NC0001899_Fact Sheet_20220324

NC0001899
Fact Sheet
NPDES Permit No. NC000001899
Permit Writer/Email Contact Sergei Chernikov, Ph.D., [e-mail]:
Date: April 7, 2017
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Moncure Holdings West, LLC WWTP
Applicant Address:
282 Century Place, Suite 2000, Louisville, CO 80027
Facility Address:
338 Pea Ridge Road; New Hill, NC 27562
Permitted Flow:
Outfall 001: 0.244 MGD
Facility Type/Waste:
Outfall 001: 92% industrial/8% domestic; Outfall 002: 52%
stormwater/48% industrial
Facility Class:
Class II/ Major /Active; Major Modification
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Treatment Units:
o Sanitary bar screen, grinder, and lift station
o Process wastewater lift station
o One (1) 1,200 gallons mixing/neutralization chamber
with automatic pH control
o One (1) 650,000 gallons aeration basin with
mechanical aerators
o Coagulent addition system
o One (1) 18,500 gallons clarifier
o One (1) 1000 ft2 sludge drying bed
o Chlorine contact chamber (no chlorination)
o Conventional water treatment plant with chemical
addition systems
o One (1) 20,000 gallons clarifier
o Two (2) alum settling ponds, one 300,000 gallons, one
500,000 gallons
o One (1) 1,000,000 gallon polishing pond
o Effluent composite sampler
o Effluent meter
Pretreatment Program (Y/N)
NA
County:
Chatham
Region
Raleigh
Briefly describe the proposed permitting action and facility background: This is a former Organic
Chemicals, Plastics and Synthetic Fibers (OCPSF) facility that was shut down in April 2015 and
demolished in April 2017. The new owner was planning to begin the Centralized Waste Treatment
(CWT) at the site. The last permit was based on the assumption that CWT operation will commence soon.
However, the plan changed and the owner decided to decommission the WWTP, this process is expected
to be completed during 2021-2022. The facility currently discharges storm water and small amount of
domestic wastewater from 2 employees remaining on site. The Division of Water Resources approved the
Closure Plan on 12/18/2017. This permit is needed until the WWTP is completely decommissioned. No
significant changes were made to the permit, several standards conditions have been updated.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Haw River (Outfall 001); Shaddox Creek (Outfall 002)
Stream Segment:
16-(42)
Stream Classification:
WS-IV
Drainage Area (mi2):
Summer 7Q10 (cfs)
40 (minimum release) (Outfall 001)
Winter 7Q10 (cfs):
40 (minimum release) (Outfall 001)
30Q2 (cfs):
40 (minimum release) (Outfall 001)
Average Flow (cfs):
460
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NC0001899
IWC (% effluent):
0.93 (0.244 MGD at 7Q10s)
303(d) listed/parameter:
No
Subject to TMDL/parameter:
No
Subbasin/HUC:
Cape Fear; 03030002
USGS Topo Quad:
E22SE, Moncure NC
3. Effluent Data Summary
Effluent data is summarized below for the period: the facility has not been
discharging any industrial wastewater since 2015.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen and temperature.
Review of instream data for downstream station (monitoring coalition station B4080000 — Haw River) for
the past five years when the facility was discharging industrial wastewater (2013-2017) indicates that the
dissolved oxygen standard of 5 mg/L was maintained, please see attached. Comparison with the upstream
station is not reasonable since it is located to far upstream of the discharge. This draft permit maintains
the same instream monitoring requirements.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): Yes
Name of Monitoring Coalition: Upper Cape Fear River Basin Association
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported 6 BOD
limit violations in 2018, 2020, and 2021.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 19 of 19 quarterly chronic toxicity tests.
Summarize the results from the most recent compliance inspection: N/A
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6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: NA
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: There are no
proposed changes.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of Y2 detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was not conducted since the facility is repurposing from OCPSF to CWT
and it is unclear what type of waste will be treated at this facility in the future.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
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NC0001899
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Major Industrial facility, and a chronic WET limit
at 0.94% effluent will continue on a quarterly frequency.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1.
A mercury evaluation was not conducted since the facility is repurposing from OCPSF to CWT and it is
unclear what type of waste will be treated at this facility in the future. The past effluent characteristics are
no longer valid.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: Individual TN/TP effluent limits were added to this permit renewal to comply with a
nutrient permitting strategy for the Cape Fear River Basin. In the prior permit cycle, there was only a
group cap for nutrient compliance.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107(c) (2) (B), 40CFR 122.47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not applicable, delete and skip to next Section)
Describe what this facility produces: Currently there is no production, this is a former OCPSF facility.
The facility was planning to convert to CWT and the last permit was designed to accommodate waste
from subparts A, B, and C. No changes are proposed for this renewal.
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List the federal effluent limitations guideline (ELG) for this facility: 40 CFR 437.
If the ELG is based on production or flow, document how the average production/flow value was
calculated: This ELG is based on flow. Since the contracts for treating waste have not been secured, the
following allocations are assumed: Domestic wastewater — 0.024 MGD, CWT Subpart A — 0.08 MGD,
CWT Subpart B - 0.07 MGD, CWT Subpart C- 0.07 MGDy.
For ELG limits, document the calculations used to develop TBEL limits: The limit calculations are
attached.
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: The comparison of TBELs and WQBELs
for metals are attached. It appears that all TBELs for metals are more stringent than WQBELs for metals
with an exception of Cd.
Document any TBELs that are less stringent than previous permit: Please see above
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
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NC0001899
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
Table. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.244 MGD
No change
15A NCAC 2B .0505
BOD5
MA 5.0 mg/L
DM 10.0 mg/L
No change
Permitting Policy per Basin Plan
Oil and Grease
MA 55.67 lb/day
DM 210.92 lb/day
No change
Change from OCPSF to CWT (40
CFR 437)
TSS
MA 30.0 mg/L
DM 45.0 mg/L
No change
Permitting Policy per Basin Plan
Temperature
Monitor only
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
NH3
MA 1.0 mg/L
DM 2.0 mg/L
No change
Permitting Policy per Basin Plan
DO
Monitor only
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH (Outfall 001
and Outfall 002)
6.0 — 9.0 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Nitrogen
4.48 lb/day
No change
Nutrient Allocation per Basin Plan
Total Phosphorus
1.0 lb/day
No change
Nutrient Allocation per Basin Plan
Total Cadmium
MA 62.9 µg/L
DM 284.7 pg/L
No change
CWT parameter, limit is based on
RPA since WQBEL is more
stringent than TBEL
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Conductivity
Monitor
No change
15A NCAC 2B .0508
Toxicity Test
Chronic limit - 0.94%
for Outfall 001, acute
limit for Outfall 002
Updated language
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
CWT
CWT parameters, limits
and monitoring.
No change
40 CFR 437.
Electronic
Reporting
Electronic Reporting
Special Condition
Updated language
In accordance with EPA Electronic
Reporting Rule 2015.
Temperature
(Outfall 002)
Limit and monitoring
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Zinc and
Total Aluminum
Monitoring only
(Outfall 002)
No change
Parameters of concern
MGD — Million gallons per day, MA - Monthly Average, DM — Daily Max
13. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): NO
If Yes, list changes and their basis below: NA
14. Fact Sheet Attachments (if applicable):
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