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HomeMy WebLinkAboutWQ0015487_DWR Response Letter_20161104Water Resources ENVIRONMENTAL QUALITY PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN Director November 4, 2016 CARL B. POWELL - PRESIDENT POWELL INDUSTRIES, INC. POST OFFICE BOX 65 WAYNESVILLE, NORTH CAROLINA 28786 Subject: Application No. WQ0015487 Additional Information Request Powell Industries, Inc. Suncrest Chip Mill Closed -Loop Recycle System Haywood County Dear Mr. Powell: Division of Water Resources' Central and Regional staff has reviewed the application package received December 22, 2015. However, additional information is required before the review may be completed. Please address the items on the attached pages no later than the close of business on December 5, 2016. Please be aware that you are responsible for meeting all requirements set forth in North Carolina rules and regulations. Any oversights that occurred in the review of the subject application package are still the Applicant's responsibility. In addition, any omissions made in responding to the appropriate items outstanding Sections A or B, or failure to provide the additional information on or before the above requested date may result in your application being returned as incomplete. Please reference the subject application number when providing the requested information. All revised and/or additional documentation shall be signed, sealed and dated (where needed), with three copies submitted to my attention at the address below. If you have any questions regarding this request, please do not hesitate to contact me at (919) 807-6352 or david.goodrich@ncdenr.gov. Thank you for your cooperation. Sincerely, � 4� David Goodrich, Hydrogeologist Division of Water Resources cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy) Bradley Bennett, Division of Water Resources (Electronic Copy) Permit Application File WQ0015487 State of North Carolina I Environmental Quality I Water Resources I Water Quality Permitting ( Non -Discharge Permitting 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919 807 6464 Mr. Carl B. Powell November 4, 2016 Page 2 of 3 A. Decision to Renew the Permit or Rescind the Permit: 1. Due to the current configuration of the Recycle Pond and Stormwater Pond, there are three possible courses of action that can be taken at this time to achieve permitting compliance at your facility. Please carefully consider each of the three scenarios and choose the one which you would like to follow. In evaluating the scenarios, you should consider the future needs of your business and the necessary engineering and site modifications each scenario will require.: Scenario A: Both the NPDES Stormwater Permit and the Closed -Loop Recycle System ("Wet - Decking") Permit would remain active. The site would have to be modified in such a way as to have the Recycle Pond receive only the water from the wet -decking operation area, and the Stormwater Pond receive only stormwater from the site. Stormwater collected in the Stormwater Pond could be used as makeup water to supplement the water in the Recycle Pond during dry periods. Water from the Recycle Pond could not be discharged or otherwise conveyed to the Stormwater Pond under any circumstances. Any hydraulic connection (underground pipe, etc.) between the Recycle Pond and the Stormwater Pond would have to be severed. Any other stormwater-only discharges from industrial activity on the site would be covered as a separate outfall under the stormwater permit or must be eliminated or rerouted into the Stormwater Pond. For the NPDES Stormwater Permit to remain active, the permittee must demonstrate that best management practices and appropriate treatment can meet the Stormwater Benchmarks in the NCG210000 General Permit. Scenario B: The Closed -Loop Recycle System Permit would be rescinded and NPDES Stormwater Permit would remain active. For the NPDES Stormwater Permit to remain active, the permittee must demonstrate that best management practices and appropriate treatment can meet the Stormwater Benchmarks in the NCG210000 General Permit. Sampling and removal of residuals from both ponds may be required because both ponds have received wastewater. Removal and proper disposal of residuals will be required if concentrations of certain parameters exceed the applicable soil screening criteria. The sampling would consist of testing of the water and sediments of each pond for Total Organic Carbon, 5-Day BOD, COD, Nitrate Nitrogen, Ammonia Nitrogen, TKN, pH, Chloride, Total Phosphorous, Phenol, Total Ammonia, Total Volatile Organic Compounds, Calcium, Sodium, Magnesium, Sodium Adsorption Ratio, Total Trihalomethanes, Toxicity Test Parameters and Total Dissolved Solids, Nitrates, and Total Nitrogen. Sampling results would have to be evaluated and Powell Industries would have to take appropriate actions to address any surface water or groundwater quality risks before the Division can consider rescinding the recycle permit. Scenario C: The Closed -Loop Recycle System Permit would remain active and the Stormwater Permit would be rescinded. A demonstration would have to be made to show that there is no pipe or other hydraulic connections between the Stormwater Pond and Jonathon Creek. Also, any other stormwater-only discharges associated with industrial activity at the site must be eliminated or rerouted into the Recycle Pond. Under this scenario, water from the Recycle Pond could not be discharged or otherwise conveyed to Jonathon Creek under any circumstances. In order to keep the existing two -pond system, you would have to demonstrate that it has adequate storage with the exception of very large events, i.e. greater than the 25-year, 24-hour storm or through sheet flow. If the Closed -Loop Recycle System were to be rescinded at some point in the future, and the facility were to continue operations and .end up with a stormwater discharge, a Stormwater Permit would again be needed and have to be applied for. Please inform us of which of these Scenarios you intend to follow. Please note that if you wish to continue wet -decking operations, only Scenario A and C apply. Mr. Carl B. Powell November 4, 2016 Page 3 of 3 B. Verification of Site Features & Submiffal of Updated Site Map (Not Required for Scenario B): 1. If the Closed -Loop Recycle Permit is to be renewed, the site map must be updated to show the present features of the site. The current map does not show the current operation/flow path of the wet deck wastewater. It does not show the residence immediately adjacent to the Stormwater Pond. Additionally, the recycle pond is able to receive stonnwater from the Stormwater Pond as makeup water. Wastewater is not to be conveyed from the recycle pond other than through wet -decking. Please submit an updated site map showing the present features of the site, the current operation/flow path of the wet deck wastewater, and the residence immediately adjacent to the Stormwater Pond.