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HomeMy WebLinkAboutNC0081621_Fact Sheet_20181206Fact Sheet NPDES Permit No. NCO081621 Permit Writer/Email Contact Qais Banihani, gais.banihani@ncdenr.gov: Date: December 6, 2018 Division/Branch: NC Division of Water Resources/NPDES Complex Permitting Fact Sheet Template: Version 09Jan2017 Permitting Action: N Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2' species WET tests. • For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter NA. 1. Basic Facility Information: Table 1. Facility information Facility Information Applicant/Facility Name: Water & Sewer Authority of Cabarrus County/Muddy Creek WWTP Applicant Address: 6400 Breezy Lane, Concord, NC 28025 Facility Address: 14655 Hopewell Church Road, Midland, NC 28107 Permitted Flow: 0.15 and 0.3 MGD Facility Type/Waste: MINOR Municipal; domestic and industrial Facility Class: Class 11 Treatment Units: Bar Screen, Equalization basin, Aeration basins, Sludge holding tanks, Aerobic digesters, Clarifiers, Tertiary filters and UV Disinfection Pretreatment Program (Y/N) Yes County: Cabarrus Region Mooresville Page 1 of 11 Briefly describe the proposed permitting action and facility background: The Water and Sewer Authority of Cabarrus County (WSACC), herein called WSACC or Permittee, applied for a permit renewal for Muddy Creek Wastewater Treatment Plant (WWTP). The Permittee's 5-year NPDES permit expires on October 31, 2018. The facility serves a population of 1463 within the Town of Midland and established a full pretreatment program in 2017 with one non -categorical Significant Industrial Users (SIUs). In September 2007, WSACC requested speculative effluent limits for flow expansion from 0.3 MGD to 5.0 MGD. WSACC received a speculative effluent limits letter evaluation for flow rates of 1.0 MGD, 2.0 MGD and 5.0 MGD in November 2007. Currently, the facility is operating at a permitted flow of 0.15 MGD. An Authorization to Construct (A to C No. 081621A02) was issued in December 2016 for expansion from 0.15 MGD to 0.3 MGD. The facility's upgrade to 0.3 MGD is underway. The last USGS stream flow data was obtained in November of 2015 and has been used to calculate the IWC and other dilution factors in this fact sheet. 2. Receiving Waterbody Information: Table 2. Receiving waterbody information Receiving Waterbody Information Outfalls/Receiving Stream(s): Outfall 001 — Rocky River Stream Segment: 13-17 Stream Classification: C Drainage Area (mi2): 553 1 Summer 7Q10 (cfs) 38.71 Winter 7Q 10 (cfs): 831 30Q2 (cfs): 941 Average Flow (cfs): 525 1 IWC (% effluent): 0.60% (0.15 MGD) and 1.2% (0.3 MGD) 303(d) listed/parameter: Yes, the segment is listed in the 2016 303(d) for Copper, Zinc and Turbidity impairment Subject to TMDL/parameter: Yes- State wide Mercury TMDL implementation. Subbasin/HUC: 03-07-12; 03040105 USGS Topo Quad: G 17 NW 1 based on information provided by USGS in 2015 3. Effluent Data Summary Page 2 of 11 Effluent data for Outfall 001 is summarized below for the period of November 2014 through March 2018. Table 3. Effluent Data Summary Outfall 001 Permit Parameter Units Average Max Min Limit Flow MGD 0.10 0.24 0.04 MA 0.15 WA 15.0 BOD summer mg/l 4.00 39.00 < 2.0 MA 10.0 WA 30.0 BOD winter mg/l 4.73 26.0 < 2.0 MA 20.0 WA 45.0 TSS mg/l 6.38 58.8 < 2.5 MA 30.0 WA 12.0 NH3N summer mg/1 3.15 181.0 < 0.1 MA 4.0 WA 24.0 NH3N winter mg/1 1.32 25.6 < 0.1 MA 8.0 DO mg/1 9.09 13.3 6.2 DA > 5.0 (geometric) Fecal coliform #/100 ml 91.52 5100 < I WA 400 MA 200 DM 28.0 TRC µg/1 NA NA NA (< 50 compliance) Temperature ° C 19.28 30.0 7.0 6.0 < pH < PH SU 6.63 7.2 6.0 9.0 MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average 4. Instream Data Summary Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership is maintained). If applicable, summarize any instream data and what instream monitoring will beproposedfor this permit action: The current permit requires instream monitoring for Dissolved Oxygen (DO) and Temperature. These parameters are among those collected by the Yadkin -Pee Dee River Basin Association (YPDRBA). Review of the coalition -collected instream data from January 2014 through December 2017 at stations 8355000 (upstream) and 8385000 (downstream) revealed that the DO standard of 5.0 mg/L was largely Page 3 of 11 maintained, and there were no significant differences between upstream and downstream (ANOVA, p > 0.5). The average over the period analyzed indicated that DO was 7.6 mg/L for both upstream and downstream stations. Tables 4 and 5 summarize the instream data at the upstream and downstream, respectively. Table 4: Instream monitoring at Upstream Station (8355000) DO Temperature m /L °C Average 7.6 1 19.7 Max 10.4 29.3 Min 6.1 5.6 Table 5: Instream monitoring at Downstream Station (8385000) DO Temperature m /L °C Average 7.6 1 19.6 Max 10.5 29.1 Min 6.2 5.4 Temperature values were nearly identical between upstream and downstream sites with a maximum differential being 1.1 °C, less than the 2.8 °C temperature standard in NCAC 2B. This draft permit maintains the same instream monitoring requirements for DO and Temperature. Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): YES Name of Monitoring Coalition: Yadkin -Pee Dee River Basin Association (YPDRBA) 5. Compliance Summary Summarize the compliance record with permit effluent limits (past 5 years): The facility reported a total of 4 limit violations from October 2014 to May 2018. Broken down by parameter, these include 1 BOD5, 1 Fecal Coliform and 2 NH3-N. The BOD5 exceeded the weekly average in July 2017, Fecal coliform exceeded the weekly geometric mean in January 2017 and NH3-N exceeded the weekly average and the monthly average in July 2017. The violations resulted in 3 Notices of Violation (NOVs) and 1 Notice of Deficiency (NOD). Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): NA Summarize the results from the most recent compliance inspection: The last facility inspection conducted in 2017 reported that the facility was operating properly. 6. Water Quality -Based Effluent Limitations (WQBELs) Dilution and Mixin.. Zones Page 4 of 11 In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits (e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and model results. If permit limits are more stringent than TBELs, describe how limits were developed Limitations for BOD are based on 1993 QUAL2E model for instream DO protection. No changes are proposed from the current permit limits. Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/1 (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals. Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values reported below 50 ug/l are considered compliant with their permit limit. Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: Wasteload Allocation (WLA) calculations resulted in a cap of 28 µg/L TRC, which is the same as in the current permit. Therefore, there are no proposed changes for TRC. No changes in ammonia nitrogen limits are proposed from the current permit for both flow tiers. Table 6 summarizes the NH3-N limit for each tiered flow. Table 6. NH3-N Limit Q=0.15MGD Q=0.3MGD Season Monthly Average Weekly Average Monthly Average Weekly Average Summer 4.0 mg/L 12.0 mg/L 4.0 mg/L 12.0 mg/L Winter 8.0 mg/L 24.0 mg/L 8.0 mg/L 24.0 mg/L Reasonable Potential Analysis (RPA) for Toxicants If applicable, conduct RPA analysis and complete information below. Page 5 of 11 The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between January 2017 and March 2018. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit: • Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: NA • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was >50% of the allowable concentration: NA • No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and the maximum predicted concentration was <50% of the allowable concentration: Arsenic, Beryllium, Cadmium, Total Chromium, Copper, Lead, Nickel, Selenium, Silver and Zinc. • POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program. Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: Toxicity testing is not currently required since the facility is classified as a minor without pretreatment program. However, the facility established a full pretreatment program in 2017; therefore, a chronic WET limit at 0.60% (0.15 MGD) and 1.2% (0.3 MGD) effluent will be added to the permit on a quarterly frequency. Page 6 of 11 Mercury Statewide TMDL Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/1) will receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/l. Table 7. Mercury Effluent Data Summary - 0.15 MGD 2017 2018 # of Samples 2 1 Annual Average Conc. n /L 0.5 0.5 Maximum Conc., n L 0.5 0.5 TBEL, n /L 47 WQBEL, n /L 2009.4 Table 8. Mercury Effluent Data Summary - 0.3 MGD 2017 2018 # of Samples 2 1 Annual Average Conc. n /L 0.5 0.5 Maximum Conc., n L 0.5 0.5 TBEL, n /L 47 WQBEL, n /L 1010.7 Describe proposed permit actions based on mercury evaluation: Since no annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury limit is required for both flow tiers. However, since this is a minor municipal facility (< 1 MGD) with no mercury limit required, the facility will be required to monitor mercury as part of its three effluent pollutant scans using EPA test method 1631 E for both flow tiers. Other TMDL/Nutrient Management Strategy Considerations If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: NO TMDL for Turbidity for Rocky River in Yadkin -Pee Dee River Basin. Other WQBEL Considerations If applicable, describe any other parameters of concern evaluated for WQBELs: NA If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall comply with in order to protect the designated waterbody: NA Page 7 of 11 If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 1 SA NCAC 2K 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA If applicable, describe any water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA 7. Technology -Based Effluent Limitations (TBELs) Municipals if not applicable, delete and skip to Industrials) Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA Are 85% removal requirements for BOD51TSS included in the permit? YES If NO, provide a justification (e.g., waste stabilization pond). NA 8. Antidegradation Review (New/Expanding Discharge): The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases, existing instream water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the results of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water quality modeling results: NA. 9. Antibacksliding Review: Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). Are any effluent limitations less stringent than previous permit (YES/NO): NO If YES, confirm that antibacksliding provisions are not violated: NA 10. Monitoring Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered Page 8 of 11 effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring frequencies. For instream monitoring, refer to Section 4. The facility's request to modify the monitoring frequency for BOD5, TSS, NH3-N and Fecal Coliform was approved in September 2014. Review of effluent data from March 2015 through March 2018 for the above parameters revealed that the facility's performance still satisfies the criteria established in the "DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally Performing Facilities" and justifies reduced monitoring for these parameters. Attached to the fact sheet is the Data Summary for Reduced NPDES Permit Monitoring Frequency. Therefore, the reduced monitoring frequencies will be maintained for BOD5, TSS, NH3-N and Fecal Coliform. 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit additional NPDES reports electronically. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12.Summary of Proposed Permitting Actions: Table 9. Current Permit Conditions and Proposed Changes 0.15, 0.3 MGD Parameter Current Permit IL Proposed Change Basis for Condition/Change Flow MA 0.15 & 0.3 MGD No change 15A NCAC 2B .0505 BOD5 Summer: No change WQBEL. Based on 1993 QUAL2E MA 10.0 mg/l model WA 15.0 mg/l Winter: MA 20.0 mg/l WA 30.0 mg/l TSS MA 30.0 mg/l No change. TBEL. Secondary treatment WA 45.0 mg/l standards/40 CFR 133 / 15A NCAC 2B .0406 NH3-N Summer: No change. WQBEL. Based on 1993 QUAL2E MA 4.0 mg/l model. WA 12.0 mg/l Winter: MA 8.0 mg/l WA 24.0 mg/l DO > 5 mg/l No change WQBEL. State WQ standard, 15A NCAC 2B Fecal Coliform MA 200 /100ml No change WQBEL. State WQ standard, 15A WA 400 /100ml NCAC 2B Page 9 of 11 TRC DM 28 µg/L No change WQBEL. Based on protection of State WQ criteria (WLA). 15A NCAC 2B Temperature Monitor 3/week No change WQBEL. State WQ standard, 15A NCAC 2B pH 6 — 9 SU No change WQBEL. State WQ standard, 15A NCAC 2B Toxicity Test at No requirement Chronic limit, 0.60% WQBEL. No toxics in toxic 0.15 MGD effluent amounts. 15A NCAC 213.0200 and 15A NCAC 213.0500 Toxicity Test at No requirement Chronic limit, 1.2% WQBEL. No toxics in toxic 0.3 MGD effluent amounts. 15A NCAC 213.0200 and 15A NCAC 213.0500 Effluent Pollutant No requirement Three times per permit 40 CFR 122 Scan cycle Total Hardness No requirement Add effluent and Hardness -dependent dissolved upstream Quarterly metals water quality standards Monitoring approved 2016 Electronic required No change In accordance with EPA Electronic Reporting Reporting Rule 2015. MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max 13. Public Notice Schedule: Permit to Public Notice: 10/02/2018 Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Director within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable): Were there any changes made since the Draft Permit was public noticed (Yes/No): NO If Yes, list changes and their basis below: NA Comments Received: Page 10 of 11 The Division did receive a comment from the Permittee. The Permittee requested to terminate the limit requirements for the Whole Effluent Toxicity (WET) once the facility has passed 8 consecutive tests. The limit requirements were added in accordance with 15 A NCAC 02B.0200 and 15A NCAC 2B.0500 Permittees should be aware that the objective of whole effluent toxicity limits placed in NPDES permits is to prevent discharge of toxic substances in amounts likely to cause chronic or acute toxicity to wildlife in the receiving stream and represents the only feasible method of evaluating the combined effects of constituents of complex wastestreams. Following is a link to review DWR's WET Strategy: htips:Hfiles.nc.gov/ncdeq/Water%20Qualiiy/ATU%2ODocuments/Whole%2OEffluent%20Toxi ci , %20(WET)/WET%20Monitoring%20and%20Reporting/NCDWQ%20WET%20Strategy.pdf Since, WET testing is a vital component to implementing water quality standards under the NPDES permits program in accordance with the CWA Section 402, all the state environmental agencies with NPDES programs implement WET testing; therefore, those requirements will not be terminated. 15. Fact Sheet Attachments (if applicable): • RPA Spreadsheet Summary • Dissolved Metals Implementation/Freshwater or Saltwater • NH3-N and TRC WLA for 0.15 MGD and 0.3 MGD • Mercury TMDL Evaluation • Data Summary for Reduced NPDES Permit Monitoring Frequency • Pretreatment information request form • Wet Testing summary results • Compliance Evaluation Report • Monitoring Report Violations summary sheet Page 11 of 11