NC0089745_Fact Sheet_20181128

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
Brianna Young 10/4/18
Permit Number
NCO089745
Facility Name / Facility Class
Marine Corps Base Camp Lejeune
Consolidated WTP / PC-1
Basin Name / Sub -basin number
White Oak / 03-05-02
Receiving Stream / HUC
Wallace Creek / 0302030202
Stream Classification / Stream Segment
SB, NSW / Index: 19-20
Does permit need Daily Maximum NH3
limits?
N/A
Does permit need TRC limits/language?
Yes
Does permit have toxicity testing? IWC (%) if
so
Yes; IWC = 10% (based on dilution model)
Does permit have Special Conditions?
Yes see below
Does permit have instream monitoring?
Yes - DO, salinity, conductivity, H
Is the stream impaired (on 303(d) list)?
No
Any obvious compliance concerns?
N/A
Any permit mods since lastpermit?
N/A
New expiration date
10/31/2023
Comments on Draft Permit?
Yes (see below)
Proposed Facility and Discharge:
This is a new permit for a proposed nanofiltration and green sand filter WTP on the
Marine Corps Base Camp Lejeune located in Onslow County. The source water for
finished potable water will be the Castle Hayne Aquifer. The design potable flowrate will
be 8.0 MGD and a designed maximum daily wastewater discharge of 2.1 MGD.
Discharge will be pumped from the facility at a rate of 2.4 MGD (based on diffuser
design). The expected average daily discharge is 0.73 MGD. The facility will generate
backflow with a daily discharge for approximately 7 hours per day (maximum of 21
hours per day). The membranes and filters will be backwashed with raw and finished
potable water (depending on the waste stream).
The discharge will consist of 4 waste streams:
• Nanofiltration membrane concentrate
o Concentrated water that the membranes reject
o Membranes are not backwashed
o Source water (influent) used for this mainline process will be raw well
water (groundwater) that is pretreated with scale inhibitor and sulfuric acid
(for pH adjustment)
NPDES Permit NCO089745
Page 1 of 8

o During normal operation, most of the nanofiltration membrane influent
(feed water) passes through the membrane (and eventually becomes
potable water) and the rest bypasses the membranes and is sent to waste in
the form of "concentrate"
• Nanofiltration membrane feed-to-waste/flush
o Wastewater from flushing the membranes after not being on. The
membranes will be rotated. The facility will not be running at full capacity
at first, therefore membranes will sit for a period of time between uses.
o Membranes will not be backwashed
o Source water (influent) used for this mainline process will be raw well
water (groundwater) that is pretreated with scale inhibitor and sulfuric acid
(for pH adjustment)
o During membrane system startup only, for a short period of time the same
nanofiltration membrane influent (feed water) is sent entirely to waste,
with none of it passing through the membranes, also known as the "feed-
to-waste/flush"
• Greensand filter backwash
o Bypass that occurs when renewing the iron in the filters
o Water used for backwash will be filtered and chlorinated (potable) water
supplied from the Transfer Pump Station in the Clearwell (downstream of
the decarbonators but prior to transfer to the Finished Water Tank)
• Strainer backwash
o Backwash from the sand strainers
o Water used for the backwash will be raw (untreated) well water
Potable water treatment will consist of.
• Sand strainers
• Pre -disinfection of raw water with sodium hypochlorite (bypass water only)
• Greensand filtration of NF membrane bypass water
• Addition of antiscalant (upstream of NF membranes only)
• Cartridge filters (ahead of NF membranes)
• NF membrane softening
• Carbon dioxide removal on NF membrane permeate
• Blending of permeate and bypass water
• Final disinfection with sodium hypochlorite
• pH adjustment with sodium hydroxide
• Corrosion inhibitor addition
• Fluoridation
• Oxidation (sodium hypochlorite) of process wastewater
• Clarification of process wastewaters
• Post -aeration of process wastewater
Wastewater treatment will consist of -
Oxidation (sodium hypochlorite)
• Sedimentation (2.0 MG clarifier)
• Post -aeration
• Discharge via diffuser
NPDES Permit NC0089745
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The facility will have a discharge to the sanitary sewer, which will include concentrate
treatment clarifier residuals, neutralized nanofiltration membrane clean in place (CIP)
solution, and process area trench drains.
Permitting Strategy:
This permit has been drafted following the 2009 WTP strategy for membrane and
greensand WTPs and the 2012 guidance update. Parameters included in permit are:
Flow
Membrane strategy
followed
Dissolved Oxygen
Membrane strategy
followed
Salinity
Membrane strategy
followed
Conductivity
Membrane strategy
followed
H
Membrane strategy
followed
Total Residual Chlorine
Membrane strategy
followed
Total Dissolved Solids
Membrane strategy
followed
Turbidity
Membrane strategy
followed
Total Suspended Solids
Greensand strategy
followed
Total Arsenic
Membrane strategy
followed
Total Copper
Membrane strategy
followed
Total Chloride
Membrane strategy
followed
Total Manganese
Greensand strategy
designed to remove
followed; Monitor only as facility is
manganese
Total Zinc
Membrane strategy
followed
Ammonia Nitrogen
Membrane strategy
followed
Total Nitrogen
Membrane strategy
followed
Total Phosphorus
Membrane strategy
followed
WET Testing
Membrane strategy followed; IWC % based on
CORMIX model submitted with application (see DWR
memo in permit file
Total Iron is not included in the permit as there is no longer a water quality standard for
iron.
Total Fluoride is not included in the permit as there is no saltwater water quality standard
for fluoride.
White Oak River Basinwide Water Quality Plan:
The most recent White Oak River Basinwide Water Quality Plan was reviewed. Wallace
Creek is not listed as having a TMDL, but is listed as supporting a shellfish growing area
(DEH Shellfish Growing Area classification of C-3) (Figure 6 of plan). Table 9 of the
basinwide plan contains the following information:
AU Number Classification Length/Area Aquatic Life Assessment Recreation Assessment
Description AL Rating Station Result REC Rating Station Result
Wallace Creek
19-20 SB NSW 248.4 SW Acres S PA17 NCE S PA17 NCE
NPDES Permit NCO089745
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From source to New River
*AL = Aquatic life
*REC = Recreation
*S = Supporting
*PA = Ambient monitoring site
*NCE = No criteria exceeded
The basinwide plan also contained the following information regarding Camp Lejeune:
There are now 29 Installation Restoration (IR) Sites and 23 Military Munition Response
Program (MMRP) Sites in need of additional remediation under CERCLA. The Base is
also in the process of assessing and remediating 26 solid waste management units and 32
underground storage tank sites regulated under RCRA. All of these Sites are potential
areas of concern on Base for human health and the environmental, although none pose as
an immediate threat. Monitoring activities at these sites indicate possible soil, ground and
surface water contamination, of particular interest are impacts on water quality conditions
in or around Brinson Creek and Edwards Creek.
Per Mike Templeton, there are currently no nutrient concerns or TMDLs for the White
Oak River Basin. Included monitoring for Total Nitrogen and Total Phosphorus in the
permit.
Special Conditions:
Section A. (3) has been added (per guidance from Julie Grzyb) to require that, in
accordance with 40 CFR 122.2 1 (k)(5)(vi), no later than 2 years after the commencement
of discharge from the proposed facility, the applicant is required to complete and submit
items V and VI of NPDES application form 2C.
Compliance History:
There is no compliance history to review as this is a new permit and the facility is not yet
built.
Camp Lejeune ran a toxicity test on 1 composite sample collected in March 2016 from
the City of Jacksonville (COJ) Nanofiltration WTP effluent since COJ uses similar
treatment technology to the proposed Camp Lejeune WTP and pulls from the Castle
Hayne aquifer as well. The toxicity test used was Americamysis Bahia Test EPA-821-R-
02-014 Method 1007 and was run at dilutions of 40:1, 20:1, 10:1, 5:1, and 2.5:1. The
result was Pass ChV = >>40%.
Quarterly toxicity test results on effluent for the COJ nanofiltration WTP were also
provided. COJ runs toxicity test TGP3E, Mysid, Americamysis Bahia Test Method
1007.0 at an IWC of 10%. Toxicity testing results were:
• Sample collected March 6, 2017 = Pass
• Sample collected June 5, 2017 = Pass
• Sample collected September 18, 2017 = Pass
• Sample collected December 4, 2017 = Pass
NPDES Permit NC0089745
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Quarterly toxicity testing will be required per the 2009 WTP strategy for membrane
WTPs. The toxicity test will be a chronic monitor only test using Mysid shrimp with an
IWC of 10% based on the dilution model.
RPA:
Monitoring data provided with the permit application were reviewed. Effluent data was
provided for 1 sample collected on March 7, 2016 from the COJ Nanofiltration WTP
since COJ uses similar treatment technology to the proposed WTP and pulls from the
Castle Hayne aquifer as well. Additional influent (groundwater) data was provided for 2
existing WTPs on Camp Lej eune (Buildings 20 and 670). One (1) sample was pulled
each day from Building 670's influent on October 9, 2017, October 11, 2017, and
October 13, 2017 and analyzed for total metals and dissolved metals. One (1) sample was
pulled each day from Building 20's influent on October 9, 2017 and October 11, 2017
and analyzed for total metals and dissolved metals. See Appendices A and B of the
dilution study provided with the permit application.
The RPA was run on data provided for the COJ Nanofiltration WTP effluent. A
maximum discharge of 2.4 MGD was used to calculate limits, as this is the diffuser
design discharge.
• Arsenic — No RP, predicted max < 50% of allowable Cw; monthly monitoring
applied as no data exists for the proposed WTP and arsenic is a parameter of
concern per membrane WTP strategy
• Copper — No RP, predicted max > 50% of allowable Cw; monthly monitoring
applied as no data exists for the proposed WTP and copper is a parameter of
concern per membrane WTP strategy
• Lead — No RP, predicted max < 50% of allowable Cw; monitoring will not be
required based on RPA and since lead is not a parameter of concern per the
membrane and green sand WTP strategies
• Zinc — No RP, predicted max < 50% of allowable Cw; monthly monitoring
applied as no data exists for the proposed WTP and zinc is a parameter of concern
per membrane WTP strategy
Radiological data was provided for the effluent at the COJ Nanofiltration WTP for 1
sample collected on March 7, 2016 (results below). 15A NCAC 02B .0222 states that
water quality standards applicable to class SC waters (found in 15A NCAC 02B .0220)
also apply to SB waters. 15A NCAC 02B .0220(15) states the average annual activity
level for combined Radium-226 and Radium-228 shall not exceed five (5) pCi/L and the
average annual gross beta particle activity shall not exceed fifty (50) pCi/L. Based on the
results below, monitoring for radiological components is as follows:
NPDES Permit NC0089745
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Parameter
Value
Modifier
Units
Monitor?
Reason
Annual
average
56.6
activity level
(before
Yes; Quarterly
is 50 pCi/L
Gross Beta
credited for
pCi/1
per 15A NCAC
per standard;
dilution)
02B .0220(15)
Will monitor
to ensure does
not exceed
standard
Radium 226
0.6
pCi/1
N/A
N/A
Radium 228
0.8
<
pCi/1
N/A
N/A
Does not
Combined
exceed annual
Radium 226/228
0.6
pCi/1
No
average 5
pCi/L
standard
• Gross Beta — No RP, predicted max < 50% of allowable Cw; quarterly monitoring
applied as no data exists for the proposed WTP and gross beta is a potential
parameter of concern per 15A NCAC 02B .0220(15)
Changes from draft to final:
• Facility class added in A(1) based on classification assigned (see comment below)
• Limit for gross beta removed in A(1) per RPA as dilution was mistakenly not
applied for draft permit
Comments received on application and draft permit:
Steve West (WiRO: via email 1/23/18):
• I would suggest asking Deborah Gore about the need for a pretreatment permit for
the waste stream clarifier portion (0.04-0.1 mgd) of the plant discharge which will
go to the French's Creek WWTF (NC0063029).
o DWR response: Per Deborah Gore, federally owned facilities do not
follow the pretreatment rules, only POTWs have to get pretreatment
permits. Since both the WWTP and proposed WTP will be federally
owned, a pretreatment permit is not required. Since the WWTP has a
discharge permit as well, if they have problems meeting their limits with
the new WTP waste, then they may implement something to deal with it,
but it would not be because of a pretreatment requirement.
• What is the water source for the membrane flush and greensand filter
backwash? Will chlorine be in the discharge? Has the impact of the discharge of
potassium permanganate from the greensand filter backwash been considered?
NPDES Permit NC0089745
Page 6 of 8

o DWR response: Per the permittee, the nanofiltration membranes are not
backwashed. Water used for the mainline processes of the nanofiltration
membrane concentrate and feed-to-waste/flush will be raw well water
(groundwater) that is pretreated with scale inhibitor and sulfuric acid (for
pH adjustment). The permittee stated that during normal operation, most
of the nanofiltration membrane influent (feed water) passes through the
membrane (and eventually becomes potable water) and the rest bypasses
the membranes and is sent to waste in the form of "concentrate," while
during membrane system startup only the same nanofiltration membrane
influent (feed water) is sent entirely to waste, with none of it passing
through the membranes (the "feed-to-waste/flush"). The source water for
the greensand filter backwash will be filtered and chlorinated (potable)
water supplied from the Transfer Pump Station in the Clearwell
(downstream of the decarbonators but prior to transfer to the Finished
Water Tank). Chlorine monitoring and limit have been added in the draft
permit as it has the potential to be discharged. The impact of potassium
permanganate is considered in the permit through the monitoring of
manganese. Please see the previously attached draft permit for all
required monitoring.
• Construction of the outfall will require a CAMA major permit (Morehead City
office)
Steve West (WiRO; via email 7/17/18)
• So they've satisfied us that they will be able to meet the effluent chlorine limit
without dechlorinating?
o DWR response: The permit contains a limit of 13 ug/L with a footnote
stating "The Division shall consider all effluent TRC values reported
below 50 µg/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 µg/L." Based on the dilution study, the permit has an
IWC of 10%. The dilution study stated that the limiting pollutant based on
the projected effluent characterization was copper.
James Marshall-Zank (Camp Lejeune; via phone 8/14/18)
• Question about the Gross Beta limit in the permit — should dilution have been
applied to this limit? (i.e. get a higher limit or was the 10% effluent concentration
accounted for in determining a limit?)
• Only 1 data point from the City of Jacksonville, and that seems kind of unreliable
• Something like radiation isn't going to go away in the water
• DWR Response: Please address this question in any written comments submitted
on the draft permit. I would like to review the data submitted for the City of
Jacksonville used to determine the limit, as well as the statute that addresses
radiation water quality standards.
NPDES Permit NC0089745
Page 7 of 8

John Townson (Camp Lejeune; via email 8/24/18)
• MCB CAMLEJ agrees with the majority of the contents as it closely follows
agency guidance for permitting wastewater discharges from water treatment
plants
• MCB CAMLEJ would like you to consider that the effluent limit of 50 pCi/L in
Part I.A. (1) of the permit for Gross Beta Radiation may not be practical as it was
developed without accounting for the dilution factor established in the Mixing
Zone Study (MZS) performed by one of our contractors and submitted with the
permit application in December 2017
• The NCDEQ provided Fact Sheet for Expedited Permit Renewals delivered with
the Draft NPDES permit does not include the rationale for not considering this
mixing in the RPA for this parameter
• Since beta particles normally deposit their energy over longer distances as part of
the mixing process, we request that the RPA for Gross Beta Radiation account for
the dilution factor of ten (10) as outlined in the MZS and otherwise used by the
NCDEQ in the RPA for arsenic, copper, lead, and zinc
• We believe that this approach will show that an effluent limit for Gross Beta
Radiation is not necessary
• MCB CAMLEJ agrees that monitoring for this parameter is appropriate to
confirm whether actual effluent from the future operational plant has elevated
levels of Gross Beta Radiation
• DWR response: After review, it was discovered that the dilution factor was
mistakenly not applied when determining whether limits for gross beta should be
included in the permit. After the analysis was reran to account for dilution, it was
determined that limits were not needed, however, monitoring for gross beta will
remain in the permit.
Maureen Kinney (WW Operator Certification Group; via email 9/18/18)
• This facility will be classified PC-1
• DWR Response: This classification will be added to the permit as required.
NPDES Permit NC0089745
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