HomeMy WebLinkAboutNC0085553_Draft Permit_20171018Water Resources
ENVIRONMENTAL QUALITY
October 18, 2017
Mr. Chris McCall, Interim Village Manager
The Village of Bald Head Island
PO Box 3009
Bald Head Island, NC 28461-3009
Dear Mr. McCall:
ROY COOPER
Govey nw
MICHAEL S. REGAN
Secy elay
S JAY ZIMMERMAN
Du ector
Subject: Draft NPDES Permit NCO085553
Bald Head Island WTP
Class PCNC
Brunswick County
The Division has reviewed your request to renew the subject permit. Please review this draft
carefully to ensure your thorough understanding of the information, conditions, and requirements
it contains.
The draft permit includes the following significant changes from the existing permit:
➢ Section A. (4) has been added to require electronic submission of effluent data, and a
footnote has been added in Section A. (1). Federal regulations require electronic
submittal of all discharge monitoring reports (DMRs).
➢ Regulatory citations have been added to the permit.
➢ Outfall map has been updated.
➢ The facility name has been updated on the permit cover sheet to reflect the Divison's
records.
➢ Language has been updated on the Supplement to Permit Cover Sheet based on current
NPDES permit formatting.
➢ Flow measurement frequency has been changed from weekly to continuous and sample
type changed from recorder to recording based on the maximum monthly average flow
between April 2014 and April 2017 per the current water treatment plant strategy.
Membrane technology water treatment plants require continuous recording monitoring
for facilities discharging > 50,000 GPD.
➢ Monitoring for temperature is no longer required, therefore it has been removed from
Section A. (1).
➢ Monitoring, limits, and an associated footnote have been added for total residual chlorine
per the current water treatment plant strategy.
➢ Monitoring has been added for turbidity per the current water treatment plant strategy
➢ Measurement frequency for pH has been changed to 2/month per current water treatment
plant strategy.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, NC 27699-1617
919 807 6300 919-807-6389 FAX
https //deq nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/npdes-wastewater-permits
➢ Limits have been added for Total Copper and Total Zinc based on a reasonable potential
to exceed water quality standards, and monitoring frequency has been changed to
monthly.
➢ Monitoring has been added for Total Nitrogen and Total Phosphorus per the current
water treatment plant strategy.
➢ "Monitor & Report" has been added to Whole Effluent Toxicity Monitoring in the
effluent table in Section A. (1).
➢ The footnote for toxicity in Section A. (1) has been updated.
➢ A Discharge Alternatives Evaluation has been added as Section A. (3) due to a history of
failed toxicity tests.
Whole Effluent Toxicity test results submitted during the past three years have demonstrated that
the Water Treatment Plant's effluent is showing potential for causing aquatic toxicity in the
receiving stream. As a result, the Village of Bald Head Island shall perform a Discharge
Alternatives Evaluation as described in Section A. (3) of this permit. This evaluation is being
requested to determine whether there are any economical and technologically feasible
alternatives available to the Village of Bald Head Island to comply with all NC Water Quality
Standards. The permittee will be given approximately one permit cycle to evaluate and document
possible treatment/discharge alternatives to eliminate aquatic toxicity. The evaluation shall be
submitted with the permittee's next permit renewal application and will be carefully reviewed by
the Division and the results will be used in the development of a compliance schedule or possible
variance request for the Village of Bald Head Island.
With this notification, the Division will solicit public comment on this draft permit by publishing
a notice in newspapers having circulation in the general Brunswick County area, per EPA
requirements. Please provide your comments, if any, to me no later than 30 days after
receiving this draft permit.
Following the 30 -day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuing a final permit. If you have questions concerning the
draft, please contact me at 919-807-6333, or via e-mail [Brianna.Young@ncdenr.gov].
Sincerely,
/�O� 1�rD
Bnanna Young
Compliance and Expedited Permitting Unit
cc: NPDES Files
cc: Wilmington Regional Office
WSS/Aquatic Toxicology Branch
Kennith D. Bowling, Village Utilities Director [kbowling@villagebhi.org]
Permit NC0085553
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
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, the
Village of Bald Head Island
is hereby authorized to discharge wastewater from a facility located at the
Bald Head Island WTP
256 Edward Teach Extension
Bald Head Island
Brunswick County
to receiving waters designated as Bald Head Island Marina Basin Channel in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become.
This permit and authorization to discharge shall expire at midnight on November 30, 2022.
Signed this day.
S. Jay Zimmerman, P.G.
Director, Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 9
Permit NCO085553
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.
The Village of Bald Head Island
is hereby authorized to:
Continue to operate a Water Treatment Plant with a discharge of Reverse Osmosis (RO) wastewater
concentrate. This water treatment plant currently has a design potable flowrate of 0.288 MGD and a
maximum, monthly average wastewater discharge of 0.0706 MGD. This facility is located at Village
of Bald Head Island WTP, 256 Edward Teach Extension, Bald Head Island in Brunswick County.
Wastewater treatment consists of:
• Antiscalant infection system
• Two (2) 0.101 MGD capacity primary RO systems with reject water flow totalizer
• One (1) 0.086 MGD capacity polishing RO system with reject water flow totalizer
2. Discharge from said treatment works at the location specified on the attached map into Bald Head
Island Marina Basin channel [Stream Segment: 18-88-8-5], a waterbody currently classified SC:#
waters within subbasin 03-06-17 [HUC: 0303000508] in the Cape Fear River Basin.
Page 2 of 9
Permit NCO085553
Part I.
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee
is authorized to discharge reverse osmosis reject water from Outfall 001. Such discharges shall be limited
and monitored' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
Parameter Code
EFFLUENT LIMITS
Monthly Daily
Average Maximum
MONITORING REQUIREMENTS
Measurement Sample Sample
Frequency Type Location 2
Flow
50050
Continuous
Recording
E
Dissolved Oxygen, m /L
00300
Monthly
Grab
E, U, D
Salinity, ppt
00480
Monthly
Grab
E, U, D
Conductivity, mhos/cm
00094
Monthly
Grab
E, U, D
pH
00400
Not less than 6.8 S.0 nor
greater than 8.5 S U
2/month
Grab
E, U, D
Total Residual Chlorine 3
50060
13 /L
2/month
Grab
E
Total Dissolved Solids, m /L
70295
Monthly
Grab
E
Turbidity
00070
Monthly
Grab
E
Total Arsenic
01002
10 /L 10 /L
Monthly
Grab
E
Total Copper, /L
01042
3 70 /L 5.80 /L
Monthly
Grab
E
Total Chloride, m /L
00940
Monthly
Grab
E
Total Zinc, /L
01092
85 6 /L 951 /L
Monthly
Grab
E
Ammonia Nitrogen, m /L
C0610
Monthly
Grab
E
Total Nitrogen TP
C0600
Quarterly
Grab
E
Total Phosphorus TP
C0665
Quarterly
Grab
E
Whole Effluent Toxicity a
TGE3E
Monitor & Report
Quarterly
Grab
E
Footnotes
1. The permittee shall submit discharge monitoring reports electronically using the Division's eDMR system [see
Special Condition A (4)].
2 E = Effluent, U at least 50 feet from the channel discharge location towards the Cape Fear River, D at least 100
feet from the channel discharge location towards Bald Head Island Manna
3 Limit and monitor only if the facility adds chlorine or chlonne derivatives to water that is eventually discharged.
The Division shall consider all effluent TRC values reported below 50 gg/L to be in compliance with the permit.
However, the Permittee shall continue to record and submit all values reported by a North Carolina certified
laboratory (including field certified), even if these values fall below 50 Rg/L.
4. Acute Toxicity 24 -hr Pass/fail Monitoring: January, April, July, and October. Permittee shall use
mysid shrimp as the test organism unless another organism of equal or greater sensitivity is deemed
more appropriate based on the characteristics of the discharge and receiving stream. See Special
condition A. (2) for details.
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.
Page 3 of 9
Permit NCO085553
A. (2) ACUTE TOXICITY MONITORING (QUARTERLY)
[15A NCAC 0213 .0500 et seq.]
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 December 2010 or subsequent versions). The monitoring shall
be performed as a Mysid Shrimp (Mysidopsis bahaa) 24 hour static test. The effluent concentration at
which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure
document). 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. These months signify the first month of each three month toxicity testing quarter
assigned to the facility.
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, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms snall 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. Upon submission of a valid test, this monthly test requirement will
revert to quarterly in the months specified above. Assessment of toxicity compliance is based on the
toxicity testing quarter, which is the three month time interval that begins on the first day of the month in
which toxicity testing is required by this permit and continues until the final day of the third month.
Should any test data from either these monitoring requirements 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.
Page 4 of 9
Permit NCO085553
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR and AT
Forms.
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
USE OF A DIFFERENT TEST ORGANISM
The permittee may request the use of a different test organism upon documentation that the alternate test
organism would provide an equal or greater level of protection and is appropriate based on the
characteristics of the discharge and receiving stream. Such documentation would consist of one of the
following:
1. For saltwater classified streams, a fathead minnow may be assigned as the acute testing species if
the salinity of the receiving stream at the point of discharge is <5 ppt throughout the tidally
influenced cycle. This determination may be based on the best professional judgment of DWQ
staff or data collection provided by the permittee and approved by DWQ staff. This evaluation
should include vertical profiles of salinity/conductivity measurements at both high tide and low
tide over several 24 hr cycles.
2. Three consecutive "side-by-side" tests with results indicating that the alternate test organism is as
or more sensitive to the facility's effluent. Each test series would consist of two separate toxicity
tests conducted on the same sample of effluent with the length of exposure specified by the permit,
the only difference between the tests being the organism used.
3. An alternate plan developed by the permittee and approved by the Aquatic Toxicology Unit that
demonstrates an equal level of protection is offered by the test organism.
For items 2 and 3, it must also be demonstrated that viable and standardized culture techniques are
available for that organism and standardized testing methodologies have been developed and
validated. This demonstration should meet guidance provided by EPA in Section 6 of EPA -821-R-02-
012, Short Term Methods for Estimating the Acute Toxicity of Effluents and Receiving Waters to
Freshwater Organisms. Fifth Edition, 2002.
A. (3) DISCHARGE ALTERNATIVES EVALUATION
The Permittee shall assess potential alternatives to eliminate Whole Effluent Toxicity (WET) test failures.
This evaluation shall assess the feasibility of all the following alternatives.
1. Connect discharge to a WWTP: Determine whether the wastewater can be discharged to a wastewater
treatment plant. Approval or disapproval from the plant operator should be acquired.
2. Obtain a Non -discharge permit: Eliminate the surface water discharge by obtaining a non -discharge
permit for spray irrigation, infiltration, or subsurface disposal (on-site drainfield,
infiltration gallery, injection wells).
Page 5 of 9
Permit NCO085553
3. Install Wastewater Treatment: Install improved wastewater treatment to enable the facility effluent to
consistently pass the WET test. If this is not technically feasible or cost prohibitive,
please explain and provide estimated costs.
4. Use Alternative Water Treatment Source: Obtain drinking water from another source (nearest
County, City, or Town or other wells) so the discharge or toxicity problem is
eliminated.
5. Use Alternative Water Treatment Method: Install alternative and/or innovative water treatment
methods or operational improvements that do not produce toxic wastewaters. For
example, install a recycle iron/manganese filtration system with no discharge or
combine discharge with WWTP or cooling water effluents.
6. Discharge to a Larger waterbody/Perform a dilution model: Relocate the facility's discharge to a
larger receiving waterbody to eliminate or reduce toxic impacts to the receiving
waterbody given the increased dilution. If applicable, perform a dilution model to
receive allowance for stream dilution in WET test.
7. Combination of Alternatives: Employ any combination of the alternatives listed above that would
result in eliminating or decreasing toxicity until a more feasible solution becomes
available.
The evaluation shall include a present value of costs analysis for all technologically feasible options as
outlined in the Division's "Engineering Alternatives Analysis Guidance Document." This Document can be
found at: http://portal.ncdenr.or web/wq/swp/ps/npdes/permits.
This evaluation is being requested to determine whether there are any economical and technologically
feasible alternatives available to the Permittee to address aquatic toxicity in the plant effluent. Based upon
the evaluation, please identify viable alternatives and present an implementation schedule and project
timeline for the preferred alternative. The Permittee shall submit the Discharge Alternatives Evaluation to the
Division along with the submission of their next permit renewal application (due 6 months prior to permit
expiration on November 30, 2022) to:
NC DENR / Division of Water Resources / Water Quality Permitting
NPDES, Wastewater Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
A. (4) ELECTRONIC REPORTING OF MONITORING REPORTS
[NCGS 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
Section B. (11.)
Section D. (2.)
Section D. (6.)
Signatory Requirements
Reporting
Records Retention
Page 6 of 9
Permit NC0085553
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring
data and submit DMRs electronically using the internet. Until such time that the state's eDMR
application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR),
permittees will be required to submit all discharge monitoring data to the state electronically using
eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one
signed original and a copy of the computer printed eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband access,
then a temporary waiver from the NPDES electronic reporting requirements may be granted and
discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms
approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See
"How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for
receiving electronic NPDES data [see 40 CFR 127.2(b)].
Page 7 of 9
Permit NC0085553
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each
type of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: https://www.federalre ig ster.gov/documents/2015/10/22/2015-24954/national-
pollutant-discharge-elimination-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electroric reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver
shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be
submitted electronically to the Division unless the permittee re -applies for and is granted a new
temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may submit monitoring data
and reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
hqp.//deq.ne.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the pen -nit issuing authority shall be signed by a person described in Part II,
Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section
B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting
purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system, registering for eDMR and obtaining an eDMR user account, please visit the following web
page:
hllp:Hdeq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22] NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
V certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
Page 8 of 9
Permit NCO085553
aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
This period may be extended by request of the Director at any time [40 CFR 122.41 ].
Page 9 of 9
Village of Bald Head Island
Bald Head Island WTP
NPDES Permit NCO085553
Receiving Stream: Bald Head Island Marina Basin Stream Class: SC
Stream Segment: 18-88-8-5 Sub -Basin #: 03-06-17
River Basin: Cape Fear HUC: 0303000508
County: Brunswick
N
SCALE
1:24,000