NC0034754_Fact Sheet_20181019

Fact Sheet
NPDES Permit No. NCO034754
Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: July 16, 2017
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑X 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" d 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
Facility Information
Applicant/Facility Name:
CommScope, Inc./ CommScope-Catawba WWTP
Applicant Address:
6519 CommScope Road, Catawba, NC 28609-0199
Facility Address:
6519 CommScope Road, Catawba, NC 28609-0199
Permitted Flow:
0.02 MGD
Facility Type/Waste:
MINOR Industrial; 100% domestic
Facility Class:
Grade 11 Biological Water Pollution Control System (WPCS)
Treatment Units:
Manual/automatic bar screen, flow equalization basin, dual train
aeration basins with two basins per train, dual secondary clarifiers, dual
trojan UV disinfection, digester, effluent composite sampler, aerobic
sludge stabilization tank, sludge holding tank, instrumented effluent
flow measurement
Pretreatment Program (Y/N)
N
County:
Catawba
Region
Mooresville
Briefly describe the proposed permitting action and facility background: CommScope Incorporated has
applied for an NPDES permit renewal at 0.02 MGD for the CommScope WWTP. The facility
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manufactures coaxial cable by extrusion of a plastic coating over copper -plated aluminum wires. While
the permittee used to generate contact cooling water from cooling pits used to cool the fabricated copper
cable, process changes have eliminated the generation of any contact cooling water. The facility now
treats 100% domestic wastewater.
In the existing 2010 permit, the facility has a primary Outfall 001 and secondary Outfalls 002, 003 and
004. With this renewal, CommScope Incorporated informed the Division that the waste streams
discharging to Outfalls 002, 003 and 004 have been eliminated and requested that Outfalls 003 and 004 be
removed from the permit. They requested that Outfall 002 become the primary outfall, mistakenly
thinking permit limits would be less stringent if the sanitary wastewaters were discharged from Outfall
002. However, since the receiving stream remains the same, whether they discharge to the facility's pond
or the unnamed tributary, the limitations remain the same. Therefore, after discussions with CommScope
Inc., it was agreed to maintain Outfall 001 as the primary outfall and eliminate Outfalls 002, 003 and 004.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — UT to Terrapin Creek
Stream Segment:
11-81-(1)
Stream Classification:
WS-IV
Drainage Area (mi2):
0.30
Summer 7Q10 (cfs)
0.06
Winter 7Q 10 (cfs):
0.10
30Q2 (cfs):
0.12
Average Flow (cfs):
0.30
IWC (% effluent):
34%
303(d) listed/parameter:
Not Listed
Subject to TMDL/parameter:
No
Subbasin/HUC:
03-08-32; 03050101
USGS Topo Quad:
E14NE
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3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of April 2014 through June 2018.
Table 1. Effluent Data Summary Outfall 001
Permit
Parameter
Units
Average
Max
Min
Limit
Flow
MGD
0.005
0.05
0.00003
MA 0.02
BOD5, Summer
mg/1
2.78
13
< 2
MA 16.0
DM 24.0
BOD5, Winter
mg/l
6.3
199
< 2
MA 30.0
DM 40.7
Total Suspended Solids
mg/1
4.96
212
2.6
MA 30.0
DM 39.2
Ammonia, Summer
mg/1
0.92
11.54
< 0.5
MA 2.0
DM 10.0
Ammonia, Winter
mg/1
1.4
28.1
< 0.5
MA 4.3
DM 21.5
Oil and Grease
mg/l
5.96
17.6
3
DM 29
TRC
µg/1
N/A
N/A
N/A
DM 28
Fecal Coliform
#/100 ml
1.5
2419
1
MA 200
(geometric mean)
DM 400
Dissolved Oxygen
mg/l
9.3
20.8
5.77
DA >6.0
Temperature
degC
19.8
31
4
0 < pH <
6.9.0
pH
S.U.
7.8
8.91
6.4
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 be proposed for this
permit action: Instream temperature and dissolved oxygen monitoring is required for the permit.
Upstream and downstream data was provided by the permittee. During this analysis, which utilized data
ranging from August 2016 to May 2018, it was concluded that the downstream DO ranged from 2.3 to
13.46 mg/L. The upstream DO ranged from 2.4 mg/L to 22.5 mg/L. One instance where the downstream
dissolved oxygen dropped below 4 mg/L occurred on September 6t1i, 2016. Upon observing the reported
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dissolved oxygen upstream on that day, it was concluded that the low DO was not due to the actions of
the facility. Based on a student's Mest, it was concluded with 95% confidence that no statistically
significant difference (p-value > .05) between upstream and downstream DO exists.
Downstream temperature ranged from 6.8 to 29.9 degrees Celsius. Upstream temperature ranged from 5.4
to 29.7 degrees Celsius. One instance where the downstream temperature rose above 29 degrees Celsius
occurred on July 17', 2017. Upon observing the reported temperature upstream on that day, it was
concluded that the high temperature was not due to the actions of the facility. The temperature differential
did not rise above 2.8 degrees Celsius during the observed months. Based on a student's t-test, it was
concluded with 95% confidence that there is no statistically significant difference (p-value > .05) between
upstream and downstream temperature.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): NO
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported two 5-
day BOD, one fecal coliform, two ammonia, and two total suspended solids limit violations in 2014. In
2015, the facility reported one fecal coliform and three ammonia limit violations. In 2016, the facility
reported one dissolved oxygen limit violation. Lastly, the facility reported two ammonia limit violations
in 2017. All reported limit violations occurred at Outfall 001.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility reported no flow for chronic toxicity monitoring events from February 2014
to May 2018 at Outfalls 001, 002, 003 and 004.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in January of 2017 reported that the facility was in compliance. It was reported that Outfalls 002, 003 and
004 can no longer discharge process wastewater. Only sanitary wastewater is discharged through Outfall
001.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
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): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): N/A
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/l for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
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If permit limits are more stringent than TBELs, describe how limits were developed: Limitations on
monthly summer and winter BOD averages for Outfalls 001, 002, 003 and 004 were initially set based on
a wasteload allocation (WLA) conducted in 1993. The monthly average limits for Outfall 001 were water
quality based and were set at 16 mg/L for summer and 30 mg/L for winter. The monthly average limit of
5 mg/L for Outfalls 002, 003 and 004 was water quality based as well and was set to protect the instream
assimilative capacity. In 2004, the Permittee requested to "bleed in" contact cooling water into the Outfall
001 and the daily maximum limits for summer and winter BOD were reassessed based on effluent
guidelines for 40 CFR 463 Plastics Molding and Forming Point Source Category, Subpart A — Contact
Cooling and Heating Water Subcategory 463.12. The daily maximum limit for summer BOD generated
based on the guidelines was less stringent than the existing water quality based limit for Outfall 001 and
was not adopted. The current daily maximum limit for winter BOD in Outfall 001 is resultant of the
reassessment based on 40 CFR 463. In their application, the Permittee explained that the use of cooling
water has been eliminated from the facility's processes. Basing the BOD limits on those applied to the
permit prior to the inclusion of contact cooling water would change the winter daily maximum limit for
Outfall 001 to 45 mg/L, which would result in a less stringent BOD daily maximum limit. Therefore, due
to antibacksliding regulations, there are no proposed changes for BOD in Outfall 001. As there will no
longer be any discharge to Outfalls 002, 003 and 004, the limits will be removed along with the
permission to discharge.
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/l (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: Limitations for
Total Residual Chlorine (TRC) were added in 2007 based on DWR procedure for facilities that use
chlorine for disinfection. The facility has made changes to its disinfection process, now incorporating UV
disinfection. However, the facility will be using sodium hypochlorite and sodium sulfite tablets as backup
if needed. Therefore, the daily maximum TRC limit of 28 µg/l will remain in the permit but monitoring
will be reduced to the time immediately following any event that sodium hypochlorite is used.
A Wasteload Allocation was conducted in 1995 which set summer and winter monthly average limits for
ammonia at 2 mg/L and 4.3 mg/L, respectively. In 2007, summer and winter weekly average limits for
ammonia were set at 10 mg/L and 21.5 mg/L, respectively, based on DWR procedure. The weekly limits
were calculated at 5 times the existing monthly ammonia limits. Ammonia has been reviewed as a
toxicant and it was concluded that the current limits are protective. There are no proposed changes for
ammonia.
Reasonable Potential Analysis (RPA) for Toxicants
All process wastewaters have been eliminated and the Permittee is discharging 100% sanitary wastewater.
Toxicants were not considered to be parameters of concern. No RPA was conducted.
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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: As this is a Minor facility and is no longer discharging
"complex" wastewater (contains anything other than domestic waste), WET testing has been removed
from the permit.
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.
Describe proposed permit actions based on mercury evaluation: The facility is not known to discharge
mercury.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: N/A
7. 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
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8. 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
9. 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 213.0500; 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 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
10. 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.
11.Summary of Proposed Permitting Actions:
Table 2. Current Permit Conditions and Proposed Changes 0.02 MGD Outfall 001
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.02 MGD
No change
15A NCAC 213.0505
BOD5
Summer:
No change
WQBEL. Based on WLA 1995. 15A
MA 16.0 mg/1(WQ)
NCAC 2B.0200; 40 CFR 463
DM 24.0 mg/1(WQ)
Winter:
No longer using cooling water;
MA 30.0 mg/1(WQ)
Antibacksliding 40 CFR 122.44(1)
DM 40.7 mg/1(EGL)
NH3-N
Summer:
No change
WQBEL. Based on WLA 1995. 15A
MA 2.0 mg/1
NCAC 213.0200
DM 10.0 mg/1
Reviewed NH3-N as toxicant and
Winter:
current limits are protective; See
MA 4.3 mg/1
attached WLA
DM 21.5 mg/1
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TSS
MA 30.0 mg/l (BPJ)
No change
WQBEL. Based on total load
DM 39.2 mg/l (EGL)
calculations conducted in 2004.
No longer using cooling water.
Antibacksliding 40 CFR 122.44(1)
Total Residual
DM 28.0 ug/L
Monitor only if
The facility utilizes UV disinfection
Chlorine
2/Week Monitoring
sodium hypochlorite is
but will use sodium hypochlorite as
added
backup
Fecal coliform
MA 200 /100ml
No change
WQBEL. State WQ standard, 15A
DM 400 /100ml
NCAC 2B .0200
Oils and Grease
DM 29.0 mg/l
Limit and monitoring
No longer using cooling water; No
removed
longer apply 40 CFR 463.12
DO
DA > 6.0 mg/L;
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Effluent, Upstream,
Downstream monitoring
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Temperature
Effluent, Upstream,
No change
15A NCAC 2B
Downstream monitoring
Toxicity Test
Acute Toxicity
Toxicity testing
WQBEL. 15A NCAC 2B.0200 and
Monitoring
requirement removed
15A NCAC 2B.0500; Facility is
Minor and does not discharge
complex wastewater
Process Water
Special Condition A.(4.)
Requirement removed
No longer treating cooling or
Estimation
process water
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max, DA —
Daily Average
As permission to discharge to Outfalls 002, 003 and 004 is being removed from the permit, all current
permit conditions/requirements regarding Outfalls 002, 003 and 004 are to be removed.
12. Public Notice Schedule:
Permit to Public Notice: August 21, 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.
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13. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• A typographical error was fixed in the fact sheet description of ammonia limitations, changing the
reference to a winter monthly average ammonia limit of "2.3 mg/L" to "4.3 mg/L."
• As Mr. George Crosby no longer works for CommScope Inc., the cover letter will be addressed to
Jeff Phillips, Mr. Crosby's replacement as EHS Manager.
14. Fact Sheet Attachments (if applicable):
Waste Load Allocation Spreadsheet
Instream Monitoring Summary
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