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Home My WebLink AboutNC0037834_Correspondence_19941108NPDES DOCUMENT SCANNIN`: COVER SHEET NPDES Permit: NC0037834 Archie Elledge WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change (*.r/e5iPo Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: November 8, 1994 This document is printed on reuse paper - ignore any content on the resrerse side CITY OF WI\STONSALEM. PUBLIC WORKS DEPARTMENT P.O. BOX 2511, WINSTON-SALEM, NORTH CAR LINA 27102 November 8, 1994 Mr. Dennis Ramsey North Carolina Department of Environment, Health, and Natural Resources 512 North Salisbury Street Post Office Box 29535 Raleigh, N. C. 27604 RE: Request for Clarification of Color Monitoring Requirements Archie Elledge WWTP (NC0037834) Winston-Salem, N. C. Dear Mr. Ramsey: �ffn1Me�� NO2 F 1994 V The new NPDES permit for Winston-Salem's Archie Elledge WWTP re- quires semimonthly color monitoring at the plant effluent, at the upstream sampling site and at the downstream (1) sampling site as of January 1, 1995. Winston-Salem is required to determine ADMI color values for these samples and must report observations of sample hue, clarity, and luminance on the plant's DMR. We are unclear as to how DEHNR wants the data on observations re- ported. These data will be descriptive, rather than numerical, and will be based entirely upon personal interpretation. We are concerned that, unless our observations are made and reported in a format that DEHNR can interpret, data from these observations will} be useless. Please provide us guidance as to specifically how to make and re- port the color observations required by the new permit. We also request that a copy of a DMR from a permittee currently performing color monitoring be included with your response. This will allow us to review firsthand how other permit holders are performing this monitoring. Although this monitoring is not scheduled to begin until January 1, 1995, we would appreciate your prompt response to our request for guidance. Mr. Dennis Ramsey November 8, 1994 Page 2 Please contact me at City of Winston-Salem, 4561 Cooper Road, Winston-Salem, N. C. 27127 at your earliest convenience. You may also call me at 910/784-4700 if you have any questions. Sincerely, Stanley B. Webb Wastewater Treatment Plant Superintendent pc: Barry Shearin, Utility Plants Engineer Ruth Swanek, NCDEHNR Greg Thorpe, NCDEHNR Steve Mauney, Winston-Salem Regional Office It DIVISION OF ENVIRONMENTAL MANAGEMENT July 8, 1994 MEMORANDUM To: Roy Byrd Water Quality Chem Lab From: Greg Nizich -�5 Permits and ngin ring Subject: Comments on Cyanide Testing Winston-Salem Archie Elledge WWTP Permit # NC0037834 Forsyth County Part IV. of the attached letter discusses interference in testing for cyanide. What is your opinion of their claim that results obtained from this test are too varied to be of value? Please advise if additional information is required. Enclosure cc: Instream Assessment Unit DIVISION OF ENVIRONMENTAL MANAGEMENT July 6, 1994 MEMORANDUM TO: Greg Nizich THROUGH: Don S FROM: Ruth Swanek C5 SUBJECT: City of Winston-Salem Archie Elledge WWTP NPDES No. NC0037834 Forsyth County I have reviewed the City of Winston-Salem's comments regarding its draft NPDES permit requirements and have the following comments: Instream Monitoring Requirements The City has requested that weekly instream monitoring for BOD, TSS, and ammonia be added to the permit and that instream and effluent conductivity be reduced to monthly. I have no objections to the request. Cadmium and Cyanide Limits The limits for cadmium and cyanide were assigned based on DEM's current procedures which have been approved by the EPA. Limits are assigned to protect the state's water quality standards for chemical specific toxics under low flow conditions. Until further review of the standards and current procedures occurs, the cadmium and cyanide limits should remain a part of the facility's NPDES permits in order to ensure protection of the state's surface waters. It should also be noted that Winston-Salem has failed some of its recent toxicity tests. In addition, all tests being performed during the summer are being performed prior to chlorination. The addition of chlorine can affect the toxicity of certain metals. Finally, I do not have the chemistry background to address the analytical protocol procedures for cyanide issues. These issues should be referred to the laboratory for comment. Upstream Sampling Site The City may move its upstream monitoring site to the bridge located 1300 feet upstream of SR 1120. cc: Winston-Salem Regional Office Central Files ..-.......e 4v& c%4 � Qe $'i /iVf 971 (.57/4 ,feray� 1 ,e, I/ / Idiatobte �� ffinviliffit Allik �z , ,, ti41 a�i #104-i *:./..0/teit idatiefit .it p‘heit ffkli `' 42, / ,*�� 4a7 G.OA �7f.. �OG5 L�G 04G` /#' _odd pD99 G.0/G a2/46 69:%4 d /ha%/ 444_ • Ol'D9 9rImc a�&atC 110,- ,aly;GGS tge Lixe,._#p" 4; 01- 93c/, a/5 �Yy &///fyr-,llitun T1A-- 4l04 /ti� ala yyC� //&&DLj2Z9 !tem U10- I'M UN .11'5 '5/14 #11l¢ 7!/i AY 4/)2/&'W1L -a�s 0/9..0z5a029--s'[! 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BOX 2511, WINSTON-SALEM, NORTH CAROLI\A 27102 pjd all V June 10, 1994 Mr. Dave Goodrich North Carolina Department of Environment, Health and Natural Resources 512 North Salisbury Street Post Office Box 29535 Raleigh, NC 27604 SUBJECT: Comments on DRAFT Permit Archie Elledge WWTP (NC0037834) Winston-Salem, NC Dear Mr. Goodrich: The City of Winston-Salem wishes to offer the following comments regarding the draft NPDES permit for our Archie Elledge WWTP. This permit is scheduled for final issue on June 30, 1994. I. Facility Location The draft permit cover sheet identifies the location of the Elledge Plant as NCSR 2972 (Griffin Road). The name of this road is actually Griffith Road. This error is repeated consistently throughout the text of the permit and should be corrected. II. Monitoring Requirements for Receiving Stream The draft permit requires that streams be monitored for dissolved oxygen, fecal coliform, temperature, and conductivity. The plant's receiving stream is water quality limited for BOD and ammonia nitrogen. It would seem that an adequate stream monitor- ing protocol would address these two parameters. Winston-Salem suggests that DEM include stream monitoring provi- sions for BOD, TSS and ammonia in the final permit, but reduce the frequency of monitoring for other parameters so as not to unneces- sarily tax our analytical capacity. Mr. Dave Goodrich June 10, 1994 Page 2 We propose that the monitoring frequency for stream and effluent conductivity be reduced to monthly and that weekly monitoring of streams for BOD, TSS, and ammonia nitrogen be added. III. Comments on Facilities Identified on "Supplement to Permit Cover Sheet" Part 1 of the cover sheet supplement identifies the Elledge Plant's current treatment train. DEM may wish to note that later this year the plant's trickling filters and surge basins will be removed from service permanently. We will be adding additional activated sludge capacity to offset the loss of the trickling filters and a dechlorination facility will be added as well. IV. Comments of Proposed Limitations for Specific Toxicants The draft permit proposes weekly average and daily maximum limits for cadmium and cyanide. Based on our understanding of the capa- bilities of the bioassay test from State staff and other research, both of these substances are toxicants whose effects are readily measured by a bioassay test. Winston-Salem feels that limits on specific toxicants such as cad- mium and cyanide are unnecessary. The permit's biomonitoring pro- visions and chronic effect level limits, as addressed in Part V of our comments, are entirely adequate to protect the receiving stream from toxic effects from any source. On this basis, Winston-Salem asks that the proposed limitations for cyanide and cadmium be deleted from the permit. Winston-Salem is not opposed to a permit monitoring requirement for cadmium but we feel that the analytical protocol for cyanide is so subject to interference that any data base generated for this parameter is suspect and no purpose is gained by monitoring for it. It has been our experience that every certified laboratory we have submitted samples to for cyanide analysis have reported inconsis- tent results. More importantly, these laboratories have failed to consistently demonstrate acceptable quality control checks. Mr. Dave Goodrich June 10, 1994 Page 3 We have noted an unacceptably high frequency of laboratories fail- ing to produce similar results on duplicate samples, failing to report acceptable spike recoveries and, in some cases, failing to accurately analyze a known standard. It should be noted that most, if not all, of these laboratories are excellent labs. Winston-Salem has no reason to suspect that the problems we have experienced in this area are due to analyti- cal incompetence. We do have reason to believe that data derived from cyanide tests conducted using the current pretreatment and distillation protocol cannot be trusted. Winston-Salem feels that, until the procedures used in cyanide analyses are refined to the point where an acceptable margin of error is present in the data, limitations and/or monitoring for this parameter are both onerous and meaningless. 0/11 A V. Biomonitoring Provisions he language requirements of Part III condition I of the �'and Act draft permit are not acceptable because none of the recommenda- LAP1 tions made by the 1992 Ad Hoc Biomonitoring Review Committee are h incorporated erein . It is Winston-Salem's understanding that DEM's permitting policy for whole effluent toxicity allows permittees discretionary use of the Phase II chronic toxicity testing methodology and allows per- mittees to request limits based on the quarterly average of the chronic effect levels of all bioassays conducted during that quar- ter. Winston-Salem requests that, with the exception of the stated instream waste concentration, the language included in the first paragraph of Part III, Condition F in the current permit for our Muddy Creek Plant (NC0050342) be incorporated into the final per- mit for the Elledge Plant. Mr. Dave Goodrich June 10, 1994 Page 4 VI. Location of "Upstream" Sampling Site The draft permit stipulates that upstream samples shall be taken from the bridge at NCSR 1120. The Elledge Plant's current permit allows upstream samples to be taken at a bridge located 1300 feet upstream of the bridge at NCSR 1120. Winston-Salem would prefer to continue conducting upstream sam- pling at the current location. The bridge on NCSR 1120 carries a heavy volume of traffic and this constitutes a danger to our em- ployees. The City of Winston-Salem would welcome the opportunity to review the final version of this permit before the June 30, 1994 effec- tive date. Such a review may allow us to jointly resolve problems with the final document without having to deal with the adjudica- tory process. Winston-Salem appreciates the opportunity to comment on this draft permit. If you have any questions regarding this matter, please feel free to contact me at 910/784-4700. Sincerely, Wastewater Treatment Plant Superintendent pc: Tom Griffin, Utilities Superintendent Lee Byerly, WTP Superintendent/MMC/Elledge Plant Barry Shearin, Utility Plants Engineer Steve Mauney, DEHNR Winston-Salem Regional Office It Page 1 Note for Ruth Swanek From: Greg Nizich Date: Mon, Jun 6, 1994 9:43 AM Subject: Archie Elledge Color Monitoring NC0037834 To: Dave Goodrich; Ruth Swanek Cc: Coleen Sullins Lee Spencer requested that we add weekly color monitoring for E,U,D. I will send out a revised draft permit and extend the comment period so they have 30 days from the modification date.