. 919-707-3606 1617 Mail Service Center, Raleigh, NC 27699-1617 Express Mail: 512 N. Salisbury St., Raleigh, NC 27604 From: Weaver. Cnarse Sent: Monday, January 25, 2021 7:58 AM To: 'Fields, Dianne L' <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov> Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov> Subject: 52620 vs. 52624 - solved When we were first setting up the PFAS effluent codes in BIMS, we knew we would need codes for both mass and concentration measurements. 52624 was chosen for PMPA, with the following codes: 52624 — concentration QM624 — quantity monthly QY624 — quantity annually Code 52620 does NOT have any codes for mass measurements, so that's why it wasn't used for the effluent sampling of PMPA. I've attached a rough draft of a corrected effluent sheet showing all the parameter codes. I'll add Turbidity and then everything for the effluent will be correct. I'll issue a minor modification/technical correction with an effective date of 2/1/2021. We'll leave 52624 for effluent PMPA and 52620 for instream PMPA. That will actually make it easier to separate the data for future evaluation. etc. Let me know if this solution sounds reasonable. Charles H. Weaver Environmental Soecialisi N.C. DEQ / Division of Water Resources 919-707-3616 charles.weaver@mcdenr.gov (mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617 1 Weaver, Charles From: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com> Sent: Monday, January 25, 2021 9:27 AM To: Weaver, Charles; Brantley, Mark Cc: Compton, Christel E Subject: RE: ?RE: [External] FW: ?52620 vs. 52624 - solved CAUTION. External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Thank you for the update. Regards, Dianne From: Weaver, Charles <charies.weaver@ncdenr.gov> Sent: Monday, January 25. 2021 9:24 AM To: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov Cc: Compton, Christel E <CHRISTEL.E.COMPTON@chemours.com> Subject: ?RE: [External] FW: ?52620 vs. 52624 - solved External email. Confirm links and attachments before opening. See answers below From: Fields. Dianne L <DIANNE.L.FIELDS@chemours.com> Sent: Monday. January 25. 2021 9:11 AM To: Weaver, Charles <charles.weaver@ncdenr.gov>; Brantley, Mark <mark.brantley@ncdenr.gov> Cc: Compton, Christel E <CHRISTEL.E.COMPTON@chemours.com> Subject: [External] FW: ?52620 vs. 52624 - solved CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Charles, Thank you for your follow up on this matter of PMPA. Please note that the monthly PMPA will be the same analytical result for that particular weekly sample. »Understood. PMPA is one compound with two parameter codes, thanks to EPA« In other words, we are using the monthly sample to count as one of the weekly samples for PMPA as well as PFMOAA and HFPO-DA. So in the eDMR we entered in that data for example on 12/8/2020 in form Outfall: 003 — Location: Effluent and the form Outfall: 003C — Location: Effluent as the same value. Will both of these forms have 52624 on them. Likewise we will enter data on form Outfall: 003 — Location: Influent and the form Outfall: 003B — Location: Influent as the same value. Will these both be switched to 52620. »No. The effluent eDMR will list 52624, and the instream locations will list 52620. We understand that the same sample numbers will be entered using two different coaes.« i It is confusing to me that only PMPA has two codes and not HFPO-DA and PFMOAA which have the same criteria on the effluent. Can you comment on why HFPO-DA and PFMOAA don't have a similar issue? ,PMPA was given duplicate codes [52620 and 52624] by EPA when we were setting up the data entry for PFAS omoounas. To my knowledge, there are no duplicates for HFPO-DA and PFMOAA in our system, so this problem did not arise for them.« You said that these changes will be effective on 2/1/2021. So should 1 wait until then to download the forms for the January eDMR or will they only be effective for February eDMR? »Do the January eDMR using the same forms as you used for December 2020. I can't back -date the permit changes to January 1, so they have to take effect 2/1/2021. This will minimally change your data -entry process; this modification is more to fill in gaps in the permit and make sure everyone knows why both 52620 and 52624 are in the permit. Sergei is OK with this solution.« CHW Regards, Dianne Dianne L Fields Sr. Environmental Consultant 910-678-1384 The Chemours Company Fayetteville Works Plant 22828 NC Hwy 87 West Fayetteville, NC 28306 Chemours' From: Weaver. Charles<charles.weaverCa@ncdenr.gov> Sent: Monday. January 25, 2021 7:58 AM To: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com>; Brantley, Mark <mark.brantley@ncdenr.gov> Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov> Subject: ?52620 vs. 52624 - solved ' External email. Confirm links and attachments before opening. When we were first setting up the PFAS effluent codes in BIMS, we knew we would need codes for both mass and :oncentration measurements. 52624 was chosen for PMPA, with the following codes: 52624 — concentration QM624 — quantity monthly QY624 — quantity annually Code 52620 does NOT have any codes for mass measurements, so that's why it wasn't used for the effluent sampling of PMPA. I've attached a rough draft of a corrected effluent sheet showing all the parameter codes. I'll add Turbidity ana tnen everything for the effluent will be correct. I'II issue a minor modification/technical correction with an effective date of 2/1/2021. 2 We'll leave 52624 for effluent PMPA and 52620 for instream PMPA. That will actually make it easier to separate the data for future evaluation, etc. Let me know if this solution sounds reasonabir Charles H. Weaver Environmental Specialist N.C. DEQ / Division of Water Resources 919-707-3616 charies.weaver@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. <="" style=' This communication is for use by the intended recipient and contains information that may be privileged, confidential of copyrighted under applicable law. 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