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Home My WebLink AboutNC0087084_Fact Sheet_20180529FACT 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 Exnedited Permit Renewals Permit Writer/Date An'ali Orlando 03/16/2018 Permit Number NCO087084 Facility Name Forest City — Riverstone Ind. Park WWTP Basin Name/Sub-basin number Broad / 03-08-02 Receiving Stream Broad River Stream Classification in Permit C Does permit need Daily Max NH3 limits? No Does permit need TRC limits/language? Already included Does permit have toxicity testing? Yes (no data; facility hasn't discharged) 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? Yes- See Comments Below Any permit mods since lastpermit? No Current expiration date 7/31/2018 New expiration date 7/31/2023 Comments received on Draft Permit? Yes Summary The Town of Forest City built a wastewater treatment system to serve the Riverstone Industrial Park, Chase High School and 200 homes in the vicinity of the industrial park which have septic systems. The design of the industrial park contains 48 individual lots on 1,152 acres. The developer projects that the industrial park will eventually employ 5,000 workers. The original permit application requested a total flow of 0.450 MGD. A modification was latter submitted to reduce the flow to 0.10 MGD. This flow will cover the industrial park only. Riverstone accepts effluent from American Zinc Products. Due to the amount of zinc in the air and around the facility from American Zinc Products, zinc is getting into the domestic waste stream via bathroom sinks and showers at the facility. There was no zinc data sufficient to run an RPA for the discharge from Riverstone. Therefore, a Monitor Only zinc limit has been added to be able to gather enough data to run an RPA (after 12 zinc data points have been received). Compliance Issues Facility has had numerous problems. 1 aquatic tox violation in 2016; 2 aquatic tox violations in 2015. L-GLLGI iFGIIL LraDr 11WHILMI 1YVV I GIIQIL]' naovaavu I GI 161Lr ni II4JLJI IL alU 0311512017 LV-2015-0031 Monitoring report has Limit Violations... 0310212015 $259.26 0311512017 LM-2016-0010 Monitoring report has Limit and blonit... 0610112016 $582.93 0311512017 LV-2016-0115 Monitoring report has Limit Violations... 06072016 $763.93 0811612016 LV-2016-0135 Monitoring report has Limit Violations... 0712712016 $462.94 0710512016 T-2016-0001 Aquatic Toxicity requirements violation 0411512016 $4074.74 10022015 TX-2015-0001 Aquatic Toxicity requirements violation 100212015 $3074.74 10202015 LV-2015-0006 Monitoring report has Limit Violations... 0111412015 $259.26 $259.26 08104J2015 LV-2015-0072 Monitoring report has Limit Violations... 051202015 $284.26 $234.26 0313012015 TX-2014-0011 Aquatic Toxicity requirements violation 0113012015 $6074.74 0211012015 LV-2015-0005 Monitoring report has Limit Violations... 0111412015 $259.26 $259.26 Changes for Renewal 2018: Added Regulatory Citations to permit. Added Units of Measurement to parameter table. Added Total Zinc Monitoring, Total Zinc, 01094, "Monitor Only", Monthly, Composite, Effluent to the parameter table. This was because Riverstone accepts effluent from American Zinc Products. Due to the amount of zinc in the air and around the facility from American Zinc Products, zinc is getting into the domestic waste stream via bathroom sinks and showers at the facility. There was no zinc data sufficient to run an RPA for the discharge from Riverstone. Therefore, a Monitor Only zinc limit has been added to be able to gather enough data to run an RPA (after 12 zinc data points have been received). Added Zinc Reopener clause. "The Division may reopen this permit after the permittee has submitted twelve (12) data points for zinc. The Division may change the monitoring frequency and/or impose a zinc limit if there is a reasonable potential for this facility's effluent to violate the Water Quality standard for Total Zinc." Comments: In their application Cover Letter, Jeff Dotson, WRF Superintendent of Town of Forest City WWTP, stated, "Riverstone WWTP has seen a significant change of its influent flow since the last permit renewal. The American Zinc Products Plant (formerly Horseshow Corporation) idled its zinc processing operation which included all production during the first quarter of 2016. American Zinc Products plant continues to employ an administrative staff of approx. 40 employees working toward a goal of correcting the problems and issues that were encountered during the initial startup. They have plans of restarting the production operations of the plant sometime midyear of 2019." From: Willmer, Mikal Sent: Tuesday, May 1, 2018 12:53 PM To: Orlando, Anjah <anjali.orlando@ncdenr.gov>; Hennessy, John <j ohn. hennes sy@ncdenr. gov> Cc: Davidson, Landon <landon.davidson@ncdenr.gov>; Heim, Tim <Tim.Heim(cr�,ncdenr.gov>; Price, Bev <bev.price o ncdenr.gov> Subject: Riverstone Permit Renewal We've reviewed the data regionally. Most of the monitoring data is from before the facility shutdown production. Of particular interest may be the toxicity evaluation completed by ETS here in Asheville. They narrowed down Zn as one of the primary causes of failure and have some statistical data and several experiments to support their conclusions. I believe this would help make a case for imposing limits on Riverstone for Zn. I spoke with Forest City and they do plan to implement metals limits in AZPs IUP before they start production again in 2019. The potential limits in the current IUP were derived from a HWA. An updated Headworks Allocation table is included with the PAR for 2017. Sonny Penson, Forest City ORC, believes without some form of pretreatment, AZP will struggle to meet IUP limits. All data is attached. I pulled the data out of the lab reports and organized them in excel for ease of use. The "solids" tab has sludge data converted to dry weight. Bev Price, our non -discharge inspector, reviewed the data (email attached). I've also attached an overhead of Riverstone WWTP and Forest City WWTP from Sonny Penson (FC WWTP ORC), which has a brief narrative of their current solids handling practices. Data from 4/27/2016 is after bankruptcy and the production facility was shutdown. You can see the significant drop in Zn levels. After the shutdown, FC conducted dye testing and found several issues (correspondence is attached). If you review the PAR for 2017 (link below), you can see there are still significant Zn fluctuations with the plant shut down and minimal staff on -site. http://edocs.deq.nc.gov/WaterResources/0/doc/639060/Pa eg laspx?searchid=9991ce4a- f557-4fee-ab 15-2228dc59bf28 Let us know if you have any additional questions. Mikal Willmer Environmental Specialist -Asheville Regional Office Water Quality Regional Operations Section NCDEQ-Division of Water Resources Office: 828-296-4686 Fax: 828-299-7043 Mikal.willmer@ncdenr. gov 2090 US Hwy. 70 Swannanoa, NC 28778 From: Gore, Deborah Sent: Tuesday, April 10, 2018 8:28 AM To: Orlando, Anjali <anjali.orlando@ncdenr.gov> Subject: RE: Riverstone Industrial Park WWTP I wasn't exactly sure which facility you meant — the Town's WWTP or the industrial facility (American Zinc) Attached is the removal rate spreadsheet for Riverstone WWTP. It has influent and effluent data from 12/2013 — 7/2017. I didn't see any other data on the DMR. From a 2016 permit application when they were still called Horsehead Metal Products: 9/15/15 Zn = 13.8 mg/1(yes mg/1) 9/ 17/ 15 Zn = 8.43 mg/1 9/ 18/ 15 Zn = 12.8 mg/1 9/22/15 Zn = 6.78 mg/1 9/23/15 Zn = 3.97 mg/1 9/24/15 Zn = 3.93 mg/1 More recently 4/27/17 Zn = 0.0475 mg/I( I wonder if this one is a typo and should be 0.475 mg/1) 5/2/17 Zn = 0.488 6/6/17 Zn = 0.408 mg/1 Let me know if you need further information. Deborah Gore PERCS Unit Supervisor Division of Water Resources Department of Environmental Quality 919-807-6383 office 919-807-6489 fax deborah.gorea-ncdenr.gov 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Orlando, Anjali Sent: Monday, April 09, 2018 1:51 PM To: Gore, Deborah <deborah. ore o ncdenr.gov> Cc: Hennessy, John <john.hennessy@ncdenr.gov>; Heim, Tim <Tim. Heim@ncdenr. gov> Subject: FW: Riverstone Industrial Park WWTP Hi Deborah, I am working on the permit renewal for Riverstone Industrial Park WWTP NCO087084 in the Town of Forest City. Their Industrial Pretreatment Permit is IUP 90008. After talking to Landon and Tim in the Asheville regional office, they would like to add a zinc limit to their permit because they are accepting wastewater from American Zinc Products which recycles zinc, and zinc has been found in their domestic waste stream. I was wondering if you might have any pretreatment data for zinc for this facility that could be used to generate a limit? Thanks Anjali Anjali Orlando Environmental Specialist Compliance and Expedited Permitting Unit Division of Water Resources N.C. Department of Environmental Quality Office: 919-807-6393 anj ali. orlando@ ncdenr. gov Mailing address: 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Orlando, Anjali Sent: Monday, April 9, 2018 10:48 AM To: Heim, Tim <Tim.Heim@ncdenr.gov> Subject: RE: Riverstone Thanks Tim From: Heim, Tim Sent: Friday, April 6, 2018 2:42 PM To: Orlando, Anjali <anjali.orlando@ncdenr.gov>; Hennessy, John <j ohn. hennes sy@ncdenr. gov> Subject: FW: Riverstone FYI, we are working on getting you this info per the call. Have a good weekend. -T From: Willmer, Mikal Sent: Friday, April 06, 2018 11:41 AM To: Heim, Tim <Tim.Heim@ncdenr.gov>; Price, Bev <bev.price o ncdenr.gov> Cc: Davidson, Landon <landon.davidson@ncdenr.gov> Subject: Riverstone Hey I went ahead and called Sonny since Jeff was leaving early today. Sonny says he'll be there this afternoon if you all have any more questions for him. He is going to get together all influent, sludge and effluent monitoring data they've been doing. They have been monitoring zinc quarterly when they collect toxicity. Sonny says generally Zn numbers above I mg/L in their effluent will cause their tox test to fail (Worked with ETS to come up with the 1 mg/L correlation). They are looking to implement actual metals limits within their IUP before they start production again in 2019. He believes the potential limits were based off of a general headworks analysis in consultation with Deborah Gore. Sonny doesn't think AZP would be able to meet the 0.406 mg/L Zn limit without some form of pretreatment especially since they're exceeding that right now. They're also not sure how many of the cross connections with the domestic sewer at AZP previously discovered have been eliminated since they've shut down. I asked them if there were other contaminants of concern and they said most metals (saw high numbers when the facility was in operation) and NH3. Ideally Forest City Staff would like to get them off of the collection system if they won't implement some form of pretreatment. Mikal Willmer Environmental Specialist -Asheville Regional Office Water Quality Regional Operations Section NCDEQ-Division of Water Resources Office: 828-296-4686 Fax: 828-299-7043 Mikal.willmer@ncdenr. gov 2090 US Hwy. 70 Swannanoa, NC 28778 ^'Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.