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HomeMy WebLinkAboutNC0090182_Draft Fact Sheet_20230627NCDENR / DWR / NPDES EXPEDITED FACT SHEET - NEW NPDES PERMIT NPDES Permit NCO090182 Joe R. Corporon P.G., Compliance & Expedited Permitting Unit 16Jun2023 Table 1 - Facility Information Applicant / Facility: Daniel Realty Company, LLC / Graham & 6th Street Applicant Contacts: Andrew Irish, Senior Development Mgr. [airish@danielcorp.com]; Cannon Conner, VP; Consultant Joseph P. Nestor, P.G., P.E., Unestor@ecslimited.com] Environmental Principal, ECS Southeast Limited LLP Pauline Burdette, Enviro MGR burdette ecslimited.com Facility Address: 301 North Graham & 420 West 6' Street, Charlotte Flow: Permitted @ 0.075 MGD [proposed treatment as continuous @ 0.050 MGD] Type of Waste: 100% Industrial - Remediated Groundwater 1) Excavation and, 2) Permanent Structure Dewatering WET Testing Acute 48-hr, Monthly [TAA6C] - monitor only Facility Class: Physical/Chemical PCNC County. Mecklenburg Permit Status: New Regional Office: MRO Stream Characteristics Receiving Stream UT to Irwin Creek Stream Classification C Stream Segment 11-137-1 Drainage basin Catawba Summer 7Q10 (cfs) 0 Subbasin 03-08-34 Winter 7Q10 (cfs) 0 Use Support Impaired for fish consumption; water -column mercury, copper 30Q2 (cfs) 0 303(d) Listed Average Flow (cfs) 0 State Grid G15NE IWC (%) 100% USGS Topo Quad Charlotte East, NC FACILITY SUMMARY - Daniel Realty Company, LLC (the Applicant) proposes to treat groundwater exposed by excavations below the groundwater table. The dewatering treatment system will support both excavations and permanent long-term dewatering for permanent subterranean structures. The treatment system proposes to polish the effluent via granular activated carbon (GAC) filters. Unless modified, the system consists of: • one (1) 18,000-gallon frac tank [w/ injector for CO2 gas to adjust pH, as needed. The CO2 gas system to be removed for permanent (long-term) dewatering unless needed] • one (1) 1,000-gallon surging tank [w/ recirculating pump, as needed <14,000 GPD] • two (2) each particle filters [in series] • two (2) each 1000-pound activated carbon vessels [in series] • sample ports, as needed, to establish filter contaminant breakthrough • appurtenant piping, instrumentation, and valving • totalizing flow meter discharge line to stormsewer inlet RECEIVING STREAM - Outfall 001 will discharge to a stormsewer inlet adjacent to the site on the SW corner of Graham Street and flow north to surface waters as an unnamed tributary (UT) to Irwin Creek. Treated effluent shall discharge via Outfall 001 under zero flow receiving stream conditions [7Q10 and 30Q2 = 0.0 cfs], i.e., this effluent receives no dilution credit from the receiving stream, consistent with similar discharges statewide. Current stream impact conditions indicate "Fair, Poor or Severe Bioclassification in its Fish Community and Benthos [DEQ 303d list for 2022]. Fact Sheet June 2023 — New NPDES Permit NC0090182 Page 1 SUMMARY OF GROUNDWATER SAMPLES - ANALYTICAL RESULTS Table 2: Application list of contaminants detected, and therefore "thought to be present." * SVOCs by EPA VOCs. by ERA Method 8260 Method 8270 Sxnple ID Sample Date fl ry m o G s a o o a o C G +� NC2LGWQ5 1 10 LI.S" 10 6 600 500 Various Residential Groundwater VI5L L6 1,400 4.6 3,800 77 Various Non -Residential Groundwater VI5L 6.9 3.6 5,900 20 16,000 320 Various GW-1 08/16/21 <1.0 1.5 <1.0 <1.0 <LO <1.0 BRL GW-2 08/16/21 <1.0 1.4 <1.0 <1.0 <1.0 <1.0 BRL GW-3 08/16/21 <1.0 4.2 <1.0 <1.0 <1.0 <1.0 BRL GW-4 08/16/21 <1.0 4.4 <1.0 <1.0 <1.0 <1.0 BRL GW-5 08/16/21 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 BRL GW-6 08/16/21 <1.0 2.7 c1.0 <1.0 <1.0 <1.0 BRL GW-7 08/16/21 <1.0 3.5 <1.0 <1.0 <1.0 <1.0 BRL GW-8 08/16/21 3.0 <1.0 2.7 <1.0 <1.0 <1.0 BRL GW-9 08/16/21 6.9 3.9 {1.0 1.4 1.2 3.1 BRL GW-10 08/17/21 <L- <1.0 <1.0 <1.0 <1.0 <1.0 BRL GW-11 08/17/21 • 1..: 1.4 <1.0 I <1.0 <1.0 1 1.0 BRL * DWR notes that BTEX [likely gasoline fuel related] and Naphthalene [likely diesel fuel related] dominate as contaminants of concern (COCs). Except for chloroform, no other chlorinated solvents have been detected to date. ENGINEERING ALTERNATIVES ANALYSIS (EAA) The Applicant documents their requests for discharge alternatives from local agencies [City of Charlotte WWTP and Charlotte Water and Sewer Authority], but these agencies have yet to respond, and did not respond with the allotted 15-day period. The Applicant will provide these correspondences as they are received. As required of all new discharges, the Applicant presented an Engineering Alternatives Analysis (EAA) as Ground surface/subsurface applications including: • spray/drip irrigation, • infiltration galleries • wastewater reuse • injection wells After considering the above, the Applicant judged these discharge alternatives "not feasible" because conditions and suitable land are not available. In consequence, they did not evaluate present value costs analysis [PVCA]. The EAA further evaluated surface -waters for potentially impacted species [none known to present] and identifying impaired waters downstream in Irwin Creek [see Receiving Stream]. They conclude the proposed effluent would make no impact. Fact Sheet June 2023 - New NPDES Permit NC0090182 Page 2 ESTABLISHING LIMITS AND MONITORING Whole Effluent Toxicity (WET) Testing -- This facility proposes to apply granular activated carbon (GAC) filters as a final effluent treatment. Based on similar treatment systems statewide, DWR considers that GAC-polished effluent may likely render the discharge devoid of necessary nutrients (too clean) to support aquatic test species, and therefore may likely fail [see A. (1.)]. DWR has therefore applied WET testing as Acute 48-hr, Monthly [TAA6C], Monitor and Report only. RPA — Reasonable Potential Analyses (RPAs) were not conducted because to date, there is no treated effluent database. The permit reflects site -assessment data only, as provided on the Application for Discharge. Establishing Contaminants of Concern (COCs) - COCs are based on analytes "known to be present" [See EPA Application form 2D] and other potential contaminants. Considering that current chemical evaluation of local groundwater is limited in scope, DWR has included VOCs and Semi-VOCs [EPA Methods 624.1 and 625.1 as a spot check for contaminants influent to the treatment system that remain unestablished [see Permit Section A. (1.) and Special Condition A. (4)]. Rationale: • If an analyte is known to be present and has an established surface water quality standard or criteria, DWR has applied this standard or criteria as the permit limit [whichever is more stringent], both as acute and chronic limits [see section A. (L)]. • DWR recommends Monthly monitoring for these organic and inorganic analytes considering a continuous flow (see permit Section A. (L)]. • DWR finds no analyses for metals in the current site -assessment database. Therefore, Total Lead monitoring will be required as may be related to vehicle fuel. • Metals in dissolved fraction require effluent monitoring for Total Hardness to established compliance with EPA guidelines. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Public Notice (estimated): Issuance (estimated): Effective Date (estimated): NPDES DIVISION CONTACT June 28, 2023 August 4, 2023 September 1, 2023 If you have questions regarding any of the above or the attached permit, please contact Joe R. Corporon, P.G., email preferred Uoe.corporon@deq.nc.gov]. NAME: DATE: 16JuN2023 Fact Sheet June 2023 — New NPDES Permit NCO090182 Page 3 9.0 EPA METALS EVALUATION - for TOTAL HARDNESS NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as approved. Table 3. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection Parameter Acute FW, µg/l (Dissolved) Chronic FW, µg/l (Dissolved) Acute SW, µg/l (Dissolved) Chronic SW, µg/l (Dissolved) Arsenic 340 150 69 36 Beryllium 65 6.5 --- --- Cadmium Calculation Calculation 40 8.8 Chromium III Calculation Calculation --- --- Chromium VI 16 11 1100 50 Copper Calculation Calculation 4.8 3.1 Lead Calculation Calculation 210 8.1 Nickel Calculation Calculation 74 8.2 Silver Calculation 0.06 1.9 0.1 Zinc Calculation Calculation 90 81 Table 3 Notes: 1. FW= Freshwater, SW= Saltwater 2. CalculatiaA = Hardness dependent standard 3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative concerns (as are all human health standards for all metals). It is still necessary to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at 10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life protection). Table 3. Dissolved Freshwater Standards for Hardness -Dependent Metals The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC 02B .0211 Subparagraph (11)(d) Metal NC Dissolved Standard, /l Cadmium, Acute WER*{1.136672-[ln hardness] (0.041838)} e^{0.9151 [In hardness] -3.14851 Cadmium, Acute Trout waters WER*{1.136672-[ln hardness] (0.041838)} e^{0.9151[ln hardness]-3.6236} Cadmium, Chronic WER*{1.101672-[ln hardness] (0.04183 8)1 e^{0.7998[ln hardness]-4.44511 Chromium I1I, Acute WER*0.316 e^{0.8190[1n hardness]+3.7256) Chromium I1I, Chronic WER*0.860 e^{0.8190[1n hardness]+0.6848} Copper, Acute WER*0.960 e^{0.9422[1n hardness]-1.7001 Fact Sheet June 2023 - New NPDES Permit NCO090182 Page 4 Copper, Chronic WER*0.960 • e'{0.8545[ln hardness]-1.7021 Lead, Acute WER*{1.46203-[ln hardness](0.145712)1 • e^{1.273[ln hardness]-1.4601 Lead, Chronic WER*{1.46203-[ln hardness](0.145712)} • eAll .273[In hardness]-4.7051 Nickel, Acute WER*0.998 eA f O.8460[ln hardness]+2.255} Nickel, Chronic WER*0.997 eA10.8460[ln hardness]+0.0584} Silver, Acute WER*0.85 • eAll .72[ln hardness]-6.591 Silver, Chronic Not applicable Zinc, Acute WER*0.978 e^{0.8473[ln hardness]+0.884} Zinc, Chronic WER*0.986 e^{0.8473[ln hardness]+0.884} General Information on the Reasonable Potential Analysis (RPA) The RPA process itself did not change as the result of the new metals standards. However, application of the dissolved and hardness -dependent standards requires additional consideration in order to establish the numeric standard for each metal of concern of each individual discharge. The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness and so must be calculated case -by -case for each discharge. Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The discharge -specific standards must be converted to the equivalent total values for use in the RPA calculations. We will generally rely on default translator values developed for each metal (more on that below), but it is also possible to consider case -specific translators developed in accordance with established methodology. RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and the critical low -flow values for the receiving stream. If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level), then the Division may remove the monitoring requirement in the reissued permit. 1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the following information: • Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfS) 0.993 • Effluent hardness and upstream hardness, site -specific data is preferred • Permitted flow • Receiving stream classification 2. In order to establish the numeric standard for each hardness -dependent metal of concern and for each individual discharge, the Permit Writer must first determine what effluent and instream (upstream) hardness values to use in the equations. Fact Sheet June 2023 — New NPDES Permit NCO090182 Page 5 The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any hardness data and contacts the Permittee to see if any additional data is available for instream hardness values, upstream of the discharge. If no hardness data is available, the permit writer may choose to do an initial evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively. If the use of a default hardness value results in a hardness -dependent metal showing reasonable potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and upstream hardness samples over a period of one week. The RPA is rerun using the new data. The overall hardness value used in the water quality calculations is calculated as follows: Combined Hardness (chronic) _ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L)xs7Q10, cfs *Avg. Upstream Hardness, mg/L) (Permitted Flow, cfs + s7Q 10, cfs) The Combined Hardness for acute is the same but the calculation uses the IQ 10 flow. 3. The permit writer converts the numeric standard for each metal of concern to a total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have been developed using federally approved methodology. EPA default partition coefficients or the "Fraction Dissolved" converts the value for dissolved metal at laboratory conditions to total recoverable metal at in -stream ambient conditions. This factor is calculated using the linear partition coefficients found in The Metals Translator: Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation: cdiss_ - 1 Ctotal 1 + { [Kpo] [SS(1+a)] [10-6] } Where: ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used, and Kpo and a = constants that express the equilibrium relationship between dissolved and adsorbed forms of metals. A list of constants used for each hardness - dependent metal can also be found in the RPA program under a sheet labeled DPCs. 4. The numeric standard for each metal of concern is divided by the default partition coefficient (or site -specific translator) to obtain a Total Recoverable Metal at ambient conditions. In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method Fact Sheet June 2023 — New NPDES Permit NC0090182 Page 6 presumes that the metal is dissolved to the same extent as it was during EPA's criteria development for metals. For more information on conversion factors see the June, 1996 EPA Translator Guidance Document. 5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration (permit limits) for each pollutant using the following equation: Ca = (s7010 + Qw) (Cwgs) — (s7010) (Cb) Qw Where: Ca = allowable effluent concentration (µg/L or mg/L) Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L) Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L) Qw = permitted effluent flow (cfs, match s7Q10) s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human health through the consumption of water, fish, and shellfish from noncarcinogens (cfs) * Discussions are on -going with EPA on how best to address background concentrations Flows other than s7Q 10 may be incorporated as applicable: IQ 10 = used in the equation to protect aquatic life from acute toxicity QA = used in the equation to protect human health through the consumption of water, fish, and shellfish from carcinogens 30Q2 = used in the equation to protect aesthetic quality 6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern. Data entered must have been taken within four and one-half years prior to the date of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper concentration of each pollutant. The Predicted Max concentrations are compared to the Total allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable potential to violate the water quality standard, and a permit limit (Total allowable concentration) is included in the permit in accordance with the U.S. EPA Technical Support Document for Water Quality -Based Toxics Control published in 1991. 7. When appropriate, permit writers develop facility specific compliance schedules in accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. 8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be compared against water quality standards for chromium III and chromium VI. 9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of the permit limits and to build a more robust hardness dataset. Fact Sheet June 2023 — New NPDES Permit NCO090182 Page 7 10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included: Table 4 Parameter Value Comments (Data Source) Average Effluent Hardness (mg/L) [Total as, CaCO3 or (Ca + Mg)] TBD Average Upstream Hardness (mg/L) [Total as, CaCO3 or (Ca + Mg)] TBD 7Q 10 summer 0.0 cfs Discharge to storm sewer 1Q10 0.0 cfs " Permitted Flow (MGD) 0.075 Outfall 001 (per permit) Fact Sheet June 2023 — New NPDES Permit NC0090182 Page 8