HomeMy WebLinkAboutNC0085979_Renewal Application_20150609 yyyyd
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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
PAT MCCRORY ANTHONY J.TATA
GOVERNOR SECRETARY
June 9, 2015
Ms. Wren Thedford
NCDENR/DWR
NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617 RECEIVED/DENR/DWR
Re: NPDES Permit#NC0085979 ZUNI 16 2015
North Carolina Department of Transportation Water Quality
Transylvania County Permitting Section
Wren:
Please find enclosed the permit renewal application for NC0085979,NCDOT-Rosman
Maintenance Facility, in Brevard,Transylvania County. A site history has been included
detailing the system in use and reviewing most recent lab results. Currently,effluent is
sampled for chlorides monthly, acute toxicity every quarter,and organics by EPA
Methods 624/625 each quarter.
Please review the application at your earliest convenience. If you have questions,please
call me at(919) 835-8020.
Sincerely,
11
Ashley B Cox,J _ _
Environmental Engineer
Enclosure
Fleet and Material Management Unit,4809 Beryl Road,Raleigh,NC 27606
Phone 919-733-2220 Fax 919-733-1192
NPDES Permit#NC0085979
Permit Renewal
North Carolina Department of Transportation
Rosman Maintenance Facility
Transylvania County
Project Summary
In 1992, Mr. Paul Harris complained of salt in his residential supply well. His well is located
approximately 350 feet north of the former salt storage bin in the Maintenance facility. The
Division of Water Quality determined that his well contained chloride at concentrations
exceeding twice those allowed by the NCAC 2L Standards. The source of the chloride
contamination was later confirmed to be the old salt bin. A new salt storage dome was
constructed near the back of the DOT facility, procedures for improved handling of salt were
implemented and the old salt bin was no longer used to store salt.
From 1992 until June 1998, a series of monitor wells were installed and periodically sampled to
track the migration of the chloride plume. In general,the concentrations peaked in mid-1995
before beginning a slight decrease. Meanwhile the plume threatens other supply wells in the
neighborhood. In 1996, the Asheville Regional Office suggested that contaminated groundwater
could be discharged directly into the French Broad River without treatment.
In 1996, S&ME prepared and submitted a NPDES permit application for discharging
contaminated groundwater into the French Broad River. Permit#NC0085979, effective April 1,
1997, was issued for the discharge of up to 86,400 gallons per day of effluent.
In 1998, Aquaterra Engineering installed the recovery system, which began operation in June
1998. The system consisted of 3 recovery wells, a shed containing a control panel and flow
meters, and a 4-inch diameter discharge line that extends to the river along SR 1129. A fourth
recovery well was installed in an area of the plume with lower chlorides levels in efforts to
minimize chloride concentrations in the effluent in attempt to pass the acute toxicity
requirements of the permit. Since the installation of this well,there have been no problems
remaining in compliance with the permit.
In the seventeen years the system has been in operation, it's pumped over 17 million gallons of
chloride contaminated groundwater and discharged it into the French Broad River.
Alternatives for Surface Water Discharge
When the contamination problem was first discovered, the first option explored to meet the
requirements of Groundwater Section was to extend the city water supply lines from Rosman.
The City of Rosman and Transylvania County were trying to get Federal funds to extend the
water line to the area just east of the DOT known as Calvert. If the supply wells within 1,500
feet of the chloride plume were replaced by city water, DOT would not have to discharge
contaminated groundwater. After several years, Federal funds could not be attained and the plan
for expansion of city water was cancelled.
Another option was to install a pump and treatment system to remediate groundwater. Ideally, a
100%efficient system would remove all of the chloride, which would result in the discharge of
clean water and the production of solid salt that would be returned to our salt storage bin. Even
the most efficient systems (75 to 90%efficient) would still produce a concentrated solution that
would have to be disposed of. A system like this would cost$100,000 to $200,000, but the
disposal cost of the 10 to 25%concentrate makes the project unfeasible. Without having an
ocean to discharge into or an industry such as a pickle factory nearby, disposal costs could run
into the millions of dollars per year. There are larger treatment systems(de-salinization plants)
that are 100% efficient used for municipal water supplies. However,these systems cost in the
millions of dollars.
Subsurface discharge was another option that is used in fuel remediation projects. However, a
treatment system that produces a concentrated solution would be needed and the same problem
of disposal costs must be considered. It would be difficult/expensive to have a treatment system
that would remove enough chloride to return the water to naturally occurring conditions.
The next option was install a groundwater recovery system and haul all of the discharge to the
nearest acceptable location. Again,the distance to the nearest disposal point makes this
impractical.
The Asheville Regional Office suggested the answer to the problem. The ARO asked the DOT
to consider discharging water directly into the French Broad River, which is a little over 1 mile
away from the DOT facility. Since there is a significant drop in elevation from the DOT facility
to the river, effluent would flow by gravity to the river without the use of expensive pumping
stations. A DOT contractor designed and installed the system for about$106,000.
Summary of Analytical Results
In accordance with the existing permit,the DOT has been sampling the effluent every month. In
January, April, July and October,the sample is analyzed for chlorides,total dissolved solids,
volatile organics by Method 624, semi volatile organics by Method 625, and acute toxicity. For
the months in between,the sample is analyzed for chlorides only. The samples have been being
collected by James& James Environmental and analyzed by Pace Analytical in Asheville and
reported to the Division of Water Quality.
In the past year, all acute toxicity tests have passed and there have been no organic compounds
observed by methods 624 or 625 during the quarterly sampling. The highest concentration for
chlorides was observed on August 28, 2014, with a concentration of 737ppm.
Sludge Management
The recovery system does not generate any sludge. There are no sediment traps, oil water
separators or holding tanks to accumulate solids. Turbidity tests have been conducted in the
pasts with levels being minimal at most(turbidity testing is no longer required per email
conversations between Eric Motzno and Jim McKay on Thursday November 10, 2011). The
chlorides being recovered are in solution and not exposed to any evaporative or filtering process.
NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number(NC0085979
If you are completing this form in computer use the TAB key or the up -down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise,please print or type.
1. Contact Information:
Owner Name NCDOT- Fleet and Material Management Unit (Equipment Unit)
Facility Name NCDOT- Rosman Maintenance Facility
Mailing Address 4809 Beryl Road
City Raleigh
State / Zip Code NC / 27606 RECEIVED/DENRIDWR
Telephone Number (919)733-2220 IN 1 A 2(l t ri
Fax Number (919)733-1192
Water Quality
e-mail Address abcox@ncdot.gov Permitting Sectior
2. Location of facility producing discharge:
Check here if same as above ❑
Street Address or State Road 100 Old Calvert Landfill Road
City Brevard
State / Zip Code NC / 28716
County Transylvania
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name NCDOT- Rosman Maintenance
Mailing Address 100 Old Calvert Landfill Road
City Brevard
State / Zip Code NC / 28716
Telephone Number (828)862-4736
Fax Number (828)862-8621
4. Ownership Status:
Federal 0 State ® Private ❑ Public 0
Page 1 of 3 C-GW 03105
NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ❑ Other Chlorides
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous ® Intermittent 0
If intermittent:
Days per week discharge occurs: Duration:
8. Treatment System Design flow 0.0288 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude
French Broad River
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No Additives are used
11. Is this facility located on Indian country? (check one)
Yes ❑ No ED
12. Additional Information
All applicants (including renewals):
• A USGS topographical map (or copy of the relevant portion) which shows all outfalls
• A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
• Engineering Alternative Analysis
• Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
• If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
• A list of any chemicals found in detectable amounts at the site,with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
• For petroleum-contaminated sites-Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
• For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3 C-GW 03/05
NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Ashley 13. Cox, Jr, LG Environmental Engineer
Printed name of Person Signing Title
3.4 vois—
ature of Applicant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than$25,000 or imprisonment not more than 5 years,or both,
for a similar offense.)
Page 3 of 3 C-GW 03/05
Permit NC0085979
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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
June 16,2015
Ashley B. Cox,Jr.LG
NCDOT-Rosman Maintenance Facility
4809 Beryl Road
Raleigh,NC 27606
Subject: Acknowledgement of Permit Renewal
Permit NC0085979
Transylvania County
Dear Permittee:
The NPDES Unit received your permit renewal application on June 16, 2015. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to
complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Sonia
Gregory at(919)807-6333.
Sincerely,
W re w Te.e0 -Qrot
Wren Thedford
Wastewater Branch
cc: Central Files
Asheville Regional Office
NPDES Unit
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Location:512 N.Salisbury St.Raleigh,North Carolina 27604
Phone:919-807-63001 Fax:919-807-6492/Customer Service:1-877-623-6748
Internet::www.ncwater.orp
An Equal Opportunity1Aifirmafive Action Employer