NC0024911_2023 Annual Compliance Report for NPDES Ammonia Schedule_20231211

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Metropolitan Sewerage District
OF BUNCOMBE COUNTY, NORTH CAROLINA
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EC 18 2023
December 11, 2023
NCDEQ/Water Quality
NPDES Complex Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Sir/Madam:
1ality Regional Opera!
ille Regional Office
NCDEQ/Water Quality
Asheville Regional Office
2090 US 70 Highway
Swannanoa, NC 28778-8211
Metropolitan Sewerage District (MSD) of Buncombe County was issued a NPDES discharge permit
(#NC0024911), effective October 1, 2018. Section A (8) of the NPDES Permit requires submission of an
annual. report stating optimization/construction progress for compliance with the NPDES ammonia
schedule. This letter provides a status update of the HRPT project and identifies ways in which MSD will
incorporate operational strategies, optimization procedures and sampling protocols to attain the future
ammonia limits as stipulated by NCDEQ.
Shook Construction was the General Contractor for the new HRPT Project. The HRPT
Project Notice to Proceed was issued December 5, 2018, and construction began January 7,
2019. The HRPT original substantial completion date was October 28, 2020. The project has
experienced significant delays. attributable to all the following: inclement weather days,
delays due to the fire on November 10, 2020, and associated lead times of replacement
equipment, COVID-19 pandemic, labor and supply chain shortages issues, and contractor
efficiency and workmanship. As a result, the revised contractual substantial completion
date was February 2022 (HRPT process online) with final completion expected in December
2022.
Introduction of wastewater into the HRPT began Thursday, December 09, 2021. The
optimization of HRPT treatment train #2 was completed Friday, December 10, 2021. Grab
samples were collected from HRPT influent and HRPT clarifier effluent. The optimization of
HRPT treatment train #1 began Monday, December 13, 2021, with grab samples collected
the same as HRPT train #2. All samples were delivered to Pace Laboratories for analysis.
The acceptance testing for HRPT train #2 began the week of January 3rd, 2022. During
acceptance testing 24-hour composite samples were collected and delivered to Pace
Laboratories for analysis. From November 8th-18th another round of testing was performed
by the vendor. As of this date an acceptable test run, within the parameters of the pilot
study, has not been achieved. We experienced unsustainable levels of sand loss and
chemical usage. In March 2023 Veolia brought back their Pilot Trailer to attempt to re-
create the results achieved in the original pilot project. This allows them to test different
parameters without disruption to plant operations.
Protecting Our Natural Resources-
2028 RIVERSIDE DRIVE, ASHEVILLE, NORTH CAROLINA 28804 TELEPHONE: [phone] FAX: [phone] WEBSITE: www.msdbc.org

MSD will begin HRPT performance testing at conclusion of acceptable results of the HRPT
acceptance testing. Influent and effluent HRPT samples will be collected as outlined in the
NPDES ammonia schedule. Data will be compiled and analyzed to achieve maximum
efficiency of the overall wastewater treatment process.
MSD will continue NPDES influent and effluent compliance sampling as per the Permit and
will incorporate additional sampling in the ammonia schedule in preparation of future
reports. A new sampling point will be established beginning as soon as feasible at the
effluent of the HRPT process located north of the headworks removal systems, prior to
entering Rotating Biological Contractor (RBC) Basin number one (1).
MSD will continue to report annually as the construction project advances and is
completed, and sampling results are collected and summarized. The overall HRPT
optimization will be achieved through operational strategies, sampling analysis and
evaluation.
On 10/28/2022 MSD issued a Request for Qualifications (RFQ) for the purpose of studying
the current solids handling and disposal practices, and recommendations for the future. On
01/06/2023 MSD issued a RFQ for the purpose of determining a new treatment process to
replace the RBCs currently in use. Both studies will consider the new ammonia limits as
well as other future potential parameter limits.
The COVID 19 pandemic has continued to have long lasting impacts on the world and has
disrupted many of the normal operations of life. Unfortunately, this has occurred during
the course of the HRPT construction project. Due to the pandemic, MSD is experiencing
supply chain disruptions, workforce shortages and economic impacts like many utilities
across the nation. MSD remains committed to meeting the established ammonia
compliance limits and will continue to comply with the reporting schedule as outlined in
the NPDES Permit. However, MSD is making notice of a general force majeure for all
projects regarding operation, maintenance and pre -established deadlines in all issued State
and Federal Permits. Due to the pandemic and the effects listed above, MSD is struggling to
deliver existing projects on time and may experience similar impacts on projects in the
coming months and years. The impacts on current and future projects are unforeseen and
immeasurable, and no prediction can be made for how projects will be impacted in the
coming years. On 6/10/2022 MSD submitted an application for NPDES permit renewal. In
this application, we have requested an extension to the 10/01/2030 deadline for ammonia
compliance due to the factors listed above.
If there are questions or concerns regarding this report, please do not hesitate to contact Bart Farmer,
Water Reclamation Facility ORC, at [e-mail] or 828-225-8224.
Sincerely,
Thomas E. Hartye, PE
General Manager
MSD of Buncombe County
Protecting Our Natural Resources-
2028 RIVERSIDE DRIVE, ASHEVILLE, NORTH CAROLINA 28804 TELEPHONE: [phone] FAX: [phone] WEBSITE: www.msdbc.org