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Home My WebLink AboutNC0078131_Fact Sheet_20180928FACT 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 Brianna Young 9/28/18 Permit Number NCO078131 Facility Name / Facility Class Brown Boulevard WTP / PC-1 Basin Name / Sub -basin number Neuse / 03-04-10 Receiving Stream / HUC McCotter Canal to Shop Branch / 0302020405 Stream Classification / Stream Segment SC; Sw, NSW / Segment: 27-115-3 Does permit need Daily Maximum NH3 limits? N/A Does permit need TRC limits/language? Already resent Does permit have toxicity testing? IWC (%) if so Yes; IWC = 90% Does permit have Special Conditions? Yes; Added discharge alternatives evaluation for failed tox tests Does permit have instream monitoring? Yes — p1l, salinity, conductivity, and DO Is the stream impaired on 303 d list)? No Any obvious compliance concerns? Yes; see below Any permit mods since last permit? Yes; per cover letter with application, the facility is undergoing a complete redesign see below New expiration date 6/30/2023 Comments on Draft Permit? Yes (see below) Facility Overview: The Brown Boulevard WTP is an ion exchange and greensand WTP that uses water softeners and is designed for a potable flowrate of 2.8 MGD and has an average wastewater discharge of 0.100 MGD (per renewal application). The facility generates backflow with a continuous discharge. The maximum, monthly average discharge between June 2015 and May 2018 was approximately 0.123 MGD. This facility is not a member of the LNBA/NRCA Monitoring Coalition (information available at time draft permit was submitted to public notice indicated facility was a member; Mark Vander Borgh [WSS/Ecosysteme Branch] confirmed it is not via email 8/17/18). Raw water treatment consists o£ • 2 aeration basins • Oxidation • Sodium permanganate for oxidation • 6 greensand filters • 4 ion exchange softeners • Zinc orthophosphate • Sodium hypochlorite • Ammonia • 1.0 MGD ground storage tank Wastewater treatment consists of: • 417,000 gallon clarifier (WaRO states 450,000 gallons with no available freeboard) • 60,000 gallon basin (WaRO states 63,000 gallons with no available freeboard) • Calcium thiosulfate for chlorine removal • 12" line to discharge • Solids are wasted and applied to 6 drying beds, then hauled to the landfill New components at facility since previous renewal: • 417,000 gallon clarifier • Polishing basin • Effluent meter vault • Dechlorination station • 12" discharge line will empty into the existing discharge point • 6 drying beds • Dechlorination method has changed from tablets to liquid calcium thiosulfate Compliance History (May 2013 to June 2017): • 12 NOVs for daily TSS exceedances (all between December 2014 and February 2018) • 16 NOVs for monthly TSS exceedances (all between December 2014 and February 2018) • Failed 10 of last 12 toxicity tests RPA: The maximum monthly average flow between June 2015 and May 2018 was approximately 0.123 MGD. • Copper — Limits added per RPA; reasonable potential to exceed WQS • Zinc — Limits added per RPA; reasonable potential to exceed WQS NCG59 General Permit Eligibility (for Greensand WTPs): • They use IE treatment technology in addition to greensand treatment, therefore they are not eligible for the NCG59 Changes from previous permit to draft: • Updated eDMR footnote in A(1) and language in A(5) • Updated outfall map • Added regulatory citations • Added facility grade in A(1) • Updated facility address on cover sheet and Supplement to Permit Cover Sheet per renewal application • Components list updated on Supplement to Permit Cover Sheet per renewal application • Updated language on Supplement to Permit Cover Sheet per 2012 WTP guidance • Increased downstream monitoring to 100 feet from outfall • Changed instream pH monitoring to monthly in A(1) per 2012 WTP guidance • Changed instream salinity and conductivity sampling from composite to grab in A(1) — instream should be grab sampling • Limits added for total copper per RPA in A(1) • Limits added for total zinc per RPA in A(1) • Added "Monitor & Report" for WET testing in A(1) • Removed former footnote #3 concerning flow in A(1) stating "The Town will have until March 1, 2016, approximately 18 months from the effective date of this permit, to install a continuous flow meter. Until then instantaneous measurements can be taken with the duration of discharge to be noted in log books and a total daily discharge reported on the DMR" as the deadline has passed and the facility should be monitoring continuously • Updated TRC footnote in A(1) to current language used • Updated tox language in A(2) • Added discharge alternatives analysis as A(3) due to history of failed WET tests • Added compliance schedule as A(4) for copper and zinc limits Monitoring for TKN and NO3-N+NO2-N will remain in the permit as the source water for the plant is an aquifer and not surface water - deviation from the 2009 WTP strategy Changes from draft to final: • None Comments received on draft permit: Scott Vinson (WaRO; via phone 7/16/18) • Concerns about setbacks of the drying beds as they may not have the appropriate setbacks from property lines • Does not remember Havelock applying for an ATC through us to do the work or the drying beds o Did they go through DWI to make upgrades and build stuff? • Drying beds are already built — what do we do if they didn't get an ATC or go through NPDES or DWI? • Scott Vinson response (via phone 7/17/18): Dealing with drying beds issue separately — move forward with permit Scott Vinson (WaRO, via email 9/4/18) • Their ORC has a question (see below). The answer to it will be yes, they will have to do an alternatives analysis evaluation by the end of this next cycle. Regardless of whether they continue to pass their future toxicity tests after the recent upgrades, UNLESS you know different? o ORC question: On our new draft permit it states, because of all the failed toxicity tests in the past, that we are to look at discharge alternatives. I thought this plant upgrade was for that purpose? We did pass our first toxicity this past July under the new plant. My question is, do we have to do this alternatives evaluation as long as we keep passing? o DWR response: My understanding is that if the condition is in the permit, they are required to do the alternatives analysis even if they pass future toxicity tests. However, given the ORC indicates the plant has already undergone upgrades to address toxicity issues, I could speak with staff here on what the appropriate action should be before the permit is finalized. o Scott Vinson response: We need to keep the alternative analysis requirement in this permit. I'm going to explain to the ORC that the upgrades they've done now would be a good argument within the alternatives evaluation to help them keep the discharge, as long as they start and continue to pass their future toxicity tests through to the end of this next permit cycle. If they continue to fail the toxicity tests, then they are back to square one with needing the alternative evaluation for the next permit renewal.