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Home My WebLink AboutWQ0004270_Permit Inactive Status Request_20220614 Via E-Mail June 14, 2022 North Carolina Department of Environmental Quality Division of Water Resources 1617Mail Service Center Raleigh, NC27699-1617 Attn: Mr. Nathaniel Thornburg and Ms. Jenee Williamston Re:Permit Inactive StatusRequest A. B. Carter – Gastonia WWTP Wastewater Irrigation System 4801 York Highway Gastonia, Gaston County, NC Permit No. WQ0004270 H&H Job No. ABC-030 Dear Mr. Thornburg and Ms. Williamston: 1.0 Introduction On behalf of A. B. Carter, Inc(AB Carter), Hart & Hickman, PC (H&H) is submitting this letter report to request that Wastewater Irrigation System Permit No. WQ0004270 (Permit) be placed in an inactive statusfor the AB Carter wastewater irrigation system located at 4801 York Highway in Gastonia, Gaston County, North Carolina. The Permit inactive status request includes suspension of the operator-in-responsible charge (ORC) visitation requirement, sampling requirements (except as proposed in Section 3.0), Non-Discharge Monitoring Report (NDMR) requirement, and compliance report (GW-59) requirement. A Site Location Map is provided as Figure 1 and a Site Map showing the wastewater irrigation system layout is provided as Figure 2. The facility formerly operated a package wastewater treatment plant with aeration, clarifier, and chlorine tanks. The package plant formerly discharged to a 235,000-gallon effluent storage pond. The water level in the pond waspumped down as needed using a 120 gallon per minute (GPM) Mr. Thornburg and Ms. Williamston #C1269 -Engineering June 14, 2022 #245 -Geology Page 2 irrigation pump and sprayed on a 2-acre spray field. As part of the permitting process, groundwater monitoring wells (MW-19, MW-20, and MW-21) were installed to monitor groundwater for impacts associated with spraying activities. The package plant was installed in the early 1970s, connected to an effluent storage pond and spray field in the early 1980s, and was approaching the end of its useful life. Therefore, ABCarter decided to connecttheir sanitary wastewater to the Two Rivers Utilities sewer system and close the on-site treatment and disposal system. AClosure Plan dated June 15, 2021 was prepared in general accordance with the DEQ Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons memorandum (Guidelines) dated June 22, 2012. Ms. Maria Schutte of the Mooresville Regional Office (MRO) provided approval of the Closure Plan in a series of emails dated June 15, 2021 and June 16, 2021. Per the Closure Plan, H&H completed assessment activities of the effluent storage pond, including gauging the sludge thickness in the effluent storage pond to estimate the sludge volume and sampling the sludge to determine if the sludge can be left in place as part of the closure process. Although metals were detected in the sludge, the concentrations were determined to not be a leaching concern to groundwater. In addition, no fecal coliform was detected in the sludge. Furthermore, a land use restriction for the site property (Attachment A) for an unrelated matter is already on file with the Gaston County Register of Deeds that states the following: “The installation of groundwater wells or other devices for access to groundwater located at or under Area B for purposes of human consumption is prohibited without prior written approval by the Hazardous Waste Section or its successor in function.” Area B incorporates the area under the effluent storage pond and monitoring wells MW-19, MW- 20, and MW-21. Therefore, H&H concluded that, after connection of the sanitary sewer line to the Two Rivers Utilities municipal sewer system, the effluent storage pond can be dewatered to https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/AB Carter/Permit Request Letter/WQ0004270_DRAFTWaiver_Request.docx Mr. Thornburg and Ms. Williamston #C1269 -Engineering June 14, 2022 #245 -Geology Page 3 the sprayfield and converted to a non-wastewater pond.In a September 29, 2021 email, Ms. Schutte indicated that the residual pond sludge may be left in place and the system closed out. 2.0 Effluent Storage Pond Closure On November 24, 2021, the sanitary wastewater from the facility was connected to the Two Rivers sewer system. Under the existing Permit, the effluent storage pond was dewatered to the spray field and converted to a non-wastewater pond. A photograph of the dewatered pond taken May 23, 2022is provided in Attachment B. An email from Ms. Schutte on May 27, 2022 indicated that the pond was dewatered sufficiently and the remaining liquid is considered rainwater. The piping that leads to the package wastewater plant was capped during the connection to the Two Rivers sewer system, and the package plant, irrigation pump, and spray field equipment were decommissioned. The remaining sludge and water in the package plant (8,300 gallons) was pumped out by a vacuum truck for proper off-site disposal by Greenway Waste Solutions. An invoice documenting the disposal is included as Attachment C. Once decommissioned and pumped of its contents, holes were drilled through the base of the package plant tanks to allow stormwater to drain and the small tanks associated with the package plant were filled to the surface with gravel. Photos during and after the decommissioning of the package plant are provided as Attachment B. The pond and decommissioned package plant are surrounded by a chain-link fence to prevent unauthorized access. Based on the successful closure of the treatment system, AB Carter is requesting that the Permit be designated as in an inactive status. The Permit inactive status request includes suspension of the operator responsible charge (ORC) visitation requirement, sampling requirements (except as proposed in Section 3.0), Non-Discharge Monitoring Report (NDMR) requirement, and compliance report (GW-59) requirement. Nitrate has been detected in MW-19 at concentrations up to 13.7 mg/L and slightly above 15A NCAC 2L .0202 Groundwater Quality Standard (2L Standard) of 10 mg/L since August 2021. In a September 29, 2021 email, Ms. Schutte requested further assessment of nitrate concentrations in MW-19. Based on the presence of the groundwater land use restriction for the site, slightly https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/AB Carter/Permit Request Letter/WQ0004270_DRAFTWaiver_Request.docx Mr. Thornburg and Ms. Williamston#C1269 -Engineering June 14, 2022#245 -Geology Page 4 elevated nitrate concentrations do not pose an unacceptable risk for the site.However, AB Carter proposes toimplement routine sampling of MW-19 as proposed in the monitoring plan outlined in Section 3.0. 3.0Proposed Monitoring Program Following approval of designating thepermitas in an inactive status, AB Carterwill implement semi-annual monitoring of MW-19beginning in August 2022. Monitoring activities will include measurement of field parameters including depth to water, pH, specific conductivity, and dissolved oxygen and the collection of a groundwater sample for laboratory analysis ofnitrate by EPA Method 9056A. Monitoring activities will continue until nitrate concentrations reduce tobelow the 2L Standard.Groundwater monitoring email updates with be provided to DEQ following each sampling event and a Permit rescission requestwill be submitted once the nitrate concentrations reduce to below the 2L Standard. If you have any questions or require additional information, please do not hesitate to contact me at (919) 847-4241. Sincerely, Hart & Hickman, PC GregoryKanellis, PE Project Manager Attachments cc:Ms. Maria Shutte, DEQ Mr. Jeffrey Talbott, DEQ Mr. Steve Renfrow, AB Carter https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/AB Carter/Permit Request Letter/WQ0004270_DRAFTWaiver_Request.docx Figure 1 Site Location Map SITE USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global Ecosystems; U.S. Census Bureau TIGER/Line data; USFS Road Data; Natural Earth Data; U.S. Department of State Humanitarian Information Unit; and NOAA National Centers for Environmental Information, U.S. Coastal Relief Model. Data refreshed May, 2020. TITLE SITE LOCATION MAP 02,0004,000 N PROJECT SCALE IN FEET A. B. CARTER, INC 4801 YORK HIGHWAY GASTONIA, NORTH CAROLINA U.S.G.S. QUADRANGLE MAP 3921 Sunset Ridge Road, Suite 301 Raleigh, North Carolina 27607 919-847-4241 (p) 919-847-4261 (f) GASTONIA SOUTH, NORTH CAROLINA 2019 License # C-1269 / # C-245 Geology DATE: 4-15-21 REVISION NO: 0 QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) JOB NO: ABC-029FIGURE NO: 1 Figure 2 Site Map DOMESTIC EFFLUENTSTORAGE POND PROCESS WASTEWATERMONITORING POINT MW-20 MW-19 DOMESTIC WASTEWATERPACKAGE PLANT TREATMENT PLANT PROCESS WASTEWATER SPRAYFIELD MW-21 A. B. CARTER MANUFACTURING PLANT S:\\AAA-Master Projects\\AB Carter\\ABC-029 Sewer Connection and Closure Plan\\Figures\\ABC.029_20210415.dwg, fig 2, 6/4/2021 8:32:58 AM, shaynes Attachment A Notice of Contamination Final Plat and Declaration of Perpetual Land Use Restrictions Attachment B System Decommissioning Photographs Photograph 1: View of dewatered pond. Photo taken May 23, 2022. Photograph 2: View of dewatered package plant. Photo taken June 7, 2022. A.B. Carter 3921 Sunset Ridge Road Suite 301 030 - 4801 York Highway Raleigh, NC 27607 919.847.4241(p) 704.586.0373(f) Gastonia, NC ABC Photograph 3: View of dewatered package plant. Photo taken June 7, 2022. Photograph 4: View of package plant filled with stone. Photo taken June 13, 2022. A.B. Carter 3921 Sunset Ridge Road Suite 301 030 - 4801 York Highway Raleigh, NC 27607 919.847.4241(p) 704.586.0373(f) Gastonia, NC ABC Attachment C Sewage Disposal Documentation Greenway Waste Solutions 5600 Lakeview Road Charlotte, NC 28269 US +1 7047417867 info@greenwaywastesolutions.com INVOICE BILL TOSHIP TOINVOICE #12393 DATE 12/16/2021 AB Carter AB Carter DUE DATE 01/15/2022 PO Box 5184801 York Hwy TERMS Net 30 Gastonia, NC 28052Gastonia, NC 28052-6808 DATEACTIVITYDESCRIPTIONQTYRATEAMOUNT 12/16/2021 Sewer Pumping 8300 gallons8,3000.252,075.00 SUBTOTAL2,075.00 TAX0.00 TOTAL2,075.00 BALANCE DUE $2,075.00