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HomeMy WebLinkAboutNC0032867_Fact Sheet_20180619FACT 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 Anjali Orlando 4/27/2018 Permit Number NCO032867 Facility Name Maliks International, Inc — Kings Mtn. Travel Plaza WWTP Basin Name/Sub-basin number Broad 03-08-05 Receiving Stream Dixon Branch (001); Kings Creek (002) Stream Classification in Permit C (both streams) Does permit need Daily Max NH3 limits? No Does permit need TRC limits/language? No Does permit have toxicity testing? No Does permit have Special Conditions? No Does permit have instream monitoring? No Is the stream impaired (on 303(d) list)? No Any obvious compliance concerns? There have been three enforcements for the current permit cycle because of limit violations and permit condition violations. Poor compliance period from April 2017 to February 2018. Any permit mods since last permit? No Current expiration date 8/31/2018 New expiration date 8/31/2023 Changes to 2013 Permit? • Added eDMR requirements • Added regulatory citations • Changed description of 900 gallon oil/grease traps to 900 gallon septic tanks. • Changed outfall 002 latitude and longitude location per recommendation from PE. Changed to Outfall 002 is at a location of Lat 35 deg 11' 49.4" and Long -81 deg 22' 12.6 Comments received on Draft Permit? Yes- please see below. Mr. Laeeq Khan requested to remove the two 900-gallon oil/grease traps from the permit in the application. He claims they are 40 years old and are leaking. Corey Basinger, Mooresville Regional Office Supervisor replied on April 3, 2018, that it could be removed provided the facility has a grease trap to handle waste from the food preparation area. Temp. Natalie Norberg emailed Mr. Khan on April 24, 2018 to confirm if there is a grease trap at the facility. Good afternoon, Page 1 of 8 I'm currently working on the renewal for permit NC0032867. The applicant, Laeeq Khan, would like to remove the two 900-gallon oil/grease traps from the permit. According to him, they are 40 years old and are leaking. The anaerobic conditions in the septic tanks led to excessive ammonia passed to the aerobic systems. The units are currently by-passed. Would it be ok to remove the traps? Thanks, Natalie Norberg, Environmental Specialist NC Dept. of Environmental Quality, Division of Water Resources Compliance & Expedited Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617 E: natalie.norberg@ncdenr.gov O: 919.707.9125 From: Basinger, Corey Sent: Tuesday, April 03, 2018 7:19 AM To: Norberg, Natalie B <Natalie.Norberg@ncdenr.gov> Cc: Pitner, Andrew <andrew.pitner@ncdenr.gov>; Tuvia, Ori A <ori.tuvia@ncdenr.gov>; Bell, Wes <wes.bell@ncdenr.gov> Subject: RE: Permit Renewal NC0032867 Yes, provided the facility has a grease trap to handle waste from the food preparation area. Thanks, Corey W. Corey Basinger Regional Supervisor Division of Water Resources Mooresville Regional Office Department of Environmental Quality From: Orlando, Anjali Sent: Friday, April 27, 2018 1:50 PM To: Tuvia, Ori A <ori.tuvia@ncdenr.gov> Subject: RE: Permit Renewal NC0032867 HI Ori, I wanted to know if the facility has another grease trap to handle waste, as Corey mentioned below. I tried to contact the owner but have not received a reply. Do you know by chance if this facility has something else or new to handle the grease/oil? Thanks Anjali Page 2 of 8 Hi Anjali, Has of now, I do not believe they do. [on From: Orlando, Anjali Sent: Friday, April 27, 2018 1:52 PM To: Tuvia, Ori A <ori.tuvia@ncdenr.gov> Subject: RE: Permit Renewal NC0032867 Okay, do you think I should I keep the two grease traps as listed in the permit , or should I remove them from the components list for now? From: Tuvia, Ori A Sent: Friday, April 27, 2018 1:56 PM To: Orlando, Anjali <anjali.orlando@ncdenr.gov> Subject: RE: Permit Renewal NC0032867 I think the facility might need some sort of grease control. The person you should contact regarding design questions is mr W Ron Haynes, WRHaynes PE@msn.com. I believe he wants the grease traps removed all together but since the facility still have a sandwich shop in the gas station grease trap might be necessary AN From: Orlando, Anjali <anjali.orlando@ncdenr.gov> Sent: Friday, April 27, 2018 2:06 PM To: WRHaynes PE@msn.com Cc: Tuvia, Ori A; Basinger, Corey; Hennessy, John Subject: FW: Permit Renewal NC0032867 Hi Mr. Haynes, We have a NPDES Permit Renewal for a facility in NC0032867 in Cleveland County, Kings Mountain Travel Plaza. In their application, Mr. Laeeq Khan, has asked to have the two 900 gallon oil/grease traps removed from the permit because they are currently very old and leaking and are being bypassed. The Mooresville Regional Office would agree to remove the grease traps from the permit, provided they have at least some sort of grease trap to handle waste from their food preparation area (they have a sandwich shop). We would like to Page 3 of 8 confirm what they are doing now to handle grease/oil to be able to correctly renew their NPDES permit, and I was directed to you as someone who might be able to provide assistance in this matter. Thanks Anjali Orlando From: W Ron Haynes [mailto:WRHaynes PE@msn.com] Sent: Friday, April 27, 2018 2:45 PM To: Orlando, Anjali <anjali.orlando@ncdenr.gov> Cc: Tuvia, Ori A <ori.tuvia@ncdenr.gov>; Basinger, Corey <corey.basinger@ncdenr.gov>; Hennessy, John <john.hennessy@ncdenr.gov>; Dan Dougherty <dandougherty55@hotmail.com> Subject: [External] Re: Permit Renewal NCO032867 Mr. Khan has communicated with me about the recent evaluation for this issue but we have not had time to discuss it thoroughly. There is consideration for installing an individual oil/grease trap just for the food area if one is not already in place. The data for the plant effluent shows no detection for oil/grease for almost all of the sampling events after the septic tanks were bypassed. Please give me a few days early next week to discuss with Mr. Khan. He lives in Pennsylvania and has been visiting the site most weeks from Tuesday through Thursday or Friday. I should be able to meet with him Tuesday or Wednesday next week and will contact you after we meet. Thanks, Ron Haynes, PE 828/962-7733 From: Orlando, Anjali <anjali.orlandokncdenr.gov> Sent: Monday, June 11, 2018 1:34 PM To: W Ron Haynes Cc: Tuvia, Ori A; Basinger, Corey; Hennessy, John; Dan Dougherty; kingsmountain85 ggmail.com Subject: RE: [External] Re: Permit Renewal NCO032867 Hello, I was wondering if you might have any update on Kings Mountain Travel Plaza's oil/grease alternatives plan? Thanks Anjali Orlando From: W Ron Haynes [mailto:WRHaynes PE@msn.com] Sent: Friday, June 1, 2018 10:17 AM Page 4 of 8 To: Orlando, Anjali <anjali.orlando@ncdenr.gov> Cc: Tuvia, Ori A <ori.tuvia@ncdenr.gov>; Basinger, Corey <corey.basinger@ncdenr.gov>; Hennessy, John <john.hennessy@ncdenr.gov>; Dan Dougherty <dandougherty55@hotmail.com>; kingsmountain85@gmail.com Subject: Re: [External] Re: Permit Renewal NCO032867 Laeeq Khan communicated to me that he would like to have two more weeks to consider the alternatives for an oil/grease trap for the food service at Kings Mountain Travel Plaza. Could you please hold on sending out the public notice for his permit renewal until June 15, 2018. Ron Haynes 828/962-7733 From: Orlando, Anjali <anjali.orlando@ncdenr.gov> Sent: Friday, June 1, 2018 10:23 AM To: W Ron Haynes Cc: Tuvia, Ori A; Basinger, Corey; Hennessy, John; Dan Dougherty; kingsmountain85@gmail.com Subject: RE: [External] Re: Permit Renewal NCO032867 Hello Mr. Haynes, The draft permit for NCO032867 has already gone out to public notice. The comment period will end on June 18, 2018. If you can get the alternatives to me by that date, they can be considered and incorporated into the final version for this permit. Anjali Orlando Environmental Specialist Compliance and Expedited Permitting Unit Division of Water Resources N.C. Department of Environmental Quality Office: 919-807-6393 anjali.orlando@ncdenr.gov From: W Ron Haynes [mailto:WRHaynes_PEgmsn.com] Sent: Wednesday, June 13, 2018 10:29 AM To: Orlando, Anjali <anjali.orlandokncdenr.gov> Cc: Tuvia, Ori A <ori.tuviagncdenr.gov>; Basinger, Corey <corey.basingerkncdenr.gov>; Hennessy, John <john.hennessykncdenr.gov>; Dan Dougherty <dandougherty55khotmail.com> Subject: Re: [External] Re: Permit Renewal NCO032867 Thanks for the opportunity to comment on the permit renewal. There is a concern that using the septic tanks for an oil/grease separator will result in compliance problems in Page 5 of 8 the future. It appears that use of the septic tanks results in high ammonia generation in the plant itself from conversion of organic nitrogen to ammonia in the anaerobic septic tanks. Also, the BOD load may bereduced in the septic tanks resulting in a low food to mass ratio in the aeration basin and operators may not be able to maintain the necessary concentrations of MLSS. This is why I have been attempting to initiate discussion of alternate oil/grease removal techniques with the Owner and ORC. Another minor point is correction of the lat/long for Outfall 002. The attachment contains a proposed lat/long for this outfall. Please consider this input as commentary. The Owner should provide a request for change in the draft after any decision with regard to issues raised. I hope to discuss with you by telephone later today. Ron Haynes, PE 828/962-7733 Comments on the Draft Permit NC0032867- From Ron Haynes, PE> The Kings Mountain Travel Plaza WWTP is a very small and low flow volume extended aeration package plant as noted in previous renewal applications. A change of operators occurred in August 2017. Since there were no plant drawings or adequate information the plant equipment was fully re-evaluated to determine the layout of the plant tanks and piping. Septic tanks originally intended for oil/grease removal and piping that had become complex due to step -wise alterations of the plant equipment were uncovered by hand excavation. This resulted in better understanding of the system. One of the parameters that seemed to be problematic from the past operations data was ammonia in the effluent. A check of potential sources for ammonia in the facility found no cleaning chemicals or other source of the high levels of ammonia. (1) Process Equipment During fall 2017, operators found that the septic tanks positioned at the influent for the treatment train appeared to be the source of excessive ammonia generation within the plant. The mechanism is thought to be anaerobic conditions in the two 900 gallon tanks operating in series that converts organic nitrogen to ammonia. At the same time, the BOD load is reduced with flow through the septic tanks so that the operators experienced difficulty in achieving necessary levels of biological growth for the activated sludge in the active aeration tank. Permit limits for ammonia levels were exceeded during the final months of 2017. After the septic tanks were uncovered as mentioned above, the tanks were full and there was no recent record of removal of solids. The operators scheduled removal of the accumulated solids. After the removal of solids and residual liquids and the tanks filled from normal flow, the operators found a leak in the horizontal seam of Page 6 of 8 both tanks. The tanks were bypassed to eliminate the health hazard from uncontrolled wastewater that was a concern of the Cleveland County Health Department. With the tanks bypassed, the plant has been brought into compliance with effluent limits and recent activated sludge MLSS are typically 15% in the aeration tank. The draft permit lists the septic tanks as oil/grease separators. If the tanks are to be used in the treatment train, they will need to be cleaned out and the leaks eliminated to be reconnected. If this is done, it could result in lower BOD loading to the activated sludge and higher ammonia in the effluent from anaerobic activity in the septic tanks that could cause future compliance issues. (2) Oil/Grease from cooking area The recent analytical data for the WWTP indicate that effluent oil/grease is less than detection. The amount of food preparation is much lower than in previous years which reduces the potential fats/oil/grease in the influent. A building that included a separate restaurant has been demolished and overall business at the facility is lower than in the past. The lower generation of oil/grease from food preparation provides some flexibility for its treatment. If there is a need for oil/grease removal prior to the extended aeration biological treatment, it could be done by installing a small oil/grease separator in the plumbing of the food service area. Another possible way to trap oil/grease is to create an oil/grease separator section in the inactive aeration basin by installing a baffle with submerged outlet. (3) Outfall Coordinates A minor correction that could be accomplished during this permit renewal is the change or update of the latitude and longitude of the Outfalls. Outfall 002 is at a location of Lat 35 deg I 49.4" and Long -81 deg 22' 12.6" using the Cleveland County GIS with aerial photography from 2015. This location is the point at which the effluent from the oil/water separator flows into the natural drainage that leads to Kings Creek. The point was verified using a color dye during a rain event earlier this year. It is likely that the original coordinates were selected by manual methods using a quadrangle sheet and/or that the datum was North American 1927 for the first permit application. (4) ORC Preferences The ORC at the facility would prefer that the treatment train include all of the available basins and tanks that are now physically present. This includes the inactive aeration basin. This would insure flexibility in operations. To achieve both flexibility and consistency, the septic tanks might be connected with piping and valves to allow intermittent operations. Page 7 of 8 From: Orlando, Anjali <anjali.orlandogncdenr.gov> Sent: Wednesday, June 13, 2018 11:31:50 AM To: W Ron Haynes Cc: Tuvia, Ori A; Basinger, Corey; Hennessy, John; Dan Dougherty Subject: RE: [External] Re: Permit Renewal NCO032867 Hi Mr. Haynes, Thank you for your comments on NC0032867. Should I will see if we can set up a call with my supervisor to discuss the options for the permit that you have outlined? We could maybe do this afternoon around 3:30-4:00 pm? We would need to approve changes, and I also need to get input from the Mooresville Regional Office. To summarize and to make sure I understand your comments: • You are requesting we remove the septic tanks from the components lists due to potential low BOD and high ammonia issues • You would like to include the inactive aeration basin in the components list • The outfall 002 needs to be updated Thanks, Anjali Orlando Anjali Orlando Environmental Specialist I Compliance and Expedited Permitting Unit Division of Water Resources The larger of the two aeration basins at King Mountain Travel is the active one. It is a nominal 10,000 gal basin. The inactive basin has a smaller "footprint" but appears to be deeper. You could call it a nominal 7,500 gal unit but my quick measurement indicated less volume than 7,500. I checked only the aerated sections. The overall size of the package plant is larger with the clarifier and old chlorine contact. Get Outlook for Android N.C. Department of Environmental Quality Page 8 of 8