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HomeMy WebLinkAboutNC0089958_TGACSE Fact Sheet BINDER - no APP 29Nov2021_20211129Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 1 NCDENR / DWR / NPDES EXPEDITED FACT SHEET - NPDES PERMIT RENEWAL NPDES Permit NC0089958 Joe R. Corporon P.G., Compliance & Expedited Permitting Unit 29Nov2021 Table 1 - Facility Information Applicant / Facility: TGACSE Central Square, LLP (TGACSE) / Excavation Dewatering and Permanent Structure Dewatering of Central Square Project Applicant Contacts: Barry James, Construction Project Manager [bjames@csere.com] Joseph P. Nestor, P.G., P.E., Environmental Principal [jnestor@ecslimited.com] ECS Southeast LLC c/o Crosland Southeast 201 South College Street, Suite 1300, Charlotte Facility Address: Central Ave and Pecan Ave, Charlotte Permitted Flow: 0.050 MGD Type of Waste: 100% Industrial - Remediated Groundwater Facility Class: PCNC County: Mecklenburg Permit Status: New Regional Office: MRO Stream Characteristics Receiving Stream UT to Little Sugar Creek Stream Classification C Stream Segment [11-137-8] Drainage basin Catawba Summer 7Q10 (cfs) 0 Subbasin 03-08-34 Winter 7Q10 (cfs) 0 Use Support Impaired for fish consumption; water-column mercury, copper 30Q2 (cfs) 0 303(d) Listed Average Flow (cfs) 0 State Grid G15NE IWC (%) 100% USGS Topo Quad Charlotte East, NC FACILITY SUMMARY TGACSE proposes to treat groundwater exposed by excavation and by construction below the groundwater table. The treatment system will support both excavation dewatering and dewatering for permanent subterranean structures. The system design capacity is proposed at 0.050 MGD. Outfall 001 will discharge onsite to a stormsewer inlet flowing north to a UT to Little Sugar Creek. The treatment system [unless modified] consists of: • one (1) 18,000-gallon frac tank (w/ injector for CO2 gas to adjust pH, as needed) • one (1) 1,000-gallon surging tank [w/ recirculating pump, as needed <14,000 GPD] • two (2) each particle filters [in parallel or series] • two (2) each 1000-pound activated carbon vessels [in parallel or series] • sample ports as needed (sufficient) to establish filter contaminant breakthrough • appurtenant piping, instrumentation, and valving • discharge line to stormsewer inlet • sample port and totalizing flow meter RECEIVING STREAM Treated effluent discharges via Outfall 001 under zero-flow receiving stream conditions (7Q10 and 30Q2 = 0.0 cfs) a stormsewer to an unnamed tributary to Little Sugar Creek. Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 2 ENGINEERING ALTERNATIVES ANALYSIS (EAA) The EAA appears complete concluding that surface discharge is the most viable discharge alternative in an urban environment [Charlotte]. The EAA states that, there is the possibility of influent contaminants originating from on- or offsite, not previously detected. Judging from the site history, these contaminants may include toxicants potentially influent to excavation groundwater [application EAA, 1.B, oooo]. See below “Temporary Additional Monitoring.” ESTABLISHING LIMITS AND MONITORING Whole Effluent Toxicity (WET) Testing – Monthly ACUTE monitoring is recommended for continuous discharge of excavation dewatering. This may be relaxed to Quarterly for a permanent dewatering system, as data may warrant. Acute pass/fail test [TGE6C] -- Monthly Monitoring at 90% effluent concentration, using Fathead Minnow (Pimephales promelas) 24-hour static test. RPA – A Reasonable Potential Analysis (RPA) was not conducted because to date there is no treated effluent database. Permit reflects only site assessment data provided on the Application for Discharge. Based on site-assessment data, DWR proposes the specific parameters Chloroform and Total Chromium as initial targets for monitoring because they were reported [see section A. (1.)]. The treatment system proposes to polish the effluent via carbon filters therefore Turbidity sampling is not required [receiving stream is not impaired for turbidity], however this permit requires temporary monitoring. Temporary Additional Monitoring – Considering the absence of effluent data, this permit requires initial sampling by EPA test methods 624/625 for volatile and semi-volatile organic compounds (Monthly), and a suite of total metals. Temporary monitoring allows the Permittee to report data in support of a petition to reevaluate contaminants of concern (POCs) as data may warrant. This precludes the need for further Public Notice. Temporary monitoring requires a minimum of twelve (12) samples collected no more frequent than 2/Month [A. (1.), Footnote 5]. DWR will require effluent analyses initially for metals, VOCs and Semi-VOCs considering: 1. history classifies this site as a Brownfields, 2. the current chemical evaluation of local groundwater is limited in scope, 3. potential contaminants influent to the treatment system remain unestablished [see application EAA, 1.B, oooo]. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Public Notice (estimated): October 12, 2021 Issuance (estimated): November 29, 2021 Effective Date (estimated): January 1, 2021 Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 3 NPDES DIVISION CONTACT If you have questions regarding any of the above or the attached permit, please contact Joe R. Corporon, P.G., email preferred [joe.corporon@ncdenr.gov]. NAME: _____ DATE: 29NOV2021 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, met al limits in draft permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as approved. Table 5. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection Parameter Acute FW, µg/l (Dissolved) Chronic FW, µg/l (Dissolved) Acute SW, µg/l (Dissolved) Chronic SW, µg/l (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 Zinc Calculation Calculation 90 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. Aqua tic 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 2B.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^{0.9151 [ln hardness]-3.1485} Cadmium, Acute Trout waters WER*{1.136672-[ln hardness](0.041838)} ∙ e^{0.9151[ln hardness]-3.6236} Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 4 Cadmium, Chronic WER*{1.101672-[ln hardness](0.041838)} ∙ e^{0.7998[ln hardness]-4.4451} Chromium III, Acute WER*0.316 ∙ e^{0.8190[ln hardness]+3.7256} Chromium III, Chronic WER*0.860 ∙ e^{0.8190[ln hardness]+0.6848} Copper, Acute WER*0.960 ∙ e^{0.9422[ln hardness]-1.700} Copper, Chronic WER*0.960 ∙ e^{0.8545[ln hardness]-1.702} Lead, Acute WER*{1.46203-[ln hardness](0.145712)} ∙ e^{1.273[ln hardness]-1.460} Lead, Chronic WER*{1.46203-[ln hardness](0.145712)} ∙ e^{1.273[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 ∙ e^{1.72[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 meta ls 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. 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 (mor e 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 l ow- 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, 7Q10 (the spreadsheet automatically calculates the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, 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 instrea m (upstream) hardness values to use in the equations. Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 5 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 n ew data. 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 (s7Q10, cfs *Avg. Upstream Hardness, mg/L) (Permitted Flow, cfs + s7Q10, cfs) The Combined Hardness for acute is the same but the calculation uses the 1Q10 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. 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. silve r), 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 = (s7Q10 + Qw) (Cwqs) – (s7Q10) (Cb) Qw Where: Ca = allowable effluent concentration (µg/L or mg/L) Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L) 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/l], 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 program under a sheet labeled DPCs. Fact Sheet November 2021 – New NPDES Permit NC0089958 Page 6 Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L) Qw = permitted effluent flow (cfs, match s7Q10) s7Q10 = 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 backgro und concentrations Flows other than s7Q10 may be incorporated as applicable: 1Q10 = 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 hexavale nt 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: Parameter Value Comments (Data Source) Average Effluent Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] N/A New Permit - No data to date Average Upstream Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] N/A New Permit - No data to date 7Q10 summer (cfs) 0.0 USGS 1Q10 (cfs) 0.0 USGS Permitted Flow (MGD) 0.050 Proposed State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report FORM: WQROSSR 04-14 Page 1 of 3 To: NPDES Unit Non-Discharge Unit Application No.: (NC0089958) Attn: (Joe Corporon in Raleigh) Facility name: Central Square Excavation Dewatering (Former Sherwin Williams BF Site) From: (Edward Watson in Regional Office) Mooresville Regional Office Note: This form has been adapted from the non-discharge facility staff report to document the review of both non- discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? Yes or No a. Date of site visit: 08/30/2021 b. Site visit conducted by: Edward Watson c. Inspection report attached? Yes or No d. Person contacted: Joe Nestor, P.E., and their contact information: (704) 525 - 5152 ext. e. Driving directions: From MRO office, travel South on Main St. for 2.7 miles to Langtree Rd. Travel for ~ 1.1 miles, then take on ramp. to I-77 on ramp South toward Charlotte. Drive S. on I-77 for ~20 miles. To exit 11 to I- 277/NC-16 S to exit 3A toward Brevard/Davidson/McDowell St. for 0 .1 miles, then bear left onto E 11th St for .5 miles, the turn left on E 10th St. for 0.5 miles bearing left onto Central Ave. 1314 Central Avenue is one of several addresses that comprise the site location. Total driving distance to the site is ~29 miles. 2. Discharge Point(s):001 Latitude: 35° 13’ 25.0” Longitude: 80° 19’ 07.7” Latitude: Longitude: 3. Receiving stream or affected surface waters: UT to little Sugar Creek Classification: C River Basin and Subbasin No. 11-137-08 Describe receiving stream features and pertinent downstream uses: Urban stream in the Catawba River Basin II. PROPOSED FACILITIES: NEW APPLICATIONS 1. Facility Classification: Minor (Please attach completed rating sheet to be attached to issued permit) Proposed flow:.050 MGD Current permitted flow: New Application 2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No If no, explain: 3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A If no, please explain: Soil conditions were not examined as no open trenches were present to be able to observe onsite soil conditions. Analysis was based on file review of multiple site soil borings. FORM: WQROSSR 04-14 Page 2 of 3 4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A If no, please explain: 5. Is the proposed residuals management plan adequate? Yes No N/A If no, please explain: 6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A If no, please explain: 7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No If yes, attach a map showing conflict areas. N/A. 8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A If no, explain and recommend any changes to the groundwater monitoring program: Please refer to the Additional Regional Office Comments for sampling recommendations. 9. For residuals, will seasonal or other restrictions be required? Yes No N/A If yes, attach list of sites with restrictions (Certification B) Describe the residuals handling and utilization scheme: N/A. 10. Possible toxic impacts to surface waters: Chronic toxicity testing will be in place to monitor breakthrough of Chlorinated Solvents being treated by the on-site system. 11. Pretreatment Program (POTWs only): N/A. III. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? Yes or No If yes, please explain: 2. List any items that you would like the NPDES Unit or Non-Discharge Unit Central Office to obtain through an additional information request: Item Reason 1 Information on the connection from the discharge line of the treatment system to the UT – there are multiple options for routing the discharge line to the outfall and the permittee needs to decide the final route and let us know. 2 Please install a sampling port after treatment and before discharge into the storm drain to be able to collect a representative effluent sample and avoid surface water run-off interference. 3 Please provide a map that displays the location of the treatment system associated wells. The map should also display topographic overlay indicating direction of GW flow. 4 Please provide an Iso-contour maps of the constituents of concern to be treated by the system. 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason FORM: WQROSSR 04-14 Page 3 of 3 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason 1 Wet Toxicity due to the presence of Chlorinated solvents. 2 Modified RCRA Metal for Chromium and Arsenic 5. Recommendation: Hold, pending receipt and review of additional information by regional office Hold, pending review of draft permit by regional office Issue upon receipt of needed additional information Issue Deny (Please state reasons: ) 6. Signature of report preparer: Edward Watson, Hydrogeologist 09/10/2021. 7. Signature of regional supervisor: Date: ADDITIONAL REGIONAL STAFF REVIEW ITEMS There is a lot of activity located nearby the subject site. A review of the DWM Site Locator Tool indicates several potential sources of contaminants near the subject site. Site Assessment documents were reviewed along with GW and Soil chemistry that was available in the application. The information for these nearby sites appears that there were several gas stations and automotive service facilities with former USTs. Many of these facilities have received NFA status from DWM. GW and Soil analytical data do not indicate petroleum constituents present at levels above 2L or PSRG Soil Standards. TW-2 reports the presence of dibromochloromethane. However, the level is below the 2L standard. Waivers have been requested for certain constituents in the application. A review of the constituents sampled in GW a nd SS indicate that absence of pesticides throughout the subject site. A waiver was also requested to remove metals sampling. A review of the site reports indicates the presence of Chromium in several soil sample and GW samples. Arsenic was present above PSRG Soil Standard in SB-1, SB-2, SB-3, and SB-4 in report IH3129_20201230_SAR_BF Limited Env. Assessment. The applicant is also requesting the following sampling parameters to be waived for the permit:  BOD  COD  TOC  NH3  TEMP SEASONAL And the MRO is comfortable with those constituents being removed. 9.10.21 AFFIDAVIT OF PUBLICATION Account #Order Number Identification Order PO Amount Cols Depth 28386 153280 Print Legal Ad - IPL0045054 $579.28 2 25 L Wren ThedfordAttention: NCDENR/DWQ/POINT SOURCE 1617 MAIL SERVICE CENTER RALEIGH, NC 276991677 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, doth 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 books and files of the aforesaid Corporation and Publication. No. of Insertions:1 Beginning Issue of:10/14/2021 Ending Issue of:10/14/2021 In Testimony Whereof I have hereunto set my hand and affixed my seal on the 14th day of October,2021 Notary Public in and for the state of Texas, residing in Dallas County Extra charge for lost or duplicate affidavits. Legal document please do not destroy!