NC0037834_Permit (Modification)_19930408

NPDES DOCUMENT SCANNING COVER SHEET
NC0037834
Archie Elledge WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
,
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 8, 1993
This document is printed on reuse paper - ignore any
content on the resrerse'side

CERTIFIED MAR.
RETURN RECEIPTRE QUESTED
Ronald G. Seeber, City Attorney
City of Winston-Salem
P.O. Box 2511
Winston-Salem, NC 27102
Dear Mr. Seeber.
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary
April 8, 1993
Subject: NPDES Permit No. NC0037834
Archie Elledge WWTP
Forsyth County
In accordance with your Petition for Contested Case Hearing filed on November 6, 1992,
and subsequent Notice of Withdrawal dated March 22, 1993, we are forwarding herewith the subject
permit. The permit has been modified as follows:
• Effluent Limitations for outfall 001 :
1. The fecal coliform limitation in question has been changed to be 1000.0/ 100m1
monthly average and 2000.0/ 100 ml weekly average. However, following final
issuance of the permit, December 31, 1994, the fecal coliform limitation will return to
the standard of 200.0/ 100m1 and 400.0/100ml effective January 1, 1995.
2. To supplement the modification and as requested by the City of Winston-Salem the
following Toxicity Limits have been withdrawn or added to the permit.
A.Chronic Toxicity (Ceriodaphnia) ChV at 76%, Episodic has been deleted
from the permit.
B.Chronic Toxicity Phase II Effluent Testing occurring monthly has been
added to the effluent limitations page specifying the monitoring requirements
that apply during the summer months.
C.Chronic Toxicity Phase II Effluent monitoring requirements to be implemented
on a quarterly basis during the months of January, April, July and October have
been added to the winter limitations pages.
D.Chronic Toxicity Phase 11 Effluent monitoring requirements to be implemented
on a quarterly basis of the effluent prior to chlorination have been added to both
the winter and summer effluent pages.
Asheville
704/251-6208
Fayetteville
919/486-1541
Regional Offices
Mooresville Raleigh
704/663-1699 919/571-4700
Pollution Prevention Pays
Washington Wilmtgton
919/946-6481 919/395-3900'
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
4.2 $. g•air
APR I G 1993
CENTRAL F iLES

Page 2
'Mr. Seeber
April 8, i 993
All other terms and conditions contained in the original permit remain unchanged and in full
effect. These modifications are issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S.
Environmental Protection Agency dated December 6,1983.
It is our understanding that this modification will resolve all items contained in the Petition
for Contested Case Hearing. If this is not the case, the City of Albemarle should notify us
immediately, but no later than ten (10) days following receipt of this letter. Unless such demand is
made, this decision shall be final and binding.
If you have any questions concerning this permit, please contact Randy L. Kepler at
telephone number 919i733-5083.
A. Preston Ho
Division of Enviro
cc: Kathy Cooper, Attorney General' Office
Winston-Salem Regional Office
Permits and Engineering Unit
Central Files
Stan Webb, Supervisor, Elledge Wastewater Treatment Plant
City of Winston-Salem, P.O. Box 2511, Winston-Salem, NC 27102
ctor
ment
CENTRAL F!LES

r, 't
PUBLIC WORKS
DEPARTMENT
January 14, 1993
City of Winston-a1cm
Mr. Don Safrit
N. C. Department of Environment,
Health and Natural Resources
512 North Salisbury Street
Raleigh, NC 27611
RE: Permit Adjudication
Archie Elledge WWTP (NC0037834)
Dear Mr. Safrit:
The City of Winston-Salem is adjudicating the Elledge Plant's new
NPDES permit because we recently discovered that the plant cannot
simultaneously comply with the new fecal coliform and toxicity
limits on a consistent basis. In early May, 1992, we discovered
that toxic levels of tri-halomethanes (THMs) occurred under cer-
tain conditions when we raised our chlorination rate to meet the
new 200/100 ml fecal limit.
When we discovered this problem, we immediately began conducting
pilot tests to determine how we could solve it. We completed the
necessary research in late October, 1992 and concluded that the
best solution to the problem was to increase the plant's chlorine
contact time. Our data showed that we can reduce our chlorine
dosage to the point where we can meet the new fecal limit and
maintain non -toxic levels of THMs in the plant discharge by in-
creasing our total chlorine contact time to sixty minutes at 30
MGD. We are unable to do this until we construct new facilities.
The Winston-Salem/Forsyth County Utility Commission has already
adopted a resolution appropriating $1,000,000 to cover the design
and construction of an additional chlorine contact chamber. This
chamber will be built as part of the $22,000,000 upgrade to the
Elledge Plant which is scheduled for completion in late 1994. I
have attached a copy of our Commission's resolution authorizing us
to proceed with. this project.
Prior to May, 1992, when we discovered the THM problem, all of our
biomonitoring data indicated that the plant could meet the toxic-
ity limit, provided the effluent was dechlorinated. The contract
for the plant upgrade already included the constructionof.: ,:..a
$1, 100, 000 dechlorination facility when the THM problem was? d`s�•
covered.
Box 2511, Winston-Salem, North Carolina 27102

•
Mr. Don Safrit
January 14, 1993
Page 2
We apologize for adjudicating this permit after agreeing to the
limits published in the draft document. At the time we agreed to
the limits, we did not realize that toxic levels of THM's would
form as a result of our chlorinating at a rate to meet the new Fe-
cal limit.
We ask that DEHNR postpone the implementation of the new limits
for these two parameters until December 31, 1994. Granting our
request should not constitute a deviation from standard regulatory
practice. EPA, for instance, has allowed permittees two years to
comply with the 503 Sludge Regulations if they have to construct
facilities. EPA has used a similar approach when implementing
other regulations. We are willing to work with DEHNR in this mat-
ter and we are willing to monitor.
The data you asked for to help you in evaluating our request is
attached as an Appendix. These data cover the period from May,
1992 through October, 1992. The appendix includes summary infor-
mation and copies of laboratory reports.
We look forward to meeting with you on January 21, 1993 to discuss
this matter. Call me at 919/784-4700 if you have any questions or
need additional information.
Sincerely,
Wg-
Stanley_B eb
Operations Manager
pc: Lee Spencer, Winston-Salem Regional Office
Lee Byerly, WTP Superintendent
Crystal Couch, IWC Supervisor
Barry Shearin, Utility Plants Engineer
Attachment(s)
It

Appendix to Letter to Don Safrit of 1-7-93
I. During the week of May 4, 1992, a bioassay test was
conducted to make sure that the act of chemically de -
chlorinating would not produce toxic effects. Raw data
sheets are attached and a data summary is shown below.
(Data Set A)
Date Sample
Collected Type
5/6/92 deCl Eff.
5/8/92 "2
C1
Doge
13.5
13
C1 Fecal Col.
Residua/(ppm) Ct./100m1 ChV%
1.05 84
0.9 208 54%
Conclusion:
Apparent toxicity in this sample indicated that a toxic agent
other than residual chlorine was present. This sample was
dechlorinated with sodium sulfite. Chlorine residual in bioassay
samples was <0.1 ppm. Toxicity is defined as a ChV% of '. e767c
II. During the week of June 22, 1993, another series of tests
were performed to determine if the toxicity was a function
of chlorination or if it was an agent entering the head -
works. Data summary follows with lab reports attached.
(Data Set B)
Date Sample C1 Cl2 Fecal Col.
Collected Type Dose ?(ppm) Residual(ppm) Ct./100m1 ChV%
6-24-92 Unchl. EF. 0 0 22,100
6-26-92 " " 0 0 -- >96%
6-24-92 deCl2 EF 11.5 1.1 360
6-26-92 " " 19 1.1 136 54%
Conclusion:
Tests indicated that the toxicity was either a function of
Chlorination or the act of dechlorination.
III. Following the June tests, we felt that pilot testing was
required to determine how we could achieve an effluent
product which would meet the 200/100 ml fecal limit and
still pass the bioassay. We assumed that toxic formation
was a function of chlorine dosage since tests on dechlori-
nated samples performed in 1990 and 1991 passed the bioas-
say easily. These samples, however, had been collected
when the chlorination dose was <10 ppm.
We were seeking to achieve a method by which we could make
our chlorine a more efficient disinfectant thus giving us
more kill per pound and allowing us to feed dosages less
than the 10 ppm level at which we suspected toxic by -prod;
ducts would not form.

Page 2
Since hypochlorous acid is the most efficient form of
chlorine and this form predominates at lower pH values, we
ran a series of bench scale contact tanks which had the pH
values of their contents manipulated to measure the effect
on fecal kill. The contact time was maintained at 40
minutes which is the plants designed contact time at
30 MGD.
The data for this pilot test is as follows.
C12 = 0 ppm 1 ppm 2 ppm 3 ppm 6 ppm 9 ppm
Reactor, pH Fecal Fecal Fecal Fecal Fecal Fecal
Number Ct. Ct. Ct. Ct. Ct. Ct.
1-1 5.5 >3400 318 56 18 4 <2
1-2 6.0 11,300 >500 44 18 2 4
1-3 6.5 22,100 >500 82 12 4 4
1-4 7.0 31,000 >500 218 4 <2 2
These data indicated that fecal kill was enhanced when the efflu-
ent pH was lowered. It remained to be seen however, if we had
ceased forming toxic by-products. We were also very surprised
when Reactor 1-4, which simulated the plant's normal pH value,
achieved a much greater degree of kill than the plants system.
(We later discovered that the post aeration system in the contact
chamber caused the tank to short circuit effectively reducing the
contact time by -42%.)
Following the conclusion of this test, we ran another series of
bioassays to determine if the pH reduction prior to chlorination
strategy would allow us to meet both the fecal and bioassay lim-
its. APAM analysis was performed on these three samples to
monitor any change in organics.
The lab data from these tests are as follows and lab reports are
attached (Data Set C)
Type of Cl2 C1 Fecal
Sample Dose ppm Contact Time(min.)* Ct. pH ChV% THM(PPb)
UNC12 Cntrl 0 0 TNTC 7.5 >76% <1.0
deCl
Plant Ef. 15 62 min.
deCl
Reactor
Ef. 2 40
*Theoretical contact time.
300 7.5 55% 127
44 6.0 >76% <1.0

Page 3
Conclusion:
The strategy of reducing effluent pH to increase the disinfection
rate was shown to be a possible solution to the problem. However,
the data showed the likelihood that the problem could be caused by
our having to feed high doses of chlorine to compensate for the
reduced contact time caused by short circuits in the tank.
V. In September we initiated tests to determine how much ad-
ditional detention time was needed in the plant's disinfec-
tion system to achieve a kill sufficient to meet the 200
#/100 ml limit when the chlorine dose was held below
10
ppm.
The data indicated that the plant required a total of
sixty minutes of contact time at 30 MGD to provide a con-
tinuous fecal count of less than 200 #/100 ml when the
chlorine dose was -9.0 ppm.
At this point in the study, we lowered the plant's chlorine
dosage to -10 ppm and ran another series of bioassay tests
to insure that the plant effluent, once dechlorinated,
would pass the bioassay test.
The data summary is as follows and lab reports are attached
as Data Set D.
Type of Cl2 C1 Fecal
Sample Dose ppm Contact Time Count ChV%
Un-
chlori-
nated
Cntrl 0 0 TNTC >96%
deC12
Effluent 9.6 40 min. 180 91%
Conclusion:
The data confirmed that the toxicity limit could be met provided
the chlorine dosage was held to <10 ppm, and the residual chlorine
removed by treatment with sulfur dioxide. The Fecal limit of 200
#/100 ml probably could not be consistently met unless additional
contact time was provided.
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Monday, November 30, 1992
MEMORANDUM
To: Trevor Clements,
Assistant Chief for Technical Support
From:
Subject:
Donald Safrit, P.E., Sup
Permits and Engineering Unit
Winston Salem, City of - Archie Elledge
Permit No. NC0037834
Forsyth County
In accordance with Water Quality Section procedures, please review the attached petition
filed with the Office of Administrative Hearings. Please evaluate the objections raised by
the permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
Fecal Coliform limit of 200.
Current construction of dechlor facilities to be completed by 9/94.
Discussed w/Stan Webb (784-4700) of WS and they have concerns about meeting
both fecal and toxicity testing requirements; more detailed letter to follow. Will
distribute upon receipt - WS will probably want to meet & discuss. DS 11/30/92
Miscellaneous comments:
If you have any questions, please contact Randy Kepler
cc:
Office of the Attorney General - Kathy Cooper
Donald Safrit
Randy Kepler
•
RECEIVED
DEC 0 1 1992
TECHNICAL SUPPORT BRANCH

•
(Your Name)
(3)
•
• PLEASE PRINT CLEARLY 2a IYPfi
STAT* OP NORTH CAROLINA
COUNTY OF (t) rors'tri
r
AO•dline
(3), Winston-Salem/Forsyth County
Utility Commission
?«hoes►,
•
v.
N. C. _Division of Environmental
Management
1 ipondent.
(1 he State Agency or Board about which you are
complaining)
IN THE Pricr. OF
ADMINISTRATIVE HEAR NOS
AV
PETITION
FOR A
CONTP.STFD CASE IIEARINO
1 hereby ask for a contested cue hearing at provided for by 0.11. 1500-23 because the:
(4)_. C. Division of Environmental Management
(name or agency)
(Briefly state facto showing how you believe you have been harmed by the state agency or board.)
See Attachment
hat:
((/ moro space Is naided, rue additional sIWn: and attach)
(5) (Chock all that apply) Because of these facts, the agency has:
deprived me or property; x acted erroneously;
ordered me to pay a tine or civil penalty; to use proper procedure;
_motherwlse substantially preludloed my `acted arbitrarily or capriciously; or
rights; and based on these sets the agency felled to act u required by law or rule.
has exceeded its authority or Juriedktion;
******* ************vl****************miter******************************
(6) Data: , November 6, 1992 (7) Your telephone number: [phone]
(8) Print your address: P . 0. Box 2511, Winston—Salem, NC 27102
(9) Print your name; mas W. Griffin
(10) Your signature:
ktsi
************** *.****A*************** *****rU***dr****tkrU******** ******
Vou must mall or deliver a soya to the State Agency named on line (3) of this form. Please indicate below.
•
CERTIFICATE OF SERVICE
1 certify that this Petition has been served on the State Agency named below by depositing a copy of it with the United States
Postal Service with sufficient postage OR by delivering it to the named agency.
Served on:
(11) A. Preston Howard, Jr., (12) N. C. Division of Environmental Management
(name}Acting Director Now)
(13) 512 N. Salisbury Street, Ralei h NC 27611
(address)
(14) This the 6th day of November 14 92 .
(1S) ,•
/your signatuia)
•
When you have completed thls form_ you Mt mall or deliver the ORt IN 1 , and one to the Office of Admints•
trative Hearings, P.O. Drawer 27447. RaIe1&h. NC 27611.7447.
11-06 (11 j91)
***END***

ATTACHMENT
Petition for A Contested Case Hearing
Winston-Salem/Forsyth County Utility Commission
Versus
N. C. Department of Environment, Health, and
Natural Resources, Division -of Environmental Management
The Winston-Salem/Forsyth County Utility Commission is seeking
relief from provisions in NPDES Permit (NC0037834) issued by the
North Carolina Department of Environment, Health, and Natural
Resources and received by our office on October 7, 1992.
The NPDES Permit requires tha the, Utility Commission monitor
each weekday for fecal of 200 mg/1 }in the plant effluent and
provides that the discharge i violation of the permit if the
monthly average fecal count exceeds 200 mg/1. In the event of a
permit violation as a result of the fecal limit, the Commission
will be subject to sanctions, including fines and penalties. The
Utility Commission is currently upgrading the ArcIie Elledge
Wastewater Treatment Plant and as a part of this upgrading,
dechlorination facilities are being installed and the Commission
feels that this new fecal limit should not be in the permit until
after completion of construction of the dechlorination facilities
and testing of those facilities. To require the Commission to
meet the 200 mg/1 prior to completion of the plant upgrade would
subject the Commission to sanctions in the event of a violation
and the limit substantially prejudices the Commission's rights.

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 31, 1992
MEMORANDUM
To: Rosanne Barona
4v
THROUGH: Trevor Clements
FROM: Ruth Swanek 5
SUBJECT: Winston-Salem Archie Elledge WWTP
Comments of Draft NPDES Permit
NPDES No. NC0037834
Forsyth County
I have reviewed the City of Winston-Salem's letter of January 30 concerning its draft NPDES
permit and offer the following comments:
1. There should be no problem moving the upstream sampling location to the bridge
located 1300 feet upstream of the SR 1120 bridge. However, this bridge is not located
on the topographic map, and it would aid us in reviewing the data if Winston-Salem
would submit a copy of the topo map with the location noted on it.
2. The monitoring proposed by Winston-Salem is acceptable to Technical Support.
3. The new Phase II toxicity test should be included in Winston-Salem's NPDES permit.
In addition, the sampling may be changed to January, April, July, and October to allow
the City to sample on the same schedule as the Lower Muddy Creek Plant.
4. Sampling for cyanide was included in the NPDES permit due to the amount of cyanide
permitted to industries. If the City monitors for cyanide for one year, and all
concentrations are below detection, the Division will reduce the monitoring frequency
upon request. One year of data is needed to determine whether any seasonal variation
occurs in the effluent.
5. Winston-Salem has identified its major cadmium source, and is now close to meeting
its permit limit. However, conversation with Crystal Couch of the City indicated that the
data are borderline and the City would like no limit during the life of the permit. Since
the time period in question is only five extra months, Technical Support does not object
to their request. However, if you would like more information concerning this issue, the
City will be meeting with Pretreatment in the near future to discuss the state funded
study the City is performing. They may bring additional cadmium data which they
recently collected.
If you have any questions concerning my comments, please call me at extension 503.
cc: Steve Mauney, WSRO
Larry Ausley, ESB

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PUBLIC WORKS
DEPARTMENT
Cityof Winston-Salem
January 30, 1992
Mr. Dale Overcash
North Carolina Department of Environment,
Health and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina 27611
RE: Comments on the Draft of NPDES Permit NC0037834
(Elledge WWTP-Winston-Salem, North Carolina)
Dear Mr. Overcash:
We received the draft of the above referenced permit on
January 3, 1992. Our staff has reviewed its terms and conditions
and we are submitting the following comments.
1. The draft permit designates the bridge on NCSR 1120 as
the "upstream" sampling location. This bridge carries
a fairly heavy traffic volume which constitutes some
danger to our personnel during ri,onitoring activities. `k':4
There is a bridge located on the plant site that is ap-
proximately 1300 feet upstreari, of the bridge on SR 1120.
We would prefer to have this bridge designated as the
upstreari, sampling point as it is a safer location.
2. During the winter months the conductivity of stream
samples must be determined weekly and the monitoring
frequency for this parameter increases to three times
per week during summer. With the exception of D. 0. ,
fecal col i forri,, and temperature, monitoring is not
required for any other parameters.
We feel that additional data is needed to adequately monitor
the plant's impact on the receiving stream. We would like to have
the conductivity monitoring frequency reduced to once per month
and have weekly monitoring instituted for 60D, TSS, pH, and am-
monia nitrogen.
Box 2511, Winston-Salem, North Carolina 27102

Mr. Dale Overcash
January 30, 1992
Page 2
3. The language and requirements of Part III, condition f
are not acceptable to us because they do not incorporate
any of the recormirrmendations made by the Ad hoc Biomonitor-
ing Review Committee.
We request that the basic language of Part III condition f in
the NPDES permit for our Muddy Creek WWTP (NC0050342) be incorpo-
rated in the final permit for the Elledge WWTP.
We also request that biorironitoring samples be taken at
Elledge during the months of January, April, July and October.
This is the same sampling schedule currently in place for the
Muddy Creek Plant and its use at the Elledge Plant will allow us
to sample both discharges at the same time.
4. The draft permit requires monthly monitoring for cyanide.
Past testing for th-is parameter indicate that the
effluent cyanide concentration is below the detection
limit for the ARAM test (<20 ug/1). (See attached APAM
test result).
The City feels that it is unnecessary to require monthly
monitoring for cyanide because it is not present in detectable
quantities. We therefore request that cyanide monitoring be de-
leted from the permit until data from the annual APAM test indi-
cates cyanide Is a parameter of concern.
5. The draft permit institutes an effluent cadmium liriiita-
tion an March 1, 1993, which is five months before the
permit's expiration date.
The implementation date for the effluent cadmium limit was
postponed because the City and a major I.U. will be participating
in a state funded study designed to evaluate methods to control
cadmium originating from an uncontrollable source.
We have no idea as to how long the study will last and we
feel that the implementation of the effluent cadmium limitation
should be delayed until the study is completed or until the permit
is renewed. This action would result in a five month delay, at
most, in implementing the effluent cadmium limitation.
�II l.�Vl 4ti L(-1_lL IL /U5-0/3(.

Mr. Dale Overcash
January 30, 1992
Page 3
Thank you for your cooperation in this matter and please call
me at 919/784-4700 if you have any questions.
pc:
1t
Sincerely,
Stan
ebb
Wastewater Operations Manager
Lee 8yerly, WT Plant Superintendent
Crystal Couch, IWC Supervisor
Barry Shearin, Utility Plants Engineer
Larry Coble, Winston-Salem Regional Supervisor