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HomeMy WebLinkAboutWQ0015487_Industrial Wastewater Pond Closure Plan_20180814INDUSTRIAL WASTEWATER POND CLOSURE PLAN CLOSED-LOOP RECYCLE PERMIT NO. WQ 0015487 POWELL INDUSTRIES, INC. SUNCREST CHIP MILL HAYWOOD COUNTY, NC Prepared for: POWELL INDUSTRIES, INC. August 14, 2018 _____________________________________ Robert Martin, LG Principal Geologist INDUSTRIAL WASTEWATER POND CLOSURE PLAN CLOSED-LOOP RECYCLE PERMIT NO. WQ 0015487 POWELL INDUSTRIES, INC. SUNCREST CHIP MILL HAYWOOD COUNTY, NC Prepared for: POWELL INDUSTRIES, INC. Prepared by: MARTIN&SLAGLE GEOSCIENCES, PA PO BOX 1023 BLACK MOUNTAIN, NC 28711 828-669-3929 Industrial Wastewater Closure Plan Powell Industries, Inc. i TABLE OF CONTENTS Section Page 1.0 Introduction 1 2.0 Work Sequence Summary 2 3.0 Site Stormwater Sampling 3 4.0 Interim Stormwater Management 5 5.0 Upper Pond Closure-Conversion to Non-Wastewater Pond 6 A. Wastewater Sampling, Analysis and Disposal 6 B. Soil and Wastewater Residuals Analysis 6 C. Soil and Wastewater Residuals Disposal 7 D. Closure Report 8 Figures Figure 1: Closure Plan-Site Map Figure 2: Closure Plan-Pond Detail Map Attachments Attachment A: Closure of Permitted Wastewater Ponds and Lagoons-Checklist and Instruction Items INDUSTRIAL WASTEWATER POND CLOSURE PLAN POWELL INDUSTRIES, INC. SUNCREST CHIP MILL HAYWOOD COUNTY, NC CLOSED-LOOP RECYCLE PERMIT NO. WQ 0015487 1.0 INTRODUCTION On January 17, 2017, Powell Industries, Inc. (PI) requested that the Closed-Loop Recycle Permit for this facility be rescinded by the North Carolina Department of Environmental Quality, Division of Water Resources (DWR). The wastewater recycle pond, 0.2-acre Upper Pond was permitted as a non-discharge system which collected the wastewater discharge from the wet-decking process conducted as part of the chipping process. In addition to receiving process wastewater, the Upper Pond also received stormwater runoff from the various areas of the mill property. The wet-decking process which generated the permitted wastewater discharge has been discontinued. (Reference Checklist Item I.b.) In a letter from DWR on April 3, 2017, specific closure requirements for the Upper Pond as well as “Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons” (June 22, 2012) were forwarded to PI. Analytical results for water samples collected by DWR on May 25, 2016 and PI on November 8, 2016 were also attached. This clo sure plan was prepared in accordance with the requirements included in DWR’s letter. The Checklist included in Attachment A of the guidelines has been completed and is attached to this closure plan. Instruction Items associated with the checked items are addressed and referenced in this plan. Closure of the Upper Pond will require management of site stormwater currently being discharged into the Upper Pond. A 0.3-acre stormwater retention pond (Lower Pond) is situated immediately downstream of the Upper Pond. The two ponds are not hydraulically connected by outlet works other than a high level open channel spillway from the Upper Pond. Figure 1 shows the 11-acre property with process areas and stormwater conveyances. Industrial Wastewater Closure Plan Powell Industries, Inc. 2 DWR believes that a hydraulic connection exists between the Lower Pond and a NC Department of Transportation (NCDOT) culvert that drains stormwater from the low area downstream of the Lower Pond dam east beneath Highway 276, Jonathan Creek Road. If the Lower Pond is incorporated into the permanent stormwater management syst em, DWR requires a dye trace study to confirm the connection. PI has chosen not to incorporate the Lower Pond into the permanent stormwater system eliminating the need to conduct the dye trace study. The goal of this pond closure plan is to remediate the Upper Pond by removal and proper disposal of impounded water and residual sediments in accordance with DWR Pond Closure Requirements. (Reference Checklist Item II.a.) Closure of the Upper Pond will be conducted in phases in order to continue to manage site stormwater, eliminate runoff into the Upper Pond and allow site operations to continue during closure activities. Management of stormwater during pond closure activities will require evaluation of the water quality associated with site runoff prior to discharge into the Upper Pond. Once water quality is characterized for the site runoff, stormwater runoff will be temporarily routed to the Lower Pond. Site stormwater quality issues identified through sampling will be addressed by incorporating temporary and permanent Stormwater Control Measures (SCMs). 2.0 Work Sequence Summary A summary of the work sequence for the pond closure activities is provided in the table below. No. Task Description Phase I 1 Conduct “site audit” (Per 4/3/17 DWR letter) to identify potential waste streams and identify opportunities to improve stormwater quality. 2 Sample and analyze representative site stormwater water quality samples during a rainfall runoff event and sample water in the Lower and Upper Pond (prior to dewatering). 3 Dewater Lower Stormwater Pond by pumping into Upper Wastewater Recycle Pond. 4 Design and install stormwater bypass system into Lower Stormwater Pond. Industrial Wastewater Closure Plan Powell Industries, Inc. 3 5 Dewater Upper Wastewater Recycle Pond by pumping into tankers and delivering to Wastewater Treatment Plant. 6 Conduct testing of wastewater residuals samples and native soil samples from the Upper Wastewater Recycle Pond. 7 Remediate Upper Wastewater Recycle Pond by removal and disposal of wastewater residuals and sediment based on results of testing and requirements specified in “Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons.” Phase 2 8 Design new stormwater management system to meet stormwater discharge permit requirements. A treatment train system with stormwater wetlands is envisioned as shown on Figure 1. 9 Construct new stormwater management system. It is expected the final stormwater management system will operate by gravity and the existing pump system will not be required. 3.0 Site Stormwater Sampling A preliminary site survey was conducted to identify the activities that may contribute to diminished stormwater quality. Based on this survey, sample locations upstream of the ponds were selected for sampling and analysis. Stormwater runoff samples will be collected following a rain event to characterize the first flush of runoff. 1. Stormwater samples will be collected from the locations shown on Figure 1. Sampling locations were selected to quantify the contribution to runoff from activities conducted upstream of the sampling point. Grab samples will be collected into clean laboratory supplied containers and placed on ice for transport to the analytical laboratory. DWR will be notified of the sampling schedule to coordinate splitting samples. 2. Two (2) stormwater samples will be collected and analyzed for monitoring parameters included in PI’s NPDES Stormwater General Permit No. NCG210000 (Certificate of Coverage NCG210097). Additional parameters were added based on the sampling conducted by DWR and PI. Stormwater samples will be analyzed for the following parameters: Industrial Wastewater Closure Plan Powell Industries, Inc. 4  Total Suspended Solids – EPA Method 2540D  pH – EPA Method 9040  Total Phenolic Compounds  Volatile Organic Compounds - EPA Method 6200  Semi-Volatile Organic Compounds – EPA Method 625  Nutrients- ammonium nitrogen, nitrate nitrogen, nitrite nitrogen, TKN, total phosphorus  BOD  COD  Turbidity 3. One water sample will be collected from each pond (stormwater and wastewater) and analyzed for the following parameters:  Metals- arsenic, cadmium, calcium, chromium, copper, lead, magnesium, mercury molybdenum, nickel, selenium, sodium, zinc  Total Phenolic Compounds  Total Suspended Solids – EPA Method 2540D  pH – EPA Method 9040  Volatile Organic Compounds - EPA Method 6200  Semi-Volatile Organic Compounds – EPA Method 625  Nutrients –ammonium nitrogen, nitrate nitrogen, nitrite nitrogen, TKN, total phosphorus  BOD  Turbidity Based on review of the laboratory analyses, temporary SCMs will be selected and implemented to reduce contaminants from discharging into the Jonathan Creek. Industrial Wastewater Closure Plan Powell Industries, Inc. 5 4.0 Interim Stormwater Management SCMs on the Powell Industries site will comply with the North Carolina Forestry Association Stormwater Pollution Prevention Plan (SWPPP) prepared for PI in 2003. This SWPPP describes the measures implemented at the PI site to:  Identify pollution sources that affect water quality of stormwater discharge.  Describe the practices that can reduce these problem areas.  Provide the operation and maintenance necessary to ensure the permitted stormwater controls operate as intended. SCMs implemented at the site consist of proper management of materials at the PI site, including storage of wood and mulch, proper storage and containment of fuels, hydraulic fluids and hazardous materials as well as proper storage, transport, and management of empty containers. A detailed list of materials and the measures implemented is included in the SWPPP. Monthly stormwater inspections, daily cleanup activities as well as other maintenance measures for the site are also specified in the SWPPP. In addition to these site SCMs, temporary stormwater management measures will be implemented during the pond closure activities. Stormwater runoff will be conveyed through a separate stormwater and bypass system into the lower pond, as shown in Figure 1. The temporary bypass will consist of a 360-ft long, 36-inch diameter HDPE pipe which will be connected to the two existing stormwater system lines that currently discharge into the upper pond. The bypass line will be connected at the existing catch basin junction boxes and intercept all upstream stormwater flow from being conveyed into the upper pond. A rock apron will be installed at the outlet of the temporary bypass into the lower pond to prevent erosion. Potential stormwater treatment areas are identified on Figure 1. These areas will be designed to improve stormwater quality based on the results of initial stormwater sampling described in Section 3.0. If use of the lower pond is necessary to meet discharge requirements, a stormwater Industrial Wastewater Closure Plan Powell Industries, Inc. 6 outfall will be installed on the lower pond. Stormwater discharges will be monitored quarterly at the outfall during closure of the upper industrial wastewater pond. Monitoring results will be reported to DWR and Department of Energy, Minerals and Land Resources (DEMLR). 5.0 Upper Pond Closure A. Wastewater Sampling, Analysis and Disposal Closure of the Upper Pond will involve dewatering of the impoundment and proper disposal of the water based on the analytical results of Item 3 above. (Reference Checklist Item IV.a.) Wastewater sampling will be accomplished during the stormwater sampling event. Results will be used to make decisions regarding disposal of the wastewater currently contained in the Upper Pond. Water currently collecting in the pond is being pumped to a frack tank and transported to the Town of Waynesville Wastewater Treatment Plant (WWTP) for disposal. If analytical results indicate no change in water quality since the last sampling event, the water from the Upper Pond will be pumped to the frack tank and disposed of at the WWTP. (Reference Checklist Item III.b.) B. Soil and Wastewater Residuals Analysis Following dewatering, the sediments remaining in the base of the Upper Pond will be sampled according to the following: 1. Two composite sediment samples will be collected above the residual soil base and analyzed by a DWR certified laboratory for the following parameters.  Metals- arsenic, cadmium, calcium, chromium, copper, lead, magnesium, mercury molybdenum, nickel, selenium, sodium, zinc.  Nutrients –ammonium nitrogen, nitrate nitrogen, nitrite nitrogen, TKN, total phosphorus  Total Phenolic Compounds  Semi-Volatile Organic Compounds (SVOCs) – EPA Method 625 Industrial Wastewater Closure Plan Powell Industries, Inc. 7 Four aliquots of sediment will be taken from various locations in the base of the pond as shown on Figure 2. The four aliquots will be collected into a stainless steel bowl, mixed then placed in appropriate containers provided by the laboratory. 2. A sediment grab sample will be collected from each aliquot location placed in laboratory supplied containers and analyzed for Volatile Organic Compounds (VOCs) - EPA Method 8260. Soil samples to be analyzed for VOCs will not be composited. 3. A second composite sample will be collected of the residual soil beneath the sediment in the same manner described above. Four aliquots will be composited and analyzed for all constituents except VOCs. Four grab samples, one from each location will be collected and analyzed for VOCs. The analytical results will be evaluated to estimate the quantity of sediment to be removed , the depth of excavation and the method of disposal. Sample results will be evaluated with respect to hazardous characteristics. It is not anticipated that that ignitability, corrosivity or reactivity will be an issue at this site based on the wastewater source. However, if any one of the metals, volatile organics or semi-volatile organics listed in the Toxicity Characteristic Leaching Procedure (TCLP) exceed their respective regulatory limit, the sample will be analyzed for leachability using the TCLP Method to determine if any of the wastewater residuals should be managed as a hazardous waste. (Reference Checklist Item IV.b.) C. Soil and Wastewater Residuals Disposal Disposal method(s) for wastewater residuals and soil will be determined following evaluation of analytical results. Since the Upper Pond may be used for future stormwater management, wastewater residuals and impacted soil as determined by analysis will be removed and disposed of. Soil may be stockpiled on site before permanent removal to a disposal facility. If wastewater Industrial Wastewater Closure Plan Powell Industries, Inc. 8 residuals/soil are stockpiled on site, they will be placed on plastic sheeting and covered with plastic sheeting to prevent contact with precipitation. Options for non-hazardous wastewater residuals disposal, depending on analytical results, include transportation to White Oak, Haywood County Landfill or Republic Waste Management in South Carolina. Depending on the moisture content, the wastewater residuals may need to be mixed with a desiccant such as kiln dried sawdust to reduce the moisture content in order to pass the paint filter test as required for disposal at landfills. (Reference Checklist Item III.c.) D. Closure Report Upon completion of the industrial wastewater pond closure a report will be prepared for submittal to and approval by the NCDEQ, DWR. The report will include:  A description of the closure activities;  Sampling results;  Volume of wastewater residuals/soils disposed and the location of disposal;  Companies and contractors responsible for closure activities;  Final certifications for proper wastewater and residuals disposal; (Reference Checklist Item V.b., V.c.)  Request for rescission of the Wastewater Closed-Loop Recycle Permit;  Request for the pond to be incorporated into the site stormwater management system. @? @? @? @? g g g g g SW-02 SW-03 WW-01 SW-01 JONATHAN CREEK RDC O N N E C T O R 1 1 4 R D JONATHAN CREEK RD[ 0 10050Feet FIGURE1MARTIN & SLAGL EGeoSciences, PAPO Box 1023Black Mountain, NC 28711828.669.3929 828.669.5289 INDUSTRIAL WASTE PONDCLOSURE PLANPOWELL INDUSTRIES, INC.SUNCREST CHIP MILLHAYWOOD COUNTY, NORTH CAROLINA LEGENDgExisting Stormwater Structure Existing Stormwater Conveyance Proposed Temporary Stormwater Bypass Potential Stormwater Treatment Area Parcel Boundaries Streets Water Sample Locations @?Stormwater Sample @?Wastewater Sample SCALE: 1"= 100'DR: TPOCHK:REV:DATE: 9/21/17 Temporary Stormwater Bypass Potential StormwaterTreatment Area Potential StormwaterTreatment Area Potential StormwaterTreatment Area Upper Pond Lower Pond !A !A !A !A !A!A !A !A CSS-02CSS-02 CSS-02 CSS-02 CSS-01 CSS-01 CSS-01CSS-01 JONATHAN CREEK RD[ 0 3015Feet FIGURE2MARTIN & SLAGL EGeoSciences, PAPO Box 1023Black Mountain, NC 28711828.669.3929 828.669.5289 INDUSTRIAL WASTE PONDCLOSURE PLANPOWELL INDUSTRIES, INC.SUNCREST CHIP MILLHAYWOOD COUNTY, NORTH CAROLINA LEGEND !A Composite Sample Location Stormwater SCALE: 1"=30'DR: TPOCHK:REV:DATE: 9/21/17 1 2 3 4 Pump Station Embankment Lower Pond Upper Pond Overflow Conveya nce ATTACHMENT CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS CHECKLIST AND INSTRUCTION ITEMS Jlit'A RCDERR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Division of Water Quality Charles Wakild, P. E. MEMORANDUM TO: FROM: Aquifer Protection Section Staff Interested Parties Director June 22,2012 Division of Water Quality i\ '{}--~? Dee Freeman Secretary SUBJECT: Ted L. Bush, Jr., Deputy Di~rct Guidelines for the Closure o mitted Wastewater Ponds and Lagoons Purpose The purpose ofthese guidelines is to provide a course of action for the closure of permitted Non-Discharge wastewater treatment ponds, storage ponds, or lagoons. According to G.S. 143-215.1, construction and operation of any sewer system, treatment works or disposal system within the state of North Carolina requires a permit. lSA NCAC 2T .OlOS(j) requires that waste treatment systems (or parts thereof, such as lagoons, storage ponds, etc.) authorized by a permit must be properly closed before that permit (or parts thereof) can become inactive. These guidelines provide clarification as to what "properly closed" entails. While each structure must be considered for its unique circumstances, the Aquifer Protection Section (APS) has ,'outlined'gerreraiprocedures (attached) to ·be used for closure ofwastewater .. treatmerlfponds 'aruflago'oris pehriittea ·· . by the Section. These guidelines are not intended to address lagoons used for animal waste and their associated facilities, or ponds used for the storage of coal combustion by-products. However, it is the intent of APS to require similar close out procedures for comparable scenarios in coordination with other permitting agencies such as the Surface Water Protection, or other interested parties. These guidelines supersede Guidelines for the Closure of Treatment Ponds and Lagoons implemented August 18,2003. Closure Approval • The closure of a Non-Discharge permitted wastewater treatment or storage pond or lagoon should begin with notification by the permittee to the APS. This should include a request to close a specific permitted pond or lagoon, and an indication whether the permit should be modified or rescinded. APS will make available the attached closure checklist/ guidelines to the permittee, who should propose a closure plan based on the attached guidelines. This closure plan should generally include or describe the following (see next page): 1617 Mall Service Center, Raleigh. North Carolina 27699.1617 Location ; 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-6300 I FAX: 919-807-6492 lntemet: WIIW.ncwatergualltv.org An Equal Opportunity I Affirmative Action Employer N~JthCarolina ;vaturall!l Guidelines for the Closure of Permitted Wastewater Treatment Storage Ponds and Lagoons • Checklist with chosen options and requirements indicated (Attachment A, page A-1) • Historical use of impoundment (include all waste streams) and current status • Future plan for site • Disposal options for wastewater • Disposal options for sludge • Sludge disposallocation(s) • Sampling plan for wastewater and/or sludge Once the permittee submits their closure plan, a preliminary inspection will be conducted and an inspection report with additional closure instructions (if needed) will be presented to the pennittee. The permittee will then submit a final closure report documenting their closure procedure. The final closure report may include the foUowing: • Sampling results • Volume of sludge disposed and location • Companies/Contractors involved • Final Certifications The RegionaJ Office will conduct a fmal inspection and present the results of that inspection to 1he pennittee, along with their recommendation to the APS Central Office for approval or disapproval of a permit modification or rescission . Applicable Regulations Regulations that may be applicable to the abandonment ofNon-Discharge permitted ponds and lagoons are listed below . These guidelines do not go into the detailed requirements of the regulation listed. However, each bullet summarizes how the regulation may be applicable to the action requested. • Title ISA NCAC 2L, Classifications and Water Quality Standards Applicable To The Groundwaters of North Carolina. This regulation requires that groundwaters must be protected to a level of quality at least -· ~·· .. ····=· ..... .. .. as -high as that required under standards established in Section .. 0202 of that Rule. • Title )5A NCAC 2T, Waste Not Discharged to Surface Waters. This rule establishes requirements that are protective of surface water and groundwater standards for systems that treat, store, transport, and dispose of residuals and do not discharge waste to surface waters. Other pertinent standards and regulations may be found in the Department of Environmental and Natural Resources (DENR) Division of Land Resources (DLR) regulations pertaining to Sedimentation and Erosion Control and Dam Safety, the DENR Division of Waste Management (DWM) regulations pertaining to the disposal of wastes and sludge, and the Department of Transportation (DOT) regulations pertaining to transportation of materials on public highways. cc : Surface Water Protection (Matt Matthews) Attachments A. Checklist and Instruction Items B. Flow Charts Page2 ATTACHMENT A . ' " . ' . ~· . ' . .. .. ·' .. ' ... : . . .. ' . ., . ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS Checklist and Instruction Items The purpose of the following checklist and instruction items is to aid in the development of a closure plan for a permitted Non-Discharge wastewater pond or lagoon to be submitted to tbe appropriate APS Regional office for approval. The following checklist allows the applicant to identify the type of lagoon to be closed, and the preferred closure and disposal options. The selected options include references to instruction items (e.g. Item A) found on subsequent pages of this attachment. The instruction items describe what steps are expected to be complete prior to approval of the closure plan, ·including expected sampling and monitoring, and final certifications of complete closure. Note that the following steps are not all inclusive, as each site is unique and may hav~ varying site conditions . In addition, flowcharts (Attachment B) have been provided as an alternate to the instructional Items A- H. These charts contain the same information, but give a visual representation of the closure process. For questions, contact the approving APS Regional Supervisor. Please check all items below that apply and submit a completed copy with the lagoon closure plan. I. Type of Pond or Lagoon System ___ a. Primary and Secondary Biological Wastewater Lagoon Systems (examples: food processing treatment lagoons, municipal treatment systems without pretreatment programs, neighborhood treatment systems). v' b. Primary and Secondary Industrial Wastewater Lagoon Systems( examples: non-food type industrial treatment systems, municipal treatment systems with pretreatment program). ·---c. Tertiary Wastewater Pond Systems ( examples: wastewater biological treatment systems with tertiary treatment to include infiltration disposal pond systems, effluent polishing pond systems). II. Closure Options -Structure vi a. Conversion to Non-Wastewater Pond -Change ofUse (Item B) , . ~~b .. Complete or parti;;tl removal of .s.t.ructu.re .(Items _ G) . _ .. . .. -.. _ ___ c. Site Reclamation (Item F and H) III. Final Liquid and Solid Content Disposal Options --r--a. Wastewater D-isposal to Onsite Permitted Field (Item A) 1/ b. Wastewater Disposal through Pump and -Haul (Item A) \7' c. Sludge Disposal to Permitted Site (Items C and D) ___ d. Sludge Left in Place (Items C and E) IV. Sampling and Monitoring Requirements v" a. Wastewater Sampling . Required (Items A and m V' b. Soil and Sludge\-Sampling Requ~d (Items C and F) ___ c. Groundwater Monitoring Required (Item G) v. Final Certification Required for Closure Activities, as required ip. Item l. ---r_a .. Structural Deconstruction (Professional Engineer or Hydrogeologist) V" b. Wastewater Disposal (Facility ORC) V c. Sludge Disposal (ORC I Licensed Sludge Land Application Contractor) , r.: '·-'--·" ,. -r. -.. ._; ;._.,.,_ ..._:·.,,'. ; •• ,: • __ d. Other (Explain: _____________________ -' A-1 Attachment A June 22, 2012 A IT ACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS Item A. Wastewater Sampling, Analvsis, and Disposal I .. Pond samples require a composite sampling technique. Samples should be composited from several locations. An adequate number of representative and composite samples should be taken and developed respectively. 2 . For permitted disposal sites, sample and analyze wastewater in accordance with permit conditions. In the absence of permit specified monitoring, sample for the following parameters: a. Fecal coliform bacteria, chlorine residuals (if used as disinfectant), total nitrogen, BOD5, TSS, pH. b. Other parameters may be required based on waste stre~ms, as directed by the APS Regional Supervisor. · 3. All wastewater samples must be analyzed by a DWQ-certified laboratory. 4. Once the wastewater is sampled, the pond/lagoon can be dewatered to a permitted disposal site (uniform application of wastewater) or through a pump and haul permit. 5. Remove or plug all inflow and outflow piping, etc to the pond/lagoon Item B. Conversion to Non-Wastewater Pond (Tertiary Treatment Ponds Only) 6. Determine pond liquid volume (if water accumulates after complete disposal per Item A, Wastewater Sampling, Analysis, and Disposal). 7. If some sludge remains, sludge can be left in place, in accordance with Item E#23 below. Otherwise, remove all residuals and dispose of properly per Item D, Sludge and Soil Disposal. 8. Disinfect and/or treat pond to meet Item B#II requirements below. 9. Sample pond (see Item A, Wastewater Sampling, Analysis, and Disposal) I 0. No pond discharge is allowed to surface water without prior approval from an appropriate Surface Water Section Regional Office. Note that pond discharge to class SA waters is not allowable. II. All discharges must meet water quality standards applicable to receiving stream classification or per limits provided by DWQ when water quality stream standards for monitored parameters are not defined . ··.:·-.;:_· . ·•·.·"' ... • '· ....... ,. ___ ·-~·-• ___ ...... _ ....... = ........... _·.···':·I"' ,._ •. ' .. _:· ·' . .')~' ···-··-~ •. ,. Item C. Soil and Sludge Analysis 12. All soil and sludge samples require a composite sampling technique. An adequate number of representative and composite samples should be taken and developed respectively. Thickness of sludge or soil and surface acreage should be c~nsidered. Example: one composite sample per acre foot. 13 . All soil and sludge samples must be analyzed by a DWQ-certified laboratory. 14 . For biological wastewater lagoons systems and tertiary wastewater pond systems, soil or sludge shall be sampled for: u a. Pathogen and Vector Attraction Reductions. Testing should be done per I 5A NCAC 02T .11 00. If project concerns only a tertiary pond, and pond sediments/sludge meets Class A pathogen reduction requirements (maximum of 1000 fecal coliform bacteria colonies per gram of total solids), additional characterization for pH, metals, nutrients, and solids as stated in 14.b and 14.c (below) may not be required, as determined on a case by case basis. b. Arsenic, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, zinc, TKN, ammonia nitrogen, nitrate/nitrite, nitrogen, phosphorus, sodium, calcium, magnesium (mg/kg dry . wt basis), percent total solids and pH. c. Other parameters may be required based on waste streams, as directed by the APS Regional Supervisor. A-2 Attachment A June 22, 2012 ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS 15. For industrial wastewater lagoon systems, this should be the same as biological wastewater lagoon system sampling plus site-specific parameters and hazardous characterization to include, but not limited to, TCLP, ignitability, corrosivity and reactivity. 16. If the sludge or soil samples are: a. Required to be analyzed for hazardous characteristics and results exceed hazardous characteristics regulatory limits, the material needs to be removed and reported to and managed in accordance with the Hazardous Waste Section in the Division of Waste Management. b. Not required to be analyzed for hazardous characteristics or results do not exceed the hazardous characteristics regulatory limits, the soil can be left in place if the following conditions are met : i. Total concentrations of contaminants in soil .do not exceed protection of groundwater soil concentrations for North Carolina based on 2L standards, as calculate~ using the Transport Model for Calculation of Soil-to-Groundwater Concentrations from the USEP A 1996 Soil Screening Guidance document. (The EPA Transport model can be found in the "Soil Remediation Goals Table" at http://portal .ncdenr.orglweb/wm/sf/ihs/ihsguide or the "2L, MCL, and Soil Screening Levels Table" at http://portal.ncdenr.org/web/wm/hw/technical/guidance.) ii. Total concentrations of contaminants in the soil ex'ceed protection of groundwater soil concentrations for North Carolina, but results do not exceed naturally-occurring background concentrations, iii. A more stringent soil clean-up level is not necessary due to site specific conditions as · determined by the Division. For sludge left in place, see Item E, Sludge Left in Place. For sludge disposal, see Item D, Sludge and Soil DisposaL c. Not required to be analyzed for hazardous characteristics or results do not exceed hazardous characteristics regulatory limits, but total concentration results exceed corresponding protection of groundwater soil concentrations for North Carolina as calculated using the Transport Model from . , the USEPA 1996 .SoilS<;reeningQuldanc.e do~ument d.es~r~bed.in 16(b)(i), soil and sludge _mu~t b~. disposed of according to Item D, siudge 'and So1lriisposal. 'For soils that exceed protection of' .. groundwater levels, Item G, Groundwater Post Closure Monitoring, must also be considered. 17. For ponds or lagoon bottoms that intercept groundwater, Regional Offices will determine what type of sampling is required for the remaining contents on a case by case basis. Item D. Sludge and Soil Disposal 18. Measure surface area and depth of sludge and soil (if required) to determine disp<tsal volume 19. Sample sludge and soil (if required) for permitted disposal option including pathogen and vector attraction reduction verification (see Item C, Soil and Sludge Analysis) 20. If a tertiary pond and sludge/sediments meet Class A pathogen and vector attraction reduction requirements, sludge/sediments can be land applied uniformly on site without sludge permitting action (additional sludge or soil characterization may not be required, as determined on a case by case basis). 21 . If sludge or soil does not meet Class A pathogen and vector attraction reduction requirements, sludge/sediments may require a permit modification to land apply. 22. Pathogen and vector attraction reduction testing will not be requjred if sludge or soil is taken to a permitted compost or another treatment facility for further stabilization. A-3 Attachment A June 22, 2012 ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS Item E. Sludge Left in Place 23. For closure purposes, the Division of Water Quality considers it practical to remove sludge content from structures. The Division will evaluate the applicability of leaving any remaining volume of sludge content in the structure on a case-by case basis. Sufficient technical justification shall be provided to support such recommendation. Item F. Liner Demolition/Disposal 24. lf a synthetic liner is present, remove synthetic liner, scarify/rip/disk underlying material in cases where . there is no potential benefit for reuse of the structure based on projected future site use. a . If there are_ rio historical problems with the lagoon (documented seepage, etc.) and the liner is intact after dewatering with no visible indications of seepage, soil sampling may still. be required on a case-by-case basis. b. If liner and/or lagoon issues are documented, the soH material under the synthetic liner should be sampled according to Item C, Soil and Sludge Analysis. 25. If clay liner is present, scarify/rip/disk and/or remove and reuse as cap if filling. If the liner is natural clay, sampling may be required on a case by case basis if the following conditions are not met: · a. Based on existing groundwater monitoring data, no groundwater violations are present, b. Domestic wastewater systems only, c. Surficial layer of earthen material (top 6"-12") removed , and d. All sludge removed and the remaining material is only soil and not co-mingled soil/sludge. 26. lfthe clay liner does not meet the conditions in #25 above, the clay liner should be sampled according to Item C, Soil and Sludge Analysis. 27. If a pond or lagoon does not have a liner, the underlying soil should be sampled according to Item C, Soil and Sludge Analysis. Item G. Groundwater Post Closure Monitorine 2&.-For faoiUtiGswith;no .historic-groundwater monitoring; monitoring may be required based on post closure soil sample results. Contact Regional Office for directions. If groundwater monitoring is not required, permittee can petition the Division for rescission once the site is reclaimed. 29. For ponds or lagoons with historic groundwater monitoring and no groundwater violations were detected, no further groundwater monitoring will be required, as recommended by the Regional Office based on existing data. 30. For ponds or lagoons with historic groundwater monitoring and/or ISA NCAC 2L standards were exceeded, the following actions would be required: u · a. Maintain permit with limited actions as recommended by the Regional Office (e.g. annual groundwater monitoring and reporting). b. Continue groundwater monitoring as permitted for a minimum of three sampling events. i. If there are no further groundwater exceedances detected or exceedances show a trend of lowering toward groundwater standards, the permittee could petition the Division for permit rescission. ii. If groundwater exceedances continue at the same level, continued monitoring and or site evaluation would be required at the Regional Office Supervisor's discretion. c. In lieu of groundwater monitoring, the Permittee may provide predictive calculations, acceptable to the Director, to demonstrate groundwater standards can be met at the property boundary. Attachment A June 22, 2012 ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS Item H. Berms/Lagoon Walls and Site Reclamation* 31. In cases where retention of municipal structures provides no value based on projected future site use, it is recommended that minimal demolition be performed to breach or remove sidewalls (dependent on the size) when the liner is demolished. Minimal demolition may be considered feasible in cases where retention of the structure or a portion thereof poses minimal risks based on conditions such as low population densities of surrounding areas, low hazard environment, low probability of encroaching development, etc. 32. For privately owned and higher risk municipal structures, more extensive structure demolition is recommended to include, but not be limited to, removal of berms/dike walls and general grading of project site. 33. If structure is completely constructed at or below grade, fill with clean material (partia! or complete, depending on size) and/or grade site to minimize any hazards posed by existing conditions. 34. If structure is finished in the groundwater table, see Item C #17. 35. Stabilize the site with vegetation. Establishment of trees, grasses, and other viable cover crops should be considered to assist site stabilization and with removing any remaining nutrients. *Recognize the added value of planned reclamation efforts. Reclamation activities incorporating created artificial wetland systems, planted trees, and other pro-active actions viewed as either mitigation efforts or secondary environmental protecti~n measures may assist with enabling the closure project to qualifY for recognition and benefit from other environmental programs, such as those offered through conservation easements. Item I. Final Certifications 36. For deconstruction including berm removal, berm breaching, or liner destruction, submit a letter certified by the overseeing professional engineer that action was taken according to the approved plan, as well as all local and state regulations. 37. For wastewater disposal, submit a copy of the monitoring report that documents lagoon wastewater disposal activities, certified by the facility ORC. -38: ·For· sludge disposal; ·submit a-copy of the records-documenting lagoon sludge disposal, certified by the __ licensed sludge land application contractor if land applied. If sludge was disposed of in a landfill, records from the receiving facility shall be provided. 39. Sampling results from any post-closure sampling conducted at the facility to document proper removal of sludge in accordance with the approved closure plan shall be submitted. 40. Photos of closure activities documenting conditions prior to initiating closure, closure activities, and post- closure conditions are recommended, but not required. 41. Other. A-5 Attachment A June 22, 2012