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HomeMy WebLinkAboutNC0004375_Meeting Notes_20000310NPDES DOCUMENT !SCANNING: COVER SHEET NPDES Permit: NC0004375 Clariant Corporation Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change eeting Notes Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: March 10, 2000 This document is printed on reuse paper - ignore any content on the reYerse side MEMORANDUM Date: March 10, 2000 To: Meeting Attendees From: Rick Carrier, Brown and Caldwell 2000 p: {H _',';:,Ti.ft 01;1.ITY 18362-01/05 18362-01/09 Subject: February 11, 2000, Meeting Regarding Charlotte Mecklenburg Utilities (CiIU) Wastewater Treatment at Clariant NPDES Facility NPDES permit: NC0004375 CMU PN: 622-97-682 A meeting was held on February 11, 2000, at North Carolina Department of Environment and Natural Resources, Division of Water Quality (DWQ) offices in Raleigh to discuss the ramifications of treating domestic wastewater from the CMU Long Creek sewer collection system at the Clariant Corporation (Clariant) wastewater treatment plant (WWTP). The following persons were in attendance: Rick Carrier, Brown and Caldwell Jackie Nowell, DWQ Dave Goodrich, DWQ Gary Sanderson, Clariant Corporation Mark McIntire, DWQ Barry Shearin, CMU A brief overview of the proposed project was presented by Mr. Carrier. Brown and Caldwell is designing a new pumping system including flow equalization to replace the existing Long Creek pumping station and force main. The new system is being designed for an average dry weather flow of approximately 2 mgd and a peak wet weather flow in excess of 14 mgd. Both Clariant and CMU wish to consider the use of the wastewater treatment facility (WWTF) to treat flows from the Long Creek sewer system. The existing Clariant WWTF is adjacent to the pumping station site and is presently permitted to discharge at flow rates up to 3.9 mgd. The WWTF is designed for a hydraulic flow of approximately 5 mgd. Recent process changes have resulted in significantly lower flow rates through the WWTF and Clariant expects further flow reductions in the near future to possibly as low as 0.5 mgd. The proposed project will eliminate the need for CMU to pump the wastewater several times in route to the CMU McAlpine Creek WWTF. It will also allow discharge directly to the Catawba River instead of to the relatively small McAlpine Creek tributary. Clariant's treatment efficiency will benefit from the carbonaceous BOD and phosphorous in the CMU wastewater. A treatability study is planned to verify that the proposed concept is technically sound and to develop treatment plant concepts. DWQ will want to review the treatability information. DWQ B3 11'N aCALDIWWELL C:\WINDOWS\TEMP\MM 00-02-11 - NCDWQCIariant.doc Meeting Attendees March 10, 2000 Page 2 would like the study to address the effect of reducing the percentage mix of domestic wastewater and will be looking for flexibility on the part of Clariant and CMU. CMU is working with DWQ to reduce sanitary sewer overflows (SSO's) associated with the existing Long Creek pumping and force main system. CMU intends to place an advertisement in the Charlotte Observer detailing their plans for the system and would like to include information on the proposed project as part of their overall strategy. CMU has significant money set aside for sewer rehabilitation. A manhole rehabilitation project has been designed and additional infiltration and inflow reduction methods are being considered for the basin. CMU is purchasing a set of portable diesel driven pumps to improve the reliability of the pumping station. Ultimately, growth in the Long Creek basin will exceed the capacity of the Clariant WWTF and CMU would like to have a regional plant in place at that time. CMU is proceeding with the construction of a parallel sewer for the Long Creek basin and has performed flow monitoring which shows the need for increased sewerage capacity on the west side of Mecklenburg County. CMU is presently exploring several regional treatment solutions but have not completed their planning efforts. Based upon experience with the Water and Sewer Authority of Cabarrus County and Union County, it appears that it will take approximately 8 years from concept through construction for a new plant. In general, DWQ approves of the proposed concept. Mr. Goodrich noted that the following similar projects have already been in operation in North Carolina: • JPS elastomerics (formerly Cramerton Automotive) in Cramerton had an underutilized WWTF (i.e., 4 mgd permitted capacity with less than 0.25 mgd process flow) and was approved to accept Cramerton's domestic sewage flow. Cramerton took over ownership and operation of the facility. • Monsanto in Fayetteville accepts and treats flows from several other nearby Organic Chemical, Petroleum, and Synthetic Fiber (OCPSF) industries. Mr. Goodrich noted that DWQ has concerns regarding eutrophication water quality problems in Lake Wylie related to elevated nitrogen and phosphorous levels. Although there currently are no Opknown algae problems in the lake,,DWQ is concerned about possible future problems. DWQ 1t - at ee s t e est Available Technology (BAT) levels for domestic dischargers is well defined; edit however, BAT levels for industrial dischargers are less defined. DWQ anticipates that Clariant will be required to meet BAT -based limits in the future. DWQ anticipates that a concentration -based summer nitrogen limit of 6 mg/1 and year-round \N...... phosphorous limit of 1 mg/1 will be imposed on all domestic discharges in the Lake Wylie basin with any requested POTW expansion. DWQ is more col_ - u a . i_' • m : 1._ . •_' . Lake Wylie than phosphorous. A total maximum daily load (TMDL) is being developed for nutrient BROWN axe CAtIIIMJL C:\WINDOWSITEMP\MM 00-02-11 - NCDWQCIariant.doc Meeting Attendees March 10, 2000 Page 3 loadings to Lake Wateree, South Carolina. Recent work by the South Carolina Department of Environment, Health and Conservation (SCDHEC) did not include fate and transport of nutrients. Clariant believes that the use of an anoxic zone at the front of their aeration basins as recommended in their recent BAT study will significantly reduce the total nitrogen loading from both CMU and Clariant. Clariant's influent organics include a relatively high nitrogen component and a 6 mg/1 total nitrogen limit would be excessively restrictive. Clariant currently adds phosphoric acid as a nutrient to support their activated sludge biomass. Clariant also adds lime for alkalinity which tends to tie up the phosphorous. DWQ is encouraging industries to undertake pollution prevention programs. Clariant has already implemented a pollution prevention program in accordance with a recent study. DWQ will review the proposed project following the treatability study based upon cost and other factors. In general, DWQ would look favorably upon a program that will not increase overall phosphorous loads and that will reduce the nitrogen loading to the Catawba River. Clariant noted that the only way that the project will be feasible from their perspective is if the cost is relatively low in comparison to other projects competing for their limited capital funds. DWQ has not recently modelled the Catawba River/Lake Wylie system. The Receive2 model was based upon the Mountain Island Lake discharge and was updated last in 1980. A WASP model would be required now to ascertain the impact of a proposed discharge and would require full calibration information including instream monitoring. DWQ's 1995 model of the main channel of the Catawba River demonstrated that the combined influence of Clariant, Mount Holly, and Belmont at nitrogen and phosphorous discharge limits in excess of 6 and 1 mg/1 respectively did not degrade water quality in Lake Wylie. This effort was performed by Steve Bevington. DWQ does not believe that modeling will be required for the proposed project because the total flow discharged will not exceed the present permitted capacity of 3.9 mgd. The present limits are based upon OCPSF effluent guidelines. DWQ did perform a Walker Bathtub analysis of Lake Wylie as part of their ongoing discussions with SCDHEC. The NPDES permit modification process was discussed: • The treatability study results should be submitted to DWQ with a 30-day period for them to review. DWQ would like the study to develop several options for treatment based upon differing discharge limits. • Following review, DWQ, Clariant and CMU will meet to discuss and negotiate new discharge limits. • Upon completion of negotiations, Clariant will submit a request to modify their NPDES permit. BROWN ANC CLDt6 C:IWtNDOWS\TEMPIMM 00-02-11 - NCDWQCIarianLdoc 1`' a Meeting Attendees March 10, 2000 Page 4 • The overall permit processing time may be reduced by approximately 2 months by directly requesting a public hearing with the request for a permit modification. The Catawba River Foundation (CRF) will likely be interested in the project and CMU/Clariant plan to involve them in the process. Michael Jones is the technical advisor to the CRF and works closely with Donna Lisenby. • A draft permit will then be issued for final negotiation four to six months following the request. Clariant will have 30 days to provide a written response to the draft permit. • Following final negotiations, a modified permit will be issued and Clariant may operate under the new permit following a 15-day waiting period. DWQ believes that the OCPSF issues raised in Clariant's response to their October 1996 draft NPDES have now been resolved and should not be an issue for the proposed project. Clariant should expect to receive their new permit prior to completion of the negotiation process for this project. A "reopener" clause may be included regarding nitrogen in Clariant's permit. A compliance schedule may be required by DWQ as part of the revised permit. Wasteload allocations and permit limits are typically set in Dave Goodrich's group. The Mooresville regional office will comment on any permit modification request and the modelling unit will also have influence on the proposed limits. Any request for a permit with limits greater than 6 mg/1 nitrogen and 1 mg/1 phosphorous will ultimately require approval by Colleen Sullens. The Catawba Basin Plan allows for reduced total pollutant loadings rather than restrictive concentration based permit levels. Dave Googst with Dennis Ramsey regarding any compliance concems. A finding of no significant impact (FONSI) will be required from NCDENR. The Environmental Assessment (EA) for the Long Creek pumping station project should include a discussion of the proposed project and possible impacts on rare and endangered species, archaeological sites, wetlands, etc. A copy of the EA should be sent to Dave Goodrich. Rick Carrier will discuss the project with Gloria Putnam prior to submitting the EA. 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