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HomeMy WebLinkAboutNC0083551_Permit Issuance_20120503r w� Sri NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Governor Director May 3, 2012 Mr. Matthew Hypes, P.E. Onslow Water & Sewer Authority P. O. Box 1.415 Jacksonville, NC 28540 Subject: Issuance of NPDES Permit NCO083551 Onslow Water & Sewer Authority -- Dixon WTP Onslow County Dear Mr. Hypes: Dee Freeman Secretary Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). The Division has reviewed the comments regarding the draft, provided on your behalf by Ms. Erica V.T. Carter, P.E. of Kimley-Horn and Associates, Inc. The following responses are offered to those comments: • The North Carolina Administrative Code does not allow NPDES permits to be issued for a period lasting longer than five years. Therefore, the permit cannot be made effective any earlier than July 1, 2012 and remain in a unified, basinwide permitting schedule. With a July 1, 2012 effective date, the facility will maintain seamless permit coverage between the existing permit (which expires at midnight on June 30, 2012) and this permit. • The Division cannot restrict its authority to reopen NPDES permits to be based only upon the results of effluent testing. Should other sources of monitoring indicate the facility is yielding a detrimental impact on the receiving stream, the Division reserves its right to modify the permit based upon those findings, in order that conditions may be mitigated and resolved. • The permit is being reissued with the test organism for Whole Effluent Toxicity testing remaining as mysidopsis hahia (Mysid Shrimp). Discussions regarding any potential change in the test organism for toxicity testing should be initiated with our Aquatic Toxicology Unit. Questions may be addressed to Ms. Carol Hollenkamp at (919) 743-8950, or via e-mail at carol.hollenkamp@ncdenr.gov. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One Location: 512 N. Salisbury St Raleigh, North Carolina 27604 NO Carolina Phone: 919-807-63001 FAX: 919-807-6492 f� Internet www.ncwaterquality.org t�'tlilrq`ll� J An Equal Opportunity 1 Affirmative Action Employer Mr. Matthew Hypes, P.E. ONWASA - Dixon WTP Permit Renewal 2012 p. 2 Therefore, this final permit includes no significant changes from the draft permit sent to ONWASA on March 14, 2012. Although this final permit does not differ in its terms from those in the draft, it contains a number of terms that differ from those found in the .existing permit. Those changes include: • The monitoring requirement for flow measurement has been changed from weekly, instantaneous sampling to continuous, recording measurement. This requirement will not become applicable until January 1, 2014 (eighteen months after the effective date of the permit), in order to allow you time to budget for, plan and install a suitable flow measurement device. • Monitoring of the effluent for Total Arsenic and Turbidity have been added to the permit. • Monitoring for Total Residual Chlorine and Ammonia Nitrogen have been removed from the permit because they are not introduced into the facility's wastewater flow. • Monitoring frequencies for Copper, Lead, Fluoride, Total Nitrogen and Total Phosphorous have been reduced from monthly to quarterly. • The footnote regarding a choice in the selection of a Whole Effluent Toxicity test organism has been removed. Within the permit, the designated test organism is Mysidopsis Bahia (mysid shrimp). • Because the facility has experienced whole effluent toxicity testing failures during the current permit cycle, a condition has been added that will allow the Division to reopen the permit to add limits for whole effluent toxicity or to direct the facility to undertake actions that will both determine the causes and eliminate the potential for aquatic toxicity as a result of the discharge. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that Stones Creek is listed as an impaired waterbody on the North Carolina 303(d) Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream data will continue to be evaluated. If there is noncompliance with permitted effluent limits' and stream impairment can be attributed to your facility, then mitigative measures may be required. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. Mr. Matthew Hypes, P.E. ONWASA - Dixon WTP Permit Renewal 2012 p. 3 If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919) 807-6398, or via e-mail at bob.sledge@ncdenr.gov. S' , Cherarles Wakild, P.E. cc: Central Files Wilmington Regional Office/Surface Water Protection Section NPDES File Aquatic Toxicology Unit DWR—Public Water Supply Section Permit NCO083551 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Onslow Water and Sewer Authority is hereby authorized to discharge wastewater from a facility located at the Dixon WTP 6661 Wilmington Highway (US Highway 17) South of Dixon Onslow County to receiving waters designated as an unnamed tributary to Stones Creek in the White Oak River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, H, III and IV hereof. This permit shall become effective July 1, 2012. This permit and authorization to discharge shall expire at midnight on June 30, 2017. Signed this day May 3, 2012. les Wakild, P.E., Director ivision of Water Quality By Authority of the Environmental Management Commission Permit NC0083551 '* 7 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Onslow Water and Sewer Authority is hereby authorized to: 1. Continue to discharge green sand filter and ion exchange backwash from a water treatment facility, with three settling basins for wastewater treatment. The facility is located at the Dixon WTP, 6661 US Highway 17, south of Dixon, in Onslow County. 2. After construction of new water treatment facilities, discharge reverse osmosis reject wastewater through the existing wastewater treatment apparatus and outfall; I. Discharge from said treatment works at the location specified on the attached map into an unnamed tributary to Stones Creek, classified SA-HQW, PNA waters in the White Oak River Basin. Permit NCO083551 x / v " \ 1 ` 1 OT6dt Sandy Run Pocosin � t7 T i %Disch y, -- i y r1;)i ABM � \ tj /1 ONWASA— Dixon WTP Facility Location -' Latitude: 34035U7" Stream Class: SA-HQW, PNA Longitude:77'27'46" Subbasin:030502 Quad# 129SW NPDES Permit NCO0835551 Receiving Stream: UT to Stones Creek Permit N00083551 7 PeK A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: f ._; �� `��T _.. , ; � f S 11 SY # +� n `S ..S';� EFLUtVTCH►l rS -S f t5 ^y. 9 "^f l j{7 =L� ._I S . � - T = i E, ' t7 s � f ,.� M �J�T��RIGEQC�iFfENI'S { ��SE . 1: 3 ...... ;f, ':i,j-.�.,`L f ': L f9 Gaa i 5�" F-. 4: x i« .k t €. T ;..""3kd�. `a,#•-`,� - +x 1'4 •jL, S' ...£.. L..>:G "•['°.�•{ Y, iv'3.� ,°..:F' «;'�'� �,p t 2v Sew..:. i .i: if'': 'Y `r s„.S;- f' i7 $�p5 F t Q�i �.t =t P.{. nn/� QQ {c. iY^ i { �{ G�f7 r .. �P :` i, _ t : r<, �:#'- 2•'iE4 a..qv.. „f st- .� a.,..,MMq,1�.�.�` =on#litAlte�a�e D;� �yciu n -•l.{ i -` r. ' Sa�mPle Tlpe a p e ocahon . ._ b uerr x F n Flow (50050) Weekly Instantaneous Effluent Flow (50050) Continuous2 Recording Effluent Temperature (00010) Monthly Grab Effluent, Upstream,and Downstream Salinity (00480) Monthly Grab Effluent, Upstream, and Downstream Conductivity (00094) Monthly Grab Effluent, Upstream, and Downstream pH' (00400) 2/Month Grab Effluent, Upstream, and Downstream Dissolved Oxygen (00300) Monthly Grab Effluent, Upstream, and Downstream Total Dissolved Solids 70295 Monthly Grab Effluent Total Suspended Solids 00530 10.0 m L 15.0 m /L 2/Month Grab Effluent Turbidity 00070 Monthly Grab Effluent Total Arsenic 01002 Monthly Grab Effluent Total Copper 01042 Quarterly Composite Effluent Total Chloride 00940 Monthly Composite Effluent Total Iron 01045 Monthly Composite Effluent Total Manganese 01055 Monthly Composite Effluent Total Lead 01051 Quarterly Composite Effluent Total Zinc 01092 Monthly Composite Effluent -Fluoride 00951 Quarterly Composite Effluent Total Nitrogen 00600 Quarterly Composite Effluent Total Phosphorus 00665 Quarterly Composite Effluent Whole Effluent Toxicity Monitoring4 Quarterly Composite Effluent GE3E Footnotes: 1. Upstream = at least 100 feet upstream from the outfall; Downstream = at least 100 feet downstream from the outfall. 2. Continuous, recording monitoring requirement will become effective January 1, 2014 (18 months following the effective date of the permit). 3. The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units. 4. Acute Toxicity 24-hour Pass/Fail Monitoring using Mysidopsis bahia (Mysid Shrimp) as the test organism. Testing to be performed in January, April, July, and October. (see A. (2.) below). All samples collected should be from a representative discharge event. There shall be no discharge of floating solids or visible foam in other than trace amounts. 14j ,1� U �( Permit NCO083551 A. (2.) ACUTE TOXICITY PASS/FAIL MONITORING (QUARTERLY) The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised-July,1992 or subsequent versions). The monitoring shall be performed as a Mysidopsis bahia 24-hour static test. The effluent concentration defined as treatment two in the procedure document will be 90%. Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The tests will be . performed during the months of January, April, July and October. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE3E. Additionally, DWQ Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, N.C. 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a valid test is submitted. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified above. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0083551 '- A. (3.) PERMIT RE -OPENER: WHOLE EFFLUENT TOXICITY MONITORING Whole Effluent Toxicity monitoring results indicating aquatic toxicity failure may result in the Division of Water Quality re -opening this permit to add a limit for Whole Effluent Toxicity, or requesting by letter that further action be taken to address toxicity failures. Mitigative actions include additional testing and/or toxicity identification/reduction evaluations to determine the cause(s) of the effluent toxicity and measures required to achieve passing effluent toxicity results. FACT SHEET FOR EXPEDITED PERMIT RENEWALS This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Basic Information for Expedited Permit Renewals Permit Writer/Date Bob Sledge 5/3/2012 Permit Number NCO083551 Facility Name Dixon WTP Basin Name/Sub-basin number White Oak 030502 Receiving Stream UT to Stones Creek Stream Classification in Permit SA-H W-PNA Does permit need Daily Max NH3 limits? No Does permit need TRC limits/language? No. TRC monitoring removed — Cl added after wastewater flow established Does permit have toxicity testing? Yes Does permit have Special Conditions? Toxicity Reo ener Added Does permit have instream monitoring? Yes Is the stream impaired on 303 d list)? Yes: Loss of Use — Shellfish harvesting prohibited Any obvious compliance concerns? Toxicity has been an issue. Expected to improve with new treatment system added. Any permit mods since lastpermit? No Current expiration date June 30, 2012 New expiration date June 30, 2017 Comments received on Draft Permit? Comment from DMF re PNA Comment from permittee addressed in cover letter The Dixon WTP NPDES permit is being reissued with modifications to the terms of the existing permit. The primary reason for changes to its terms is the introduction of a new, reverse osmosis water treatment system at the facility. The move to RO has been necessitated by (primarily aesthetic) issues associated with drinking water rules. Once constructed, upgraded WTP will use the RO system as the primary producer of potable water. However, its green sand filter and ion exchange systems will remain in operation, albeit at a reduced capacity. Water generated from those systems will be blended with that from the RO system to produce a final product with adequate taste characteristics for consumers. Pilot studies done on an RO product from the source water (wells) indicate concentrations of pollutants in the wastewater will decrease when the new system comes online and use of the ion exchange system is reduced. The addition of the new system only required the additional monitoring of two parameters (Turbidity and Arsenic) per application of the reverse osmosis provisions of the WTP permitting strategy. The facility will be required to add a flow measurement device that will account for all volumes of wastewater that are discharged. This condition will not become effective until January 1, 2014. Other changes from the terms of the existing permit: • Monitoring for Total Residual Chlorine and Ammonia Nitrogen were removed from the permit because they are not introduced into the facility's wastewater flow. The facility does not use chloramines for disinfection. The facility uses filtered, non -chlorinated water to backwash. a • Monitoring frequencies for Copper, Lead, Fluoride, Total Nitrogen and Total Phosphorous were reduced from monthly to quarterly. An RPA was initiated regarding the discharge. However, very few of the metals the facility has collected data for actually have water quality standards associated with them. Data for copper was all reported as less than the detection level, therefore the monitoring frequency was reduced (even though RPA calculations would show potential to cause the 3 µg/L action level to be exceeded). Zinc data also show potential for the action level to be exceeded in the stream, but most recent data are much improved. The monthly monitoring requirement was retained. • The footnote regarding a choice in the selection of a Whole Effluent Toxicity test organism was removed. Based upon the facility's historical preference, the designated test organism is the mysid shrimp. • Because the facility has experienced whole effluent toxicity testing failures during the current permit cycle, a condition was added that will allow the Division to reopen the permit to add limits for whole effluent toxicity or to direct the facility to undertake actions that will both determine the causes and eliminate the potential for aquatic toxicity as a result of the discharge. Upstream and downstream data were reviewed. Downstream conductivity and salinity consistently appear higher than upstream values. It's inconclusive whether this has been due to the discharge or if stream conditions change as one moves closer to Stones Bay in the New River. Stones Creek has been designated as a prohibited area for shellfish harvesting, and therefore is 303d listed. The actual reason for the designation is based upon surveys conducted by the Shellfish Sanitation Section of DMF, which has found their bacteriological standards to be exceeded in the stream for many years. Their staff had very little concern regarding the discharge from this water treatment plant and its potential to impact shellfish habitat. The permittee provided comments regarding the draft, requesting: The effective date be changed; The text within the toxicity condition be changed, and The toxicity test organism be changed. Each of these requests were denied. Explanations were given to the consulting engineer on the phone and are repeated in the cover letter. The engineer had no problem with the DWQ response. The Division of Marine Fisheries provided one comment, noting the discharge was to Primary Nursery Area waters. Follow up was made with DMF. They had no specific concerns regarding the permit; they just wanted to be sure that conditions associated with PNA (HQW) waters were applied in permit development (they were; there is little legitimate application of the standards for WTP discharges). Sledge, Bob From: Jenkins, Shannon Sent: Thursday, May 03, 2012 10: 00 AM To: Sledge,' Bob Subject: Stone's Creek Bob, It appears that Stone's Creek first closed to shellfish harvest on 9/17/74. It.appears that it was due to high bacteriological sampling results, likely related to a sewer discharge in Stone's Creek from _Dixon High School and Elementary. It has remained closed since -that time. Shannon Jenkins NCDENR-DMF-Shellfish Sanitation and Recreational Water Quality Section 3441 Arendell St. Morehead City, NC 28557 Phone: 252-726-6827 shannon.ienkins@ncdenr.eov Email correspondence to and from this address is subject to the North Carolina Public Records law and may be disclosed to third parties unless the content is exempt by statute or other regulation. PROHIBITED TERRITORY NEW RIVER AREA Area C-3 (Map 40) Designated A-1 Identifier Shellfish Harvesting Boundary Areas • + Prohibited Boundary Areas ® Area L i Locator Map N /' NA ---�`f/r- NC Statete Plane 0 05 1 Miles (Prohibited areas are hatched) COUNTY: ONSLOW '� Rhodes Point � 1 L > �, •� / ,\� I,t_r-> ><��', Grey 't � r ` S Point . } // Garfish Hickory Pt Stones Creek :.Point HfAES �E'- �1 J Point � Z i , 1 Pollocks' V /� 1� Paint/ ' �[a / Ferry Jarretts Paint Point Creels' h Point «}s' r J� Everett Creek ?A PovertyPt Fulchet anding G Map 40 (SEE BACK OF MAP FOR AREA DESCRIPTIONS.) NEW RIVER AREA PROHIBITED AREA ONSLOW COUNTY Area C-3 (Map 40) (Prohibited Areas are Hatched) (a) Everett Creek - All those waters of Everett Creek and it's tributaries upstream of a straight line beginning at a point 340 34.2522' N -770 24.8557' W on the west shore; running easterly to a point 340 34.2359' N -770 24.6818' W on the east shore. (b) Stones Creek - All those waters of Stones Creek, Muddy Creek and other tributaries upstream of a straight line beginning at a point 340 36.8738' N -770 26.5163' W on the north shore; running southerly to a point 340 36.5330' N -770 26.6570 ' W on the south shore near Stones Landing. (c) New R_ - All those waters of New River upstream of a straight line beginning at a point 340 38.8205' N -770 22.6757' W on the west shore; running northeasterly near Channel Marker #42 to a point 340 40.1177' N-771 21.4913'W on the east shore. (d) Frenchs Creek / Duck Creek- All those waters bounded by a line beginning at a point 340 39.2161' N -770 20.8991' W on the shore north of Frenchs Creek; running southwesterly to a point 340 39.0036' N -770 21.1486' W; running southerly to a point 340 37.7822' N -770 20.8079' W on the shore south of Duck Creek. (e) Mill Creek - All those waters in Mill Creek upstream of a straight line across the mouth beginning at a point 34 37.2371' N -77 25.7025' W on the west shore; running easterly to a point 34 37.2383' N -77 25.6860' W on the east shore. NC 2010 Integrated Report Categories 4 and 5 Impaired Waters All113,123 Waters in NC are in Category 5303(d) List for Mercury due to statewide fish consumption advice for several fish species AU —Number AU Name AU_Description LengthArea AU Units Classification C neeory Parameter kcasm for Raving Ux (;vcgun Collection Year 3,031dbear White Oak River Basin New River Watershed 0302030202 Q 19-(11) New River From Atlantic Coast Line Railroad Trestle to 574.3 S Acres SC;HQW,NS Mumford Point W 4b Chlorophylls Standard Violation Aquatic Life 2008 2008 5 Copper Standard Violation Aquatic Life 2008 2008 5 Enterrococcus Standard Violation Recreation 2008 2008 5 High pH Standard Violation Aquatic Life 2008 2008 Q. 19-(27)b New River 5 Shellfish Growing Area -Prohibited Q 19-16-(3.5)a Northeast Creek 4b Chlorophyll a Q 19-16-(3.5)b Northeast Creek 46 Chlorophylla From Everett Bay to DEH closure line. Loss of Use Shellfish Harvesting From N. C. Hwy.24 to a line crossing Northeast Creek downstream of NC 24. Standard Violation Aquatic Life From a line crossing Northeast Creek 1.8 miles downstream of NC 24 to downstream side of mouth of Scales Creek Standard Violation Aquatic Life 2.8 S Acres SA;HQW 2006 2002 400.3 SAcres SC;HQW,NS W 2008 280.0 SAcres SC;HQW,NS W 2008 2002 QQ 19-17-(6.5) Southwest Creek From Mill Run to New River 594.7 S Acres C;HQW,NSW 4b Chlorophyll Standard Violation Aquatic Life 2008 QQ 19-3Oa2 Stones Bay Entire Bay except for the area enclosed by 23.9 S Acres SA;HQW the DEH closure at the mouth of Stones Creek. '.. 5 Shellfish Growing Area -Prohibited Loss of Use Shellfish Harvesting 2006 2008 '.. (D 19-30b Stones Bay From Stones Creek to DEH closure line. 32.6 S Acres SA;HQW 5 Shellfish Growing Area -Prohibited Loss of Use Shellfish Harvesting 2006 2002 Q 19-30-3 Stones Creek From source to Stones Bay 76.9 S Acres SA;HQW 5 Shellfish Growing Area -Prohibited Loss of Use Shellfish Harvesting 2006 2002 White Oak River Basin New River Inlet Watershed 0302030203 Q 19-39-3a Alligator Bay Bay south of ICW W 260.2 S Acres SA;ORW 5 Shellfish Growing Area -Conditionally Appr Loss of Use Shellfish Harvesting 2008 2002 Q. 19-39-3b1 Alligator Bay Remainder of bay north of ICW W 22.1 S Acres SA;ORW 5 Shellfish Growing Area -Conditionally Appr Loss ofUse Shellfish Harvesting 2008 2002 Q 19-39-3b2 Alligator Bay DEH closure area at mouth of Mill Creek. 8.4 S Acres SA;ORW 5 Shellfish Growing Area -Prohibited Loss of Use Shellfish Harvesting 2006 2002 NC 2010 integrated Report Category 4 and 5 303(d) List EPA Approved Aug 31, 201 9/20/2010 Page 123 of 145 ❑�� NmleyHorn and Associates, Inc. April 26, 2012 Mr. Robert Sledge Environmental Specialist NCDENR DWQ 1601 Mail Service Center Raleigh, NC 27699-1601 Re: NPDES Response Comments ONWASA Dear Bob: ■ 501 Independence Parkway Suite 300 Chesapeake, Va. 23320 On behalf of the Onslow Water and Sewer Authority (ONWASA), Kimley-Horn and Associates, Inc. is pleased to offer the following comments on the NPDES Permit Renewal for the Dixon Water Treatment Plant. 1. Request that the permit be effective no later than June 30, 2012. /✓r 2. Under A.(2.) add the red text to the tad to last paragraph to "Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality on the data required on this permit on A.(1.) indicate potential impact to the receiving . I stream, this permit may be re -opened and modified to include alternate monitoring e requirements or limits." 3. We would like to discuss the potential change under A. (1.) Footnote 4 to read "Menidia beryllina (Silverside Minnow)' as the test organism (rather than Mysidopsis bahia (Mysid Shrimp)). Ida Please feel free to contact me should you have any questions or comments at 919-247-7297 (cell) or edca.carter@kimley-horn.com, and thank you for your continued partnership on this project. Very Truly Yours, e�K,;7L0 Erica V.T. Carter, P.E. Vice President Kimley-Hom and Associates, Inc. cc: Matthew Hypes, PE, ONWASA Karen Fergason, ONWASA Karen Wallace, ONWASA Sledge, Bob From: Hardy, Jeanne Sent: Wednesday, April 04, 2012 3:23 PM To: Sledge, Bob Subject: Comments on NPDES permit Attachments: Jeanne J Hardy.vcf Dixon WTP, Permit No. NCO083551: This facility discharges into PNA. If you have any questions, please contact Jessi Baker at jessi.bakera-ncdenr.gov or at 252-808-8064. Regards, ]eanne'. Hardy Administrafte.:Asst. NC.UMS[on 'of Marine Fisheries Habitai;' Protedon Section 52M Hwy.:70 `lest Morehead City. NC 28557 (254 86"066 Work (2,�2j,727 5127;fax 3eanne:hardycderu,gov Email correspondence to and from this address is subject to the North Carolina Public Records Low and may be disclosed to third parties unless the content is exempt by statute or other regulation. 1 ONSLOW COUNTY NORTH CAROLINA AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of County and Stale of said publisher, duly commissioned, qualified and authorized by law to administer oaths, personally appeared who being first duly sworn, deposes and says: that he (she) is Jimmy Williams, Editor (Owner, partner or other officer or employee authorized to make this affidavit) of THE CARTERET PUBLISHING CO., INC., Carteret County, N.C., engaged in the publication of a nc paper known as Tideland News, published, issued, and entered as second class mail in the Town of Swansb in said County and State; that he (she) is authorized to make this affidavit and sworn statement; that the nc or other legal advertisement, a true copy of which is attached hereto, was published in Tideland News on following dates: 3/21/12 and that the said newspa LEGAL NOTICES PUBLIC NOTICE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COM ISSIONINPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 NOTICE OF INTENT TO I ISSUE A NPDES WASTEWCSER PERMIT in which such notice, paper, document, or legal advertisement was published was, at the time of each and eV The North Carolina Envi- ronmental Management Com- ublication, a newspaper meetin all of the requirements and qualifications of Section 1-597 of the Gen mission proposes to Issue e such p$' q q fNPDES wastewater discharge permit to the person(s) listed Statues of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the Geni below Statues of North Carolina. This the 18th day of April 2012. Vv vV Signature of person making affic Sworn to and subscribed before me, this 18th day of April My commission expires August 24, 2014 2012. Notary Publi Written comments regard- ing the proposed permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Divi- sion of Water Quality (DWQ) may hold a public hearing should there be a significant degree of public interest. Please mall comments and/or information requests to DWO at the above address. Interest- ed persons may visit the DWQ at 512 N. Salisbury Street, Ra- leigh, NC to review information on file- Additional information on NPDES permits and this notice may be found on our w e b s I t e http://portal.ncdenr.orgAveb/w q/swp/ps/npdes/calandar, or by calling (919)807-6304. Beacham Associates, Ltd. has requested renewal of per- mit NCO028223 for Beacham Apartments #1 WWTP; On - slow County. This permitted facility discharges 0.04 MGD treated wastewater to an un- named tributary to Brinson Creek; White Oak River Basin. Onslow Water and Sewer Authority requested renewal of permit NCO083551 for the Dix- on WTP in Onslow County; this permitted discharge is treated WTP process waste- water to an unnamed tributary to Stones Creek In the White Oak River Basin. M21 ONWASA Dixon WTP REASONABLE POTENTIAL ANALYSIS Outfall 001 AC0083551 Qw = 0.29•MGD Qw (MGD) = 0.29 WWTP/WTP Class: PC-1 1 Q I OS (cfs) = Tidal, IWC =100% IWC @ 1 Q l OS = 100.00% 7QIOS (cfs) = Tidal, IWC =100% IWC @ 7QIOS = 100.00% 7QIOW (cfs) = Tidal, IWC =100% IWC @ 7Q10W = 100.00% -30Q2 (cfs) = Tidal, IWC =100% IWC @ 30Q2 = 100.00% Avg. Stream Flow, QA (cfs) = Tidal, IWC =100% IWC @ QA = 100.00% Receiving Stream: UT to Stones Creek Stream Class: SA, HQW, PNA YOU HAVE DESIGNATED THIS RECEIVING STREAM AS HOW OR ORW. CHRONIC TEST CONCENTRATION = DEFAULT % =90% PARAMETER STANDARDS S CRITERIA (2) N REASONABLE POTENTIAL RESULTS TYPE (1) -� a � NC WQS / Applied �/2 FAV / Cl # Det. Max Pred Allowable Cw Chronic Standard Acute Cw Acute: NO WQS Arsenic C 5 HH(Qavg) ug/L 0 0 N/A --- _ _ — --- — Chronic: 5.0 - - -- - - --- Acute: 21.0 Cadmium NC 2.5 SW(7Q10s) 21 ug/L 0 0 N/A __ _—_—__ _ — _—_—_—_—_—_ —_—_—_ — _ Chronic: 2.5 ----- -- Acute: NO WQS Total Phenolic Compounds NC 150 A(7Q10s) 10.0 ug/L 0 0 N/A -------------------------- Acute: NO WQS Chromium NC 10 SW(30Q2) ug/L 0 0 N/A - -- ---_ _—_ -----:—_ Chronic: 10 --- - - Acute: 5.8 "A d AL(Cu,Zn,Ag: Ql) .apply Quarterly Copper (AL) NC 1.5 SW(7Q l Os) 5.8 ug/L 37 0 6.8 _ _ _ _ — _ — _ _ _ _ — Montoringin conjunction' with TOX Test Chronic: 1.5 36 value(s) > Allowable Cw Acute: 0.5 Cyanide NC 0.5 SW(7Q10s) 0.5 10.0 ug/L 0 0 N/A _ _ - — - _ _—_ — — _—_—___ ----- — — --- Chronic: 0.5 Acute: 110.5 Lead NC 12.5 SW(7Q1Os) 110.5 ug/L 37 0 7.00 —_—__ __— _ _ _ _—. ...... Chronic: 12.5 No value > Allowable Cw Acute: NO WQS Mercury NC 12.5 SW)7Q1Os) 0.5 ng/L 0 0 N/A------13 Acute: NO WQS Molybdenum NC 1.0 HH(7Q I Os) mg/L 0 0 N/A ------------------------------- Acute: 37.5 Nickel NC 4.15 SW(7QlOs) 37.5 ug/L 0 0 N/A __— _— - — -__—_—_—___ —_— ----- Chronic: 4.2 Dixon WTP 2011 RPA-Saitwater,rpa• Page 1 of 2 5/3/2012 ONWASA Dixon WTP REASONABLE POTENTIAL ANALYSIS Outfall 001 MCMA12-A-Al Ow = 0.29.MGD Acute: NO WQS Selenium NC 35.5 SW(7Q1Os) ug/L 0 0 N/A __— ----------- --------------- +, _—_—__ Chronic 35.5 Acute: 0.950 Silver (AL) NC 0.05 SW(7Q1Os) 0.95 ug/L 0 0 N/A _ _ __ __ ___—_—_—__ Chronic: 0.050 Acute: 48 TtP1s for.AL(Cu;Z0 jg Fe Cl) - remin monthly' Zinc (AL) NC 43 S W(7Q 1 Os) 48 ug/L 37 18 422.50 _ _ _ _ — _ — _ _ _ _ — moriitonn_g Chronic: 43 3 value(s) > Allowable Cw Acute: NO WQS Manganese 37 37 4.0 —_—_—_—_— _-------------------------- No value > Allowable Cw Acute: NO WQS Iron 37 37 413.82 -------------------------- Chronic:--------- No value > Allowable Cw Acute: NO WQS Fluoride 0 0 N/A ------------------------------------- Chronic: Acute: 0 0 N/A — — — ---- -- ------- _ _ _ Chronic --------- — Acute: 0 0 N/A ---------- - ----------------------- - Chronic- Acute: 0 0 N/A — ------ ------------ _ _ Chronic---------- Acute: 0 0 N/A --------- --- --- - - _ _ Chronic: --- Acute: 0 0 N/A — — — — _ Chronic:--------- - ----.----------- Acute: 0 0 N/A -- --------------------- Chronic---------- — Dixon WTP 2011 RPA-Seltwater,rpa Page 2 of 2 5/3/2012 Whole Effluent Toxicity Testing Self -Monitoring Summary February 15, 2012 FACILfIY RBQUDtII.¢Nf YEAR JAN FEB, MAR APR MAY JUN AM AUG SEP OCF NOV DEC Daniel Stave Rarealcal GardN Chu Monin 90% Cmi]dPF NO - - Fill - - H - - H - - H NCO088684/001 BeiurMQN$ Fmqucnry:Q Marlun Sep Dec NonComp: =9 - - Fel - - Fel - - PoI - - Fa County: Coupon Region: MO Subbases: C037 2010 -- - FeA - - Fal - - FeA - - Fel PF: 0.0038 Slrcul N11 _ - F.Nam - - Fall - - Far - - Fal 1QI0'. 0 MC(%) IN am: 012 Bare County-A1D3(go)W 241rfJfac.&W.mysid Myad24PF Nie Pan - - Pose - - Pau - - Pow - - NC001015T/N2 Begin 2 InM Freglmry: Q lm Apr Jul Oct NonComp: NN Pox - - Fell - - Far - - Paw - - Couny Due Region: WARD Subbann: PAS56 Not Peu - - Pere - - per - - paw - - PF:1.42 Slwul Nil Pow - - Poas - -- FN - - Full - - 1QIO:Total MC(V.)NA Colo: 2012 Depiction Water Ins. WfP Cbr Monig 90p. Cm7eF NO - - - - - - - - - - - NCN84425=1 Begin IVIZZM Frequenry:Q Feb Mey Aug Nov Noranti: NN - - - - - - - - - - - - Cooper. Davidson Region: WSRO Subbaan: YADUC 2310 - Pau - - Invalid - - Fen - - Fell - PF:0.3 .,W nil _ Fen - - Fee - - Fat - - Fell - 9QI0: MCC%) adm: M12 Dwmn Inclinational Pmp-Albermarle vhrli.W. Ceri]dPF 2N6 Pou - - pats - - pas. - - Pare - - NC0(emm7/NI Begin Wl/NDI Frequency:Q Jon Apr Jul Oct + NNCamp:Sm le Not H X H H Fe1 04.81 31.82 70.37 94.87 Pau - - Cnmry. Sourly Region: MRO Subb®n: YADOB "In Fell ]Bag >1N one - H Pow - - Fel -IN -IN PF: D.03 BISYI N11 H - - Pep - - New - - FY >IN -IN 7QI0: 0.0 IWC(%)IN Dnb: M12 Drer Clue SOIHA.ian WW'1'P chr lion: Wit,@ 0.05 or 0.11 or 0.22 MOD C.67RF NO Pon - - Imsld Fan >10 PInw-l00 -- - pass - - NCN63T461NI Begin 6/1RN8 Frequenry:Q IN Apr Jul Oct + Non6inp:Single Not Pose - - Pa.c - - pew - - Pee. - - Comy Wake Region: PRO Subbuin: NEU02 NIO Pau - - Furl 58.1 -IN Per. - - pew - - PIP: 005 spz61 nit pep - - Pecs - - Pau - - From - - 1QI0:00 IWC(%)IN tadw: N12 Mlm AOpertl dolien 12% CUTdaV 2008 - - Me - - 15.6 - - 15.6 - - 15A NCON6190/NI Begin 7/IR009 Frequonry:Q Mu lion SW Du + NonComp:Single Nor - - 16.5 - - 15.6 - - 15.5 - - 16.07 Count'(2mwba Region. MRO Subbuin=35 N1O - - 10.97 - - 10.97 - - 15,97 - - 10.07 PF: Ll Spots 2011 _ - m.91 - - 18,97 - - 1697 - - 16.97 1QI0: 12 MC(%) I I order: 2012 Server du llm:9W. Cn74PF 2N8 - Paw - - Fen >1001P1 >Rm(Pl Pere - - peas - NCN266B9/N1 Repr IO/InN4 Frequnry:Q Feb May Aug Nov + NonComp:Single NN - Pan - - Fei 94.9 -IN ".t(p).Pne - - Pase - COonyDevldwn Region: WSRO Subbuin: YADOS N10 - Pow - - Pou - - Pose - - Fa -IN PF: 0.8 S,cr.l 2011 >100 Pau - - Pou - - Pore - - vase - 9QIO:0.0 IWC(aA)100 (Xdm: 2012 Denver GWR Chrunt W% No T. NO - - - - - - - - - - - - NCN89NI/001 Begin 41VNI1 Fngtmnry:Q Men lion Sep Dec NonComp: NO - - - - - - - - - - -- - County: Cue"a Region: MO Subbuin:=32 2010 - - - - - - - - - - - - PF: 0.0115 swc61 2011 _ _ _ _ _ _ - - - - - H 7010: IWC(%) G4c: N12 Devils WondYard WTP a, Merit: 90% flhd24PF- NCN86N1N1 Begin Vi R011 Frequency:Q 1. Apr Jul Oct NonComp:- CoNy Wr,ym Region: WARO Subbuin: Cl N10 - - - - - - - - - - - - PP e,w61 Nil _ _ _ - - - - - - H - - TQIO: IWC(V.) C,m. N12 H Dial. Yarn., I.e. v1trlint 911% CedTOPF Nm H - - H - - H - - H - - NCNB3963/0I Be®n1/1R004 Frequenry:Q Jon Apr Jul Oct + NonComp:Single =9 H - - H - - H -- - H - - COonySunly Region: NRO Subbuin: YAD12 2010 H - - - - - - - - H - - PF:0On apx Nil H - - H - - H - - H - - 7QI0:0 MC(%) IN anger: M12 Diva WTP-Onelow Weclr&sewer Aum AcP/FMNi1:W4Myed.Fghd,or RIvenide. Myrd24PF 200e Paw - - Pew - - Pan - - Pep - - NCN83551/NI Begin9/IYdN9 lemcmory:Q Jan Apr Jul Oct NonComp: 2009 Fill - - peas - - Fe1 - - Pou - - Couny Owl" Regius: WIRO Subbuin: WOK% Will Fal - - Fri - - Fe1 - - Pou - - PF: S,. imul Nil Fel - - Feel - - Fell - - one - - 'JQIO: MCC%) Crd^: W12 LEGEND: PERM=Pemul Requremont LEf-Admirdmadve Levu-Targm Frnpume,e Monitoring frequmry: Q-Quenedy; M. Monthly; BM- Bimmlthly; SA-Seommully; A- Annually;CIM,y whrn discharging,D- Discontinued monitoring mqubcmmt Begi=Firnmonlhtequired TQIO-Receiving aaeam tow now ailerion(c@) Monthsthutminemgm oncur-a Ian, Apr, jw.(kt NonComp- Cumin Compliance Requirement PF-Pomdned ROW(MGD) IWC%=Iuneamwame Nncentmion P/F=PareNail test AC=Acute CULL=Chmic DrumNotation f-FattAha Kl w,,>.Ccdodaphtdasp.;my-My6dshdmp;ChV-Chronicvale;P-Monalityofmmedp nlagealhighest Nnmmmtim;at-Porfomedby DWQAquOc Toe Unit;bt-Badtest grooving Notation--- Date not required; NR-Not reposed Facility Activity Stalu: I - lnacnvq N-Newly Issue I(To construct); 11 - Active but not discharging; t-Mom dam ovallable for month in quntion;=ORCsignaturencNed 17 Yetnber Governments Holly Rulge Jacksonville North Topsail Beach Onslow County Richlands Swmuhow 28-Nov-2011 NCDENR/DWQ NPDES Unit 1617 Mail Service Center Raleigh NC 27699-1617 0 NwAS Onslow Water &Sewer Authority In Re: Renewal and Modification of NPDES Permit NCO083551 Dixon Water Treatment Plant Onslow County Eneineering Division James K (Rod) Butler. P.F. F.ngineering Director rburler@mwasa.com Herewith, please find our NPDES Permit renewal package for our Dixon WTP, as above identified. 910,937.7521 Tel 910,455.5607 Fax ONWASA has been attempting to move forward with its permitting and installation of reverse osmosis (RO) treatment at the Dixon plant. The purpose for the is removal of trace organics, to assist in our compliance with the Stage 2 Disinfection By -Product Rules, and silica, an aesthetic nuisance. We have been informed that NCDENR/DWR/Public Water Supply Section will not permit the RO project until such time as our NPDES Permit allows the inclusion of the RO Reject Water as part of our discharge under the NPDES Permit. We have been further advised by DWQ that due to the concurrent timeline of Permit Renewal and Permit Modification that the two should be combined within our Permit Renewal application package, which is what is exhibited in the enclosure. The enclosure includes an abundance of analytical data on the reject water from a pilot RO system we have been operating during the last 6-months, predictive models indicating what the quantity and quality to be anticipated in the combined waste streams subsequent to the installation of the Ro system, toxicant data, supporting our application. Please give me a call or e-mail if you have any questions regarding the enclosed. Sincerely, 1 mes R. Butler, PE Engineering Director 228 Georgetown Road • P.O. Box 1415 • Jacksonville. NC 28540 • Tel 910.455.0722 • Fax 910.455.2587 • www.onwasa.com NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants 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 CC 0083561 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 Onslow Water & Sewer Authority Facility Name Dixon Water Treatment Plant Mailing Address 228 Georgetown Rd City Jacksonville State / Zip Code NC/ 28540 Telephone Number (910)455-0722 Fax Number (910)455-0115 e-mail Address rbutler@onwasa.com 2. Location of facility producing discharge: Check here if same as above ❑ Street Address or State Road 6661 Wilmington Hwy City Holly Ridge State / Zip Code NC/ 28445 County Onslow 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 Onslow Water & Sewer Authority Mailing Address 228 Georgetown Rd City Jacksonville no State / Zip Code NC/28540 D Telephone Number (910)455-0722 NOV 28 2011 Fax Number (910)455-0115 ►,�,��oa ,.,,, 4. Ownership Status: Federal ❑ State ❑ Private ❑ Public Z 5. Type of treatment plant: Page 1 of 3 C-WTP 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants ® Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by filtration and disinfection) ® Ion Exchange (Sodium Cycle Cationic ion exchange) ® Green Sand Filter (No sodium recharge) ® Membrane Technology (RO, nanofiltration) Check here if the treatment process also uses a water softener 6. Description of source water(s) (i.e. groundwater, surface water) Groundwater 7. Describe the treatment process(es) for the raw water: Aeration -Potassium Permanganate -Contact Basin-Greensand Filtration for Iron & Managanese-Ion Exchange for Calcium & Magnesium, Reverse Osmosis for trace organics and silica removal -Chlorine Disenfection-Orthophosphate-Fluoridation 8. Describe the wastewater and the treatment process(es) for wastewater generated by the facility: Process waste from greensnad filters & Ion exchange softeners and reject from Reverse Osmosis filtration. Discharged to a series of sedimentation lagoons, supernate discharge to receiving stream. 9. Number of separate discharge points: 1 Outfall Identification number(s) 001 10. Frequency of discharge: Continuous ❑ Intermittent If intermittent: Days per week discharge occurs: 7 Duration: 12hrs 11. Plant design potable flowrate 4.0 MGD Backwash or reject flow 1..0 MGD 12. Name of receiving stream(s) (Provide a map shouting the exact location of each outfall, including latitude and longitude): UT to Stones Creek 13. Please list all water treatment additives, including cleaning chemicals or disinfection treatments, that have the potential to be discharged. Page 2 of 3 C-WTP 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - WTP For discharges associated with water treatment plants Potassium Permanganate Hypochlorite Hydroflourosilic acid Household Cleaners Descaling Agent 14. Is this facility located on Indian country? (check one) Yes ❑ No 15. Additional Information: > Provide a schematic of flow through the facility, include flow volumes at all points in the treatment process, and point of addition of chemicals. Solids Handling Plan 16. NEW Applicants Information needed in addition to items 1-15: > New applicants must contact a permit coordinator with the NCDENR Customer Service Center. Was the Customer Service Center contacted? ❑ Yes ❑ No > Analyses of source water collected > Engineering Alternative Analysis > Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a water quality model. 17. 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. James R. Butler PE Engineering Director Printed name of)'�rson Signing Title Signature z3 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-WTP 03/05 Dixon Water Treatment Plant Receiving Stream 6661 Wilmington Hwy Holly Ridge, NC 28445 NPDES# NCO083551 915,000 Gallons 915,000 Gallons 915,000 Gallons Primary Secondary 1 Tertiary Estimated 3 Estimateld 3 Days Detention 1 Estimated 3 Days Detention Time Days Detention Time Time Influent Pipe No Chemical Addition Max influent flow 1340gpm per greensand filter backwash. Effluent vault has 2 - 350gpm pumps. 2 Alternate influent points. Pump Vault Plant Waste Flow Residual Management Plan Dixon Water Treatment Plant Effective February, 2006 A pump and haul method of removing solids from the three (3) lagoons at Dixon will be utilized. Solids will be dewatered to pass the paint test and transported by truck to the Onslow County Landfill. The lagoons will be pumped every three (3) years so as not to allow solids accumulation to interfere with detention time. Member Govts. Onslow County Holly Ridge Jacksonville North Topsail Beach Richlands Swansboro OSAS Onslow Water & Sewer Authority Email: kwallaced5onwasa.com Website: www.onwasa.com Office of the Water Production Superintendent Karen Wallace ONWASA would like to formally request the Division of Water Quality reconsider including the following parameters when issuing renewal NPDES Permit NCO083551, Dixon Water Treatment Plant. Copper, Lead, Zinc, Ammonia Nitrogen, Total Phosphorus, Total Nitrogen. The attached document supports data indicating these parameters are routinely testing at or less than the level of detection for that method. Process at this Physical/Chemical I plant has not changed to indicate by- products of biological treatment are present and source water treated at the plant is absent of the metals currently being monitored in the waste product. The attached data includes the last 22 months of monitoring results but more can be provided upon DWQ's request. 228 Georgetown Road. • P.O. Box 1415 • Jacksonville, NC 28540 • Tel 910-455-0722 • Fax 910-347-0793 E Dixon WTP NC 0083551 Ammonia Total Total Copper Zinc Nitrogen Phosphorus Nitrogen mg/I Lead mg/I mg/I mg/I mg/I mg/I Jan-10 <0.010 <0.010 0.031 <0.2 <0.04 <0.5 Feb-10 <0.010 <0.010 0.017 <0.2 <0.04 <0.5 Mar-10 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Apr-10 <0.010 <0.010 0.018 <0.2 <0.04 <0.5 May-10 <0.010 <0.010 0.071 <0.2 <0.04 <0.5 Jun-10 <0.010 <0.010 0.012 <0.2 0.06 <0.5 Jul-10 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Aug-10 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Sep-10 <0.010 <0.010 <0.010 <0.2 <0.04 Oct-10 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Nov-10 <0.010 <0.010 <0.020 <0.2 0.08 <0.5 Dec-10 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Jan-11 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Feb-11 <0.010 <0.010 <0.010 0.4 0.07 <0.5 Mar-11 <0.010 <0.010 0.042 <0.2 <0.04 <0.5 Apr-11 <0.010 <0.010 0.013 <0.2 <0.04 0.5 May-11 <0.010 <0.010 0.015 <0.2 0.19 <0.5 Jun-11 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Jul-11 <0.010 <0.010 <0.010 <0.2 0.08 <0.5 Aug-11 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Sep-11 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 Oct-11 <0.010 <0.010 <0.010 <0.2 <0.04 <0.5 C=I1 Kimley-Hom and Associates, Inc. Memorandum To: Rod Butler Karen Wallace From: Erica V.T. Carter John Potts Subject:Dixon Water Treatment Plant Toxicity Date: November 23, 2011 Proiect Description: The Dixon Water Treatment Plant (WTP) discharges filter backwash wastewater to tidal waters; in this case, an un-named tributary to Stones Creek in the White Oak River basin. This un-named tributary to Stones Creek is considered SA-HQW waters for market shell fishing — saltwater and high quality water. The WTP has an NPDES permit (NC0083551 dated August 15, 2007) from NCDENR's Division of Water Quality (DWQ) to allow this discharge (see Appendix A). This permit requires quarterly testing of the discharge for acute toxicity. For approximately five years, this toxicity testing has always met regulatory monitoring requirements. Recently, this testing began to show a pattern of failures on an inconsistent but persistent basis. Currently, the permit requirement to conduct the toxicity testing is a monitoring requirement and not a compliance requirement. This means that under the current permit, this system does not fall out of compliance with the permit when toxicity requirements are not met. However, the permit is to be renewed in 2012, and ONWASA must be prepared for toxicity testing to become a compliance requirement of the renewed permit. This means that the cause of the failure to meet toxicity requirements must be discovered and resolved. ONWASA retained Kimley-Horn and Associates, Inc. (Kimley-Horn) to review available acute toxicity results at the Dixon WTP, review plant operations to determine if a change over time could be causing the acute toxicity failures, and to run additional testing of the plant discharge water. Kimley-Horn and Associates, Inc. ONWASA is currently in the pilot study, design, and permitting stages of the addition of reverse osmosis (RO) membrane treatment trains to upgrade the plant to meet 2012 Disinfection Byproduct requirements (e.g. total organic carbon (TOC) upper limit of 2 mg/L; current plant produces TOCs of approximately 10 mg/I), equip the plant to handle saltwater intrusion should that become more prevalent (ONWASA well 3 currently is showing increased total dissolved solids (TDS)), and remove high concentrations of reactive silica (currently approximately 50 mg/1) to a concentration that does not cause plating (approximately 15 mg/I). During permitting activities and from conversations with DWO staff, it was recommended that the RO pilot unit discharge, the concentrate, be tested for acute toxicity. The proposed total discharge to the un-named tributary to Stones Creek is 1 mgd. The current discharge is approximately 0.5 mgd. History The data over the past 5 years of acute toxicity testing from the Dixon WTP discharge was reviewed for trends and any changes in plant operations. The compilation of this data is included in Appendix B. Acute toxicity samples are collected by WTP staff and local Envirochem (a Wilmington -based environmental testing lab) staff. Envirochem staff ships the samples to ETS Laboratory in Asheville, NC where the samples are tested in accordance with Parameter Code TGE3E, North Carolina Methodology for Determining Acute Toxicity in a Single Effluent Concentration — Revision: September 1994. The species that ETS tests are the Mysidopsis Bahia. According to the NPDES permit, the permittee could test using the Fathead Minnow, Mysid Shrimp (Bahia), or Silverside Minnow as the test organism; however, ONWASA was required to use Mysid Shrimp (Bahia). Table 1 summarizes the test results over the past 4 years based on information provided by ETS. Rainfall data was also compiled during the past 4 years to determine if significant rain events led to passing results (i.e. a diluted discharge). The acute toxicity tests were only conducted for the Mysid Shrimp species. Dixon WTP Toxicity, November 23, 2011, Page 2 Ito• Kimley-Hom ti and Associates, Inc. Table 1. Dixon WTP Acute Toxicit Results and Rainfall Data Collection Date Pass/Fail Mean Mortality Month Before Sample Regional Rainfall Data 4/4/2011 Fail 40.0% 3.78 2.70 1/17/2011 Fail 55.0% 2.46 1.53 10/4/2010 Pass 0.0% 12.41 2.14 7/12/2010 Fail 100.0% 4.92 4.73 4/13/2010 Fail 97.5% 3.52 0.81 1/4/2010 Fail 52.5% 7.17 3.94 1015/2009 Pass 0.0% 4.32 2.24 7/6/2009 Fail 37.5% 3.68 5.14 4/6/2009 Pass 0.0% 4.16 2.33 1/5/2009 Fail 82.5% 3.11 2.20 10/6/2008 Pass 0.0% 7.44 2.23 4/7/2008 Pass 0.0% 3.56 4.83 IM2008 pass 0.0% 3.87 2.65 Based on Table 1, there is no correlation between regional rainfall data and passing results. In year 2008, every sample passed. In 2009, 50% of the samples passed; while in 2010 only 25% of the samples passed. In 2011, only 25% of the samples passed. Several site visits were conducted by Kimley-Horn staff in summer and fall 2011 to tour the plant facilities and interview WTP operators. Based on WTP operations, there is no known change in operations that would cause toxicity to routinely fail. It is notable that the most recent toxicity test dated October 4, 2011 did pass (see Appendix C). The test results are summarized below in Table 2. Table 2. October 4, 2012 Dixon WTP Acute Toxicity Survival Data Replicate 24-hour Survival # of living organisms) Control 90% A 10 10 B 10 10 C 10 10 D 10 10 Mean mortality 0.7 0.7 There was not a significant rainfall event prior to the testing or in the month prior to this test date. WTP operations are unchanged from the previous 3 year 2011 tests that failed. Dixon WTP Toxicity, November 23, 2011, Page 3 C=F J KimleyHorn I and Associates, Inc. Additional Testing Kimley-Horn staff initiated two acute toxicity tests to further investigate toxicity: 1. Independent laboratory analysis of current backwash water discharge 2. Independent laboratory analysis of the RO pilot unit concentrate discharge The current Dixon WTP backwash water was tested in September 2011 by an independent laboratory, Hydrosphere Research, based on samples collected by Kimley-Horn staff at the discharge testing location. Table 3 is the summary of the report for acute toxicity for two species: Mysid shrimp (Bahia) and the Silverside minnow. The full report is included in Appendix D. Table 3. Dixon WTP Effluent Acute Toxicity Results, September 2011 % of Effluent % Final Survival Mysid Shrimp Silverside Minnow Control 100 100 6.25 95 100 12.5 100 100 25 95 100 50 90 100 100 5 100 LC50 64.4 >100 The results indicate that the lowest concentration at which 50% of the species live (LC50) is 64.4% for the Mysid Shrimp and greater than 100% for the Silverside Minnow. Based on the results, the Dixon WTP backwash water discharge is toxic to the Mysid Shrimp but non -toxic to the Silverside Minnow. Since the discharge with the Dixon RO Improvements project is increasing by 100%, it was the request of NCDENR DWQ staff that the RO pilot unit concentrate discharge be tested to determine if the proposed WTP upgrades would help the acute toxicity. The RO pilot unit concentrate discharge was tested in October 2011, and the full report is included in Appendix E. A summary of the test results is included in Table 4. Dixon WTP Toxicity, November 23, 2011, Page 4 C_FJ KimleyHorn and Associates, Inc. Table 4. Dixon RO Pilot Unit Concentrate Acute Toxicitv Results % of Effluent % Final Survival Mysid Shrimp Silverside Minnow Control 100 100 6.25 100 100 12.5 100 100 25 100 100 50 100 100 100 100 100 LC50 >100 >100 The results indicate that greater than 100% of both the Mysid Shrimp and Silverside Minnow species live in a solution that is 100% of the RO concentrate discharge water. Since the RO concentrate discharge is not toxic to either the Mysid Shrimp or the Silverside Minnow, the Dixon WTP RO Improvements project not only improves the WTP's performance with TOCs, saltwater intrusion, and silica plating but also acute toxicity as it relates to the Mysid Shrimp and Silverside Minnow. Additionally, the RO Concentrate discharge was sampled for all NPDES elements with the addition of Arsenic, which was indicated by Linda Willis of DWQ would be an additional monitoring requirement when the plant add the RO treatment process. The results of these tests are included in Appendix F, and a summary is included below and in Table 5. The following elements are below detection limits: • Arsenic • Copper • Lead • Zinc • Nitrate+Nitrite-Nitrogen • Residual Chlorine • Chlorine Table 5. RO Concentrate Regulated Elements Element NPDES Permitted Limit Actual Total Suspended Solids 15.0 mg/L (Daily Max) 13.6 mg/L Residual Chlorine 13 /L Dail Max <10 /L not detectable Based on these results, the RO concentrate discharge meets current NPDES regulatory requirements and meets the additional Arsenic requirement. A mass balance was performed using an average of the data provided in Appendix B for the current Dixon WTP process and the data collected on the RO concentrate discharge to predict the water quality as it relates to the NPDES permit for the Dixon Dixon WTP Toxicity, November 23, 2011, Page 5 Kimley-Horn and Associates, Inc. WTP when the RO process is operational. A summary of the mass balance is provided in Table 6. Table 6. Predicted Future Dixon WTP Discharge Water Quality Data Parameter Current Avera a RO Concentrate Combined Flow, m d 0.5 0.5 1 Salinity, t 5.7 0.9 3.3 H 7.65 7.58 7.62 Total Dissolved Solids, m /L 7100 1280 4190 Total Suspended Solids, m /L 3.9 13.6 8.8 Total Residual Chlorine, IL ND ND ND Total Copper, m /L 0.007 ND 0.007 Total Chloride, m /L 3933 54 1994 Total Iron, m /L 0.061 4.79 2.43 Total Manganese, m /L 0.44 0.432 0.436 Total Lead, m /L 0.007 ND 0.007 Total Zinc, m /L 0.98 ND 0.98 Ammonia -Nitrogen, m /L 0.19 0.8 0.50 Fluoride, m /L 0.9 0.2 0.6 Total Nitrogen, m /L 1 0.5 0.75 Total Phosphorous, m /L 0.16 0.24 0.20 Note: ND = not detectable Based on this mass balance, the proposed Dixon WTP discharge also meets current NPDES permitted limits as summarized in Table 7. Table 7. Pro osed Dixon WTP Discharge Re ulated Elements Element NPDES Permitted Limit Predicted Total Suspended Solids 15.0 mg/L (Daily Max) 8.8 mg/L Residual Chlorine 13 /L Dail Max not detectable Next Steps Subsequent to this memorandum, next steps for ONWASA relating to the Dixon WTP acute toxicity include: • Continue efforts on the RO Improvements project - anticipated construction is late Spring 2012 Dixon WTP Toxicity, November 23, 2011, Page 6 KtmleyHom and Associates, Inc. • Provide acute toxicity results to DWQ permitting staff regarding the RO Improvements project (previously provided via email to Gil Vinzani and Tom Belnick) • Submit 2012 NPDES permit renewal (consider including a copy of this memorandum) Because the only chemical added to the RO pilot unit (and subsequent RO process after the RO Improvements project is implemented) is scale inhibitor and because this scale inhibitor is organic (Avista's Vitec 4000), it should not be, and based on test results is not toxic. The current Dixon WTP process has several chemical additions. One in particular is the addition of Potassium Permanganate as an oxidant. It is possible that this chemical could be causing increased susceptibility to acute toxicity failures. Additional testing may be conducted to further examine this chemical's effect on acute toxicity. Dixon WTP Toxicity, November 23, 2011, Page 7 Dixon Water Treatment Plant Data Total Dispended Solids (TDS) 10000 8000 E 7000 6000 w 5000 4000 3000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ 0 \ M \ \ \ 0 \ M \ \ M 0 \ \ \ \ \ \ \ N 1� O1 � �-1 M N I� O� � ti M N Date Total Suspended Solids (TSS) 30 25 20 ec E a c 15 7 N 10 L5 5 0 0 N \ m 0 0 N \ m 0 0 N \ m 0 0 N M m 0 0 N \ m 00 0o 0 0 0 0 0 0 0 0 0 0 0 N N N N N \ \ \ \ \ m m m m m 0 0 m m m 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N \ \ M \ \ \ \ \ \ \ m m m m m m m m m m 0 0 N m M 0 0 N \ m n 0 a N \ M m 0 0 N \ m .\i 0 0 N \ m \-� 0 0 N \ m m 0 0 N \ m 0 0 N \ m Date f pH 8.2 8 7.8 x ,°, 7.6 c v 7.4 AA w 7.2 7 6.8 n n n n n n oo ro m eo m m m m m m m m o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N 0 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ m m m m m m m m m m m m m m m m m m m m m m m m m m m m n rn N\i m u\i n m\i .\i m v\i n m \-i ti m m n m \+ ti m m n Date Dissolved Oxygen 14 13 12 JAll io 11 a 10 c m g W 7 6 n n a m ao 0a 00 00 m m m m m m o 0 0 0 0 0 .+ .+ .�+ .-� 0 0 0 0 0 0 0 0 0 0 0 0 0 0 .+ .-� •+ 0 0 0 0 0 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ try I(1 ill N N ll1 In N N t/1 V1 N V1 V1 N lA V1 � N N N N VI ll1 \ \ \ \ \ \ \ m \ \ \ \ \ m \ \ m \ \ \ \ \ T N n m "'� m �/1 n m t11 n m � �"� 0 m � Date Chloride 10000 - 9000 8000 7000 E 6000 5000 Q) 4000 3000 w 2000 1000 0 0 0 0 0 0 0 000 0 0 0 000 o O10 o 00 00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 .-i m 0 n m m m .�+ .ti m m v� m n m m .�+ .�+ m m �n n m m N .� m m in 0 n Date Fluoride a 5 4 m E 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ rn m m m m m m m m m m m m m m m m m m m m m m m 0 m \ \ � m m \ \ m \ \ \ \ \ \ \ \ \ \ \ \ \ \ m .-+ vi n m .-i .�+ m n m N ti ti N Date Ammonia Nitrogen 0.45 0.4 0.35 J ono 0.3 E 0.25 Y v 0.2 M 0.15 W 0.1 0.05 0 n n w w w w w w M M M M M M 0 0 O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0. . . ' . . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 m m rn m m m m rn m rn m m m rn m m m m m m m m rn \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ m� .-+ m In � m� m Date Salinity 9 8 7 a6 a �• 5 c W q M: 3 2 1 0 n n w w w w w w rn m rn m rn m o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ Vl Vl Vl Vl Ill N Vl N Ill ltt 1(1 t!1 Vl N Vl VI V1 N N Ill IA Ill I!1 V1 \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ Date Total Nitrogen 20 18 16 14 E 12- 10 G Qj 7 8 .2 6 w 4 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 m rn m m m m m m m m m m m m m m m m m m m m m H m Date Total Phosphorous 5.5 4.5 no 3.5 E c 2.5 d_ w 1.5 0.5 -0.5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 m m m m m m m m m m rn m m m rn m m m m rn m m m O1 Copper 0.012 0.01 0.008 E c 0.006 w 3 0.004 w 0.002 0.7 W. =, 0.5 na E 0.4 c v 0.3 3 w w 0.2 0.1 0 n n w m w w w w m m m m m m 0 0 0 0 0 0... 0 0 0 0 0 0 0 0 0 0 0 0 0 0 H. N ti•. H • ' 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 m m m m m m m m m m m m m m m m m m m m m m m Date Iron 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 a a� 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 m m m m m m m m m m m m m m m m m m m m m m m m m m m m m m Date Manganese 2.5 of 0.5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ m m m m m m m m m m m m m m m m m m rn m m m m ti ti ti ti Date Lead 0.03 0.025 J b- 0.02 G Y 0.015 C v 0.01 W W 0.005 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N N N N N N N N \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ rn rn m rn rn m m rn m rn m rn m m o� m m rn rn m m m m \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ mH m Date Zinc 0.14 0.12 m 0.1 E 0.O8 Y y 0.06 1 0.04 W 0 1 n w w w m w w m m m m m m O O O O O O H H H O O O O O O O O O O O O O O H H O O O O O O O O O O O O O O O O O O O O O O O N N N N N N N N N N N N N N N N N N N N N N N m m rn m m m rn m m m m m m rn m m m m m m m m rn H H H H H H H H H H H H H H H H H H H H H H H 0 m H H m vi n m 0 H H H H Date