NC0081191_Report_19920818

NPDES DOCUHENT SCANNING: COVER SHEET
NC0081191
Washington WTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 18, 1992
This document is printed on reuse paper - more any
content on the re'rersse side

• •:.�..;�•�• �' -.r.�= =. '•== WATEREM QUALITY SECTION TO
AUG-2r1�2 09� 4.9 FROM {�h&‘t
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Environmental Management.
August s. 8 r 19 92
•
wAR0 P.ei,ee
64,
Preston Howard, ,Direent q"�3 1R'4?
�o. Pre ugi
-Division of Environmental Managem
From: 'Ueri Eagleso
,�g$s.St4r�stantt Water Quality Section Chief fQ' . WATER
SLCTi„r t�
Environmental Sciences
Officers Report; Washington Water Treatment
Subect: kear n g proposed NPDES Discharge NC0081191
r'
Background 1t t0 r-: ..- ._
;� NPDES pew '� ^rz
washiagton• N.C. has applied fora v= t.,..•: ���
The City .f r softener backwash water from a proposed 3.0
dischar�3e gilte The applicants 1 ''�
gallon per day water treatment facility. to ica ��• •��
million g discharged
low of Q . 341 MG) be, �.�
intend that the design f � �• Banks Community .:r .,�
Pamlico River at a point 7 50 feet �f etwoult�abe delivered t o the .�. %.
Pam ro oleo discharg
Ap p.;,
near washing`gh.
Pamlico through a 150 foot diffuser located "a .min r,�yn of yee� ,. r
below the surface of the watex". .
21
treatment plant wild, be located n 1.0.4 acresrn six
r
The water6 miles•
Douglas Crossroads with the ' lou�ix�est inC3.ude apprQximst•e1Y
e�roundwat$r ,wells . The loop , �' ,
of force rnas.s�S,1D
miles of distribution force' mains and 3.4 miles
of discharge main. •
ram of the
a.chment 1, I have included a shatic diagram
ag first aerated and
As Attachment Incoming' supplywater
t
treatment with potassium
s .
reated with'
otassium permanganate to bring dsh$�lssndsf1 i-4S out
for
of solution. The water• is then fsitleryyed , through
ch+xauy available for ore-
this point is avai�'.
solids removal. Chloki�reaLrnesif. • FThe supply water is the:.
chl.orinat�.Cn and Shoe the additicri ©f
F�, oridatior., itiC1 oatxon
softened using zeox3.te falters, Zinc orthophosphate),
corrosion inhibitors (typically
he addition of ammonia are then performed
e+for and ed prior and f�ltexs
distribution. are
and
t Both the Zeolite Filters
distribution;
ashtd
on an as needed balls with a resultant
stxea;ne
thatbwill
is the Sub j6Ct � of .this NPDES i'ermyt .
CO
• levels of chloride (S 'Parts-per-�thousad ammonia, average/8
pa ts- high 1e e well
parts -Per -thousand tnaximum).�ar metalscontainedchlorine,
the ground 1s
p}rQsphates, fluoride and other groundwater metals
water. There will. be no 'concentx'at ion of the g
by the treatment process. •
of this particular facility is located in
3rhe point of daS charge e is located
c
proximity to a bathing beach and the discharge While any :-
w where
p waste stre�►m is certain
where human contact withst the
to be the abject of iesen�.ment by
point source discharge �.
owners, this discharge is particularly troublesome.
local of
4 r the Shady Banks
most a the waterfront along propertylimi all have a
very limited. Most
is
headed. This meant that beachwater sfront small
bulk
of the residents s that do to,, have
pe rmane�n) portion rat in their deed. for.beach access
t r uglta is this
(40 feet) Part lax► of the shoreline that is not
1
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W.JG-25-t992 09 : A9 FROM Dem WATER eueL i TY SECT i ON TO
rovides much of the recreationalnareow strip, of property that F residents. It is this sae narrow strip
Of bss e ach that for the _saran y
Of
beis to provide the passage for the waste
discharge•
c construction indicate what �
Blueprints for the discharge pipe n with regard to beach access.
intrusive design resent a
feel is a minimally waste of any sort may p
Residents, however, feel that a
and that their use of the resourcesi beingoreline along
risk SwThey with all the mil
removed.es They question who,
the Pam3icO, does this
ni$beachneed to be placed immediately
.
adjacent to their bathing concerned citizens,
n May14,1992, due to numerous comments fromwith regard to
O Rearing Officer �.992 .n
D. . George Everett , assigned me as was :�e�.d on June 18, arises
this proposed permit. The hearing
ton Civic Center. This memorandum svmm
the City o� Washington recommendation.
the public ctinutcerit and provides my
public Rearing
people In attendance at the pvb3.ie heariX , 4
There were 84 and 7 written comments were received
spoke. All 7permitting of this
ept
people eived wereopposed to the p lint of
three comments recthree comments Were neutral. A
discharge • These
attendees may be found as attachment 2• r vou=
tlb of. a similar nature. a
Many attendees expressed cancert I have been
below each area Of concern th8t 1 have eSn
use, have listed 1 have also each
ableinto identify
from the record.
my
s conclusions atd recommendat .Oils regarding
findings,
individual issue.
ess�-ng these issues, I would like to state ray
prior adds most affected by the location of the
observation
ion that the people discharge pipe, these of the Shady dank s Comrcux� it y l
very
re s sed their concerts, fears and
aulimpressions
essionst for me to
regarding
exp. it would be di
capture a the issue pat hand. sensitivity that h
impressions in this memorandum but it is my o
pe
capture all these p reflects the deep
that from th �tatipeople tO you,
the Pamlico and its well being.
heard these
Areas of Concern blocated adjacent to the discharge acine location
curtanay
* The tidal Greek isolated or altered clue to a
became biologically �.sa+,
presented by the effluent discharge. potential for impacts
It is difficult for me to quantify the p Yge .
tidal creek located. adjacent to
td discharge.
ischits basic
To a small t the creek have descr
The residez�t5 along yGh.i.1e this is
character as a freshwaterenvironment.
itslocationit must receive
baSical1Y correct, due This in itself, however,,
frequent saline •,�atesei-b intrusion.
�.nhabitants •
would not preclude u Y
h review by D= • Don Stanley tP,Cu) of
thorough placement of
There was ,a very would result with the. p1 report
� regimes that
the saicn r as described in the NPDESS Permit.
Thisr, I red my
the discharge :r requested, is available for your review l�
staff have carefully
reviewed the document, as have meMbers
WARO 15-02/09
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_ , .. 392 05=50 FROM nEM WATER CL1ALITY
of Marine rjshe, ies. The bo`tom Brie
of the N.C. Division „it is extremely unlikely
is that ppt) salinity variance
me the analysis greater than O.l
immediate� � several. ;neLers
will ei�le t .. a �3This
will be detected outside tefil effluent dine'" • would
or tens of meters) of the n salinity in the Creek
indicates that the Q�'�eGtS QVarl$tiO S of 5a1.1Y13.�•y •
probably
be lost in natural
e would degrade the aruatic
* the saline effluent i������r and degrade the fisheries
environment in the Pamlico
resources . above, the actual changes ink �iiniy lettera re
minimaz• as attachment 3from our
ms discussed ah I have provide
s Division with t1 eir statement that the
Marche �.e
disdischargege would have min imx+l impacts on the
resources of the Pamlico.
It bay been statedthe easement obtained by the City °'
*
Washington to route
discharge pipe through a common Beach
that their d� ,
not valid. several times in the 32tig1zC
access area is -nen,.s . It was also , mentionedPublic
in
This inf �yrmation was offered Me
Tearing and as written oom� a the
Public Hearing that the individual the
�o�ity with he the
the t turned the payment
easement, had returned
intent of negating the agreement.
part of
v reviewed taw materials submittedtier, but f the not
Y a a which deal with �earin5 Process ,rant of recommending any
y� Of ing easement
pursued n is issue awftnDEM .e If the legal y eeam
action u the part Q �.
• - ions then there are other bodies of government
ys lr. quest
which nay provide a remedy.
that alternative discharge points Wexe
* Many citizens believe the City
not adequately considered.
discharge e identified by dints of discharg h the e:�Cit
There were three p w through inady
,.heir project documentation. One
ivL'I�r.S permit itself.
B4 as identified in
Banks Community econd Location was to Broad Creek
applit. fAformed the City by letter thawart this
our Regional office �r�� a to Broad C..eekl ,�
alternative (discharge proposed a Regional Office indicated that discharge f
acceptable. Theeafrequently freshwater enviroftment was
05 t�.on . Due to
u saline waste to with'this position.
rion . is e o
unacceptable. I tend to agree
wind driven water movement �ene3�s,lweicQu�d not be
the W v events would not
develope it three small encylof hypoxic e e
confident that the °�
increase.
for routing the
City has also provided cost estimates ,
The Y ose Creek. The estimated additional
discharge to 000.0e �aI f this option were chosen,' the city
gout is $e5.0ma e0• a indicated that these
have to make severe modifications
s to their .
construction ha plans. The City has
Coz�stxuatiQn p non-compliance with a
wolsld cause them to D��.�ki�gn�at�r act for .�
changesmade under the Safe group o�
mandate new water treat-iLent plant. A
pobstruct Son O� a
• has petitioned for this same alternative
public citizens
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»" {,3n P •
....::..,M..: TION TO
•
r�•----�-'^"" "-, .., .�.... DEr'1 WATER QUALITY 5 C
a-�ri992 09:50
FROM
discharge point •
Total
four �im�•t � � parameters; � t was
drafted with only alo±
was � Turbidity. and a was
The permit Solids, Settleable s ,ha+ se�.f �mpn ditty ng waste
bythe public characteristics 4f the
not adequate
strongly stated
e uate to reflect effluent not ad � regarding,
stream. Incident reg water . In
reflect lect a previous drinking
comments t the city
These as,evels of T s in even require $elf_
actuality, Unreported permit does self- Washington
the draft p ,mmer�.d�►t you from the which they
self -
monitoring. tO r subsequent recce parameters A rovided a list of requirements
ri°��-tOrinq •monitoring i=emer'.ts
Regional Office a hasdded as
• e should a with these monitoring
Ala be
believe
ant 4) • I agreeare as
and
h added numerical 1i.164.ts that.�cI eel - should
aid cia ith the monitoring rem
associated
,imitation t�e�4mend�t�Ons
pearl t Monitoring and
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AUG -25-1992 09=51 FROM
DEM WATER QUALITY SSCTION TO WARD P,i5/08
* unknown and unregulated effluentconstituents have been
overlooked in the permit development.
It is true that certain constituents were leftl unregulated
by the draft permit that should have been gut. ads ca able
However, with regard to unknown CorstituentS, P
of characterizing this waste stream very much mor a .pr precisely
than typical municipal or industrial waste
eustreams wells. Th
source water for he discharge
groundwafrom
er eonstitaer�ts as
ter
There is no concentration
might be expected from alternate forms iofttrea men . Anyare
constituents other than those present process and are
those that are added in the water treatment
easy to inventory. The proposed modlEiaatians to the NPDES
permit will address these constituents.
�
be a potential hazard to
* The effluent discharge pipe nay
swimmers,skiers and boaters due to the concrete ballasts that. are
used to anchor the discharge pipe to the b requires that the 8'
The construction of the discharge pipe
'vC pipe be held below the river bottom bycoscrete hallasts
until 750 feet offshore where a diffuser ri
bottom for 150 feet.
The NPDES permit requires that the di°fuofer betherlocatedlahave
minimum of five feet below the Chart and fir,dace that the diffuser willCan$ulted a nautical
be in 6 feet of water during mean low water.
I woe5ldeet
anticipate that at times the diffuse will
below the surface.
Other concrete ballasts will residein even more shall
�.l low
areas but it theory will be coveredby
The construction blueprint indicates that any co eiage of
the ballasts will be only
wseveral
andinches.
er skiers would fall
expressed concern that simmers
and get hurt by these structures if the ballasts become
exposed by the natural movements of the bottom sediments
e beach area in the vicinity of the
It is my finding that threcreatiorial area. Manof thedischarge is a high use swimmers are children. A boat house immediately downstream
w
hin
of the proposed discharge and boat slips boating
common.heetidal
Creek immediately upstream also indicate
afor both primary andcommon. This area is intensively used
secondary recreation.
I believe the health risk to primary recreation
users
i•stbe
extremely small with regard to chemical constituents
discharge. The issue has been raised, however, that the
discharge structure itself presents a hazard to
isl reatearnd
skiers. The risk of injury here, in my opinion g
than any risk associated with chemical constit1. eats in the
discharge. Under certain conditions I cantenvisiOnr from ai�oat or
swimmer being inured as they enter
fall while water skiing. Both of these risks can be reduced
significantly if the areas are marked. This, however,
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AUG-25-1992 09:51 FROM DEM WATER QUALITY SECTION To
-
WARD P.06/08
removes two uses that are protected in accordance with 15
NCAC 23 .0212 (d) (1) . Mile the impacted
rand might as extremely
small when compared to the size of the Pamlico
considered insignificant in that light, the location of the
structure immediately within a swimming area
alasds aCroof se that
▪ high use boating area gredlstructureeS isthe constructed.
would occur if the propose
Mean Low Tide at the diffuser is approximately 6 eet. With pipe
wind tides and low low tides, thediffuser�o discussion of
present hazards to boat trafficTherewas
these issues in the EA.
* Loss of use due to aesthetic degradation.
The Environmental Policy Act (113A--3) y state: " ... itseek,fs allibe
the poliNorthcy oe the State of North Carolina t
its citizens, safe, healthful, productive
vesand aeetaetioally
pleasing surroundings, to attain the risk
beneficial. uses of the withoutenvironment
servetheimportant yhlstorio
to health or safety; and to pre
And cultural elements of our common inheritance.
This policy requires abalance bet een It testhetic
so resents a very
,surroundings and beneficial use.
difficult evaluation of aesthetics • As you know, criteria
for aesthetic quality are non-existent, while
baeneficial
uses are much more easily tabulated. e
c
values are so difficult to define, their use in permitting
decisions is also very difficult. In this regard, I can
only summarize to you the feelings of the residents and my
own.
The residents perceive either upon discharge or at some
pointin the future, that, the waste water er ill ccontairs.Alm4st
n
Constituents harmful to tie healtho
the entire record indicates this concern. Most indicated
that of primary concern was the well benot being of
theresiidren
Swimming in the beach area. Whether or
is
real, the residents perceive it as present and many have
indicated that their use of the swimming
area
would
either
cease or be reduced if the discharge was allowed.
wile those of us who have dealt with effluents for my presents a
years know that this discharge is of a type
very predictable waste character, that experience is not
available to guide the perceptions of the residents. I
believe that there will be a partial loss of use of this
portion of the Pamlico by some residents based on
nlaaes hetice
perceptions. I also believe, however, that
thiswould be justified by the beneficial uses (providing
drinking water to the City of Washington) , if no reasonable
alternatives are available.
* The consideration of non -discharge or discharge alternatives
was inadequate •
Five alternative water treatment processes were were
comeareviewed
dery
the City. Alternate discharge pa
attachment 5. Of the five alternate water treatment
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AUG-25--i332 09:52 FROM DEM WATER QUALITY SECTION TO WARO P.07/08
processes the City of Washington chose a process where water
hardness is removed by zeolite resins. This process yields
a brine waste that needs disposal. It is also the least
expensive alternative. I have reviewed each alternative
using the information presented by the Citys' consultant. I
agree with the choice made by the City.
Discussion
x indings
If this NPDES is issued and if the waste discharge line is
constructed as indicated in the permit appiication, I find
the following:
1.) The NPDFS permit as drafted is not adegaate and should
be modified as outlined above.
2.) I expect that water quality impacts (with regard to
Chemical constituents) to the Pa:tiiCO and adjacent waters
will be minimal or non-existent if the permit is modified as
suggested.
3.) The effluent line as proposed will pose an obstacle to
boating traffic and swimmers unless well marked.
4.) There will be a partial loss of use associated with the
discharge to. the Pamlico (boating and swimmingY in an area
that is very actively used for primary recreation.
Recommendations
The decision to issue or deny this NPDE3 permit, is
extremely difficult. The decision is not merely whether
nimerioal water quality standards will be met. I am
confident that the modifications to the permit that I have
suggested will protect water quality chemistry. our
regulations move beyond chemical characterization, however.
They require protection Of specific uses and aesthetic
qualities while mainhaveiagr�adylance indicated to youthat other
my
beneficial uses.
opinion is that there will be a partial loss of use of this
portion of the Pamlico.
There is however, a major beneficial use that offsets this
loss. This is the delivery of quality drinking water to the
citizens of Washington. No alternate discharge points
appear reasonable at this time. It is my finding that other
reasonably attainable discharge areas would either have
higher potential for environmental impacts or have equal
potential for loss of primary recreation.
It is my recommendation to you that the NPDES permit be
issued with the modifications to the numerical limits and
monitoring requirements suggested above. Additionally, the
Permits and Engineering Unit should be directed to
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AUG-25-1992 09:52 FROM DEM WATER QUALITY SECTION TO WARD P.09/08
• ,
• •
critically review tie plans and specifications for the
discharge line and diffuser so as to minimize risks
presented to boating and primary recreation.
Please feel free to contact :►e should you have any further
questions.
cc: Steve Tedder
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