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Home My WebLink AboutNC0024201_Permit (Issuance)_20030912NPDES DOCUMENT ! CANNIN` COVER SHEET NC0024201 Roanoke River 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 Report Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: September 12, 2003 This document is printed on reuse paper - ignore arty content on the resrerse'side Michael F. Easley, Govemor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality Mr. Dan Brown, Roanoke Rapids P.O. Box 308 Roanoke Rapids September 12, 2003 CEO Sanitary District , North Carolina 27870 Subject: Issuance of NPDES Permit NC0024201 Roanoke Rapids WWTP Halifax County Dear Mr. Brown: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is 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 May 9, 1994 (or as subsequently amended). The attached final permit incorporates minor changes requested by you after review of the draft permit. Specifically, the sample type for mercury has been changed to grab. Condition A. (2) has been corrected to include proper footnote references. Finally, the metals reopener has been modified to include upstream metals sampling. Compliance with all terms and conditions of the attached permit is the responsibility of the Permittee. Please note that T15A 08G .0204 of the North Carolina Administrative Code has been interpreted to mean that the Operator in Responsible Charge is responsible for operation of water pollution control systems. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits which may be required. If you have any questions or need additional information, please do not hesitate to contact Mark McIntire of my staff at (919) 733-5083, extension 508. Sincerely, ORIGINAL SIGNED BY Mark McIntire Alan W. Klimek, P.E. cc: Central Files NPDES Unit Files Raleigh Regional Office Aquatic Toxicology Unit Madolyn Dominy, EPA Region 4 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE 919-733-5083/FAX 919-733-0719 VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES t Permit NC0024201 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Roanoke Rapids Sanitary District is hereby authorized to discharge wastewater from a facility located at the Roanoke Rapids Sanitary District WWTP 135 Aqueduct Road Weldon Halifax County to receiving waters designated as Chockoyotte Creek at the Roanoke River in the Roanoke River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof. The permit shall become effective October 1, 2003. This permit and the authorization to discharge shall expire at midnight on March 31, 2007. Signed this day September 12, 2003. ORIGINAL SIGNED BY Mark McIntire Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0024201 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The Roanoke Rapids Sanitary District is hereby authorized to: 1. Continue to operate an existing 8.34 MGD wastewater treatment facility located at 135 Aqueduct Road near Weldon in Halifax County. This facility discharges through outfall 001 and includes the following wastewater treatment components: • Bar screen and grit chamber • Dual primary clarifiers • Dual trickling filters • Three Aeration basins • Dual final clarifiers • Chlorination • Dechlorination • Dual Secondary sludge thickener • Three anaerobic digesters • Lime stabilization • Sludge storage • Sludge drying beds 2. Discharge from said treatment works at the location specified on the attached map through outfall 001 into Chockoyotte Creek, a class C water in the Roanoke River Basin. -? P. t.4, 3. Upon relocation of the outfall, discharge from said treatment works at the location specified on the attached map through outfall 001 into the Roanoke River, a class C water in the Roanoke River Basin. Roanoke Rapids Sanitary District WWTP State Grid/Quad: Weldon Latitude: B 28 NE Longitude: Receiving Stream: Chockoyotte/Roanoke Drainage Basin: Stream Class: C Sub -Basin: 36° 26' 10" N 77° 36' 34" W Roanoke 03-02-08 61.d NPDES Permit No. NC0024201 Halifax County Permit NC0024201 A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Discharges to Chockoyotte Creek through May 31, 2005) Beginning on the effective date of this permit and lasting until May 31, 2005 or until relocation of the outfall to the Roanoke River is complete, the Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Weekly Average - Daily Maximum Measurement Frequency Sample Type Sample Location' Flow 8.34 MGD Continuous Recording Influent or Effluent CBOD, 5-day, 20°C2 25.0 mg/L 37.5 mg/L Daily Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N Daily Composite Effluent Total Residual Chlorine 28 pg/L Daily Grab Effluent Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily Grab Effluent pH Between 6.0 and 9.0 Standard Units Daily Grab Effluent Dissolved Oxygen Daily Grab Effluent Temperature Daily Grab Effluent Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite Effluent Total Phosphorus Monthly Composite Effluent Total Mercury3 Monthly Grab Effluent, U Total Copper Monthly Composite Effluent Total Zinc Monthly Composite Effluent Total Selenium Monthly Composite Effluent Total Fluoride Monthly Composite Effluent Chronic Toxicity's Quarterly Composite Effluent Dissolved Oxygen Variables Grab U, D Temperature Variables Grab U, D Notes: 1. U: Upstream at 308 Rollingwood Road, on the Roanoke River and the U.S. 158 crossing at Chockoyotte Creek. D: Downstream at U.S. 158 crossing at the Roanoke River. 2. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. Mercury samples must be analyzed using EPA Method 1631, low-level mercury analysis. 4. Chronic Toxicity (Ceriodaphnia) at 39 %; January, April, July and October (see condition A. (4)). 5. Upstream/downstream samples shall be collected 3/Week during June, July, August, September, and 1/Week during the remaining months of the year. Stream sampling may be discontinued at such times as flow conditions in the receiving waters or extreme weather conditions will result in substantial risk of injury or death to persons collecting samples. In such cases, on each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for the month in which the event occurred. Stream sampling shall be resumed at the first opportunity after the risk period has ceased. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0024201 d A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Discharges to Chockoyotte Creek after May 31, 2005) Beginning on June 1, 2005 and lasting until relocation to the Roanoke River or until permit expiration, the Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Locations Flow 8.34 MGD Continuous Recording Influent or Effluent CBOD, 5-day, 20°C2 25.0 mg/L 37.5 mg/L Daily Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N Daily Composite Effluent Total Residual Chlorine 28 pg/L Daily Grab Effluent Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily Grab Effluent pH Between 6.0 and 9.0 Standard Units Daily Grab Effluent Dissolved Oxygen Daily Grab Effluent Temperature Daily Grab Effluent Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite Effluent Total Phosphorus Monthly Composite Effluent Total Mercury3 0.031 pg/L Weekly Grab Effluent, U Total Copper Monthly Composite Effluent Total Zinc Monthly Composite Effluent Total Selenium 12.8 pg/L Weekly Composite Effluent Total Fluoride 4.62 mg/L Weekly Composite Effluent Chronic Toxicity, Quarterly Composite Effluent Dissolved Oxygen Variables Grab U, D Temperature Variables Grab U, D Notes: 1. U: Upstream at 308 Rollingwood Road, on the Roanoke River and the U.S. 158 crossing at Chockoyotte Creek. D: Downstream at U.S. 158 crossing at the Roanoke River. 2. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. Mercury samples must be analyzed using EPA Method 1631, low-level mercury analysis. 4. Chronic Toxicity (Ceriodaphnia) at 39 %: January, April, July and October (see condition A. (4)). 5. Upstream/downstream samples shall be collected 3/Week during June, July, August, September, and 1/Week during the remaining months of the year. Stream sampling may be discontinued at such times as flow conditions in the receiving waters or extreme weather conditions will result in substantial risk of injury or death to persons collecting samples. In such cases, on each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for the month in which the event occurred. Stream sampling shall be resumed at the first opportunity after the risk period has ceased. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC002420 1 A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Discharges after outfall relocation) Beginning upon relocation of the outfall to the Roanoke River and lasting until permit expiration, the Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: CHARACTERISTICS ISTICs NT EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Weekly .• • Average ` Daily Maximum Measurement Frequency Sample Type Sample Location1 Flow 8.34 MGD Continuous Recording Influent or Effluent CBOD, 5-day, 20°C2 25.0 mg/L 37.5 mg/L Daily Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N Daily Composite Effluent Total Residual Chlorine 28 pg/L Daily Grab Effluent Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily Grab Effluent pH Between 6.0 and 9.0 Standard Units Daily Grab Effluent Dissolved Oxygen Daily Grab Effluent Temperature Daily Grab Effluent Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite Effluent Total Phosphorus Monthly Composite Effluent Total Mercury3 0.012 pg/L Weekly Grab Effluent, U Total Copper Monthly Composite Effluent Total Zinc Monthly Composite Effluent Total Selenium Monthly Composite Effluent Total Fluoride Monthly Composite Effluent Chronic Toxicity's Quarterly Composite Effluent Dissolved Oxygen Variables Grab U, D Temperature Variables Grab U, D Notes: 1. U: Upstream at 308 Rollingwood Road. D: Downstream at the U.S. 158 crossing at the Roanoke River. 2. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85% removal). 3. Mercury samples must be analyzed using EPA Method 1631, low-level mercury analysis. 4. Chronic Toxicity (Ceriodaphnia) at 1.1 %; January. April, July and October (see condition A. (5)). 5. Upstream/downstream samples shall be collected 3/Week during June, July, August, September, and 1/Week during the remaining months of the year. Stream sampling may be discontinued at such times as flow conditions in the receiving waters or extreme weather conditions will result in substantial risk of injury or death to persons collecting samples. In such cases, on each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for the month in which the event occurred. Stream sampling shall be resumed at the first opportunity after the risk period has ceased. There shall be no discharge of floating solids or visible foam in other than trace amounts. r Permit NC0024201 A. (4) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) (Discharges to Chockoyotte Creek) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 39%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia •Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0024201 A. (5) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) (Discharges after outfall relocation) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 1.1%. The permit holder shall perform at a minimum, Quarterlu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998. or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required. the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit NC0024201 A. (6) Effluent Pollutant Scan The permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached table (in accordance with 40 CFR Part 136). Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be analyzed as "total recoverable." Ammonia (as N) Trans- 1 ,2-d ichloroethylene Bis (2-chloroethyl) ether Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate Oil and grease Methyl bromide 2-chloronaphthalene Phosphorus Methyl chloride 4-chlorophenyl phenyl ether Total dissolved solids Methylene chloride Chrysene Hardness 1, 1 ,2,2-tetrachloroethane Di-n-butyl phthalate Antimony Tetrachloroethylene Di-n-octyl phthalate Arsenic Toluene Dibenzo(a,h)anthracene Beryllium 1, 1, 1 -trichloroethane 1,2-dichlorobenzene Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene Chromium Trichloroethylene 1,4-dichlorobenzene Copper Vinyl chloride 3,3-dichlorobenzidine Lead Acid -extractable compounds: Diethyl phthalate Mercury P-chloro-m-creso Dimethyl phthalate Nickel 2-chlorophenol 2,4-dinitrotoluene Selenium 2,4-dichlorophenol 2,6-dinitrotoluene Silver 2,4-dimethylphenol 1,2-diphenylhydrazine Thallium 4,6-dinitro-o-cresol Fluoranthene Zinc 2,4-dinitrophenol Fluorene Cyanide 2-nitrophenol Hexachlorobenzene Total phenolic compounds 4-nitrophenol Hexachlorobutadiene Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene Acrolein Phenol Hexachloroethane Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene Benzene Base -neutral compounds: Isophorone Bromoform Acenaphthene Naphthalene Carbon tetrachloride Acenaphthylene Nitrobenzene Chlorobenzene Anthracene N-nitrosodi-n-propylamine Chlorodibromomethane Benzidine N-nitrosodimethylamine Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine 2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene Chloroform 3,4 benzofluoranthene Pyrene Dichlorobromomethane Benzo(ghi)perylene 1 ,2,4-trichlorobenzene 1,1-dichloroethane Benzo(k)fluoranthene 1 ,2-dichloroethane Bis (2-chloroethoxy) methane Test results shall be reported to the Division in DWQ Form- A MR-PPA1 or in a form approved by the Director within 90 days of sampling. Two copies of the report shall be submitted along with the DMR to the following address: Division of Water Quality, Water Quality Section, Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. A. (7) Metals Reopener The Permittee may request modification of the effluent limitations/upstream monitoring for metals described herein after 12 months of data collection. Roanoke Rapids Sanitary District Comments on Final Dra... Subject: Roanoke Rapids Sanitary District Comments on Final Draft NPDES Pe rmit From: "Sadler, Mary" <MSadler@arcadis-us.com> Date: Fri, 25 Jul 2003 09:07:45 -0600 To: "Mark McIntire (E-mail)" <mark.mcintire@ncmail.net>, "Dan Brown (E-mail)" <dbrown@rrsd.org>, "Gregg Camp (E-mail)" <gcarp@rrsd.org> CC: "Maynard, John" <JMaynard@arcadis-us.com>, "Stroud, Ross" <RStroud @ arcadis-us.com> Hi Mark!! I hope you had a good time in Chicago!! Dan, Gregg, and I have looked over RRSD's final draft permit, and we have a few comments, mostly editorial: 1. Composite mercury sampling is shown at both the Effluent and Upstream sampling locations. I have already talked with you about this and verified that the composite sampling should be changed to grab sampling at both locations. 2. In Section A(2), 4 (instead of temperature (instead of 7) . the chronic toxicity footnote should be footnote footnote 6), and the measurement frequency for DO and measured upstream and downstream should be footnote 5 3. In Section A(2), the footnote for total mercury should reference footnote 3 instead of footnote 5. 4. We would like to Section A(7) applies to both the location requirement. If so, modified to include the upstream sampling. For example, "The Permittee may request modification of the effluent limitation/upstream monitoring for metals described herein after 12 months of data collection." verify that the metals reopener clause in effluent limit and the upstream sampling we respectfully request that the language be 5. Additionally, the RRSD will request a permit modification to 1 of 2 8/19/03 9:00 AM RoanokeRapids Sanitary District Comments on Final Dra... a their cover page and map at such time the discharge is relocated to the Roanoke River. They would like to make sure the language on the cover page and the location on the map accurately reflect where they are discharging. Also, are you aware of any public comment on the permit? The public comment period expires August 2nd. Dan has a board meeting on August 12th, and he would like to be able to tell the board definitively if there has, or has not, been any comment. If there has been public comment, Dan will need to report to his board on the details. Thank you for your help in straightening RRSD's permit over the last several months!! Your help has been very much appreciated! Please give me a call if you have any questions. Mary 2 of 2 8/19/03 9:00 AM UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 L 2 3 2003 W. Klimek, P.E., Director ivision of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJ: Review of Proposed NPDES Permit City of Roanoke Rapids WWTP NPDES Permit No. NC0024201 Dear Mr. Klimek: crt d 2003 DIV. OF WATER QUALITY DIRECTOR'S OFFICE We have reviewed the July 2, 2003, proposed National Pollutant Discharge Elimination System (NPDES) permit referenced above that was received by our office on July 9, 2003. This proposed NPDES permit replaces the proposed permit that was submitted electronically by your office on March 20, 2003. Because the July 2, 2003, proposed permit and amended fact sheet address the concerns of our December 17, 2002, objection, this letter serves to withdraw EPA's objections and the Division of Water Quality may proceed with issuance of this proposed permit. We request that we be afforded an additional review opportunity only if significant changes are made to the proposed permit prior to issuance or if significant comments to the proposed permit are received. Otherwise, please send us one copy of the final permit when issued. I appreciate the cooperation provided by you and your NPDES permitting staff in resolving this matter. If you have any questions, please feel free to contact me directly or have your staff contact Marshall Hyatt at (404) 562-9304. Sincerely, a,c6)-t0c9 Xifloo-uA James D. Giattina, Director Water Management Division cc: Daniel Brown, P.E., Roanoke Rapids Sanitary District EooZ o£ inr Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) Sop—On-03 10:46A P .02 Sop—O3—O3 1O:46A P. 01 ) PUBLIC NOTICE STATE OF NORTH CAROUNA ENVIRONMENTAL COMMISSION NPDE9 UNIT 1817 AILY1E{{�,�n' ICE arpra NOTIFICATION OF INTENT 5 WASTEWA- TER PERMIT On t,o basis el thor- ough staff review and application of StaNC le General 143.21, Publlo law 92- 500 end other lavAul atandanda and regl4a- tiiona. the North Carols- . E enonm�Rel Menagsm ro set . mission p P° osue a Iydlonal Pdlu- Iant.OtsChar9e EGrni- natlen System (NPDES) wastewater olsca)erge permit to the earaon(s) Yale: below. 8necove 45 days Imm the plOfah date of Ihls notice. • Written comments re - ending .Me proposed gpormil will be acce- roposed ed until 30 days natter the publish dale nl this. notice. NI com- ments receNeo pear to that data are con• skived n the final de- terminations re9erdn9 tow proposed pert. The Director of the NC Division of Water Oualiy may declde to hold a public mooting for the. proposed per' mil should the DWI' mien receive 0 si06 cant degree 01 p interest. Copies of me dials Parfait and other huh - poring idonnailan on No used to determine condition present In the draft permit are available triton r - quael and payment of the costa of reproduu- tion.'Moll comments rnhdsor requests for In- formatbn to the NC Division of Water Quality el the obeys addreee or call Me. Valery Stephens at (919) 733.5083. ex- tension 520. Please Include the NPDES permit number (at- tached) in any COm- muntcationinterest.: persons may also visit the Division et Water Quality at 512 N. Sal- isbury Street, Raleigh, NC 27804-114a be- tween the hours of a:00 am. .rid 5:00 o.m. !0 review Infor- mation of flle. The Roanoke Rapids Sanitary District has Implied for rorfownl or the NPDES permit for e s sanitary weelewe- ter treatment plant to- eated err Wagon, NC, Halifax County. This Meaty hen hlotorkally discharged to Chock- oyolte Creed and win continue to do so for a period of 18 months beyond the proposed e nactors dale of the NPDES panne. Altar 18 months. the IacAily will either relocate their outlet! to the Roanoke River or meet more stringent .nhurrl fmitatinns for toxicants- Currently, total mercury. Idol iw- oride. acid total seleni- um are water quality Rmiled. This dischar0• may impact future al- iecalkan s In either Chodtwyoae Creek or the Roanoke Rivet. July 7; `20D3 . . AFFIDAVIT OF PUBLICATION ROANOKE RAPIDS DAILY AND SUNDAY HERALD ROANOKE RAPIDS, NC 27870 NCDEN WD WQ/N PDES Attn: Velery Stephens 1617 Mail Service Ccliter Raleigh, NC 27699-1617 Date Description Amount Public Notice July 07 12 W' @ S7.36 393.84 UII.I V 1)I IF AP'IL'R I•IRS T IN31:g 110k Kt IN8l;KY R r•QGlKI!U NI!MBEIS OP PCNI.ICA I IONS ATTDRNLYs Pi. At'Ihki AUVIIRTICIN , .ARP, RI-SM1NaRl n MR wccYx l'rc AFFIDAVIT OF PUBLICATION North Caroline Halifax County Uefare the undersigned, n Notary Public of said ('aunty and Slane, duly eonnaic Toned. qualified, .nd aurhai nl by law to administer oaths. personally uppcsrcd Cathy C. Joins who being first duly sworn. depress and u)ys• that harsh, is Asst. Reokkeencr. (Owner, partner, publisher, or other officer or employee authorized to nuke this atlidavit) of l'H E ROANOKE RAPIDS HERALD engaged in the publication ore newspaper known sib DAILY AND st 1.41)AY HeltAlh. published, iraalod, aril entered as seumd class nrall In the City or Roanoke Rapids in said (loamy and SIAIN; that he/she is out erircd to stake this erllatuvil and swum ostenwnl; Ihal the notice or other level advertisement. a true ropy of wine,. is nRuehcd lu-.au,.vus pulrli.had m 'tiler DAILY AND SUNDAY HERALD on the following dater luly07 2003 and that the said newspaper in %shish such notice, panel, document. dr Iegnl edvullisrni nt was published. at the time Omit and every such publication. a newspaper meeting all of the ohpiistmons anti gldhhealinny of 5enhm I -597 alit,: Ocnctal Statutes erhenh Carolina and Wt. ■ quaWled n:wsp)per within the meaning gtSection I.597 or the (ica•nd Semmes ur North Csrohn). A.dst.ant Bookkeeper Subserihed and swam Io beliefs me Ilea July 10. ZW7. A1j•iiemmoilusespires �M NOTARY PUBLIC Amendment to Fact Sheet Roanoke Rapids Sanitary District NC0024201 - March 19, 2003 Reasonable Potential Analysis: The Roanoke Rapids Sanitary District discharges to Chockoyotte Creek approximately 100 feet upstream of its confluence with the Roanoke River. In 1997, the Division conducted a mixing study at the mouth of Chockoyotte Creek in an effort to more accurately quantify flows. Conductivity was used as a surrogate during the study. The study, in combination with a settlement agreement from a contested case, yielded an instream-waste-concentration (IWC) of 39%. The settlement agreement used an IWC of 39% for whole effluent toxicity (WET) testing but continued to evaluate reasonable potential for toxics using an IWC of 1.1% based on the 7Q1O of the Roanoke River. With this renewal, toxics have been evaluated using an IWC of 39% (corresponding to a 7Q1O flow of 20.2 cfs). The table below summarizes the reasonable potential analyses for the parameters listed. Allowable Parameter I concentration Chronic (p9/1) Allowable concentration Acute (pgl ! Maximum I predicted ! (pg/1) RP (YIN). Comments _ Beryllium .----------------------- Cadmium 16.7 360 i 1.1 15 4.8 N ; No changes to permit are required _ N No changes to permit are required 4-5.1 Chromium I 128.2 1022 N ; No changes to permit are required Copper 17.9 _ ------ 7.3 -4- ____18.2 _ 347- Y Acute reasonable potential, add monitoring. Nickel 225.6 261 26 N No changes to permit are required Zinc 128.2 67 460 Y Acute reasonable potential, add --------------------------�- Mercury --------a I 0.031 -1------------ NA --------- Y monitoring. •------------------ -----_-_--_w--------_------------ --------- ; Add limit of 0.031 pg1L 22.2 Selenium i 12.8 NA 82.5 ! Y ! Add limit of 12.8 µg/L 12.8-----1_------ Cyanide -------_------- ------- _ 22-------_,__iI8ii -----__--------------.._ N _ Nochanges to permit arrequred- ....__------------------------------------_... w__-e----------------- . Chloroform 1205 NA i 5.9 N No changes to permit are required Fluoride 4615 NA i 7590 Y Add Limit of 4615 µg/L Compliance Schedule: In an effort to give the Sanitary District time to meet the new effluent limitations outlined above, an 18 month compliance schedule is being proposed. This 18 month timeframe should provide the facility with the necessary time to either relocate their outfall to a location along the Roanoke River or address operational requirements necessary to meet the new limits. Should outfall relocation occur, effluent limitations for toxics will be evaluated using the 7Q1O flow of the Roanoke River - approximately 1172 cfs. This facility will have the opportunity to submit a request for permit modification should the toxics data collected during the compliance schedule period warrant a change in effluent limitations. Furthermore, the facility will be required to monitor for mercury upstream of a potential Roanoke River outfall location in an effort to document background mercury concentrations. If reasonable potential to exceed the State's mercury criterion continues to exist at the time of outfall relocation, documentation regarding the lack of impairment based on background mercury concentrations must be provided before credit for dilution using the 7Q10 of the Roanoke River can be given. Amended by Mark McIntire 03/19/03 Roanoke Rapids Sanitary District May 12, 2003 Mr. Mark McIntire NPDES Unit, Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina, 27699-1617 P.O. Box 308 1000 Jackson Street Roanoke Rapids, NC 27870 (252) 537-9137 Fax: (252) 5374138 3cb¢ www.rrsd.org CERTIFIED MAIL RET1�R(NRECEIPT REQUESTED . JVJ RE: Revised Draft NPDES Permit — Permit No. NC0024201 Roanoke Rapids Sanitary District Wastewater Treatment Plant Dear Mr. McIntire, M AY .t 3 2003 The Roanoke Rapids Sanitary District (RRSD) received the revised subject draft permit on 1 April 2003. We have carefully reviewed it and we request the following modifications. A few of these issues were included in a letter dated 8 October 2002 in response to the first draft permit. The following issues organize our comments: • Outfall 001 Comments • Request for New Effluent Limits Page to the Roanoke River • New Special Condition for Metals Reopener • General Editorial Comments OUTFALL 001 COMMENTS (SECTION A(1) AND A(2)) A. Section A(1) and A(2) Note #4 — Removal of Dissolved Oxygen Limit A dissolved oxygen limit has been imposed in section A(1) Note #4 of the permit. Dissolved oxygen is limited by a water quality standard if a BOD5 limit in a permit is less than 30 mg/L for Class C waters. RRSD has a CBOD5 limit of 25 mg/L, which is equivalent to a BOD5 concentration of 30 mg/L (per Water Environment Federation Manual of Practice 8). Historically, BOD5 has very little impact on downstream dissolved oxygen concentrations and has therefore never been water quality limited. For example, during the hot weather month of July 2002, the average downstream DO levels were 7.3 mg/L with a plant effluent dissolved oxygen concentration of 4.9 mg/L. We respectfully request that Note #4 be removed from the permit. B. Upstream Mercury Sampling Location In Section A(1) and A(2) Note #1 of the permit, an upstream sampling location for mercury is specified differently than the normal permitted upstream sampling location at 308 Rollingwood Road. The RRSD respectfully requests that the sampling location for mercury be identified in the permit at 308 cAtarnentsand ithny thamenWrples pertriMalpeimitco mienls2.dx Page: 1/3 Rollingwood Road. This will eliminate RRSD staff from having to go to two different sampling locations to collect essentially the same sample. C. Clarification of Monitoring and Reporting Requirements We request that language be added within the text of the permit stipulating that influent or effluent sampling may be discontinued when flow conditions or extreme weather conditions could result in injury or death of the persons collecting the samples, with the requirement that sampling will be resumed at the first opportunity after the risk period has ceased and that written justification for the discontinuance be included in the discharge monitoring report for the month in which the event occurred. This provision has already been added to Note #6 in Section A(1) and A(2) that applies to stream sampling. We respectfully request that the statement "This provision also applies to influent and effluent sampling" be added to the end of Note #6 in Sections A(1) and A(2). D. Removal of Fluoride Limit A fluoride monitoring and reporting requirement and limit has been added to this revised permit. It is our understanding that only two data points for fluoride were used to calculate the reasonable potential for this parameter. The RPA analysis is statistically invalid for two data points. Additionally, all of the fluoride in the effluent originates from City water. The RRSD respectfully requests that the fluoride limit be removed from Section A(2) the revised permit. E. Section A(1) and A(2) — Compliance Schedule Date We respectfully request that the date of the compliance schedule be modified to reflect the full 18-month compliance schedule starting from the actual date of permit issuance. REQUEST FOR NEW EFFLUENT LIMITS PAGE TO THE ROANOKE RIVER We respectfully request that a new effluent limits page for a discharge to the Roanoke River be added to the permit. We fully intend to relocate the existing effluent gravity outfall per the Final Effluent Outfall Relocation Study, and we are waiting on a response from DWQ to approve the recommendation to relocate the outfall upstream of the confluence of the Roanoke River with Chockoyotte Creek. We also respectfully request that the same permits limits be applicable for the existing force main discharge to Chockoyotte Creek. Per the Final Effluent Outfall Relocation Study, the existing force main discharge was only operated 3.6% of the time over the last decade and only for emergency use. Additionally, we exercise the effluent flood pumps for 1 to 2 hours per month. NEW SPECIAL CONDITION FOR METALS RE -OPENER Per DWQ's negotiated agreement with EPA, an 18-month compliance schedule is drafted into the permit for meeting permit limits if the RRSD chooses not to relocate the outfall to the Roanoke River. It is our understanding that the RRSD may collect as much data as needed from the active start date of the revised permit to refute the current metals limits. Therefore, RRSD respectfully requests that language be included in this revised permit stating that the RRSD may request a permit re -opener after 12 months of sampling and monitoring for re-evaluation of metals limits. GENERAL ISSUES A. Cover Page • The address of the cover page should add a "NC" after "Weldon". We very much appreciate the time and effort of the NPDES Unit in developing our revised draft permit and thank you for your consideration of these requests. We look forward to your response. We would be happy to provide additional information or to meet with you to clarify the issues. Please do not hesitate to call Mary Sadler with ARCADIS (919-782-5511) or me if you have any questions. Sincerely, Roanoke Rapids Sanitary District Q..b....."-ir.---- R. Danieley Bro , PE Chief Executive fficer Attachments Cc: Gregg Camp, ORC RRSD Wastewater Treatment Plant Dave Goodrich, DWQ, NPDES Unit Supervisor Mary Sadler, ARCADIS NPDES Unit File — 2 File UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 7 2002 'Alan W. Klimek, P.E., Director Division of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJ: Review of Draft NPDES Permit City of Roanoke Rapids WWTP NPDES Permit No. NC0024201 Dear Mr. Klimek: DEC 2 0 2002 We have completed our review of the draft National Pollutant Discharge Elimination System (NPDES) permit received by this office on September 18, 2002, for the facility referenced above. In an attempt to reach agreement between our staffs on our concerns, the Environmental Protection Agency (EPA) had indicated through an October 11, 2002 letter that its review of this permit would be completed by December 17, 2002. Based on our discussions to date, agreement on all issues could not be reached. Thus, EPA is providing two specific objections that are detailed below, pursuant to Section III.B.1 of the North Carolina/EPA Memorandum of Agreement (MOA) and federal regulations. This facility discharges to Chockoyotte Creek, just above its confluence with the Roanoke River. The permit fact sheet indicates that a reasonable potential analysis for toxics was conducted based on the low flow dilution available for the Roanoke River, not Chockoyotte Creek. It is EPA's understanding that limits for several parameters would be needed if a reasonable potential analysis was conducted using the low flow dilution for Chockoyotte Creek. Because these limits are lacking, the draft permit does not appear protective of water quality standards in Chockoyotte Creek, and thus, EPA specifically objects based on Clean Water Act (CWA) §301(b)(1)(C) and 40 C.F.R. §122.44(d). The 40 C.F.R. §122.44(d) regulations require effluent limits where reasonable potential to exceed state numeric criteria exists and that all effluent limits must derive from and comply with all state water quality standards. To resolve this specific objection, a reasonable potential analysis for toxics based on the low flow dilution for Chockoyotte Creek must be conducted. If reasonable potential is found for any parameter(s), the permit must be redrafted with suitable limits and the fact sheet must reflect the rationale for the limit(s). The revised permit also may contain a compliance schedule for the limited parameter(s), if appropriate. If reasonable potential is not found to exist for any parameter, an updated fact sheet including this analysis and rationale must be prepared and submitted:to EPA prior to permit reissuance. 03\u9\ Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer) 2 Second, since the facility discharges first to Chockoyotte Creek, the draft permit's mercury limit that is based on the low flow dilution of the Roanoke River is not appropriate. EPA specifically objects based on CWA §301(b)(1)(C) and 40 C.F.R. §122.44(d). To resolve this specific objection, the permit must be redrafted to contain a mercury limit based on the low flow dilution available from Chockoyotte Creek. It is EPA's understanding that the permittee is considering relocating its discharge to the Roanoke River. The Roanoke River is now on the North Carolina CWA Section 303(d) list for mercury. Due to that listing, an assumption of zero background for mercury is not valid. Any permit based on a direct discharge to the Roanoke River must contain an end -of -pipe mercury limit because no dilution credit is available. However, the permittee may choose to conduct sufficient and appropriate ambient mercury monitoring of the Roanoke River, using clean techniques and EPA Method 1631E. These data could be used to show that background levels for mercury do not exceed North Carolina water quality criteria. If such a demonstration can be made and credit for dilution given, such a permit for direct discharge to the Roanoke River may contain a mercury limit based on such dilution. I request that you redraft the permit to address the specific objections expressed above and submit a proposed final permit and a revised fact sheet to EPA for review under the provisions of Section III.B.3 of the MOA. If you have any further questions, please contact me or Mr. Marshall Hyatt of my staff at 404/562-9304. Sincerely, James D. Giattina, Director Water Management Division cc: R. Danieley Brown, P.E., Roanoke Rapids Sanitary District ,o• S? . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY .� A Yw REGION 4 i Q ATLANTA FEDERAL CENTER 3 o� 61 FORSYTH STREET yTq< pnoi�G. ATLANTA, GEORGIA 30303-8960 R 2 0 2003 flan W. Klimek, P.E., Director 'vision of Water Quality North Carolina Department of Environment and Natural Resources 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJ: Review of Proposed NPDES Permit City of Roanoke Rapids VVWTP NPDES Permit No. NC0024201 Dear Mr. Klimek: MAD 2 2003 DV. OF WATER QUALITY DIRECTOR'S OFFICE We have reviewed the proposed NPDES permit referenced above that was submitted electronically on March 20, 2003. This is in response to the Environmental Protection Agency's (EPA) December 17, 2002 objections. Because the proposed permit and amended fact sheet address our concerns, this letter serves to withdraw EPA's objections and the Division of Water Quality may proceed with issuance of this proposed permit. We note that the discharge may be relocated to the Roanoke River and that background mercury sampling in the River is being required. If reasonable potential to exceed the State's numeric mercury criterion exists at the time of relocation, River background mercury levels must demonstrate the lack of impairment before any credit for dilution using the critical low flow of the Roanoke River can be given. We request that we be afforded an additional review opportunity only if significant changes are made to the proposed permit prior to issuance or if significant comments to the proposed permit are received. Otherwise, please send us one copy of the final permit when issued. If you have any questions, please feel free to contact me directly or have your staff contact Marshall Hyatt at (404) 562-9304. Sincerely, James D. Giattina, Director Water Management Division cc: R. Danieley Brown, P.E., Roanoke Rapids Sanitary District Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable 011 Based Inks on Recycled Paper (Minimum 30% Postconsumer) Amendment to Fact Sheet Roanoke Rapids Sanitary District NC0024201 - March 19, 2003 Reasonable Potential Analysis: The Roanoke Rapids Sanitary District discharges to Chockoyotte Creek approximately 100 feet upstream of its confluence with the Roanoke River. In 1997, the Division conducted a mixing study at the mouth of Chockoyotte Creek in an effort to more accurately quantify flows. Conductivity was used as a surrogate during the study. The study, in combination with a settlement agreement from a contested case, yielded an instream-waste-concentration (IWC) of 39%. The settlement agreement used an IWC of 39% for whole effluent toxicity (WET) testing but continued to evaluate reasonable potential for toxics using an IWC of 1.1% based on the 7Q1O of the Roanoke River. With this renewal, toxics have been evaluated using an IWC of 39% (corresponding to a 7Q1O flow of 20.2 cfs). The table below summarizes the reasonable potential analyses for the parameters listed. Parameter Allowable concentration Chronic (l4li Allowable concentration Acute (Ng/ Maximum predicted (pg/i) RP (YIN) Comments Beryllium 16.7 360 1.1 N No changes to permit are required Cadmium 5.1 15 4.8 N No changes to permit are required Chromium 128.2 1022 18.2 N No changes to permit are required Copper 17.9 7.3 347 Y Acute reasonable potential, monitoring. add Nickel ' 225.6 ' 261 1 26 i N ! No changes to permit are required Zinc 128.2 67 460 Y Acute reasonable potential, monitoring. add __Mercury Selenium 0.031 12.8 NA NA 22.2 82.5 Y Y Add limit of 0.031 pg/L ~ ~_ Add limit of 12.8 µg/L Cyanide 12.8 22 8 N , No changes to permit are required Chloroform 1205 NA 5.9 ____ JNNo changes to permit are required : 7590 I Y Add Limit of 4615 µg/L _ Fluoride 4615 NA Compliance Schedule: In an effort to give the Sanitary District time to meet the new effluent limitations outlined above, an 18 month compliance schedule is being proposed. This 18 month timeframe should provide the facility with the necessary time to either relocate their outfall to a location along the Roanoke River or address operational requirements necessary to meet the new limits. Should outfall relocation occur, effluent limitations for toxics will be evaluated using the 7Q1O flow of the Roanoke River - approximately 1172 cfs. This facility will have the opportunity to submit a request for permit modification should the toxics data collected during the compliance schedule period warrant a change in effluent limitations. Furthermore, the facility will be required to monitor for mercury upstream of a potential Roanoke River outfall location in an effort to document background mercury concentrations. If reasonable potential to exceed the State's mercury criterion continues to exist at the time of outfall relocation, documentation regarding the lack of impairment based on background mercury concentrations must be provided before credit for dilution using the 7Q1O of the Roanoke River can be given. Amended by Mark McIntire 03/19/03 Roanoke Rapids Sanitary District 1000 Jackson Street P. O. Box 308 Roanoke Rapids, NC 27870 (252) 537-9137 Fax (252) 537-9136 October 8, 2002 Ms. Teresa Rodriguez NPDES Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina, 27699-1617 CERTIFIED MAIL RETURN RECEIPT REQUESTED RE: Draft NPDES Permit— Permit No. NC0024201 Roanoke Rapids Sanitary District Wastewater Treatment Plant Dear Ms. Rodriguez: 0 CT - g 2002 8 DBNR-WAt CEQUALITY BRANCH POINT SOU The Roanoke Rapids Sanitary District (RRSD) received the subject draft permit on September 11, 2002. We have carefully reviewed it and we request the following modifications to the draft permit. Most of these issues were discussed with you during a meeting on September 26, 2002. The following issues organize our comments: • Outfall 001 Comments • Chronic Toxicity Permit Limit Comments • General Editorial Comments • Supplemental Parameters OUTFALL 001 COMMENTS (SECTION A(1)) A. Section A (1) Note #4 A dissolved oxygen limit has been imposed in section A (1) Note #4 of the permit. Dissolved oxygen is limited by a water quality standard if a BOD5 limit in a permit is less than 30 mg/L for Clams C waters. RRSD has a CBOD5 limit of 25 mg/L, which is equivalent to a BOD5 concentration of 30 mg/L. Historically, BOD5 has very little impact on downstream dissolved oxygen concentrations and has therefore never been water quality limited. For example, during the hot weather month of July 2002, the average downstream DO levels were 7.3 mg/L with a plant effluent dissolved oxygen concentration of 4.9 mg/L. We respectfully request that Note #4 be removed from the permit. A:\my documentsInptles perm) Araftpermitcomments.Aoc Page: 1/4 B. Proposed Selenium Limit A selenium limit has been imposed in Section A (1) of the permit. The Reasonable Potential Analysis (RPA) from the Long Term Monitoring Plan (LTMP) data showed a large and unusual selenium data point on 4/5/99 of 0.076 mg/L. This selenium data pointwas a transcription error. The 0.076 mg/L value is actually the concentration for zinc on this date. The correct selenium value on 4/5/99 is ND, provided in Attachment # 1. When the RPA for selenium is performed using the correct data point, a limit should not be imposed. We respectfully request that DWQ re -perform the RPA with the correct selenium data and take into consideration the removal of selenium from the permit. The RRSD is working to prevent future errors and apologize for any inconvenience the transcription error may have caused. C. Proposed Mercury Limit A mercury limit has been imposed in Section (1) of the permit. A Priority Pollutant Analysis (PPA) in April 2000 showed a large and unusual mercury data point of 0.002 mg/L. We consider this data point to be highly questionable in light of the fact thatthe mercury data from the LTMP has been below detection over the last three years and the results from the annual PPA for 2001 and 2002 were also below detection. We confirmed with Southern Testing and Research Laboratories that the 2000 PPA mercury data point was not a transcription error. However, review of the laboratory QA/QC procedures revealed highly suspect QA/QC results. The spike QA/QC mercury sample used for the sample set analyzed for the 2000 PPA was reported to be 0.002 mg/L, which is identical to our effluent sample result of 0.002 mg/L. Therefore, we believe the effluent sample was spiked accidentally prior to analysis. During the same PPA sampling event in April 2000, a portion of the sample collected for the PPA was also used for required quarterly Ceriodaphnia toxicity testing. The result of the April 2000 toxicity test was a pass. The questionable PPA levee w mercuy test result suggests that the concurrent WET test should have -�'�been a_fail if the effluent mercury as indeed an order of magnitude higher than the detection level. In light of the aforementioned evidence (Attachment #2), we strongly feel that this April 2000 mercury data point was contaminated during QA/QC procedures. We respectfully request that DWQ re -perform the mercury RPA without this data point and take into consideration the removal of mercury from the permit. RRSD is working with Southern Testing and Research Laboratories to prevent future QA/QC errors. D. Upstream and Downstream Sampling Locations Note # 1 in Section A(1) lists the incorrect sampling locations for the RRSD WWTP. The upstream and downstream sample locations are not at NCSR 1451 or at NC Highway 210, respectively. The correct upstream sampling location is at 308 Rollingwood Road on the Roanoke River and downstream at the US 158 Crossing on the Roanoke River. d:Yny doaimentsVipdes pCm1 bBRDCmd mnentS.dOC Page: 2/4 E. Clarification of Monitoring and Reporting Requirements We request that language be added within the text of the permit that stipulates that influent or effluent sampling may be discontinued when flow conditions or extreme weather conditions could result in injury or death of the persons collecting the samples, with the requirement that sampling will be resuimd at the first opportunity after the risk period has ceased and that written justification for the discontinuance will be included in the discharge monitoring report for the month in which the event occurred. This provision has already been added to Note #6 in Section A(1) that applies to stream sampling. We respectfully request that the statement "This provision also applies to influent and effluent sampling" be added to the end of Note #6. CHRONIC TOXICITY PERMIT LIMIT COMMENTS (SECTION A(2)) Section A (2) describes the permit limit requirements for chronic toxicity testing. The current permit contains a statement that should RRSD choose to relocate the outfall to the Roanoke River, quarterly P/F q) II. chronic toxicity testing at 1.3% will be required. We respectfully request that this statement be added to Section A (2). GENERAL ISSUES A. Cover Page • The "City of Roanoke Rapids" should be modified to read "Roanoke Rapids Sanitary District". • The address of the cover page should add a "NC" after "Weldon". • The receiving waters description should be changed to "...receiving waters designated as Chockoyotte Creek at the Roanoke River in the Roanoke River Basin..." B. Supplement to Cover Sheet • The RRSD treatment facility is located in Halifax Countyand not Lance County. • Revise the treatment description. The RRSD is a 8.34 MGD waste treatment facility consisting of a bar screen, grit chamber, dual primary clarifiers, dual roughing trickling filters, triple aeration basins, dual final clarifiers, chlorination, dechlorination, dual secondary gravity sludge thickeners, triple anaerobic digesters, lime stabilization facilities, sludge storage, and sludge drying beds. • Modify comment number 2 to read, "Discharge from said treatment works at the locationspecified on the attached map into Chockoyotte Creek at the Roanoke River (001), classified Class C waters in the Roanoke River Basin." d: uy documentslnpdes pemdlldraftpennilcomments.doc Page: 3/4 SUPPLEMENTAL PARAMETERS Per a letter from you dated 18 July 2002, you requested effluent analyses of eight additionalparameters and a second species toxicity test. We are forwarding herein the results of the requested testing (Attachment #3) with the exception of a second species chronic toxicity test. In regards to the second species test, the USGS had conducted research toxicity testing at our plant earlier this year, and at one point we had requested that the results of the USGS testing be acceptable as our second species test. Matt Mathews in the Toxicological Unit has assisted us in the determination of the applicability of the USGS research. Matt reviewed the USGS water quality data and bench sheets from the USGS study. We learned that the USGS did not obtain the required three sample sets, and thus the data will not meet established North Carolina criteria and is therefore unacceptable. We have arranged for our second species sampling to be conducted the week of October 14, which is concurrent with our quarterly toxicity testing. The results will be forwarded to you upon our receipt. We anticipate that we wil receive our results two to three weeks after sampling. We very much appreciate the time and effort of the NPDES Unit in developing our draft permit and thank you for your consideration of these requests. We look forward to your response. We would be happy to provide additional information or to meet with you to clarify the issues. Please do not hesitate to call Mary Sadler with ARCADIS (919-782-5511) or me if you have any questions. Sincerely, Roanoke Rapids Sanitary District f4 R. Danieley Brown, PE Chief Executive Officer Attachments Cc: Gregg Camp, ORC RRSD Wastewater Treatment Plant Dave Goodrich, DWQ, NPDES Unit Supervisor Mary Sadler, ARCADIS NPDES Unit File— 2 File d:My documents\opdes permit dmflpertnemmments.doc Page: 4/4 PUBLIC NOTICE STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION/ NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 NOTIFICATION OF INTENT TO ISSUE A NPDES WASTEWATER PERMIT On the basis of thor- ough staff review and application of NC General Statute 143.21, Public law 92- 500 and other lawful standards and,regula- tions, ire North Caroli- na Environmental Management Corn - mission proposes to issue a,National Pollu- tant Discharge Elimi- natiori System (NPDES) wastewater discharge permit to the person(s) listed below effective 45 days from the public date of this notice. Written comments re- garding the proposed permit will be accept- ed until 30 days after the publish date of this notice. All com- ments received prior to that date are con- sidered in the final de- terminations regarding the proposed permit. The Director of the NC Division of Water Quality may decide to hold a public meeting for the proposed per- mit should the Divi- sion receive a signifi- cant degree of public interest. Copies of the draft permit and other sup- porting information on file used to determine conditions present in the draft permit are available upon re- quest and payment of the costs of reproduc- tion. Mail comments and/or requests for in- formation to the NC Division of Water Quality at the above address or call Ms. Christie Jackson at (919) 733-5083, ex- tension 538. Please include the NPDES permit number (at- tached) in any com- munication. Interested persons may also visit the Division of Water Quality at 512 N. Sal- isbury Street, Raleigh, NC 27604-1148 be- tween • the hours of 8:00 a.m. and 5:00 p.m. to review infor- mation on file. NPDES Permit Num- ber NC0024201. Roa- noke Rapids Sanitary District, P.O. Box 308, Roanoke Rapids, NC 27870 has applied for a permit renewal for a facility located in Hali- fax County discharg- ing treated wastewa- ter into Chockoyotte Creek in the Roanoke River Basin. Currently CBOD are water qual- ity limited. This dis- charge may affect fu- ture allocations in this portion of the receiv- ing stream. September 10; 2002 AFFIDAVIT OF PUBLICATI ROANOKE RAPIDS DAILY AND SUNDAY HERAL ROANOKE RAPIDS, NC 27871 Ii J DFNR_WATPR QU UTY POINT SOURCE BRANCH To: NCDENR/DWQ/NPDES Attn: Christie Jackson 1617 Mail Service Ct. Raleigh, NC 27699-1617 Date Description Amount Environmental Management Commission/ NPDES Unit September 10 14 1/4" @ $7.15 $101.89 BILLS DUE AFTER FIRST INSERTION TO INSURE REQUIRED NUMBER OF PUBLICATIONS — ATTORNEYS PLACING ADVERTISING ARE RESPONSIBLE FOR ACCOUNTS. AFFIDAVIT OF PUBI..ICATION North Carolina Halifax County Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified, and authorized by law to administer oaths, pet sonally appeared Cathy C. Jones, who being first duly sworn, deposes and says: that he/she is Asst. Bookkeeper. (Owner, partner, publisher, or other officer or employee authorized to make this affidavit) of THE ROANOKE RAPIDS HERALD engaged in the publication of a newspaper known as DAILY AND SUNDAY HERALD, published, issued, and entered as second class mail in the City of Roanoke Rapids in said County and State; that he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a true copy of which is attached hereto, was published in THE DAILY AND SUNDAY HERALD on the following dates: September 10, 2002 and that the said newspaper in which such notice, paper, document, or legal advertisement was published, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning ection 1-597 of the General Statutes of North Carolina. Signed Assistant Bookkeeper Subscribed and sworn to before me this September 13, 2002 My commission expires (SEAL) mYGamdEssen-Erfoffseis.e toLa NOTARY PUBLIC Re: comments on NC0024201 - Roanoke Rapids Subject: Re: comments on NC0024201 - Roanoke Rapids Date: Wed, 06 Nov 2002 09:12:17 -0500 From: Teresa Rodriguez <teresa.rodriguez@ncmail.net> Organization: NC DENR DWQ To: Hyatt.Marshall@epamail.epa.gov Marshall, I received comments from Roanoke Rapids on the draft permit. They sent information showing that the selenium data used for the rpa had an error. The maximum value reported in the data (76 ug/1) was a result for zinc, not selenium. They provided the lab sheet showing the actual results. I did the reasonable potential again and the limit is not necessary. In response to your comments: 1. The reason the dilution for the river has been used in this permit is due to the proximity of the discharge to the river and the influence of the river into the creek. The discharge is about 100 feet upstream of the river. Full dilution occurs quickly because the head pressure of the river pushes water up into the creek into the discharge area. The toxicity test was implemented in the last permit renewal with the 39 percent dilution with the condition that if they fail the toxicity testing due to toxic pollutants, the metal limits would be reevaluated. Further studies will be needed to calculate the actual dilution and Roanoke Rapids has decided to relocate the effluent pipe to the river. We propose to use the same approach as the previous permit since there has been no significant changes. Relocation will probably occur during the next permit cycle. 2. I did a reasonable potential evaluation for fluoride using the two values from the PPA. The results show no reasonable potential. 3. At the present time there is no TMDL or strategy for mercury for the Roanoke River and the priority ranking is low. The advisory is part of a broad mercury advisory for the eastern part of the state. We believe the approach used is appropriate until the Division establishes a TMDL or implements a management strategy. 4. In the last permit renewal the permittee requested that the limits be changed from BOD5 to CBOD5 and they were given equivalent limits. 5. I inadvertently omitted the toxicity test results from the fact sheet. They had one failure in July 2001. I also made some changes and corrections to the permit. I'm including the copy of the permit and the cover letter. Thanks, Teresa Hyatt.Marshall@epamail.epa.gov wrote: > Hope these comments are useful. Will you be able to provide a response > by Oct 9, so we have time to prepare a comment or objection letter (if > needed)? thanks! Marshall > 1. The fact sheet for this draft indicates than an agreement was > reached to resolve an appeal of the current permit to use an IWC of 39% > for WET and 1.3% for toxics. Pis explain why these values are different > and the basis for each. I am concerned that the 39$ IWC is based on > dilution provided by Chockoyotte Creek and the 1.3$ dilution is based on > that provided by the Roanoke River. If that is the case, I don ' t think > it's legal to allow dilution based on the Roanoke R. for discharges to 1 of 2 11/7/2002 1:21 PM Re: comments on NC0024201 - Roanoke Rapids > Chockoyotte Cr and that you didn't conduct an RPA for toxics to protect > Chockoyotte Cr. Pis explain - w/o a sufficient basis, this may > constitute a permit objection based on Sec. 301 (b) (1) (C) of the Clean > Water Act and 40 CFR 122.44(d)(1). > 2. In the materials that were attached to the application, I did see 2 > effluent values for fluoride of about 2 and over 7 mg/1. The lack of a > limit for this is a problem if there is not a good basis for the 1.3% > IWC for toxics. > 3. The fact sheet indicates that the Roanoke River is on the 303(d) > list for Hg due to high fish levels. It appears that the 1.3% that's > allowed for dilution is based on the Roanoke River, not Chockoyotte Cr. > If this is correct, how can you assume any dilution is available for Hg > when the Roanoke River is 303(d) listed for Hg? Pis explain. W/o a > sufficient explanation, it seems this would be a basis for objection, > since an end of pipe limit of 0.012 ug/1 for Hg would probably be > required to be consistent with 40 CFR 122.44(d)(1). At the most, > dilution provided by Chockoyotte Cr could be considered (is this where > the IWC of 39% comes from?) in deriving the limit since it is not on the > 303(d) list > 4. I noticed that this permit contains CBOD5 limits. Most, if not all > other, NC POTW permits that I've seen had BOD5 limits. Am curious why > this permit is different. > 5. why doesn't the fact sheet mention or address previous WET results? permit 24201.doc Name: permit 24201.doc Type: Microsoft Word Document (application/msword) Encoding: base64 Download Status: Not downloaded with message cov let final 24201.doc Name: cov let final 24201.doc Type: Microsoft Word Document (application/msword) Encoding: base64 Download Status: Not downloaded with message or 2 11/7/2002 1:21 PM Michael F. Easley, Govemor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality September 26, 2002. R. Daniely Brown Roanoke Sanitary District P.O. Box 308 Roanoke Rapids, North Carolina 27870 Subject: NPDES Draft Permit Permit no. NC0024201 Roanoke Rapids Sanitary District WWTP Halifax County Dear Mr. Brown: The Division evaluated the proposed plan for a dye study for the potential outfall relocation to the Roanoke River submitted by Arcadis on September 23, 2002. The proposed study is hereby approved. The temporary pumping station shall only be used during dye testing and shall be removed after completion of each dye test. The results of all the tests performed shall be summarized and submitted to the Division after termination of the study. If you have any additional questions, please call Teresa Rodriguez at (91.9} 733,5083, extension 595. Sincerely, Dave Goodk`ich NPDES Unit Supervisor Cc: NPDES Files Raleigh Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-5083 FAX (919) 733-0719 An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us ?cd 4/DBl°a �? ARCADIS Infrastructure, buildings, environment, communications Teresa Rodriguez NPDES Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina, 27699-1617 Subject: Dye Study Field Test Protocol Effluent Outfall Relocation from Chockoyotte Creek to the Roanoke River Roanoke Rapids Sanitary District Dear Ms. Rodriguez, On behalf of the Roanoke Rapids Sanitary District (RRSD), we are forwarding you the attached proposal for the dye study test protocol for the potential effluent outfall relocation. The RRSD is currently evaluating the alternatives for relocating the existing Chockoyotte Creek outfall to the Roanoke River. For economic reasons, the RRSD would like to relocate the discharge upstream of the Roanoke River and Chockoyotte confluence instead of crossing the creek for a discharge downstream of the confluence. In a February 27, 2002, meeting the DWQ approved an upstream discharge provided that field tests be performed to show that plant effluent will not back up into, or pond in, the confluence of the creek and the river. In a September 3, 2002 meeting, the DWQ indicated that a visual dye study test would be sufficient to show the behavior of plant effluent in the river. If the DWQ concurs that the visual evidence is favorable for an upstream discharge, the RRSD may formally request a permanent outfall relocation upstream of Chockoyotte Creek. If you have any questions, please do not hesitate to call. Sincerely, ARCADIS G&M of North Carolina, Inc. Mary E. Sadler, PE Project Engineer Copies: Dan Brown, RRSD Gregg Camp, RRSD John Maynard, ARCADIS ARCADIS G&M of North Carolina, Inc. P.O. Box 31388 Raleigh, NC 27622-1388 2301 Rexwoods Drive - Suite 102 Raleigh, NC 27607-3366 Tel 919 782 5511 Fax 919 782 5905 www.arcadis-us.com WATER AND WASTE MANAGEMENT Date: 20 September 2002 Contact: Mary Sadler Extension: 136 E-mail: msadler@arcadis-us.com Our ref: NC702011.0000 Part of a bigger picture ARCADIS Infrastructure, buildings, environment, communications MEMORANDUM To: Teresa Rodriguez Dave Goodrich From: Mary Sadler, ARCADIS Dan Brown, Roanoke Rapids Sanitary District Copies: Gregg Camp John Maynard File NC030191.0000 Date: 20 September 2002 Subject: Dye Study Field Test Protocol Effluent Outfall Relocation from Chockoyotte Creek to the Roanoke River Roanoke Rapids Sanitary District ARCADIS G&M of North Carolina, Inc. P.O. Box 31388 Raleigh, NC 27622-1388 2301 Rexwoods Drive - Suite 102 Raleigh, NC 27607-3366 Tel 919 782 5511 Fax 919 782 5905 WATER & WASTE MANAGEMENT Background The Roanoke Rapids Sanitary District (RRSD) discharges to Chockoyotte Creek in Subbasin 030208 of the Roanoke River Water Quality Management Basin. The current RRSD discharge location is approximately 100 feet upstream of the confluence of the Chockoyotte Creek with the Roanoke River. This confluence is downstream of the Roanoke Rapids Lake. Virginia/North Carolina Power controls the discharge rate from the Roanoke Rapids Lake to the Roanoke River. The 7Q10 in the Roanoke River is approximately 1000 cfs or 633 MGD. On June 20, 1997 the North Carolina Department of Environment and Natural Resources (NCDENR) Division of Water Quality (DWQ) issued a draft National Pollutant Discharge Elimination System (NPDES) Permit No. NC0024201 that included requirements fora modified instream waste concentration (IWC) of 79%, an increase from the original permitted IWC of 1.3%. The RRSD challenged the draft permit limits, and a settlement agreement was reached in November 1997 for an IWC of 39%. The settlement agreement stated that when the plant discharge is relocated to the Roanoke River, the IWC would revert to 1.3%. Additionally, the settlement agreement states that a diffuser will not be required for a discharge to the Roanoke River. Purpose of Dve Study Test The RRSD is currently evaluating the alternatives for relocating the existing Chockoyotte Creek outfall to the Roanoke River. For economic reasons, the RRSD would like to relocate the discharge upstream of the Roanoke River and Chockoyotte confluence instead of crossing the creek for a discharge downstream of the confluence. In a February 27, 2002 meeting the DWQ approved an upstream discharge provided that field tests be performed to show that plant effluent will not backup into, or pond in, the confluence of the creek and the river. In a September 3, 2002 meeting, the DWQ indicated that a visual dye study test would be sufficient to show the behavior of plant effluent in the river. If the DWQ concurs that the visual evidence is favorable for an upstream discharge, the RRSD may formally request a permanent outfall relocation upstream of Chockoyotte Creek. 1/2 ARCADIS Proposal for Dve Study Test The RRSD proposes the following protocol for the visual dye study test: 1. The RRSD agreed in the September 3, 2002 meeting to operate under the existing permit limits and conditions as specified in the current NPDES permit during the duration of the field tests. 2. The RRSD will notify the DWQ contact (Theresa Rodriquez) via email with the date and time a dye study(s) will be performed. 3. The RRSD will voluntarily notify the public prior to performing each dye test. 4. The RRSD will locate a temporary pump in the existing plant outfall structure. A temporary pipe will be constructed to the Roanoke River with its point of discharge located at the top of bank. The temporary effluent outfall will be located in the vicinity of the proposed outfall location (upstream of Chockoyotte Creek). The temporary pump and piping will not be constructed on site unless a dye test or other testing activities are being performed. 5. Energy dissipation will be provided by the roughen surface of the existing concrete stabilized slope embankment during discharge to mimic the behavior of a gravity outfall line. 6. The RRSD will let the pumped flow to the river stabilize for a 30 to 60 minute period before adding the dye. 7. A fluorescent dye will be used (one example is Rhodamine WT, which has been approved by the EPA as a tracer dye in potable water supplies). Fluorescent dyes are typically used in infiltration and inflow (I&I) testing and monitoring. 8. A person(s) standing at the edge of the riverbank will take pictures or video of the dye dissipation at the confluence of the Roanoke River and the Chockoyotte Creek, as well as upstream and downstream of the confluence. 9. Each dye study event will run for a sufficient length of time to gather good visual data. 10. Dye study tests will be performed for varying flow events in the Roanoke River and at various times during normal working hours, so as to simulate several scenarios of river flow and plant effluent flows. It is anticipated that a dye test will be run before the end of the dry season (October) to capture a low river flow event, and by the end of March 2003 to capture a high river flow event. 11. It is anticipated that the temporary pump and piping will be used for several months in order to test during varying flow conditions in the river. 12. Once each dye study is completed, the normal effluent outfall to Chockoyotte Creek will be placed back into service. Temporary pump & piping may be returned to the vendor and reserved until the next temporary discharge event. G:\Wwm\Roanoke\30191\Dye Study\M TRodrigucz DyeStudy.doc 2/2 09/11/02 15:22 FAX 919 782 5905 ARCADIS G M elooi ARCADIS infrastructure, buildings, environment, communications TELEFAX To: Teresa Rodriguez NPDES Unit Division of Water Quality From: Mary Sadler Fax: 715-6048 OENR - WATER QUALITY POINT SOURCE BRANCH Copies: File NC030191.0000 Dan Brown John Maynard Date: 11 September 2002 Total pages: 3 Subject: ARCADIS Project No.: Dye Study Field Test Protocol NC030191.0000 Effluent Outfall Relocation from Chockoyotte Creek to the Roanoke River Roanoke Rapids Sanitary District ARCADIS G&M 1 of North Carolina, Inc. P.O. Box 31388 Raleigh, NC 27622-1388 2301 Rexwoods Drive - Suite 102 Raleigh, NC 27607-3366 Tel 919 782 5511 Fax 919 782 5905 www.arcadis-us.com WATER AND WASTE MANAGEMENT Extension: 136 If you do not receive all pages, please call to let us know as soon as possible. Hi Theresa! On behalf of the Roanoke Rapids Sanitary District, attached is the proposal for the field dye study test for the effluent outfall relocation from Chockoyotte Creek to the Roanoke River. I will put a clean copy and cover letter in the mail for you this week. Thank you! I look forward to hearing from you! Mary Sadler 1 2 2002 - VIATER QUALITY r..i1a1. SOURCE BRANCH THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT 15 PRIVILEGED, CONFIDENTIAL, AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message Is not the Intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone and return the original message to us at the above address vla the U.S. postal service. Part of a bigger picture .. 09/11/02 15:22 FAX 919 782 5905 ARCADIS G M Cj 002 ARCAD1S Infrastructure, buildings, environment communications MEMORANDUM To: Copies: Teresa Rodriguez File NC030191.0000 Dave Goodrich John Maynard ARCADIS G&M of North Carolina, inc. P.O. Box 31388 Raleigh, NC 27622-1388 2301 Rexwoods Drive - Suite 102 Raleigh, NC 27607-3366 Tel 919 782 5511 Fax 919 782 5905 From: Date: WATER & WASTE Mary Sadler, ARCADIS 11 September 2002 MANAGEMENT Dan Brown, Roanoke Rapids Sanitary District `"' subject Dye Study Field Test Protocol Effluent Outfall Relocation from Chockoyotte Creek to.the Roanoke River Roanoke Rapids Sanitary District Backiround The Roanoke Rapids Sanitary District (RRSD) discharges to Chockoyotte Creek in Subbasin 030208 of the Roanoke River Water Quality Management Basin. The current RRSD discharge location is approximately 100 feet upstream of the confluence of the Chockoyotte Creek with the Roanoke River. This confluence is downstream of the Roanoke Rapids Lake. Virginia/North Carolina Power controls the discharge rate from the Roanoke Rapids Lake to the Roanoke River. The 7Q10 in the Roanoke River is approximately 1000 cfs or 633 MGD. On June 20,1997 the North Carolina Department of Environment and Natural Resources (NCDENR) 'sq Division of Water Quality (DWQ) issued a draft National Pollutant Discharge Elimination System (NPDES) Permit No. NC0024201 that included requirements for a modified instream waste concentration (IWC) of 79%, an increase from the original permitted IWC of 1.3%. The RRSD challenged the draft 1.1 permit limits, and a settlement agreement was reached in November 1997 for an IWC of 39%. The settlement agreement stated that when the plant discharge is relocated to the Roanoke River, the IWC would revert to 1.3%. Additionally, the settlement agreement states that a diffuser will not be required for a discharge to the Roanoke River. Purpose of Dve Study Test fogl The RRSD is currently evaluating the alternatives for relocating the existing Chockoyotte Creek outfall to the Roanoke River. For economic reasons, the RRSD would like to relocate the discharge upstream of the Roanoke River and Chockoyotte confluence instead of crossing the creek for a discharge downstream of fu' the confluence. In a February 27, 2002 meeting the DWQ approved an upstream discharge provided that field tests be performed to show that plant effluent will not backup into, or pond in,'the confluence of the creek and the river. In a September 3, 2002 meeting, the DWQ indicated that a visual dye study test would be sufficient to show the behavior of plant effluent in the river. If the DWQ concurs that the visual evidence is favorable for an upstream discharge, the RRSD will formally request a permanent outfall relocation upstream of Chockoyotte Creek. twl G:1Wwm\Roanoka1301911Dye Study M TRodrigi,a DyeStudy.doc 1/2 Op/11/02 15 : 22 FAX 919 782 5905 ARCADIS G M (j 003 AIR ARCADIS Proposal for Dve Study Test The RRSD proposes the following protocol for the visual dye study test: `.' 1. The RRSD agreed in the September 3, 2002 meeting to operate under the existing permit limits and conditions as specified in the current NPDES permit during the duration of the field tests. 2. The RRSD will notify the DWQ contact (Theresa Rodriquez) via email with the date and time a dye study(s) will be performed. 3. The RRSD will voluntarily notify the public prior to performing each dye test. Rim 4. The RRSD will locate a temporary pump in the existing plant outfall structure. A temporary pipe will. be constructed to the Roanoke River with its point of discharge located at the top of bank. The temporary effluent outfall will be located in the vicinity of the proposed outfall location (upstream of Chockoyotte Creek). The temporary pump and piping will not be constructed on site unless a dye test or other testing activities are being performed. 5. Energy dissipation will be provided by the roughen surface of the existing concrete stabilized slope 6.1 embankment during discharge to mimic the behavior of a gravity outfall line. 6. The RRSD will let the pumped flow to the river stabilize for a 30 to 60 minute period before adding the dye. 7. A fluorescent dye will be used (one example is Rhodamine WT, which has been approved by the EPA as a tracer dye in potable water supplies). Fluorescent dyes are typically used in infiltration and inflow (I&I) testing and monitoring. W 8. A person standing at the edge of the riverbank will take pictures or video of the dye dissipation 9. Each dye study event will run for a sufficient length of time to gather good visual data. 10. Dye study tests will be performed for varying flow events in the Roanoke River and at various times during normal working hours, so as to simulate several scenarios of river flow and plant effluent flows.. GIt is anticipated that the temporary pump and piping will be used for several months in order to test during varying flow conditions in the river, h� "✓ outfall to Chockoyotte Creek wi be placed fan PRI 12. Once each dye study is completed, the normal effluent ll back into service. Temporary pump & piping may be returned to the vendor and reserved until the next temporary discharge event. > O,1WwmlRoemoke1301911Dye StudylM TRodrigucz DycStudy.doc 2/2 S64(.51 Fw: Effluent tests with shortnose sturgeon] Subject: Fw: Effluent tests with shortnose sturgeon] Date: Thu, 8 Aug 2002 14:55:33 -0400 From: "Gregg Camp" <gcamp@rrsd.org> To: "Teresa Rodrigues" <teresa.rodriguez@ncmail.net> CC: "Dan Brown" <dbrown@rrsd.org> Teresa...We intend to submit the following to meet our Chronic Tox second species testing requirements. Please review this information and confirm this will be acceptable and in conformance with EPA requirements prior to September 10th. We have sampled for our other parameters, as requested, and anticipate results by mid September. If acceptable, we will submit ALL required test results at this time. Alternatively, and as previously discussed, we would be requesting our second species testing concurrent with our normal quarterly tox test in October and then forward to you our results immediately upon acquisition from the lab. Should the short nosed gar/fathead minnow testing be acceptable, please advise us of any other required information beyond the results shown, herein. Sincerely, Gregg Camp, ORC Roanoke River Wastewater Treatment Plant 135 Aqueduct Road Weldon, NC 27890 (252) 536-4884 www.rrsd.org Original Message From: Matt Matthews To: acamp @ rrsd.orq Sent: Wednesday, August 07, 2002 3:05 PM Subject: [Fwd: Effluent tests with shortnose sturgeon] Greg, Here's the Shortnose data forwarded to me by Tom Augspurger. Note that it does not contain growth endpoints. I'll forward that information to you as soon as I get it. Matt Original Message Subject: Effluent tests with shortnose sturgeon Date: Tue, 6 Aug 2002 17 :42: 5 2 -0400 From: Tom Augspurger@fws.gov To: matt.matthews@ncmail.net CC: chris ingersoll @usgs.go% Hi Matt - Here's what I've received from the Columbia lab so far on this year's shortnose sturgeon toxicity tests. Its a note from Chris Ingersoll with preliminary results listing the concentrations (with 100 being 100 percent effluent and no dilution...50 being 50 percent effluent, etc...) that were toxic and not toxic (based on tethality...biomass data not available yet). I edited Chis's old note slightly to provide concentration ranges (a couple entries had just the concentration of the effluent that was toxic without the next lower concentration being listed). For a couple entries, the percent mortality at the tesred concentration is also provided. of 3 8/9/2002 I :58 PM Fw: Effluejit tests with shortnose sturgeon] I've talked with Chris about the effluent project, and they are preparing a paper on all the effluents tests (i.e., it will include, among other data, all nine facilities in NC and all species tested), a draft of which should be available this summer. If you need additional specific information, feel free to let me know or to check with Chris. Take care, and thanks for your help in pulling this off. We'll have a report available soon. Tom 919/856-4520 x.21 Forwarded by Tom Augspurger/R4/FWS/DOI on 08/06/2002 05:18 PM Christopher G Ingersoll@USGS 04/03/2002 04:46 PM Tom and Jim: To: Tom Augspurger/R4/FWS/DOI@FWS, cc: GS-B-CERC Toxicology@USGS, Chr Ingersoll/BRD/USGS/DOI@USGS Subject: Effluent tests with shortnose We just completed the effluent tests with the 3 species and it looks like a very good test. Control survival on Day 7 was 98% for the shortnose sturgeon, 90% for the fathead minnows, and 93% for the Ceriodaphnia. We have summarized below the dilutions that bracket the treatments that were nontoxic or toxic. Looks like the sturgeon are somewhat more sensitive compared to fatheads or Ceriodaphnia. Note that this is consistent with what we have observed in the past with sturgeon in single chemical exposures. In these previous studies, were concerned in the sturgeon may have been stressed. In the current study, the sturgeon look to be in excellent condition. We will for the biomass fathead send you the biomass data for the fish and the reproductive data Ceriodaphnia at a'later date. It will be interesting to see if or reproduction endpoints result in more of a sensitive response in minnows or Ceriodaphnia compared to the sturgeon. Treatment Archer Daniels Midland Roanoke Rapids municipal wastewater Perdue 'Sturgeon 150-100 / 50-100 a' 112.5 -25 (57% -s 'survival in 25) 'Fathead minnows ICeriodaphnia 150-100 (57% 'survival in 100) >100 125-50 125-50 >100 150-100 Thanks for all of your help in pushing through the permit and identif the sites for testing. It was GREAT to not have to wait another year conduct these exposures Chris Ingersoll Coumbia Environmental Research Center, USGS 42u0 New Haven Rd, Columbia, MO 65201 571/876-1819, fax -1896, email chris_ingersoll@ gs.gov b 2ofj {OJ P nn /I ia c. n,�. obt fri c°0-rsc 8/9/2002 1 58 PM DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0024201 Facility Information Applicant/Facility Name: Roanoke Rapids Sanitary District/RRSD WWTP Applicant Address: P.O. Box 308, Roanoke Rapids, NC 27870 Facility Address: 135 Aqueduct Road, Weldon , NC 27870 Permitted Flow 8.34 Type of Waste: Domestic (85%) Industrial (15%) Facility Classification: IV Permit Status: Renewal County: Halifax Miscellaneous Receiving Stream Chockoyotte Cr. Regional Office: Raleigh Stream Classification C State Grid B28NE 303(d) Listed? Yes USGS Quad: Weldon Basin Roanoke River Permit Writer: Teresa Rodriguez Subbasin 03-02-08 Date: 7/17/02 Drainage Area (mi`) N/A • Lat. 36° 26' 10" N Long. 77° 36' 34" W Summer 7Q10 (cfs) Winter 7Q10 (cfs): 3002 (cfs) Average Flow (cfs) IWC (%) 39 Summary: Roanoke Rapids Sanitary District (RRSD) submitted an application for renewal of their permit on December 6, 2001. They completed Form 2A. They requested to eliminate instream monitoring for temperature and dissolved oxygen based on past data or provide language to the effect that sampling doesn't need to be performed under dangerous weather conditions. RRSD is evaluating the relocation of the outfall to the Roanoke River. This renewal process will not consider the relocation of the discharge. The discharge from the treatment system is to Chocoyotte Creek just before the confluence with the Roanoke River. Since the river backs up into the creek, a study was performed on 1997 to determine the IWC at the discharge location considering the influence of the river into the creek. RRSD challenged the last permit and an agreement was reached to use 39% for the IWC for the toxicity test and 1.3 % for toxicant pollutants. Metal limits were not included in the permit but continued to be monitored in the LTMP. Treatment system description: The treatment system consists of a bar screen, grit chamber, dual primary clarifiers, dual trickling filter, aeration basins, dual final clarifiers, chlorination, dechlorination, dual secondary sludge thickener, anaerobic digestors, lime stabilization facility, sludge storage and sludge drying beds. Pre-treatment: The NPDES permit requires RRSD to maintain a Pretreatment Program under federal regulations 40CFR 403 and NC State regulations 15A NCAC 2H.0900. The City has an approved pre-treatment program with 3 significant industrial users. Fact Sheet NPDES N00024201 Renewal Page I Basin Plan: Chocoyotte Creek is impacted by collection systems overflows in Roanoke Rapids. RRSD has completed a project to prevent sanitary sewer overflows. The Roanoke River is listed as impaired due to fish consumption advisories. In this section of the river the advisory is for elevated levels of mercury. The section of the Roanoke River is listed as impaired in the 2000 303(d) list. A TMDL for dioxins was approved on Dec 1996. DMR Review: DMRs were reviewed for the period of January 2000 to May 2002.. They reported 5 pH exceedances, one total suspended solids and one CBOD. The average flow was 5.08 MGD. Reasonable Potential Analysis: Data from the long term monitoring plan and the results of the Priority Pollutant Analysis were used to evaluate reasonable potential. In the PPA beryllium, cyanide, cadmium and chloroform were detected. The results of one analysis for each of these parameters were used for the RPA. LTMP data were used for the RPA for chromium, copper, nickel, zinc, mercury and selenium. Parameter Allowable concentration* (Pgll) Maximum predicted (pg/I) RP (Y/N) Comments Beryllium 500 1.1 N No changes to permit is required Cadmium 153.8 4.8 N No changes to permit is required Chromium 3846.2 18.2 N No changes to permit is required Copper 538.5 347 N No changes to permit is required Nickel 6769.2 26 N No changes to permit is required Zinc 3846 460 N No changes to permit is required Mercury 0.92 22.2 Y Add limit of 0.92 pg/I Selenium 384.6 843.6 Y Add limit of 0.384mg/I Cyanide 384.6 8 N No changes to permit is required Chloroform 36153 5.9 N No changes to permit is required * Based on IWC of 1.3 % Waste Load Allocation (WLA): The last waste Toad allocation was performed in 1996. SUMMARY OF PROPOSED CHANGES • Limits for total selenium and total mercury were added to the permit. The results of the reasonable potential analysis show reasonable potential to exceed water quality standards. Selenium and mercury were previously monitored in the long term monitoring plan. • A special condition was included for annual sampling of priority pollutant. Fact Sheet NPDES NC0024201 Renewal Page 2 PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: September 11, 2002 Permit Scheduled to Issue: October 25, 2002 NPDES DIVISION CONTACT If you have questions regarding any of the above information or on the attached permit, please contact Teresa Rodriguez at (919) 733-5083 ext. 595. NAME: i-- 1&'7-1DATE: 9 7 Da REGIONAL OFFICE COMMENTS NAME: DATE: SUPERVISOR: DATE: Fact Sheet NPDES NC0024201 Renewal Page 3 REASONABLE POTENTIAL ANALYSIS Prepared by: Teresa Rodriguez y Facility Name = RRSD f I Parameter= Beryllium NPDES # = NC0024201 I I Standard = 6.5J/g/I Ow (MGD) = ; Dataset= LTMP 99-01 Ow (cfs) _ 7Q10s (cfs)= Modified Data < Nondetects RESULTS IWC (%) = 1.30 ! 1 0.7 Std Dev. #DIV/O! Receiving stream Chocoyotte Creek 1 Mean 0.700 Classification C C.V. #DIV/0! { Sample# 1 Chronic CCC w/s7Q10 dil. Acute CMC w/no dil. Frequency of Detection Parameter FINAL RESULTS, ug/I FINAL RESULTS, ug/l #Samples # Detects Mull Factor = 1.600 Beryllium Max. Pred Cw Max. Value 0.700 Ng/I 1.1 Max. Pred Cw 1.120 yg/i ii _ Allowable Cw 500.0 360 1 1 Allowable Cw 500.000 pg/i Cyanide Max. Pred Cw 8.0 Allowable Cw Cadmium Max. Pred Cw 384.6 • 4.8 Allowable Cw Chromium Max. Pred Cw 153.8 - 15 - 1 1 • 18.2 J Allowable Cw Copper Max. Pred Cw Allowable Cw 3846.2 1022 14 9 347.4 538.5 r , __ 7.3 14 14 Chloroform Max. Pred Cw 5.9 Allowable Cw Nickel Max. Pred Cw 36153.8 33.8 1 1 26.0 Allowable Cw 6769.2 261 11 5 Silver (A.L.) Max. Pred Cw 0.0 Allowable Cw Zinc (A.L.) Max. Pred Cw 4.6 1.2 0 0 460.0 Allowable Cw Mercury Max. Pred Cw 3846.2 67 • 14 13 22.2 Allowable Cw 0.923 NA 12 1 Molybdenum Max. Pred Cw 0.0 Allowable Cw Selenium Max. Pred Cw NA 1 NA 0 0 843.6 Allowable Cw 384.6 r„ A 11 2 Parameter = Cyanide Parameter = Standard = Dataset= 5PO Standard = Dataset= Cadmium —pg/1 DMR Modified Data < Nondetects RESULTS 5, ,Std Dev. r #DIV/0! Mean 5 C.V. #DIV/01 Modified Data < Nondetects 3 RESULTS Std Dev. #DIV/0! Mean 3.000 C.V. #DIV/0I Sample# 1 Mult Factor = 1.6 Mult Factor = 1.600 Max. Value 5 Max. Pred Cv‘ 8 Allowable Cw 384.6 Max. Value 3.000 pgll Max. Pred Cw 4.800 pg/I Allowable Cw 153.8 pg/I Parameter= Chromium ! Parameter= Cop er Parameter= Chloroform PP Standard = 50lpg/I Standard = 7jpg/1 Standard = 470 pgli ` Dataset= LTMP 99-01 Dataset= Dataset= DMR _ _I ModifiedData < ---- � < ! Nondetects RESULTS ModifiedData < ,Nondetects RESULTS ::: ModifiedData < Nondetects,RESULTS A 4 3 ---_--7 2.5 4 Std Dev. 3 Mean 1 5-C.V. � 1.842 1 311 Std Dev. 48.025' 3.7, Std Dev. #DIV/0! 1 3.107 17 Mean 27.64291 Mean 3.700 H 0.593 23 14 C.V. 1.73734 1 ;;;; _ — -__ C.V. Sample# #DIV/0! 7 Sam le# ! 14 p Sample# 14' p 1 j 1 < 2 Mult Factor = 2.600 9 Mult Factor = 1.8 Mult Factor = 1.600 2 12 Max. Value 7.000 pg/l 10 Max. Value 193 pg/l Max. Value 3.700 p l 3 3 Max. Pred Cw 18.200 pg/I 16 Max. Pred Cw 347.4 pg/I Max. Pred Cw 5.920 I 1 < 2 Allowable Cw ; 3846.154 WWI 12 Allowable Cw 538.5 pg/I Allowable Cw 36153.846 pg/I 2< 4 i 11 1< 1 2 1 9 3 21 3 193 i rameter= Nickel Parameter= Zinc (A.L.) Parameter= Mercury tandard = 88jpg/I Standard = 50 pg/I Standard = 0.012I4I LTMP 99-01 Dataset= LTMP 99-01, PPA Dataset= LTMP 99-01 (ug/l) ug/I lodifiedDa( < NondetectsRESULTS ModifiedData < Nondetects RESULTS ModifiedData < Illoindetects RESULTS 6 6 Std Dev. 2.29426 50 < 100 Std Dev. 48.338 0.1 < 0.2 Std Dev. 0.548 10 10 Mean 4.81818 74 Mean_ 97.357 0.1 < 0.2 Mean 0.258 5 5 C.V. 0.47617 62 ~� C.V. 0.4971_ _ _ - \ 0.1 < 0.2 C.V. 2.123 5 < 10 Sample# 11 67 ' Sample# 14 }, 0.1 < 0.2 Sample# 12 6 6 56 0.1I < 0.2 6 6 64 Mult Factor = 2.300 ., 0.1, < 0.2 Mult Factor = 111.100 2.5 < 5 Mult Factor : 2.6 i 154 Max. Value 200.000 pgli 0.1 < 0.2 Max. Value 2.000 p /g�i pg/i pg/i 2.5 2.5 2.51 < < < < 5 Max. Value i 10 p lili 153 Max. Pred Cw 460.000 pg/I 0.1 < 0.2 Max. Pred Cw 22.200 5 5 .Allowable 10 Max. Pred pi_26 Cm__ 11al 200 Allowable Cw 3846.154 pg/i 0.1 < 0.2 Allowable Cw 0.923 6769.2 FA 76,__i ___Jjr 0.1 < 0.2 5 - - 121 \ 0.1 < 0.2 i 150 (2r\ 2 - -- 571 - L 79 i-__- . r 1 1 • • i r E 1 Parameter = Selenium Standard = 5 pg/1 Dataset= LTMP 99-01 ug/l btg/1 ModifiedData < Nondetects RESULTS 1.5 < 3 • Std Dev. 22.180 5 < 10 Mean 10.182 1.5 < 3 C.V. 2.178 2.5 < 5 Sample# 11 15 15 1.5 < 3 Mult Factor = 11.100 2.5 < 5 Max. Value 76.000,pg/l 2.5 < 5 Max. Pred Cw 843.600 pg/1 2.5 < 5 Allowable Cw 384.615 pC 76 76 1.5< 3 t 1 i REASONABLE POTENTIAL ANALYSIS Prepared by: Teresa Rodriguez I Facility Name = RRSD NPDES # = NC0024201 Qw (MGD) = Qw (cfs) = 7Q10s (cfs)= !WC(%)= 39.00 Receiving stream Chocoyotte Creek Classification C _ i Chronic CCC w/s7Q10 dil. Acute CMC wino dil. Frequency of Detection Parameter FINAL RESULTS, ugll I FINAL RESULTS, ugli #Samples # Detects Beryllium Max. Pred Cw 1.1 Allowable Cw Cyanide Max. Pred Cw 16.7 360 1 1 1 8.0 Allowable Cw Cadmium Max. Pred Cw 12.8 22 1 4.8 Allowable Cw Chromium Max. Pred Cw 5.1 15 1 18.2 Allowable Cw Copper Max. Pred Cw 128.2 1022 14 9 347.4 Allowable Cw 17.9 7.3 14 14 Chloroform Max. Pred Cw 5.9 1 --- -- - 1 ....----- Allowable Cw Nickel Max. Pred Cw 1205.1 33.8 26.0 Allowable Cw 225.6 261 11 5 Silver (A.L.) 0 0 Max. Pred Cw 0.0 Allowable Cw Zinc (A.L.) Max. Pred Cw Allowable Cw Mercury Max. Pred Cw 0.2 1.2 460.0 14 13 128.2 67 22.2 Allowable Cw 0.031 NA 12 1 Molybdenum Max. Pred Cw 0.0 Allowable Cw Selenium Max. Pred Cw NA NA 0 0 82.5 Allowable Cw Fluoride Max. Pred Cw 12.8 NA 11 1 74382.0 Allowable Cw 4615.4 NA 2 2 REASONABLE POTENTIAL ANALYSIS Prepared by: Teresa Rodriguez Facility Name = RRSD NPDES # = NC0024201 Ow (MGD) Ow (cfs) _ 7Q1Os (cfs)= !WC (%) = 39.00 Receiving stream Chbcoyotte Creek Classification C Chronic CCC w/s7Q10 dil. Acute CMC wino dil. Frequency of Detection Parameter FINAL RESULTS, ug/I FINAL RESULTS, ug/I #Samples l # Detects Beryllium Max. Pred Cw I 1.1 Allowable Cw Cyanide Max. Pred Cw 16.7 360 8.0 Allowable Cw Cadmium Max. Pred Cw 12.8 22 1 ; 1 4.8 Allowable Cw Chromium Max. Pred Cw 5.1 15 1 1 18.2 Allowable Cw Copper Max. Pred Cw 128.2 1022 14 9 347.4 Allowable Cw 17.9 7.3 14 14 Chloroform Max. Pred Cw 5.9 Allowable Cw Nickel Max. Pred Cw 1205.1 33.8 1 1 26.0 Allowable Cw 225.6 261 11 5 Silver (A.L.) Max. Pred Cw 0.0 Allowable Cw Zinc (A.L.) Max. Pred Cw 0.2 1.2 0 0 460.0 Allowable Cw Mercury Max. Pred Cw 128.2 67 14 13 22.2 Allowable Cw 0.031 NA 12 1 Molybdenum Max. Pred Cw 0.0 Allowable Cw Selenium Max. Pred Cw NA NA 0 0 82.5 Allowable Cw Fluoride Max. Pred Cw 12.8 NA 11 1 1 74382.0 Allowable Cw 4615.4 NA 2 2 REASONABLE POTENTIAL ANALYSIS IAMMENDED 10/15/02 Prepared by: Teresa Rodriguez i1 Facility Name = RRSO NPDES # = NC0024201 Qw (MGD) = Qw (cfs) = 7Q10s (cfs)= IWC (%) = 1.30 Receiving stream Chocoyotte Creek j Classification C Chronic CCC w/s7Q10 dil. Acute CMC w/no dil. Frequency of Detection Parameter FINAL RESULTS, ug/I FINAL RESULTS, ug/I #Samples # Detects Beryllium Max. Pred Cw 1.1 Allowable Cw 500.0 360 1 1 Cyanide Max. Pred Cw 8.0 Allowable Cw Cadmium Max. Pred Cw 384.6 22 1 1 4.8 Allowable Cw Chromium Max. Pred Cw 153.8 15 1 1 18.2 Allowable Cw Copper Max. Pred Cw 3846.2 1022 14 9 347.4 Allowable Cw 538.5 7.3 14 14 Chloroform Max. Pred Cw 5.9 1 Allowable Cw Nickel Max. Pred Cw 36153.8 I 33.8 1 26.0 Allowable Cw 6769.2 261 11 5 Silver (A.L.) Max. Pred Cw 0.0 Allowable Cw Zinc (A.L.) Max. Pred Cw 4.6 1.2 0 0 460.0 Allowable Cw Mercury Max. Pred Cw 3846.2 67 14 13 22.2 Allowable Cw 0.923 NA 12 1 Molybdenum Max. Pred Cw 0.0 Allowable Cw Selenium Max. Pred Cw NA NA 0 0 82.5 Allowable Cw Fluoride Max. Pred Cw 384.6 NA 11 1 74382.0 Allowable Cw 138461.5 NA 2 2 Trickling f ilter Maintenance Subject: Trickling Filter Maintenance Date: Thu, 20 Jun 2002 12:41:13 -0600 From: "Sadler, Mary" <MSadler@arcadis-us.com> To: "Dan Brown (E-mail)" <dbrown@rrsd.org> CC: "Cordon, Raymond" <RCordon @ arcadis-us.com>, "Teresa Rodriguez (E-mail)" <teresa.rodriguez@ncmail.net>, "Stroud, Ross" <RStroud@arcadis-us.com> Dan, I talked with Teresa Rodriguez this morning about the status of your NPDES permit. She was very helpful and really nice to take the time to answer all my questions. She indicated to me that your BOD limits and ammonia limits would be the same as your current permit; no changes to these two paramenters are expected. So, your trickling filter project should be a "go"!!! I would also like to add, however, that she did fill me in on the status of your NPDES renewal application. There are three issues: 1. There are seven parameters missing from your priority pollutant scan: oil & grease, total dissolved solids, hardness, thallium, total phenolic compounds, methyl bromide, and methyl chloride. She has many applications that she is reviewing right now with these parameters missing. She thinks that possibly some laboratories may not have the updated priority pollutant list. The labs have simply indicated "Not applicable" under these parameters. So additional sampling for these parameters will be required. 2. This second issue deals with toxicity testing and she is waiting to hear back from EPA for concurrence on her plans for handling the issue. NPDES permit applications now require 3 chronic toxicity tests with a second species for application renewal. This takes a year to do three of these tests (since toxicity is done on a quarterly basis), so she is trying to get EPA to agree to to one toxicity test with a second species for the NPDES permit renewals she has in house right now (this is the reply she is waiting on). 3. She hasn't yet had the opportunity to go over your priority pollutant data or done any RPA analyses yet, so she could not confirm any other potential limits (metals, volatiles, etc.). But this of course does not affect BOD or ammonia. She has a letter ready to mail to all the NPDES permit holders who are waiting for renewals detailing #1 and/or #2, but again, she needs EPA to agree with the issue #2. She estimated it would probably be another month before your application can go on public notice, but issues #1 and #2 may most likely be handled concurrently with the public notice. You can probably go ahead and check with the laboratory you guys use about the priority pollutant scan. I hope this helps!!! Dan, please let me know if you would like to assist you further. I will help in any way that I can!! Mary E.R. Sadler ARCADIS G&M of North Carolina, Inc. 2301 Rexwoods Drive, Suite 102 Raleigh, NC 27607 Phone: 919-782-5511 Fax: 919-782-5905 msadler@arcadis-us.com Original Message 1 of 3 6/21/02 7:33 AM Trickling Filter Maintenance From: Cordon, Raymond Sent: Wednesday, June 19, 2002 4:48 PM To: Sadler, Mary Subject: FW: SECTION 11940 - TRICKLING FILTER DISTRIBUTOR Please call Teresa Rodriquez and inquire about the permit as requested by Dan. You will need to write a short teleconv report that we can send to Dan and copy to Teresa. CAn we get this done this week? Raymond A. Cordon, P.E. ARCADIS Geraghty & Miller 2301 Rexwoods Drive, Suite 102 Raleigh, North Carolina 27622 Phone 919-782-5511 Fax 919-782-5905 RCordon@arcadis-us.com Original Message From: Dan Brown [mailto:dbrown@rrsd.orgl Sent: Wednesday, June 19, 2002 5:45 PM To: Cordon, Raymond Cc: Gregg Camp Subject: Re: SECTION 11940 - TRICKLING FILTER DISTRIBUTOR We concur with your evaluation and recommendation for filter replacement, however, we need to get a "nod" from DWQ regarding our renewal NPDES permit. We would be interested in learning if there are any surprises in the new permit that would make us reconsider the direction we are headed with replacing our filter equipment. Will you please contact Teresa Rodriquez w/ DWQ to check the status of our permit and learn as much as you can about what we can expect will be coming down the pipe. Teresa met with us at our Plant Discharge Relocation meeting in February and, as I understand it, has been assigned to write our renewal permit. I look forward to your response, please call if you have questions. Thanks! Dan Original Message From: Cordon, Raymond To: 'Dan Brown' Cc: Stroud, Ross ; Sadler, Mary Sent: Monday, June 17, 2002 4:14 PM Subject: RE: SECTION 11940 - TRICKLING FILTER DISTRIBUTOR Ross will be reviewing the specifications for this equipment purchase, and will forward his comments to you when his review is complete. Ross, Mary, and I discussed your second request regarding the technology upgrade. We feel that the rehabilitation of the trickling filters is the most cost effective alternate at this time. The trickling filters serve as a good buffer prior to the aeration basins and are an inexpensive way to remove BOD. The trickling filters would not be a good idea if the state were to impose an ammonia limit in this current permit round. Have you received your draft permit yet? If this is the case, you will need more aeration capacity for nitrification (tankage and air). If you need additional tankage for nitrification, then you will get the BOD out also, and you wouldn't necessarily have to upgrade the trickling filters unless you still wanted the buffer. Adding additional tankage will be a costly upgrade. 2of3 6/21/02 7:33 AM Trickling,Filter Maintenance Since RRSD is not expecting a change in the discharge limits, especially the addition of an ammonia limit, this is not a concern at this time. Now, if you were ever faced with a total nitrogen limit (very unlikly any time soon), then the trickling filters would most likely need to be decommissioned. You would need the carbon in the basins and not used for growing biofilm. So in summary, if your new discharge permit is the same as your previous permit, rehabing the trickling filters is your best option at this time. Raymond A. Cordon, P.E. ARCADIS Geraghty & Miller 2301 Rexwoods Drive, Suite 102 Raleigh, North Carolina 27622 Phone 919-782-5511 Fax 919-782-5905 RCordon@arcadis-us.com Original Message From: Dan Brown [mailto:dbrown@rrsd.org] Sent: Thursday, June 13, 2002 6:07 PM To: Raymond Cordon; Gregg Camp Subject: SECTION 11940 - TRICKLING FILTER DISTRIBUTOR The RRSD intends to replace our rotary distributor No. 1 equipment through an equipment purchase agreement. You are aware of this need as you have assisted us in preliminary equipment selection services. I have prepared a technical specification of the requirements for this equipment replacement. We plan to forward same to selected vendors for the purpose of receiving installed quotes. We are requesting a technical review of the specification, attached. Referenced drawings are in Arcadis shop drawing files for Olsen Associates Contract No. 936.0. I have highlighted the capacity performance requirement because our current equipment is not self actuated at low flows. The flow requirements shown are a departure from the flows previously specified in 1981. We also request alternative recommendations that we may consider in lieu of replacement of this equipment since there may be a technology upgrade opportunity afforded to the District at this time. Please call me to discuss this at your earliest convenience. Thanks! Dan Brown, PE Chief Executive Officer Roanoke Rapids Sanitary District PO Box 308 Roanoke Rapids, NC 27870 www.rrsd.orq (252) 537-9137 (252) 537-9136 (FAX) \of3 6/21/02 7:33 AM Roanoke R'pids Violations BIMS retreval Errors Subject: Roanoke Rapids Violations RIMS retreval Errors Date: Tue, 16 Apr 2002 14:08:44 -0400 From: Dana Folley <Dana.Folley@ncmail.net> To: Tom Poe <Tom.Poe@ncmail.net>, Shannon Langley <Shannon.Langley@ncmail.net> CC: Charles Weaver <Charles.Weaver@ncmail.net>, Teresa Rodriguez <Teresa.Rodriguez@ncmail.net>, Vanessa Manuel <Vanessa.Manuel@ncmail.net>, myrl nisely <myrl.nisely@ncmail.net> Dear Tom and Shannon, As I have discussed with Myrl, Vanessa, and Charles, I did a "Violations (all types)" retreaval for 2001 and 2000 prior to going on -site to do an Audit of Roanoke Rapids Sanitary District NC0024201 Pretreatment Program. I will leave a copy of the report in your in -boxes for you to look at. RRSD (Greg Camp, ORC - 252-536-4884) says the limits violations are correct but the monit/report ones are wrong, and I told him I would find out who can determine out what's wrong (if anything) and fix it. First, all the parameters listed in the "reporting violations" section of the retreaval are not even in RRSD's NPDES permit, and most have never been in it. Charles indicated he will fix this, but said that Shannon would be the best person to figure out the rest. For the "monitoring violations" section, these parameters are in the NPDES permit, and the frequency even appears to be right. However RRSD claims they are performing the required daily monitoring. Please note they have not received any NOVs for missed monitoring. They noted that the specific days that are listed are the Fridays of the week, and they were speculating the computer was looking for Monday -Friday sample days. They sample Sunday -Friday which produces 5 24 hours composite samples which they date Sunday through Thursday. Tom, I'm sending this to you so I am going through the "proper chain of command," but on advice from Charles, I'm assuming that Shannon will be the one to address this (or he will be the one to decide who will address this). I have no idea if this is a problem with only RRSD's permit or something larger in BIMS. If possible, when the situation gets fixed, I'd love to know the outcome. Myrl, if you could forward this to the RRO person who has this facility for regular NPDES, that would be great! Have fun! Dana Rees Folley Environmental Chemist II Division of Water Quality Water Quality Section Pretreatment Unit 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 telephone: (919) 733-5083 x523 facsimile: (919) 715-2941 http://h2o.enr.state.nc.us/Pretreat/index.html 1 of 1 4/17/2002 9:00 AM • �y VIOLATIONS (all Types) for: ' Permit: nc002420j Facility Name ai't;lr. MMQQ r tits ; D s e een#'rfi=2� ifs � �-ts•� 62-Q_ S2Arv-e":1/41 and 12=?�00 AegI91: °/a Page: 1 0! 4 Report Date: 04/11/02 PERMIT: NC0024201 FACILITY: Roanoke Rapids WWTP )( COUNTY: Halifax REGION: Raleigh LIMIT VIOLATIONS: DMA OUTFALL LOCATION 07 - 2001 001 Effluent 08 - 2001 001 Effluent 12- 2001 001 Effluent 12 - 2001 001 Effluent 03 - 2001 001 Effluent 03 - 2001 001 Effluent 03 - 2001 001 Effluent MONITORING VIOLATIONS: PARAMETER PH PH PH PH SOLIDS, TOTAL SUSPENDED SOLIDS, TOTAL SUSPENDED SOLIDS, TOTAL SUSPENDED VIOLATION DATE 07/30/01 08/06/01 12/17/01 12/28/01 03/24/01 03/31/01 03/31/01 UNIT OF MEASURE su su su su mg/1 mg/1 mg/1 6 6 6 45 30 45 CALCULATED LIMIT FROM REPORTED VIOLATION DESCRIPTION 6 5.7 Daily Minimum Not Reached 5.8 Daily Minimum Not Reached 5.9 Daily Minimum Not Reached 5.5 Daily Minimum Not Reached 65.66 Weekly Average Exceeded 35.92 Monthly Average Exceeded 48.58 Weekly Average Exceeded DMR 08-2001 08-2001 08-2001 08-2001 08-2001 09-2001 09-2001 09-2001 09-2001 10-2001 OUTFALL LOCATION PARAMETER 001 001 001 001 001 001 001 001 001 001 Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent BOD, CARBONACEOUS 20C BOD; CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD, CARBONACEOUS 20C BOD,CARBONACEOUS 20C 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, 05 DAY, VIOLATION DATE MEASUREMENT FREQUENCY 08/03/01 08/10/01 08/17/01 08/24/01 08/3I/01 09/07/01 09/14/01 09/21/01 09/28/01 10/05/01 Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays VIOLATION DESCRIPTION Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation VIOLATIONS (all Types) for: Permit: nc0024201.t:' • 'r' ;: 10111;� Dim * ,'.1-2001 ; ;and' 12=2001:Wl tj '•-R% egton: ' : ,; '_ '; ; '31ls, `:;' Facility Name % "County . % i. •- . . i' ,, 10. 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 10/12/01 Daily -- weekdays Frequency Violation 20C 10- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 10/19/01 Daily -- weekdays Frequency Violation 20C 10-2001 001 . Effluent BOD, CARBONACEOUS 05 DAY, 10/26/01 Daily -- weekdays Frequency Violation 20C 11- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 11/02/01 Daily -- weekdays Frequency Violation 20C 11- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 11/09/01 Daily -- weekdays Frequency Violation 20C I I - 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 11/16/01 Daily -- weekdays Frequency Violation 20C 11- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 11/23/01 Daily -- weekdays Frequency Violation 20C 1 11- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 11/30/01 Daily -- weekdays Frequency Violation 20C 12- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 12/07/01 Daily -- weekdays Frequency Violation 20C 12-2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 12/14/01 Daily -- weekdays Frequency Violation 20C - 12- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 12/21/01 Daily -- weckdays Frequency Violation 20C _ 12- 2001 001 Effluent BOD, CARBONACEOUS 05 DAY, 12/28/01 Daily -- weekdays Frequency Violation 20C 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/01/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/02/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/05/01 Daily -- weekdays Frequency Violation 11- 2001 001. Effluent CHLORINE, TOTALRESIDUAL 11/06/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/07/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/08/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/09/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/12/01 Daily -- weekdays Frequency Violation 1 1 -2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/13/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent ' CHLORINE, TOTALRESIDUAL 11/14/01 Daily -- weekdays Frequency Violation 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11/15/01 Daily -- weekdays Frequency Violation Page: 2 of 4 Report Date: 04/11/02 VIOLATIONS (all Types) for: Permit; nc0024201 Facility Name, % , • 11- 2001 001 Effluent 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 Effluent CHLORINE, TOTALRES1DUAL 11- 2001 001 Effluent CHLORINE, TOTALRESIDUAL 11- 2001 001 - Effluent DO, Oxygen, Dissolved 09 - 2001 001 Effluent NITROGEN, AMMONIA TOTAL (AS N) 09- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 09/14/01 Daily -- weekdays Frequency Violation (AS N) 09- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 09/21/01 Daily -- weekdays Frequency Violation (AS N) 09- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 09/28/01 Daily -- weekdays Frequency Violation (AS N) 11- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 11/02/01 Daily -- weekdays Frequency Violation (AS N) 11- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 11/09/01 Daily -- weekdays Frequency Violation (AS N) 11- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 11/16/01 Daily -- weekdays Frequency Violation (AS N) 11- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 11/23/01 Daily -- weekdays Frequency Violation (AS N) 11- 2001 001 Effluent NITROGEN, AMMONIA TOTAL 11/30/01 Daily -- weekdays Frequency Violation (AS N) 12-2001 001 Effluent NITROGEN, AMMONIA TOTAL 12/07/01 Daily -- weekdays Frequency Violation (AS N) 12-2001 001 Effluent NITROGEN, AMMONIA TOTAL 12/14/01 Daily -- weekdays Frequency Violation (AS N) 11/16/01 11/19/01 11/20/01 11/21/01 11/22/01 11/23/01 11/26/01 11/27/01 11/28/01 11/29/01 11/30/01 11/30/01 09/07/01 Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Daily -- weekdays Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Frequency Violation Page: 3 of 4 Report Date: 04/11/02 VIOLATIONS (all Types) for: Permit: nc0N4201; Facility Name % 12-2001 001 Effluent 12-2001 001 Effluent REPORTING VIOLATIONS: NITROGEN, AMMONIA TOTAL (AS N) NITROGEN, AMMONIA TOTAL (AS N) 12/21/01 12/28/01 Daily -- weekdays Daily -- weekdays Frequency Violation Frequency Violation Page: 4 of 4 Report Date: 04/11/02 DMR OUTFALL LOCATION PARAMETER VIOLATION DATE VIOLATION DESCRIPTION 11- 2001 001 Effluent BOD, 5-DAY (20 DEG. C) 11/30/01 Parameter Missing 12- 2001 001 Effluent BOD, 5-DAY (20 DEG. C) 12/31/01 Parameter Missing 11- 2001 001 Effluent CADMIUM, TOTAL (AS CD) 11/30/01 Parameter Missing 12- 2001 001 Effluent CADMIUM, TOTAL (AS CD) 12/31/01 Parameter Missing 11- 2001 001 Effluent CHROMIUM, TOTAL (AS CR) 11/30/01 Parameter Missing i 12-2001 001 Effluent CHROMIUM, TOTAL (AS CR) 12/31/01 Parameter Missing 11- 2001 001 Effluent COD, Oxygen Demand, Chem. 11/30/01 Parameter Missing (High Level) 12-2001 001 Effluent COD, Oxygen Demand, Chem. 12/31/01 Parameter Missing (High Level) 11- 2001 001 Effluent COPPER, TOTAL (AS CU) 11/30/01 Parameter Missing 12-2001 001 Effluent COPPER, TOTAL (AS CU) 12/31/01 Parameter Missing 11- 2001 001 Effluent LEAD, TOTAL (AS PB) 11/30/01 Parameter Missing 12-2001 001 Effluent LEAD, TOTAL (AS PB) 12/31/01 Parameter Missing 11- 2001 001 Effluent NICKEL, TOTAL (AS NI) 11/30/01 Parameter Missing 12- 2001 001 Effluent NICKEL, TOTAL (AS NI) 12/31/01 Parameter Missing 11- 2001 001 Effluent SOLIDS, SETTLEABLE 11/30/01 Parameter Missing 12- 2001 001 Effluent SOLIDS, SETTLEABLE 12/31/01 Parameter Missing 11- 2001 001 Effluent SOLIDS, TOTAL 11/30/01 Parameter Missing 12- 2001 001 Effluent SOLIDS, TOTAL 12/31/01 Parameter Missing 11- 2001 001 Effluent ZINC, TOTAL (AS ZN) 11/30/01 Parameter Missing 12- 2001 001 Effluent ZINC, TOTAL (AS ZN) 12/31/01 Parameter Missing VIOLATIONS (all Types) for: Permit: NC0024201 Facility Name % DMRs Between 1-2000 and 12-2000 Region: % County %, Page: 1 of 1 Report Date: 04/11/02 PERMIT: NC0024201 FACILITY: Roanoke Rapids WWTP COUNTY: Halifax REGION: Raleigh LIMIT VIOLATIONS: UNIT OF CALCULATED DMR OUTFALL LOCATION PARAMETER VIOLATION DATE MEASURE LIMIT FROM REPORTED VIOLATION DESCRIPTION 04-2000 001 Effluent BOD, CARBONACEOUS 05 04/22/00 ing/I 37.5 42.22 Weekly Average Exceeded DAY, 20C 01 - 2000 001 Effluent SOLIDS, TOTAL SUSPENDED 01/08/00 ntg/I 45 65.2 Weekly Average Exceeded SOC PRIORITY PROJECT: No If Yes, SOC No.: NPDES STAFF REPORT AND RECOMMENDATIONS FOR ROANOKE RAPIDS WWTP Date:4/02/02 To: Water Quality Section NPDES Permitting Unit Attention: Teresa Rodriguez County: Halifax Permit No.: NC0024201 C eQ-M a'a D PART I - GENERAL INFORMATION 1. Facility and Address: Roanoke Rapids WWTP - PO Box 308 Roanoke Rapids, NC 27870 V',;11:f r�- -�It A 1uuZ PERMITTING 1 ON -DISCHARGE 0 1_APR 1 7 2002 DENR - WATER QUALITY POINT SOURCE BRANCH 2. Date of Site Visit: 2/27/02 3. Report Prepared by: Bob Mangum 4. Persons Contacted and Telephone Number: Gregg Camp-ORC-252-536-4884 5. Directions to Site: Hwy 64 East to I-95 North to Hwy 158 East (exit 173), App. 1 mile turn left onto Aqueduct Rd. Facility is at the end of the road 6. Discharge Point(s), List for all discharge points: Latitude: 36° 26' 10" Longitude: 77 ° 36' 36" Attach a USGS map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad No.: B28NE U.S.G.S. Quad Name: Weldon 7. Site size and expansion area consistent with application? Yes Non -Discharge Staff Report Page 1 8. Topography (relationship to flood plain included):Facility is above 100 yr flood plain 9. Location of nearest dwelling: none within 1500 ft. 10. Receiving stream or affected surface waters: Chockoyotte Creek a. Classification:C b. River Basin and Subbasin No.: 03 02 08 c. Describe receiving stream features and pertinent downstream uses: Weldon WWTP is located downstream PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of Wastewater to be permitted: 8.34 MGD b. What is the current permitted capacity of the Waste Water Treatment facility? 8.34 MGD c. Actual treatment capacity of the current facility (current design capacity)? 8.34 MGD d. Date(s) and construction activities allowed by previous Authorization to Construct issued in the previous two years: n/a e. Please provide a description of existing or substantially constructed wastewater treatment facilities: mechanical bar screen with manual bar screen by -pass -two degritting devices -influent pump station -two primary clarifiers -two recirculating rock roughing filters -intermediate pump station -three rectangular activated sludge aeration basins -two rectangular final clarifiers with traveling bridge systems -chlorine disinfection with chlorine contact tank f. Please provide a description of proposed wastewater treatment facilities: g. Possible toxic impacts to surface waters: metals h. Pretreatment Program (POTWs only): in development: approved: x should be required: not needed: 2. Residuals handling and utilization/disposal scheme: a. If residuals are being land applied, please specify DEM permit no.: WQ0001989 Non -Discharge Staff Report Page 2 Residual Contractor: SYNAGRO Telephone No.: 919-766-0328 b. Residuals stabilization: PSRP: PFRP: Other: PH adjustment or lime stabilization c. Landfill: d. Other disposal/utilization scheme (Specify): 3. Treatment plant classification (attach completed rating sheet): Class IV 4. SIC Code(s): 4952 Wastewater Code(s) of actual wastewater, not particular facilities i.e.., non -contact cooling water discharge from a metal plating company would be 14, not 56. Primary: 01 Main Treatment Unit Code: 040-3 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved. (municipals only)? n/a 2. Special monitoring or limitations (including toxicity) requests: toxicity 3. Important SOC, JOC or Compliance Schedule dates: (Please indicate) Date Submission of Plans and Specifications Begin Construction Complete Construction 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available? Please provide regional perspective for each option evaluated. Spray Irrigation: not enough land Connection to Regional Sewer System: n/a Subsurface: n/a Other disposal options: none Non -Discharge Staff Report Page 3 PART IV - EVALUATION AND RECOMMENDATIONS The Raleigh Regional Office has reviewed all records/reports and conducted a Compliance Evaluation Inspection. This inspection shows the WWTP appears to operating properly without any significant problems. The ORC indicated that the facility may be requesting moving the discharge point to the Roanoke River. Therefore, it is recommended that this permit be renewed as requested. Signature of report pr arer Date Water Quality Regional Supervisor al Supervisor ate Non -Discharge Staff Report Page 4 NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form NPDES OR NONDISrArGE PERMITTING UNIT COMPLETES THIS PART: Date of Request Ct0 Facility KO _4 (,o ci, 0 Permit # hc.o U ; c-J 2U 1 Region W. Rc7 Requestor P. a&r i qp.e Z Pretreatment Contact A_D Towns- Keyes McGee (ext. 580) E-L Towns- Deborah Gore (ext 593) (M R Townsina Folley text. 523)) S-Z Towns- Steve Amigone (ext 592) PRETREATMENT UNIT COMPLETES THIS PART: Status of Pretreatment Program (circle all that apply) 1) the facility has no SIU's and does have a Division approved Pretreatment Program that is INACTIVE 2) the facility has no SIU's and does not have a Division approved Pretreatment Program the facility has. is4teuelepiag) a Pretreatment PrograT tf�� 3a) is Full Program with LTMP or 3b) is Modified Program with STMP 4) the facility MUST -develop a Pretreatment Program - Full Modified 5) additional conditions regarding Pretreatment attachedlor listed below Flow Permitted Actual ` kNa. P�S� ST P t' rame: % Industrial f j (YIC� 7Y1 ( mot cen L % Domestic ne cycle 6//c} L (S) T MP Pollutant Check List POC due to NPDES/Non- Discharge Permit L mlt Required by EPA' Required by 503 Sludge" POC due to SIU"' Site specific POC (Provide Explanation)"" ST - Freque efflue y at LTMP Frequency at effluent J Ce)un� I 4 M -B64D J TSS Q M Ni NH3 Q M V Arsenic , Q M v Cadmium v •✓ v' 4 Q M v Chromium V V Q M \I Copper -J V J 4 Q M Cyanide - Q M V Lead -J ✓ v Q M V Mercury ✓ 4 Q M ' Molybdenum V Q wl V Nickel d y V 4 Q M Silver Q M V Selenium V 4 0 M 'iZinc d J V • QM J TIL-y\ 4 Q M Q M ` 4 Q M t, - 'A 0, , 0:i -g I i , Q M WI 0, s-i /1 Q M 4 tM Q . 'Always in the LTMP "On y in the LTMP it the POTW land applies sludge v "' Only in LTMP while the SIU is connected to the POTW - "" Only in LTMP when the pollutant is a specific concern to the POTW (ex -Chlorides for a POTW who accepts Textile waste)`lae `'C"~-0 Q= Quarterly 4-n h Q M=Monthly Comments: l_ a. S vt N N. • c - TX el' c ,r\ I)I 4-5, t-P5 arQ-- - rS f ( j ' -7 • version 8/23/00 / tU-yN . NPDES_Pretreatment.requesLfonn.070613 f43 piA J Jae, 5r2.6,-A4g-ee- ct � c;1• -Dm (s _?4' -k GuL, i j) 5e' -/ /Y-e asp Pv.i' �r� Par�uh rs Revised: August 4, 2000 ARCADIS MEETING REPORT Subject: Roanoke Rapids Sanitary District Effluent Relocation meeting with the North Carolina Division of Water Quality (NCDWQ) and the U.S. Army Corps of Engineers (USACE), Roanoke Rapids Sanitary District (RRSD) and ARCADIS. Department: Water and Waste Management Place/Date of Meeting: February 27, 2002, 10:00 a.m., at the RRSD Wastewater Treatment Plant Minutes by: Mark A. Mulder Participants: Dan Brown, RRSD Gregg Camp, RRSD Mitchell Robinson, RRSD Judy Garrett, NCDWQ- Raleigh Regional Teresa Rodriquez, NCDWQ — NPDES Amanda Jones, USACE — Raleigh Field Office John Maynard, ARCADIS Raymond Cordon, ARCADIS Mark Mulder, ARCADIS Action by: Introduction Comments: ■ Sign -In passed out. MAR - 8 2002 J ARCADIS Project No.: NC30191.0000 Report No.: 1 Issue Date: March 7, 2002 Not Present: ARCADIS G&M of North Carolina, Inc. P.O. Box 31388 Raleigh, NC 27622-1388 2301 Rexwoods Drive - Suite 102 Raleigh, NC 27607-3366 Tel 919 782 5511 Fax 919 782 5905 www.arcadis-us.com Copies: Participants File • Mr. Cordon welcomed the participants and explained the reason for the meeting. ■ RRSD entered into an agreement with the NCDWQ on December 4, 1997 (copies were passed out), which states that RRSD can relocate its surface discharge to the south bank of the Roanoke River downstream of the Chockoyotte Creek, which would allow RRSD to base their chronic toxicity tests on IWC of 1.3% instead of the current 39%. G:1Wwm\Roanoke1301911E ng1DWQMeetingReport.doc Page: 1/3 ARCADIS • ARCADIS has investigated three options for relocating the effluent and handed out a drawing with two of three effluent relocation options shown. All options include a new junction box with a tideflex valve on the 36" gravity plant effluent line, a 16" force main line from the Plant Effluent Pump Station, and a 36" plant effluent line out to the Roanoke River. The first option is placing the new effluent discharge on the south bank of the Roanoke River upstream of Chockoyotte Creek and on the WWTP site. The second option is extending the existing 36" effluent line across Chockoyotte Creek and then discharging just downstream of the Roanoke River and Chockoyotte Creek confluence. The third option is to extend the 36" effluent line to just downstream of the Roanoke River and Chockoyotte Creek confluence by placing it on the bottom of Chockoyotte Creek using river crossing pipe, without trenching and possibly with concrete anchors to hold it in place. US Army • Ms. Jones (USACE) stated that any structures in the creek or river would require a Corps of 404 Section 10 permit. Engineers • Nationwide Permit (NWP) No. 12 is required for trenching in the creek. • NWP No. 33 is required for dewatering excavation pits for structure construction in the creek or river. • Stabilization will be required on the disturbed embankments. • There are no buffer requirements for Chockoyotte Creek. • USACE has no objections to an aerial crossing of Chockoyotte Creek with the effluent line or placement of the pipe along the bottom of the creek. • ESACE has no objections with placing the 36" effluent piping on the bottom of Chockoyotte Creek. Division of • DWQ said that Option 1 with the effluent discharge upstream of Chockoyotte Water Creek is a possibility, but would require modeling or field testing to insure that the Quality effluent would not backup into Chockoyotte Creek. DWQ noted that RRSD had first expressed this concern when relocation of the WWTP discharge was first discussed. • DWQ expressed concern about how the integrity of the effluent piping in the creek (Option 3) could be tested in 20 years. • DWQ expressed concern on Option 3 on the strength of the river crossing pipe and the possibility of structural failure. • RSSD expressed the desire to continue to discharge the 16" effluent force main at Roanoke its current location in Chockoyotte Creek. The 16" force main and pump station Rapidare not used unless the river level is above flood stage and therefore would have Sanitary little impact on the river. DWQ said they would check on the possibility of leaving District the 16" effluent discharge in Chockoyotte Creek. GAWwmlRoanok6301911EngTWQMeettngRepoRdoc Page: 2/3 6 ARCADIS ARCADIS Field Observation • The river -crossing pipe is class 56 and has a wall thickness of 0.73" for 36" diameter ductile iron pipe. The river -crossing pipe has an allowable deflection of 15 degrees. • Observed the effluent relocation for all three options from the dike around the WWTP. The Roanoke River was at the lowest level the plant operators or DWQ personnel had ever seen it. ARCADIS ■ Adjourn Summarized the meeting comments as follows: o Option 1: This option is acceptable provided that flow modeling or field- testing proves that the plant effluent would not back up into Chockoyette Creek and cause stagnation problems in the creek. o Option 2: This option is acceptable. The creek crossing can be an aerial crossing or the pipe can be trenched into the creek bottom. All creek and river banks disturbed would need to be stabilized to prevent erosion of the "point" at the confluence of the creek and river. o Option 3: This option is acceptable. DWQ has some concerns about "damming" up water behind the pipe during low flows, so the pipe system should be designed to allow flow under the pipe during low water level conditions in the creek. • The meeting was adjourned at approximately 11:30 a.m. G:iWwmlRoanoke1301911EngIDWQMeetIngReport.doc Page: 3/3 - Roam*. LocurP Asivkibt- 1 )14rcad ke.J J -i,' <)/JJ4:c- Co/7,J T. - h,S d,cJ`1(1'1116 ap�'o"`' -a` Cat-eeL — wGxi 70 WO .6FJ sticti ,Wad, //yed- pow fXte% • f� Meel�— cichnLat- 0.) ,ditt peew thy yo da+14- agtk filiv itew-t mceZti -Lk at,a/C ,10 ait‘t c 364-0A-y--- rAi - os_o_ ��ln, ceari¢aQ @fe»�ry ICoLe. � dQoox C' -/-ked b6u4- spy ,ta6e ai ,u;c � �v� Iteicek �- tpr156 — � .?,�, _ 1../Litt Mz tail( i4 IU-ral elc sta.. Alitu s<:err (k-el Awl C'oe7Zs )owu,7e (1,4disc/tale pa.41- c/K_ fe/(A.. maat a - Cad cam- A..i chi. Crt9s�.c=rlS, 8on -}-�.e bd-��r�vw o 1 ovzslic . VOA) eei)J2-i kiinio owns Sic c Cte/G - 7L �c �`� i c� al e-- ? Cw ► u. ►, c,L.s CAI Cult - 5..t, Matt 414).6 ` 0 p G uic, cL - r 1t..R. I' f S zz,F - C 2AAS iseAii „di/At-ICJ No I- I t.t CtG J ivS Lc.QYrn.�:C� tOldecd-- V1(1 Cud& b r 0-.01 o 0 c r P� w,. u ! 11 R U 1 Q, 50a /7+ a..1)-1v'. iocctcorn - (1O ` -uu.. 4:L m) J 'i F'1 4v c hat — Z cce u1 de 114ak C a- ) — ;: it cut- di-i-f-czu v1 F -f' iou (64h 4-e-L'u,-± / .0 "") ,21OO d-s - kaboLu foco - ci Ock --(9YAA c,c) • C,c)...us4Lk p.,2A.vite e-41 CC tt- nik,c i` _ Cervukcc-tivi-6)(rnchLU'L 04 A►r�) 1 -12cb ufs'uctivi of Q-kobairtsvc 64(.) owo4he r s d( ` �-c vicP sorru) Qd uutic , cs2tkc.. Roanoke Rapids Sanitary District 1000 Jackson Street P. O. Box 308 Roanoke Rapids, NC 27870 (252) 537-9137 Fax (252) 537-9136 November 29, 2001 Mr. David A. Goodrich, Supervisor NPDES Unit NCDENR/Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: Renewal of NPDES Permit Number NC0024201 Roanoke Rapids Sanitary District WWTP Halifax County Dear Mr. Goodrich: 'E 22001 FiR:Clij?1fI1TY The Roanoke Rapids Sanitary District is permitted to discharge 8.34 MGD of treated effluent at the mouth of Chockoyotte Creek at the Roanoke River under NPDES Permit No. NC0024201, which expires on May 31, 2002. This application is for renewal of the current permit. In accordance with the requirements of NC G.S. 143.215.1(c) we are submitting the following: 1. Completed and signed permit application, EPA Form 2A, in triplicate (Attachment A); 2. Complete reports of expanded effluent test results for three scans of the last 4 ''A years (Attachment B); 3. Complete reports of whole effluent toxicity test results for the last 4 '/ years (Attachment C); 4. Complete reports of remediation waste test results for two years (Attachment D); and 5. A narrative description of the biosolids program (Attachment E). Permit Application Highlights Prior to renewal of this permit in 1997, the Division of Water Quality (DWQ) had historically established permit limits for this facility based on the 7Q10 of the Roanoke River. The facility discharges into Chockoyotte Creek, at its confluence with the Roanoke River. When DWQ issued the draft permit for this facility in June 1997, a change in DWQ's permitting strategy caused the Sanitary District to file a Petition for a Contested Case Hearing in the matter, in July 1997. At issue was a change in the instream waste concentration (IWC) required to be used in the quarterly pass/fail chronic whole effluent toxicity tests. A negotiated settlement agreement reached in December 1997 provided for an [WC of 39% for the chronic whole effluent toxicity tests, which became effective February 1, 1999. The settlement agreement did not impact the permitting strategy for conventional pollutants and toxicants, and limits for those parameters remained established based on the 7Q10 of the Roanoke River. Page: 1/3 v Given the proximity of the facility's discharge to the Roanoke River and the facility's record of passing the chronic whole effluent toxicity tests at the lower IWC, the Sanitary Istrict respectfully requests that: 1. Permit limits for conventional pollutants and toxicants for this facility remain based on the 7Q10 of the Roanoke River, as this is the current permitting strategy. 2. The IWC percentage of 39% for quarterly pass/fail chronic whole effluent toxicity tests is maintained. Other Issues 1. Part D of EPA Form 2A requests data on volatile organic compounds, acid -extractable compounds, and base -neutral compounds. This is data that would typically be generated if a facility were required to conduct Priority Pollutant Scans on the effluent. Although RRSD is not required by the current NPDES permit to conduct these scans; we have continued to maintain this monitoring and rather than enter this complex data on the form, we believe it is much more appropriate to provide you with copies of the expanded effluent test data lab reports and are included as Attachment B. 2. Part E of EPA Form 2A requests toxicity testing data. The data required is the same as that provided by our laboratory when they conduct the tests. Rather than enter this complex data on the form, we believe it is much more appropriate to provide you with copies of the full toxicity test lab reports. These are included in Attachment C. 3. Since our last permit renewal the District has accelerated our commitment to preventing sanitary sewer overflows. In this regard we have placed a diesel operated 12" pump in the vicinity of our influent collection box with a piped discharge to our abandoned primary clarifiers. These tanls were previously utilized for residuals holding and will remain available as secondary storage for biosolids and primarily for influent flow equalization. Other Requests for Permit Renewal We would appreciate DWQ's consideration of these additional requests for this permit renewal: 1. Our current permit requires instream monitoring for dissolved oxygen and temperature. During this period we have recorded consistent results without any anomalies being observed, therefore we are requesting this permit requirement be written out of our permit renewal, understanding this may be revisited on our next renewal. Should this request by denied, we request language in the permit that specifically incorporates the provisions of 15A NCAC 2B.0505(c)(4) into the permit. This rule provides that stream sampling may be discontinued when flow conditions or extreme weather conditions could result in injury or death of the persons collecting the samples and includes requirements for reporting. 2. The Roanoke Rapids Sanitary District believes it is the State of North Carolina's intention that the exclusion from sampling during extreme weather and hazardous conditions promulgated Page: 2/3 { under 15A NCAC 2B.0505(c)(4) includes influent and effluent sampling in addition to receiving stream sampling activities. We request the following language be included as a Special Condition in the NPDES permit: "Influent and effluent sampling events may be discontinued at such times as extreme weather conditions or other hazardous conditions (such as local flooding, high winds, hurricanes, tornadoes, electrical storms, etc.) exist which will result in substantial risk of injury or death to persons collecting samples. In such cases, on each day that sampling is discontinued, written justification for tit discontinuance shall be specified in the monitoring report for the month in which the event occurred. Sampling shall be resumed at the first opportunity after the risk period has ceased." 3. Please provide us with a copy of the Fact Sheet prepared as part of the draft permit development as soon as it is available. 4. Please provide documentation of methodology, data, and assumptions used in any Reasonable Potential Analysis that may be conducted. 5. We request a copy of any comments that DWQ may receive from the public regarding this permit renewal. Should additional information be required, please contact me. Very truly yours, Roanoke Rapids Sanitary District le R. Danieley Bro (:43Pr- n, PE Chief Executive Officer Enclosures Copies: Gregg Camp, RRSD Francine Durso, ARCADIS NPDES Unit File — 2 File CHOCKOYOTIE CRUX DUTFALL RIPER DUTFALL r DIVERSION BOX -�-� INFLUENT EOUAUZATION SULFURIC ACD FOR pH ADdISININT--1 ri-I wwuu j—, I I LeRsa J II DIVERSION TO CHOCKOYOTTE CREEK OVERFLOW TO aKICKOYOTTE CREEK --0"- PRIMARY SWDGE HIM EFTLUENT Tird PRIMARY IRMO A �STATION 4PUMPS 0 NATANT QDRAINAGE o c _J ROM RECIRCULATION PUMP �TSN 0 PU2PPU SUPERNATANT E i .r l dRASSTATIONMP __HMIAs crumw THICKENERS 1 IrAs oRu�1 _ THICISER I � GLUM STAEJLIT�ATION HIDING FACLTTY TANKS PERNATANT,._ 0 SUPERNATANT_ PRIMARY SLUDGE2 PRIAARY 1 SEc ARY PUIP STATION DID ANAERCDIMESTERG DIGESTED SLUDGE DIGESTED SLUDGE LAND APPLICATION ORlWAGE 1--�SLIIDS;E DBTYING eEDS} -r- T J LEGEND NORMAL OPERATION -----INTERMITTENT OPERATION D6a1ARGE TO CHOOCO1fOTTE CREEK OISOURCE CHOCXOYOTTE CREEK PLANT FLOW SCHEMATIC ROANOKE RAPIDS SANITARY DISTRICT WASTEWATER TREATMENT PLANT f ARAD1S • ■0 w Q cc STRUC1URE LEGEND 1. IFUIENT DIVERSON BOX 2. INFLUENT SEEN 3. GRIT SEPARATOR 4. INFLUENT PUMP STATION 5. IF111ENT VAULT 6. DISTRIBUTION BOX j1 7. PRIMARY CLARIFIER j2 B. PAYARY CLARIFIER j 9. TRICKING FILER DISIR®UTION BOXES I0. TRICKLING FLIER f2 IT. TRICKLING FILTER fI 12. FILTER EFFLUENT DIVERSON BOX 13. FLIER RECIRCULATION PUMP STATION 14. FILTER EFFLUENT PIAP STATION 15. AERATION TANK 1-3 16 QARIFRRS 1 & 2 17. R.A.S. PUMPS I8. DISINFECTION TANKAGE 19. DISINFECTION CONTROL BULGING 20. NOT USED 21. NOT USED 22. NOT USED 23. NOT USED 24. NOT USED 25. EFFLUENT LEERING FLUME 26 EFFIIR:NT PUMP STATION 27. EFFLUENT DISCHARGE 26. PUMPED EFFLUENT DISCHARGE 29. PRIMARY SLUDGE PUMP STATION 30. PRIMARY DIGESTERS 31. SECONDARY DIGESTER 32. DISTRIBUTION BOX 33A. SLUDGE STORAGE 33. RELENT EQUAUZA110N/SWOGE STORAGE 34. V.S. PUMP STATION 35. GRAVITY SLUDGE 1WCIO HERS fl & f2 36. DRUM 1HICI NER & THICKENED SLUDGE PUMP STATION 37. LIME TAX TANKS 38. V.A.R. TANKS 39. V.A.R. PUMP STATION 40. SLUDGE TRANSFER PUMP STATION 41. TANKER LOADING STATION 42. ACID STORAGE TANK 43. OPERATIONS BUILDING 44. LABORATORY BUILDING 45. BLDWER AND MAINTENANCE BUIDING 46. SNATPRY SEWER PUMP STA110N 47. SLUDGE BED DRAIN PUMPS 48. GENERATOR 49. MCC 50. MCC 51. TANKER SPILL PROTECTION 52. SIGRYWAIER PULP STATION PLANT SITE PLAN ROANOKE RAPIDS SANITARY DISTRICT WASTEWATER TREATMENT PLANT itt A! CAD1S