NC0026689_CORRESPONDENCE_19891228

NPDES DOCUMENT SCANNIM& COVER SMIZET
NPDES Permit:
NC0026689
Denton WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization -to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondences
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
December 28, 1989
Thies docu eat is printed oa reuae paper - ianoz-e aay
coateat cam the rerwerse Bide

MEMO I oa
DATE:_-L� O O
TO: l o V�� SUBJECT: 1 Vkc Iii WW iP
l two ;tAS Co vvtvK2a o� e5t {�✓ n<� c� f �s i(q�uf5t -�otr rtitod i
T 0, vY& . wig evevy�',v j w ?ram++ �oww{� Yvµo - h5 *
3e ✓ � �eque�cc� a� 4t�rIT-�v �oD,�55, N+
(d CD U 4v vw hj yedL) ctr -}, glyv-b a5j�e✓►�u,c.-(
oXidcm\c�ic{H CC�uSes ox�i-��� 0
-� Q(l�kC� UXJS wU�tn Vac}Fk6 f `�(^t �V�av� C�AVit L20 4 De ��isc�.•
riot/-� �=iv '8�1 �uere vc�o y�o-} Coh�stEQ
ppevcc V q*j Pa54 Sub h �i , ►5� � dafw
7 i5tov�co P data -b 0e4tvmvw �ontpuav u - vo
— l v� e 5cr rnpleo aej.c) -�D
cows uv%-eKd o 4uJtorV, a b v i vq +b lie TU&) U
yy� 't Y i � J -�cz 4D 1'Iti0
vrouit0V;K dutycx�e o�culntotp tbTV-bYtCU C4- b65j6-Gv watua;kK�.
vwou. u\, Mdu/t4l&w�w� Su�a�ew�bte."
North Carolina Department of Environment,
`:u�g Health, and Natural Resources

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Winston-Salem Regional Office
December 20, 1989
M E M O R A N D U M
TO: Don Safrit
FROM: Mike MickeyV`�
SUBJECT: Draft Permit Modification Request
NPDES Permit No. Nc0026689
Davidson County
0
7989
POO
The Town of Denton's permit modification request dated
November 28, 1989, has been reviewed. The town requested
that the proposed weekly monitoring requirements for BOD,
TSS, NH3as N and fecal coliform be reduced to 2/month and
the monitoring frequencies for all metals be reduced to
quarterly.
WSRO recommends that the frequencies for BOD, TSS,
NH -N and fecal coliform remain as stated in the permit for
tha following reasons:
1) The oxidation ditch channel overflows during heavy
rains. The operator must bypass the oxidation
ditch for hour or days at a time until the I/I
subsides. The partially treated wastewater is
only routed to the secondary clarifier before
discharging. Weekly monitoring would better
document this poor effluent quality.
2) All samples collected prior to August 1989, were
not taken by compositing as required by the
permit. Since all samples were grab, the previous
self -monitoring data is not representative of the
effluent actually discharged.
3) An investigation by WSRO staff revealed that the
operator in responsible charge (ORC) had submitted
falsified data on the self -monitoring reports.
The operators certificate was revoked by the WWTP
Operators Certification Commission on 9/28/89.
This further questions the reliability of past
historical data with which to determine
compliance.
Y$

Don Safrit
Page #2
December 20, 1989
4) On December 19, 1989, the Director assessed civil
penalties against the Town totalling $6,379.39 for
violations of final effluent limits for BOD, TSS,
NH -N and fecal coliform in February, March and
April 1989.
In summary, the weekly monitoring requirements for the
above parameters are necessary to provide an accurate data
base in order to determine compliance. The present 2/month
frequencies are totally inadequate for a 0.3 MGD WWTP with
obvious design, operational and compliance problems.
In regards to metals monitoring, WSRO recommends a
reduction in the monitoring frequency to monthly for the
three metals with limits. (not quarterly as requested by the
town). Samples collected by WSRO on 7/10/89 showed Cd, Ni
and Pb to be less than detectable. The influent wastewater
to the town is predominantly domestic with Bisher Hosiery
(4,500 GPD) the only industry required to pretreat their
wastes. In addition, it may be advisable to include the
following clause in the permit so the town will have the
option for further metals frequency reductions if monitoring
data is consistently below detection:
"If the permittee, after monitoring for at least twelve
months, can provide monitoring data that indicates the
metals are below the reference method detection limit or
well below the permit limitation, the permittee may request
that the monitoring requirements be reduced to a lesser
frequency."
If you have any questions, please call.
MMM/vm
cc: Central Files
WSRO

gown Of J�enE0I2
1µ''
(s'�� 4 19g9
111VUIJIt�/I9Ih IY( SLoif�I{
Phone [phone]
DENTON, NORTH CAROLINA 27239
November 28, 1989
RE: NPDES Draft Permit
RECEIVE[1o. NC 0026689
DEC 8 1989
AJ7t.
1'-'ATER r-:UAUTY
'SCC k i0N
DEC 111989
Mr. R. Paul Wilms, DirectovERMITS&ENGINEERING
Division of Enviornmenta�l Management
P.O. Box 27687 ! F
Raleigh, North Carolina 27611-7687
Dear Mr. Wilms:
With regards to the referenced draft permit, we respectfully
request modification of the proposed frequency of testing
for BOD, TSS, NH3 as N, and fecal coliform be reduced to
twice per month. In addition., we req4uest the proposed
frequency of analysis for the six heavy metals be reduced
to quarterly tests. Recent analysis for these metals,
conducted by the town's certified lab and the state lab., have
yielded results below detectable.limits. This is directly
attributed to the town's relatively small number of significant
industrial users. It should be noted also, that thedraft.
requirements will increase lab costs by a factor of:4:=$;over._,.
one renewal period.
As required, the town will instigate the proposed draft's
testing requirements in December 1989• We propose;to adhere
to these requirements for a`six (6)-month period, at which
time we request your office re-evaluate ._:the,;,propos'_ed testingi `
frequency based upon the available dataiw
N V T
Your favorable consideration of"this request would ben l_ '_,
CC: Town Commissioners
Mr. Mike Mickey, WSRO
Mr. Daniel W. Pritchett, PE