NC0029131_Meeting Notes_20020712

NPDES DOCUWENT !;CANNING COVER SHEET
NPDES Permit:
NC0029131
Kittrell Job Corps WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Meeting Notes
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
July 12, 2002
This document is printed on reuse paper - ignore any
content on the reYerse side

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Re: kittrell mtg. tomorrow
Subject: Re: kittrell mtg. tomorrow
Date: Thu, 11 Jul 2002 15:23:23 -0400
From: Dave Goodrich <[e-mail]>
To: Susan A Wilson <[e-mail]>
Composite is obviously ok. I think 3/week would be the limit. Daily
monitoring seems excessive.
Susan A Wilson wrote:
> RRO has some issues with these guys we are meeting with tomorrow. due
> to sporadic compliance history and because they can't seem to find a fix
> for their problems - RRO wants to give the composite sampling and a
> great frequency than weekly. what's out line on this? they have hired
> dewberry and davis which i guess is a good thing.
1 of 1 7/11/02 3:31 PM

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Hey Susan,
Attached is the CEI and pictures at Kittrell Job Corps. I talked to
the director of the center yesterday and he still has no idea what
Dewberry (their engineers) will present. I think they plan to do little
or nothing due to a stretch of compliance even though the plant is
easily upset by one running toilet. If they pursue this line, I plan to
ask Ken to require them to do composite sampling and more frequent
sampling than weekly. They pull samples between 7:30 AM and 8 AM. I will
also place samplers at their discharge and run a tox test. The effluent
is consistently cloudy from what the RRO has seen on visits. Thanks for
your help and see you tomarrow around 8:30.
-7(4-4 9\11

June 18, 2002
Mr. Kenneth Schuster
Water Quality Regional Supervisor
Point Source Compliance/Enforcement Unit
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
REF: Notice of Violation
Show Cause Meeting
Compliance Evaluation Inspection
Kittrell Job Corps Center WWTP
NPDES Permit No. NC0029131
Vance County
Dear Mr. Schuster:
In response to the Compliance Evaluation Inspection Report of May 21, 2002 per your
direction to respond to inspection items comments and/or recommendations #s 4, 5, 6, 7,
9, 11, 15 and #16 respectively, the following responses are submitted.
item #4. An ORC log is kept in accordance with the requirements of 15A NCAC 2B
.0506(c) (3). However, a daily calibration log of the pH, residual chlorine, and
dissolved oxygen meters is not being kept which is a violation. Please ensure that
these logs are created and utilized every time a meter is used for reporting data on
the Discharge Monthly Report (DMR).
Response: Our calibration of our pH and dissolved oxygen meters are normally
kept on our benchsheets themselves. We have had problems with our 4.0 pH
buffer solution being read by our meter. We have purchased a new pH probe
(received June 17, 2002) to remedy this problem. Our pocket colorimeter was
factory calibrated, however if we need to calibrate the meter each time it is used,
we will order reagents to prepare a known chlorine standard solution. Our
dissolved oxygen meter is calibrated in water saturated air. We calibrate this
instrument using barometric pressure, altitude, and salinity. This was not
recorded on some of our bench sheets. We will procure a separate notebook for
each of these instrument and calibration records will be clearly recorded for each.

Inspection Response
Page 2
Item #5. Mr. Matthews stated during the inspection that the pH meter would not
read the 4.0 buffer and the meter had recently been returned after being repaired.
It was noted that, in the past, the pH meter was calibrated with pH buffers 4.0, 7.0
and 10.0. All field parameters that are measured with a meter must have a three
point calibration. It is recommended that a 4.0 and 10.0 pH buffer be utilized to
calibrate the meter and a 7.0 pH buffer be used to check the calibration. The meter
reading for the 4.0, 10.0 and 7.0 must be recorded in a log. Conductivity is also
reported by field meter and must employ a three point buffer calibration that is
recorded in a log. In addition, all buffers must have an expiration date noted on the
bottle. Dissolved oxygen is determined by air calibration and also must be recorded
in a log along with a check of calibration accuracy. Please state the facility's remedy
for these concerns.
Response: We have purchased a new pH probe (received June 17, 2002) and we
will calibrate the meter using a 4.0 and 10.0 pH buffer solution. We will then
check the calibration with a 7.0 pH buffer solution. We will then check the
calibration with a 7.0 pH buffer. We do have all of these buffer solutions on site,
but the factory did not record an expiration date on the containers. ORC will call
Hach (manufacturer) to find out what the expiration date for our buffers are and
record it on the containers.
We do not conduct our own conductivity recording or testing. This parameter is
collected by us and sent to Tritest Laboratory for testing weekly. Results for the
weekly tests are maintained in a log located at the WWTP.
Item #6. The effluent was cloudy in appearance and appeared to have excess solids
suspended in it. Please state what the facility plans are to improve the effluent
quality.
Response: The effluent does get cloudy from time to time. On the day of
inspection, the effluent was slightly cloudier than normal, but the samples taken did pass
effluent test that day. The Subcontract Operators keep sludge blankets at 2 to 3 feet as
much as possible and waste when needed. This is the only control available to keep
solids out of our effluent.

Inspection Response
Page 3
Jtem #7. The circular clarifier is approximately 10 feet across and 10 feet deep. At
the time of the inspection, the sludge depth was 6 feet and the discharge was cloudy.
Response: The reason for the sludge blanket depth of 6 feet is that our return
sludge flow cannot be increased. We keep it returning to its maximum, but still
sometimes the clarifier has slightly more sludge in it than we would like and if we
waste too much sludge our MLSS numbers plummet and we don't get maximum
removal of BOD, TSS, and other parameters. Mr. Pulley, Kittrell JCC; Facility
Maintenance Supervisor and Mr. Matthews, Subcontract ORC Team, also found
another contributing factor to our recent return sludge problem. The pipe in the
center of the clarifier that pulls the sludge from the bottom and sends it to the
aeration basin our digester was eaten up and surely impeded some of the return
back to the aeration basin. This contributed to some of the cloudy appearance; but
we have been compliant on all samples April 2 - May 02. So the cloudiness is not
causing parameter violations.
Mr. Pulley has ordered a stainless steel piece of pipe for the clarifier and replaced
the corroded pipe, which should have been stainless steel originally. (Any submerged
piping in wastewater should be stainless steel). With this new pipe in place our sludge
blankets are around 2-3 feet and the effluent is clear.
Item #9. Mr. Matthews stated that sludge from this facility is land applied by
Granville Farms. Please supply sludge hauling records detailing dates and
amounts that were hauled for the period January 2001 through December 2001.
Response: Below are the sludge hauling records detailing dates and amounts that
were hauled the period requested.
Sludge Hauling Record
January 01 - December 31, 01
Date of Haul # of Loads Total Gallons (8000 gal/load)
01/09/01 2 16,000
02/02/01 1 8,000
03/09/01 2 16,000
04/20/01 1 8,000
06/06/01 2 16,000
07/22/01 3 24,000
08/29/01 2 16,000
10/21/01 2 16,000

No sludge removals occurred in November or December 2001. Not enough sludge was
generated to warrant removal during that period. This period included the two week
Winter Break for the students. January 21, 2002 had three loads removed.
Inspection Response
Page 4
Item # 11. Please detail what type of device is used for reporting daily
effluent temperature and how that instrument is calibrated. Be aware that
thermometers used for reporting purposes must be calibrated at least annually and
a record of that calibration should be kept.
Response: We use a NIST approved thermometer for reporting daily effluent
temperatures. The actual thermometer is a Thomas thermometer that reads from -
1 to 51 degrees Celsius, ordered from Fisher Scientific. We will check this
thermometer against a certified thermometer on a year basis and record in a
calibration log.
Item # 15.) The facility has applied for Field Parameter Laboratory Certification
to conduct Residual Chlorine, Dissolved Oxygen, pH and Temperature
measurements. In addition, Mr. Pulley stated that a low level residual chlorine
meter is being purchased that can detect to their permit limit of 28 mg/l. Please
indicate when that meter is to be purchased.
Response: The center has received the Food Parameter Laboratory Certification
to conduct the tests. Certification was received June 17, 2002. The new low level
residual chlorine meter (PR/2500 spectrum photometer) has been purchased and
was received June 17, 2002.
Item #16.) The subject facility has been assessed eighteen (18) times for violations of
the NPDES Permit since May 1998. The facility entered into Special Order by
Consent (SOC) EMC WQ 99-012 on June 19, 2000. That SOC was undertaken by
the Permittee to address problems at the wastewater treatment plant but those
changes have not been successful in achieving consistent compliance. Most
recently, on May 7, 2002, a "Noncompliance Report" was received for a plant upset
that discharged 12,150 gallons of partially treated wastewater. According to the
report, this was the result of a toilet suck running. This incident indicates that the
plant is easily upset and in fact the operator stated that the plant has problems when
the students return from holiday breaks.
Mr. Pulley stated during the inspection that the facility was recently
evaluated to determine what was required to maintain consistent compliance with
the subject permit and that he had made recommendations also. He also stated that

the City of Henderson's wastewater collection system was three miles away. Please
detail the findings of that evaluation along with the feasibility of connection to
Henderson's collection system. Please include cost analysis for all options. Upon
receipt of this correspondence, please contact Mr. Stafford to set up a Show Cause
Meeting at the Raleigh Regional Office to discuss the plant evaluation.
Inspection Response
Page 5
Response: * The subject plant received considerable upgrades during the year
2000. Upon the completion of the upgrades, the plant was functioning properly and our
record indicated long periods of compliance. Although recently, the compliance record
was punctuated with sporadic violations, we remain convinced that the current plant is
fundamentally sound. The Office of Job Corps is currently conducting a thorough
assessment of the plant to determine if the violations are the results of improper operation
or because of plant deficiencies. We will present our findings in the upcoming Show
Cause meeting scheduled for July 12, 2002.
The Office of Job Corps has invested considerable amount of funds in the current
plant and we firmly believe that the past history of compliance indicates that the plant has
adequate capacity and is capable of meeting the NCDENR requirements. We will
evaluate the plant and provide further enhancement where necessary. However, our
assessment and findings so far do not support the abandonment of the current plant. We
look forward to meeting you and would like to assure you our utmost cooperation.
*Denotes response submitted by National Office of Job Corps through PB Dewberry
McKissick & McKissick
In conclusion, the recommendations/suggestions and information from the Division of
Water Quality Central Office are being utilized or reviewed for consideration for use.
Sincerely,
Tim Wilkerson
Center Director
cc: Cookie Glasser, MTC Eastern Region VP
Gwendolyn Parks, Regional DOL Project Manager
Jef Fisher, MTC Director of Engineering

ae�of Nardi:hCaratria� = i
�part'rri`ent ofs Erivironme
aNatural,,�Resourc - „`
' •"��, �a •, ., , �
eigh,Regior Regional Office
:a1o. i. a �.-.+ lit+�f�).��:'.'.._�'+L'-?.a•.'�?'r._�: �,.«".-_;lkwis .
Subject: Notice of Violation • " . .
Show Cause Meeting
Compliance Evaluation Inspection
Kittrell Job CorpsyCenter<-
NPDES Permit No. NC0029131
Vance County
On May 15, 2002, Mr. Kirk Stafford "of the Raleigh _Regional Office and Ms.:Vanessa
Manuel of the Central Office ,conducted a: Compliance Evaluation Inspection;;of the subject
facility accompanied by Mr. Dale Matthews, Backup; Operator, in Responsible Charge and Mr.
Lawrence Pulley,. facility maintenance Their assistance and cooperation was helpful and
appreciated. As a rsult .of.the inspection, thefollowing items were noted
2) The facility' consists of three manual bar screens sputter box aerated_ equalization tank w
fine bubble diffusers, aeration basin with baffles, clarifier, chlorine contact with tablet" rr
chlorinator, dechlorination tank with tablet dechlonnator, ultrasonic effluent flow meter, anc
cascade aeration in the -last manhole before the ;discharge point: °j
3) A review of self monitoring data submitted from January 2001-thro
showed compliance with permit limits except those noted in Attachment
4) An ORC log is kept in accordance with the requirements of 15A NCAC 2B .0506(c) (3)."
However, a daily calibration log of the pH,'residual chlorine, and dissolved oxygen meters is no
being kept which is a violation. Please ensure that these logs:' are created and utilized every time a
meter is used for reporting data on the Discharge Monthly Report (DMR).
1628 Mail Service Center, Raleigh, NC 27699-1628
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone] B
50'/o recycled/10% post -consumer paper
•

Kittrell Job Corp
Page Two
5) Mr. Mattews stated during the inspection that the pH meter would not read the 4.0 buffer and
the meter had recently been returned after being repaired. It was noted that, in the past, the pH
4Notigmmeter was calibrated with pH buffers 4.0, 7.0 and 10.0. All field parameters that are measured
with a meter must have a three point calibration. It is recommended that a 4.0 and 10.0 pH buffer
be utilized to calibrate the meter and a 7.0 pH buffer be used to check the calibration. The meter
reading for the 4.0, 10.0 and 7.0 must be recorded in a log. Conductivity is also reported by field
meter and must employ a three point buffer calibration that is recorded in a log. In addition, all
buffers must have an expiration date noted on the bottle. Dissolved oxygen is determined by air
calibration and also must be recorded in a log along with a check of calibration accuracy. Please
state the facility's remedy for these concerns.
6) The effluent was cloudy in appearance and appeared to have excess solids suspended in it.
Please state what the facility plans are to improve the effluent quality.
7) The circular clarifier is approximately 10 feet across and 10 feet deep. At the time of
inspection, the sludge depth was 6 feet and the discharge was cloudy.
8) A review of laboratory data and self monitoring data for the month of March 2002 showed
consistent reporting of results.
9) Mr. Matthews stated that sludge from this facility is land applied by Granville Farms. Please
supply sludge hauling records detailing dates and amounts that were hauled for the period
January 2001 through December 2001.
10) All sampling is being conducted as "Grab" samples as per the subject permit.
11) Please detail what type of device is used for reporting daily effluent temperature and how
that instrument is calibrated. Be aware that thermometers used for reporting purposes must be
calibrated at least annually and a record of that calibration should be kept.
12) The effluent flow meter is calibrated at least twice per year and was last calibrated on April
18, 2002. An instantaneous comparison of the effluent flow meter to the effluent staff gage
coincided within 10%.
13) The current permit was issued on January 25, 2000, became effective March 1, 2000 and
expires on September 30, 2004.
14) The facility has a permanent on -site generator that can power the entire WWTP. It was tested
during the inspection and appeared to function properly.

Kittrell Job Corp
Page Three
15) The facility has applied for Field Parameter Laboratory Certification to conduct Residual •
Chlorine, Dissolved Oxygen, pH, and Temperature measurements. In addition, Mr. Pulley stated
that a low level residual chlorine meter is being purchased that can detect to the permit limit of
28 ug/l. Please indicate when that meter is to be purchased.
16) The subject facility has been assessed eighteen (18) times for violations of the NPDES
Permit since May 1998. The facility entered into Special Order by Consent (SOC) EMC WQ 99-
012 on June 19, 2000. That SOC was undertaken by the permittee to address problems at the
wastewater treatment plant but those changes have not been successful in achieving consistent
compliance. Most recently, on May 7, 2002, a `Noncompliance Report" was received for a plant
upset that discharged 12,150 gallons of partially treated wastewater. According to the report, this
was the result of a toilet stuck running. This incident indicates that the plant is easily upset and in
fact the operator stated that the plant has problems when the students return from holiday breaks.
Mr. Pulley stated during the inspection that the facility was recently evaluated to
determine what was required to maintain consistent compliance with the subject permit and that
he had made recommendations also. He also stated that the City of Henderson's wastewater
collection system was three miles away. Please detail the findings of that evaluation along with
the feasibility of connection to Henderson's collection system. Please include cost analysis for all
options. Upon receipt of this correspondence, please contact Mr. Stafford to set up a Show Cause
Meeting at the Raleigh Regional Office to discuss the plant evaluation.
Please respond to items 4, 5, 6, 9, 11, 15 and 16 within 20 days of receipt of this letter. If
you have questions concerning this notification, please contact Mr. Kirk Stafford at 919-571-
4700.
eu--
cc: Vance County Health Dept.
EPA -Maurice Horsey
Sincerely,
4.
Kenneth Schuster, P.E.
Regional Supervisor

' RITTRELL JOB CORPS CENTER
P.O. Box 278, Kittrell, N.C. 27544 [phone]
NON COMPLIANCE REPORT
MAY 7, 2002
7:30 P.M.
I arrived at KJCC at 5:00 p.m. Upon arrival at the plant, I noticed the flow equalization pump
station alarm was on. Upon assessing the situation, there were no blockages. I assumed there
must be a toilet hung open in one of the buildings. I called Mr. Pulley's office (Facility
Maintenance Supervisor) and got no answer. I then called Mr. Willie McLaughlin Kittrell Job
Corps Center (KJCC) Finance Administration Director and spoke to Sandra Parham, Finance &
Administration Secretary. She said "She would notify Mr. Pulley". Upon further investigation, I
noticed solids leaving the plant and decided to turn off all air in the aeration basins and turn off
the arm in the clarifier to prevent more solids from leaving the plant.
I then called Ms. Parham back to see if she had contacted Mr. Pulley. She had and he was on his
way. I then asked to speak to Mr. McLaughlin and I informed him of the situation.
I then decided to turn off all air to the plant; stopping return and aeration at contact chambers.
The reason for this was to allow solids to settle. I plan to have contact basins drained May 8,
2002 to get remaining solids out. Mr. McLaughlin came to the plant at 5:25 p.m. and Mr. Pulley
followed a few minutes later. Mr. Pulley had been checking dorms to see if he could find the
problem. Mr. McLaughlin and Mr. Pulley both toured the plant and again began search for the
problem.
At 6:10 p.m., Mr. Pulley returned to the plant and had found a toilet stuck running in a
construction area that is not used by KJCC employees. He corrected the problem and informed
Mr. McLaughlin and myself.
At this time I went to the outfall and collected some effluent samples. I tested my self for PH-
6.7, Dissolved Oxygen -8.0, and Chlorine Residual <100. I retained three containers for future
testing if needed. There was some evidence of solids at the outfall, but not as bad as I expected.
The peak flow I saw was 81 GPM. If this event began at 4:00 p.m. and ended at 6:30 p.m, that is
2.5 hours or 150 minutes x 81 GPM =12,150 gallons of partially treated waste water that left the
plant.
The plant's (effluent) flow and all basins were all back to normal at 7:30 p.m. on May 7, 2002.
Respectfully Submitted
James Marshbum, ORC
OPERATED FOR THE U.B. DEPARTMENT OF LABOR. EMPLOYMENT AMO TRAINING ADMINISTRATION BY THE
4TC MANAGEMENT & TRAINING CORPORATION

PERMIT NUMBER: NC0029131
FACILITY NAME: Kittrell Job Corps Center - Kittrell Job Corps Center
CITY: Kittrell
OUTFALL: 001
EFFLUENT
COUNTY: Vance
PERIOD ENDING MONTH: 4 - 2002
REGION: Raleigh
DMR 12 Month Calculated
PAGE ► OF 2
00010
deg c
TEMPERATURE,
WATER DEG.
CENTIGRADE
00300
mg/1
DO, Oxygen,
Dissolved
00310
mg/1
BOD, 5-DAY
(20 DEG. C)
00400
su
PH
00530
mg/1
SOLIDS, TOTAL
SUSPENDED
00600
mg/1
NITROGEN, TOTAL
(AS N)
00610
mg/1
NITROGEN,
AMMONIA TOTAL
(AS N)
00665
mg/1
PHOSPHORUS,
TOTAL(AS P)
5 - 01
17
30
2
24
8
5.82
6.9 - 7.1
20.2
17.3
0.85
1.89
6 01
17
30
2
26
7.8
3.7
6.8 - 7.2
11.1
33
0.15
3.64
7 01
17
30
28
8.2
4.9
6.9 - 7.1
21.8
42
1.92
1.04
8-01
17
30
29
8.1
1.8
6.9 - 7.1
11.5
24.1
2.36 Violation
3.42
9 01
17
30
26
7.8
1.3
6.8 - 7.6
24
38
2.35 Violation
6.26
10-01
17
30
21
7.8
4.3
6.9 - 7.1
39 Violation
30.66
2.9 Violation
3.37
11 01
30
.30
4
19
7.9
4
22
36.8
1.83
8.2
12 01
30
30
4
16
8.3
8
20
52.7
0.42
0.23
1 - 02
30
30
4
13
7.9
12.4
19.9
39
2.73
5.15
2-02
//
30 �l�No . �0
30 2%a1 Tii =19'�
(l �
15
8.7
30
69 Violation
50.2
3.59
6.73
3-02
30
30
4
16
8.6
13
6.8 - 6.9
37 Violation
34
1.9
4.04
4 - 02
17
30
2
21
8.6
12
6.6 - 7
19
10.03
0.4
5.04

PERMIT NUMBER: NC0029131
FACILITY NAME: Kittrell Job Corps Center - Kittrell Job Corps Center
CITY: Kittrell COUNTY: Vance
PERIOD ENDING MONTH: 4 - 2002 DMR 12 Month Calculated
PAGE 2 OF 2
REGION: Raleigh
31616
$/100m1
COLIFORM, FECAL
MF, M-FC
BROTH,44.5C
50050
mgd
FLOW, IN
CONDUIT OR THRU
TREATMENT PLANT
50060
mg/1
CHLORINE,
TOTALRESIDUAL
50060
ug/1
CHLORINE,
TOTALRESIDUAL
TGP3B
pass/fail
P/F STATRE 7DAY
CHR CERIODAPHNIA
5 01
0.025
1.2
0.004
11
6 01
0.025
0
0.01
11
7 01
0 025
0
0.009
13
8 01
0025
1
13
9 01
c'.025
1
0.01
10
10-01
,) .2[
4
0.012
11
11 -01
0:
0.017
14
12-01
'``"
0.015
14
1 02
0.025
0.015
11
2 02
0.025
0.018
16
3 02
0.025
1
0.015
100
4 02
0.025
1.4
0.018
100
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
OCT 1 8 2001
Memorandum
To: Regional Water Quality Supervisors
From: Coleen Sullins
Re: Sampling for enforcement
purposes and permit modifications
ArprA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
We have received several inquiries regarding the validity of effluent samples taken by DWQ
staff for enforcement purposes, requirements for incorporating these samples into a permittees
DMR reports and different permitting options for facilities with operational problems. This
memo will provide guidance and clarification on these matters.
Effluent samples taken by DWQ staff and analyzed by a certified laboratory are valid to stand
alone for enforcement of daily maximum limits. These samples are not required to be averaged
with values from samples that may have been taken for a facility on that day. However, results
from samples taken by the permittee may be considered in determining whether to pursue
enforcement actions. The inspector's observation with respect to the facilities sampling and
laboratory protocols can play an important role in support of enforcement decisions. DWQ
samples must be collected as specified in the facility's permit, adhering to protocols for
collection, preservation, and transport and be analyzed within specified holding times with chain
of custody maintained throughout the process to be valid for enforcement of effluent limits.
Correspondingly, it is the position of the agency that samples taken by DWQ staff are not
required to be considered by permittees when computing and reporting averages for a month,
week or day on a permittees DMR. To do so would require a considerable and unnecessary
coordination effort on the part of the Regions and permittees and would lead to many unessential
"amended" DMR's being submitted to the agency with data already housed in our files. Further,
it is not reasonable to ask Operators in Responsible Charge to certify the accuracy of sample data
they had no control over.
Samples from facilities with design flows of < 0.03 MGD are routinely required to be taken as
"grab" samples. The Director, on a case by case basis, may modify permits for these facilities
and require additional, increased and/or different sampling be performed. Given adequate
justification, staff may request modification to a facility's permit(s) at any time in the permit
cycle to establish a more detailed picture of a facility's effluent quality. It is preferable however
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to time these requests with the regular permit renewal process in all but the most severe cases.
Examples of adequate justification are significant discrepancies between DWQ sampling and
permittee sampling for the same time period(s), discrepancies in split sample results and/or
solids deposition instream below the facility while the facility shows compliance with its permit
limits
Typical permit modification requests would include items such as more frequent monitoring of
the effluent, (including weekend sampling) additional stream sampling and/or flow proportional
composite sampling instead of grab sampling. Recommendations from the regional offices to
incorporate such requirements into permits will carry a large amount of influence when
supported by adequate justification as described above and detailed explanations as to why the
requested modification is warranted.
In instances where specific types of operational problems are suspected, staff may seek permit
modifications to include permit conditions that address wastewater management. Some of the
aspects that a waste management plan would entail are an analysis of treatment and disposal
alternatives, a facility assessment and optimization plan, or a biosolid management plan. The
plan could also entail an estimate of future flows and a demonstration by the facility to provide
the capability for adequate treatment of such flows. The attachment included with this
memorandum provides more information about this special condition. Please note that the
attachment was developed to be used in a "modular" fashion. That is, any of the bulleted items
can be included or deleted as the situation warrants.
If you have any questions about the information contained in this memorandum please contact
Shannon Langley at [phone].
CC: Bill Reid
Dave Goodrich
PSCEU Regional contacts