THE CITY OF BRYANT, ARKANSAS SAMPLING AND TESTING PLAN FOR SITE SPECIFIC TESTING FOR COPPER AND ZINC BRYANT WASTEWATER TREATMENT FACILITY
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1 THE CITY OF BRYANT, ARKANSAS SAMPLING AND TESTING PLAN FOR SITE SPECIFIC TESTING FOR COPPER AND ZINC BRYANT WASTEWATER TREATMENT FACILITY NPDES PERMIT NO. AR342 ORIGINAL SUBMISSION DATE: NOVEMBER 16, 215 PREPARED FOR: City of Bryant Department of Public Works 119 S.W. 2 nd Street Bryant, Arkansas 7222 PREPARED BY: Crist Engineers, Inc. 25 Executive Court Little Rock, Arkansas 7225
2 SECTION 1 INTRODUCTION TABLE OF CONTENTS 1.1 Background Scope of Work SECTION 2 SAMPLING AND ANALYSIS 2.1 Sampling Testing and Frequency Data Analysis i
3 LIST OF TABLES Table 1 1: Effluent and Monitoring Requirements for Cu an Zn Table 2 1: Description of Sampling Locations Table 2 2: Testing Parameters and Frequency ii
4 LIST OF FIGURES Figure 2 1: Sample Locations Hurricane Creek Basin iii
5 1.1 BACKGROUND SECTION 1 INTRODUCTION The City of Bryant is authorized to discharge treated sewer through the National Pollutant Discharge Elimination System (NPDES) administered by the Arkansas Department of Environmental Quality (ADEQ). On November 7, 214, the City of Bryant received a new NPDES permit (Permit No.: AR342) that outline effluent limitations and monitoring requirements for Total Recoverable Copper (Cu) and Total Recoverable Zinc (Zn). Currently Cu and Zn are being reported once per month by obtaining grab samples. Unless otherwise modified, Cu and Zn effluent limitations outlined in Table 1 1 will become effective November 7, 217. Effluent Characteristic Discharge Limitation Mass Concentration (lbs/day) (µg/l) Monthly Monthly Avg. Avg. 7 Day Avg. Monitoring Requirements Frequency Sample Type Copper, Total Recoverable (Cu) Once/month Composite Zinc, Total Recoverable (Zn) Once/month Composite Table 1 1 Effluent and Monitoring Requirements for Cu and Zn As required under Section B.2, a progress report on Cu and Zn was submitted on October 21, 215, under separate cover to ADEQ that demonstrated one exceedance on Zn for the month of March 215 based on the proposed effluent limitation scheduled to be effective on November 7, 217. The Cu and Zn progress report is attached in Appendix A. In concert with the Cu and Zn effluent testing, upstream Hardness values were sample and tested from June 215 to September 215. The Hardness values ranged from 35 to 88 mg/l. The Hardness value used to calculate the Reasonable Potential at the time of the permit issuance was 31 mg/l. The current eco region Hardness established by the Continuing Planning Process (CPP). Initial Hardness testing upstream of the Outfall 1 has demonstrated a range of Hardness values greater that the Hardness value utilized to calculate the Reasonable Potential for the permit (31 mg/l). A letter presenting the upstream Hardness testing results were sent to ADEQ on October 21, 215. Further the letter outlined the intent of the City of Bryant to exercise the right identified in Condition 16 of Part II of the NPDES permit and submit a major modification request to modify or remove Total Recoverable Copper and Total Recoverable Zinc based upon site testing. A copy of the initial Hardness testing letter to ADEQ is provided in Appendix B. City of Bryant Site Specific Testing for Copper and Zinc Crist Engineers, Inc. Page 1 1
6 As a result of the October 21, 215 letter to ADEQ advising the initial Hardness testing results and intent of a modification request, ADEQ requested a meeting on November 9, 215, to discuss the requirements of the on site Hardness evaluation for the City of Bryant. The attendees of the meeting is shown in Appendix C. The meeting reviewed the testing and evaluation requirements outlined by ADEQ to consider a permit modification request for Cu and Zn. 1.2 SCOPE OF WORK The scope of work for the site specific Hardness testing and evaluation is to document a plan to develop the necessary data set to support site specific hardness, dissolved and total fractions of Cu and Zn, and TSS linear coefficients that could be used to adjust or eliminate the need on effluent limitations for Cu and Zn on Outfall 1. The sampling and analysis plan proposed in Section 2. below is to develop a data set to support site specific values to adjust water quality based effluent limitations for Cu and Zn. City of Bryant Site Specific Testing for Copper and Zinc Crist Engineers, Inc. Page 1 2
7 2.1 SAMPLING SECTION 2 SAMPLING AND ANALYSIS PLAN The Hurricane Creek drainage basin was delineated utilizing USGS quadrangle maps and further sub divided into sub basins for sampling. ADEQ advised the City of Bryant at the November 9 meeting to ensure that samples were taken in rural or natural areas to gain Hardness values that were not influenced by other point sources. The delineation approach divides the subbasins into rural and urban areas upstream of Outfall 1. Table 2 1 provides the sample location and descriptions. Figure 2 1 provides a graphical representation of the subbasins on the USGS quardrangle map. Sample Point. Drainage Basin Subbasin Area (mi 2 ) Cumm. Drainage Area (mi 2 ) HC 1 HC LHC 1 LHC HC 2 HC HC 3 HC & LHC HC 4 (1) HC Description Hurricane Creek at drain culvert on Avilla W.,.6 miles west of Congo Ferndale Rd.; upstream of Outfall 1 Little Hurricane Creek at drain culvert on Northlake Rd.,.5 miles west of Springhill Rd.; upstream of Outfall 1 Hurricane Creek at bridge on Zuber Road,.1 mile west of Gilbert Rd; upstream of Outfall 1 Hurricane Creek at bridge on I 3 frontage road (westbound),.4 miles west of Springhill Road; upstream of Outfall 1 Hurricane Creek at HWY 183 (S. Reynolds Rd).culvert,.21 mi. north of Tom Road; downstream of Outfall 1 Abbreviations: HC = Hurricane Creek LHC = Little Hurricane Creek Cumm. = Cummulative (1) Note: On days that HC 4 is sampled, Outfall 1 will be sampled Table 2 1: Description of Sampling Locations City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page 2 1
8 LEGEND LHC 1 LHC 2 HC 1 HC 2 HC 3 HC 4 SAMPLE POINT HC 4 LHC - LITTLE HURRICANE CREEK SUB-BASINS HC - HURRICANE CREEK SUB-BASINS BRYANT WWTP SAMPLE POINT LHC 1 HC SQ. MILES OUTFALL 1 SAMPLE POINT HC 3 LHC SQ. MILES LHC SQ. MILES HC SQ. MILES SAMPLE POINT HC 2 P:\213 Projects\ Bryant WWTP NPDES Renewal\6 - CADD\2 - Civil\EXHIBIT 1.dwg HC SQ. MILES HC SQ. MILES SAMPLE POINT HC 1 CRIST ENGINEERS, INC. CONSULTING ENGINEERS BRYANT, ARKANSAS SAMPLE LOCATIONS HURRICANE CREEK BASIN N 5,' FIGURE 2-1 DESIGNED: CAJ DRAFTED: RDW CHECKED: CAJ 1" = 5,'-" DATE: NOVEMBER 215 JOB NO.: 1314 SCALE: 1" = 5'
9 A review of the ADEQ National Pollutant Discharge Elimination System (NPDES) database showed that there were not any permitted discharges upstream of Outfall 1 in the Hurricane Creek watershed. 2.2 TESTING AND FREQUENCY Cu and Zn limits are derived from values that are function of the default Gulf Coastal eco region which uses a Hardness (31 mg/l). Hardness values are further adjusted using a ratio of dissolved to total metal (C/Ct) that is based on a linear coefficient. The linear partition coefficient is based on the default Gulf Coastal eco region total suspended solids value of 5.5 mg/l. The values are referenced in the Continuing Planning Process (CPP). Based upon this derivation of values to establish reasonable potential and effluent limits for Cu and Zn, Table 2 2 provides the testing schedule and methodology for each location identified in Section 2.1. In addition to the test parameters the plan proposes to utilize a frequency of 2 sample sets, with ten (1) sets collected during low flow months (June 216 through October 216) and ten (1) set collected during high flow months (November 215 through May 216). To the extent possible sampling will be conducted to capture actual low and high flow conditions, not low and high flow seasons. Water levels will be documented at each location during each sampling event. Note that sampling will occur at Outfall 1 on days when HC 4 is samples indicated in Table 2 2. Parameter Test Method Frequency Sample November May June October Type TSS USGS Tests 1 Tests Grab Hardness SM234 B Tests 1 Tests Grab Zinc, Dissolved EPA Tests 1 Tests Grab Zinc, Total Recoverable EPA Tests 1 Tests Grab Copper, Dissolved EPA Tests 1 Tests Grab Copper, Total Recoverable EPA Tests 1 Tests Grab Abbreviations: USGS = United States Geological Service SM = Standard Method EPA = Environmental Protection Agency Table 2 2: Testing Parameters and Frequency 2.2 DATA ANALYSIS At the November 9, 215 meeting, ADEQ indicated guidelines proposed for the Gerdau Inc. facility in Fort Smith, Arkansas, be utilized as guidance. As such, the 5 th percentile of all data will be used for site specific Hardness and the 95 th percentile of the data will be uses for the total and dissolved fractions of Zn and Cu. The 15 th percentile TSS value will be used for the site specific TSS based linear partition per ADEQ (2). The percentile values will the be used for the basis City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page 2 3
10 to recalculate the reasonalble potential for Zn and Cu and subsequent effluent limits, if necessary. City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page 2 4
11 APPENDIX A City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page A 1
12
13
14 1-Dec 5-Jan 14-Jan 4-Feb 25-Mar 9-Apr 7-May 4-Jun 11-Jun 17-Jun 24-Jun 2-Jul 9-Jul 15-Jul 6-Aug 13-Aug 21-Aug 26-Aug 1-Sep 1-Sep 17-Sep 24-Sep Copper (ug/l) Figure 1: Bryant WWTP - Outfall 1 Copper 7-Day Concentrations 3 Copper 7 Day Permit Limit 25 7 Day Permit Limit = 24.5 ug/l
15 January February March April May June July August September Copper (ug/l) Figure 2: Bryant WWTP - Outfall 1 Copper Monthly Concentrations Copper Monthly Permit Limit Monthly Permit Limit = 12.2 ug/l
16 January February March April May June July August September Copper (lb/day) Flow (MGD).35.3 Figure 3: Bryant WWTP - Outfall 1 Copper Monthly Loading Copper Monthly Loading - Permit Limit Effluent Flow Monthly Loading Permit Limit =.31 lb/day
17 1-Dec 5-Jan 14-Jan 4-Feb 25-Mar 9-Apr 7-May 4-Jun 11-Jun 17-Jun 24-Jun 2-Jul 9-Jul 15-Jul 6-Aug 13-Aug 21-Aug 26-Aug 1-Sep 1-Sep 17-Sep 24-Sep Zinc (ug/l) 25 Figure 4: Bryant WWTP - Outfall 1 Zinc 7-Day Concentrations Zinc 7 Day Permit Limit 7 Day Permit Limit = 232. ug/l
18 January February March April May June July August September Zinc (ug/l) 14 Figure 5: Bryant WWTP - Outfall 1 Zinc Monthly Concentrations Zinc Monthly Permit Limit 12 Monthly Permit Limit = ug/l
19 January February March April May June July August September Zinc (lb/day) Flow (MGD) 4 Figure 6: Bryant WWTP - Outfall 1 Zinc Monthly Loading Zinc Monthly Permit Limit Effluent Flow Monthly Loading Permit Limit = 2.89 lb/day
20 APPENDIX B City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page B 1
21
22
23 1-Dec 5-Jan 14-Jan 4-Feb 25-Mar 9-Apr 7-May 4-Jun 11-Jun 17-Jun 24-Jun 2-Jul 9-Jul 15-Jul 6-Aug 13-Aug 21-Aug 26-Aug 1-Sep 1-Sep 17-Sep 24-Sep Copper (ug/l) Figure 1: Bryant WWTP - Outfall 1 Copper 7-Day Concentrations 3 Copper 7 Day Permit Limit 25 7 Day Permit Limit = 24.5 ug/l
24 January February March April May June July August September Copper (ug/l) Figure 2: Bryant WWTP - Outfall 1 Copper Monthly Concentrations Copper Monthly Permit Limit Monthly Permit Limit = 12.2 ug/l
25 January February March April May June July August September Copper (lb/day) Flow (MGD).35.3 Figure 3: Bryant WWTP - Outfall 1 Copper Monthly Loading Copper Monthly Loading - Permit Limit Effluent Flow Monthly Loading Permit Limit =.31 lb/day
26 1-Dec 5-Jan 14-Jan 4-Feb 25-Mar 9-Apr 7-May 4-Jun 11-Jun 17-Jun 24-Jun 2-Jul 9-Jul 15-Jul 6-Aug 13-Aug 21-Aug 26-Aug 1-Sep 1-Sep 17-Sep 24-Sep Zinc (ug/l) 25 Figure 4: Bryant WWTP - Outfall 1 Zinc 7-Day Concentrations Zinc 7 Day Permit Limit 7 Day Permit Limit = 232. ug/l
27 January February March April May June July August September Zinc (ug/l) 14 Figure 5: Bryant WWTP - Outfall 1 Zinc Monthly Concentrations Zinc Monthly Permit Limit 12 Monthly Permit Limit = ug/l
28 January February March April May June July August September Zinc (lb/day) Flow (MGD) 4 Figure 6: Bryant WWTP - Outfall 1 Zinc Monthly Loading Zinc Monthly Permit Limit Effluent Flow Monthly Loading Permit Limit = 2.89 lb/day
29
30 APPENDIX C City of Bryant Site Specific Testing and Analysis for Cu and Zn Crist Engineers, Inc. Page C 1
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