HomeMy WebLinkAboutNC0003760_Wasteload Allocation_19830419NPDES DOCUMENT !;CANNIN`: COVER SHEET
NPDES Permit:
NC0003760
DuPont Kinston facility
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Approval
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 19, 1983
Thin document is printed on reuse paper - ignore any
content on the rezrerise side
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DISCHARGER
RECEIVING STREAM
WASTEFLOW
! SEG NO !REACH 1 LEG MI 1
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KINSTON F`EACHTREE i NORTHSIDE' DUPONT
MEUSE RIVER
6. 7 5, 4.7 5 7 3. 6 M G ID
TIC 1 CBOD 1 ORGN 1 NH3i! 1
0+001 0+001 0.001 0+001
0+04 1 0.001 0+001 0.001
0.071 0+001 0.001 0.001
0+111 0+001 0.001 0+001
0.141 0+001 0.001 0.001
0.181 0+001 0.001 0.001
0.211 0.001 0.001 0.001
0+251 0.001 0.001 '0.001
0.281 0.001 0.001 0.001
0.311 0.001 0.001. 0.001
0.351 0.001 0.001 0.001
0.381 0+001 0+001 0+001
0.421 0.001 0+001 0.001
0.451 0.001 0+001 0+001
,0.481 0+001 0.001 0+001
0.521 0.001 0+001 0+001
0.551 0+001 0+001 0+001
0.581 0.001 0+001 0+001
0.621 0+001 0.001 0+001
0+651- 0+00 i 0-+-001
0+681 0+001 0.001 0+001
0+711 0.001 04001 0+001
0.75i 0.001 0+001 0+001
0.781 0.001 0+001 0+001
0.811 0.001 0+001 0.001
0+841 0+001 0+001 0+001
0.871 0+001 0.001 0.001
0.901 0.001 0.001 0.001
0.941 0.001 0.001 0.001
0+971 0+001 0+001 0+001
1+001 0+001 0+001 0+001
1+031 0+001 0.001 0.001
1.061 0.001 0+001 0.001
1+091 0.001 0+001 0.001
1+121 0.001 0+001 0.001
1.151 0+001 0.001 0.001
1.181 0.001 0.001 0.001
1+211 0.001 0.001 0.001
1+241 0+001 0.001 0+001
1+271 0.001 0.001 0.001
1.301 0.001 0+001 0+001
1.331 0.001 0.001 0.001
1.361 0.001 0.001 0+001
1+391 0+001 0+001 0+001
1+421 0.•001 0+001 0.001
1.451 0+001 0+001 0.001
1+401 0+001 0+001 0+001
1+461 0+001 0+001 0+001
1+511 0+001 0+001 0.001
1.571 0+001 0.001 0+001
1+631 0.001 0.001 0.001
1.681 0+001 04001 0+001
NO3 1 FLOW 1 CS I
0+001220+4612604.3!
0.001220+5112529.91
0.001220.5712457.6i
0.001220+6212387.41
0+00122046712319+21
0+001220.7212252.91
0;001220+7 7 12188+61
0 + 00 1 220 + 83 1 2126 .. 1.1
0.001220.8812065.31
0.001220+9312006.31
0+001220.9811949.01
0.0 1 221 + 03 1 1893 t 1
0.001221.0911839.31
0.001221+1411786+71
0.001221+1911735.71
0+001221+2411686..11
0+001221+2911638+01
0+001221.3511591.2.1
0+001221+4011545.81
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0.001221.8111226.01
0+001221+8r11191.01
0+001221+9211157+01
0+001221.9711124.01
0.001222.0211091.91
0+001222+0711060.71
0+001222.1311030.51
0+ 00 1 222 4 18 1 1001 .:1. 1
0.001222.231 972+51
0.001222+281 944.71
0+001222.331 917.81
0+001222+39! 891461
0.001222.441 866.21
0.001222.491 841.51
0.001222+541 817.5i
0. 00 1 222 .59 1 794.11
0.001222.651 771.5E
0+001222.701 749.51
0.001222.751 728.1.1
0+001222.80i 707.31
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1 1 2 1 5.901 1.791 0.001 0.001
I 1 1 . IT 6:101 1.851 0.001 0.001
I 1 1 2' 1 6.301 1+ 90 1 0.001 0.001
1 1 I 2 ▪ 1 6+501 1.951 0.001 0.00!
1 1 2 1 6+70 ! 2.001 0.001 0+001
1 1 2' 1 6.901 2.061 0.001 0.001
1 1 2 I 7.101 2. 11 1 0.00 1 0.001
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1 1 1 2 1 7.501 2+21 1 0.001 0.001
1 1 • 1 7.701 2i261 0+001 0+001
1 I L. 1 7.901 2.31! 0.001 0.00!
1 1 I 2 1 8+ 10 1 2.361 0.001 0.001
1 1 I `? 1 «30! 2.411 0.00! 0+00I
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1 1 2 1 8.701 2+50 1 0.001 0.001
1 1 I 2 1 8.901 2.551 0.001 '-?+OV I
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! 1 1 2 1 9.301 2.641 0.001 0.001
1 1 1 2 1 9.501 2.691 0.001 0.001
I 1 1 2 I 9.701 2.731 0.001 0.001
1 1 2 1 9.901 2.781 0.001 0.001
1 I 2 110.101 2.821 0.001 0.00i
I 1. 1 '1 110+301 2.871 0+001 0.001
1 1 1 2 110.501 2.911 0.001 0.001
I 1 I 3 I 10.501 2.841 0.001 0.001
t 1 1 3 1 10 + 70 1 2.891 0.001 0.001
I 1 I 3 1 10+90 1 2.931 0.001 0.001
1 1 1 3, 1 11.101 2.971 0.001 0+001
I 1 I 3 1 11.301 3.021 0.001 0.001
1 1 I 1 11.501 3.061 0.001 0.001
1 l 3 1 11.701 3.101 0.001 0.001
1 11 3 1 11+901 3.141 0+001 0.001
I 1 1 3 I 12.101 3+181 0.001 0.001
1 1 I 3 1 12.301 3.221 0.00 ! 0.001
1 1 1 3 1 12.501 3.261 0.001 0.001
I 1 1 3 112.701 3.301 0.001 0.001
I 1 1 3 1 12.901 3.341 0.001 0+001
1 I 3 1 13.101 3.381 0.00i 0.001
1 I 1 13+301 3.421 0.001 0.001
1 1 3 I 13.501 3.461 0.001 0.001
1 1 3 113+701 3.501 0.001 0.001
! 1 1 3 113.901 3.541 0+001 0.001
1 1 ,:, 1 14 + 10 1 3+ 57 I 0.001 0.001
1 1 1 .3 1 14.301 3. 61 1 0.001 0.001
I 1 1 3 1 14.501 3.651 0.00E 0.001
I 1 1 3 1 14.701 3.681 0.001 0.001
1 I 3 1 14.9901 3+721 0.001 0.001
1. I :s 1 15.101 3.751 0.001 0.001
1 1 3 1 15+30! 3+791 0.001 0.001
1 1 11 3 1 15.501 3,821 0.001 0.001
i 1 1 I 0.001 0.001 - 0
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2 1 1 1 0.201 0. 17 1 0.001 0.001
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2 1 1 I 0.401 0.341 0.001 0.001
1 2 1 1 1 0+50! 0.42! 0.001 0.001
1 2' 1 1 1 0.601 0.501 0+001 0.001
2' 1 1 I 0.701 0+ 58! 0+001 0♦00!
1 2 1 1 1 0.801 0.661 0.001 0.001
1 2 1 1 1 0.901 0+741 0.001 0.001
1 2 I 1 1 1.00i 0.821 0.001 0.001
I 2 1 1 I 1.101 0.891 0.001 0.001
1 2 1 1 1 1+201 0.971 0.001 0.001
I 2 1 1 1 1.301 1.041 0.001 0+001
2 1 1 1 1.401 1.1.21 0.001 0+001
1 1 1:.50! 1.1 % 00l 0 O i
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1 1 1 1.701 1.331 0.001 0.001
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1 1 I 1.901 1.47i 0.001 0.001
I 1 1 2.001 1 .'54 1 0+001 0.001
I 1 1 2..101 1.601 0.001 0.001
1 1 1 2.201 1.671 0.001 0+001
1 2 1 1 1 2.301 1.741 0.001 0.001
1 1 I 2.401 1.R01 0.001 0.001
1 2 I 1 I 2.501 1.871 0.001 0.001
1 1 1 0.001 3.541 0.001 0.001
1 I 1 I 0.501 3.641 0.001 0.00!
1 3 I 1 i 1.001 3.731 0,001 0.001
1 3 1 1 1 1.501 3.821 0.001 0.001
1 "3 1 1 I 2.001 3+901 0.001 0.001
1 .3 1 1 1 2. 50 1 3.991 0.001 0.001
1 •3 1 1 1 3.001 4,071 0.001 0.001
I a 1 1 1 3.501 4.151 0.001 0.001
I 3; 1 1 1 4.001 4.231 0,001 0.001
1 3 I 1 1 4.501 4.311 0.001 0+001
I 3 1 1 I 5+001 4.381 0.001 0+00!
1 3 I 1 1 5.501 4+46! 0.001 0.001
! _ 1 1 .1 6.001 4.531 0.001 0.001
1 3 1 1 1 6.501 4.601 0.001 0.001
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1 3 1 1 1 7.501 4+731 0.001 0.001
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1 1 I 9.001 4.921 0.001 0+001
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1 1. 110.001 5.041 0.001 0.001
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0.001230.8911540.91
0+001231.0011456.71
0.001231.1011377.11
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0.001 '2 31 + 3 1 1 1230 .7 !
0.00 1 231 .4.1. 1 1163+4 1
0.001231.5211099.91
0+001 231.621 103 +81
0.001 31.721 987.01
0.001231.831 929.31
0.001231.931 878.51
0+001232.041 830.51
0.001232+141 785+21
0.00 1232.241 742.31
0.001232;35i 701.81
0 : 00 1 232 . 45 1 663.51
0.001232.561
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0.00 1 2. 2.66 1 593.11
0. 00 1 232. 76 1 560.71
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0. 00 1 232 . 97 1 501.21
0.001233.081 473.91
0.0001233.181 448.11
0.001233.28i 423+61
0.001 238.861 647.41
0.00 1238 .9971 612+91
0.001239.071 580.21
0.001239.181 549+31
0.001239.28i 520.01
0+001239.381 492.31
0.001239.491 466.1.1
0.001239.591 441+31
0.001239.701 417.81
0.001239.801 395.61
0.001 '39.901 374.51
0.001240+011 354.61
0. 00 1 240. 11 1 335.81
0 . 00 1 240 . 22 1 317.91
0.00 1 240.32 1 301.01
0.00 1 240.42 1 285.01
0. 00 1 '40 + 53 1 269.91
0 . 00 1 240 . 63 1 255.61
0+001'40.741 242+01
0 . 00 1 240. 84 1 229.21
0.001240.941 217.01
0.001 41,051 205.51
0 + 00 1 241 . 15 1 194.6i
0 .00 1 24, 1 . 26 1 184.31
0.001241.36 1 174.61
0. 00 1 241 .46 1 165.31
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0.001 39.151 281 +8 1
0.001 39.201 262.21
0.001 39..26i 243. i
0.001 39.311 2 6+ 9 1
0.00! 39.361 211.11
0.001 39.411 196.51
0.001 39.461 182.9i
0.001 39.521 170.21
0.001 39+571 158.41
0.001 39.621 147.5i
0,001 39.671 1.37.41
0+00! 39.72! 127+91
0.001 39.781 1 1.9 +'. 1
0.00! 39.831 111.+01
0.001
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0.001 39.981 89.91
0.00i 40.041 83.81
v.00 1 40.091 78.2 1
0.001 40+141 72+91
0+00! 40+19 1 68.11
0.001 40.241 63.51
0.001 40.301 59+31
0.001 40.351 55.41
0.001 40.401 51.131
0.00 1 281 . 86 i 143,11
0.001282.121 130.81
0.001282.381 114.91
0.001282.641 100.8!
0 . 00 1 282 . 9'0 1 88 + 6 1
0+001283.161 77.8E
0.001283.421 68.4!
0.00 1 283. 68 ! 60.11
0.001283.941 52.91
0. 00 1 '284 . 20 1 46.51
0+001284.461 41.01
0.00 1 284. 7 "2 1 36. 1 1
0.001284.981 31.8E
0.001 2.2 85.4 i 28. 1 1
0.00 1 285.50 1 24. 8 1
0. 0 0 12.8 5 .7 6 i 21.91
0+ 0 0 1 2 8 6 . 0 i 1 19.41
0.001286+281 17.21
0+00 1 286.54 1 15+31
0 , 00 1 286 + 80 1 13.61
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DIVISION OF ENVIRONMENTAL MANAGEMENT
April 27, 1983
MEMORANDUM
TO: Steve Tedder, Supervisor
Technical Services Unit
FROM: Forrest R. Westall, Head
Operations Branch
SUBJECT: Disinfection Requirements for the
Lower Neuse River Near the Kinston Area
Attached for your review is a memorandum from the Washington Regional
Office concerning this subject. I would ask that the observations from
the Washington Regional Office be reviewed in relation to the evaluation
performed by Randy for disinfection requirements in the Neuse River near
the Kinston area. In the case of the Kinston Northside plant, it appears
that monitoring data prior to disinfection will be necessary in order to
evaluate whether disinfection at this facility can be discontinued.
Following your review of this information, please provide a brief summary
of the results of your review. If you have any questions concerning this
request, please let me know.
Attachment
lit1,7•i
WATER QUALITY
OPERATIONS. BRANCH
MEMORANDUM
TO: Lee Fleming, Jr., Chief
Water Quality Section
60164,1.Tt A".3
DIVISION OF ENVIRONMENTAL MANAGEMENT
THROUGH: Jim Mulligan, Regional Supervisor
Washington Regional Office
FROM: Roger K. Thorpe, legion 1 Engineer
Water Quality Section-WaRO
SUBJECT: Disinfection Requirements for the
Lower Neuse River Near the Kinston Area
April 19, 1983
a
Per your request, I have reviewed the letter from DuPont and the assessment made
by Technical Services.
In the case of DuPont's discharge, I believe that water quality standards in the
Neuse River can be maintained without disinfection. As stated in Mr. Long's
letter, only about 5% of the influent flow to the waste treatment plant is domes-
tic flow. This coupled with the dilution ratio of approximately 36 to 1 should
prevent violations of the fecal coliform standard in the Neuse River. Mr. Long
related by telephone conversation on April 15, 1983, that he had sampled the
effluent prior to chlorination from both of the final clarifiers that week and
obtained F.C. concentrations of 50/100 ml and 200/100 ml.
CMSD discharges to Contentnea Creek. The dilution ratio is approximately 11.6 to
1. Without disinfection, I feel that the coliform concentrations in the effluent
may be high enough to contravene water quality standards in Contentnea Creek during
low flow conditions. I could not recommend removing the disinfection requirement
on the facility without first obtaining data which shows that the fecal coliform
concentrations in the effluent without disinfection are consistently at or below
the 20,000/100 ml range.
In the case of Kinston's Northside plant, I could not recommend removing the
disinfection requirement without first obtaining data which shows that the fecal
coliform concentrations in the effluent without disinfection are consistently at
or below the 50,000/100 ml range. If this information could be obtained, then in
both the case of CMSD and Kinston Northside, I believe that monitoring should be
required and a re -opener be included in the permit which would allow us to require
disinfection when a certain concentration is reached.
RKT / ekw
DIVISION OF ENVIR0 4EQ TAL MANAGEMENT
March 28, 1983
Hr. E. L. Long, Specialist
Environmental Control
E. I. du Pont de furs & fany
Kinston Plant
Kinston, North Carolina 28501
Dear 14r. Long:
Thank you for your letter of January h, 1983 concerning chlorination of
the wastewater effluent at the Kinston plant. Also, I appreciate the recent
opportunity we had to discuss this issue in my office.
As I indicated to you, the water quality program is taking a hard look
at the issue of chlorination of treated wastewater. ly staff has been in
communication with the Department of Human Resources and with the researchers
at area universities on this important issue. It appears that some research
effort may be directed toward the issue of wastewater chlorination during the
coming year. It would be our intention to use that research effort to examine
our existing requirements for disinfection.
With specific reference to your request to reconsider disinfection at the
Kinston facility, we have prepared a peal iminary analyses of the four plants
discharging in this area of the Neuse River. Because this evaluation is very
preliminary and could affect all concerned discharged, we need to carefully
SWIM the results before a final determination is made. As a result, I am
referring the preliminary determination to our regional office water quality
staff In Washington and to the central water quality staff to determine if
dropping disinfection requirements is in the best interest of water quality of
the Meuse River. This evaluation will be completed by Ap i 1 22, 1983. At that
time, we will notify you of the results of our determination.
In reviewing our disinfection requirement, I think it is 'important to
point out a few key things. our NPDIES vomit does not require chlorination
of effluents but ratter requires an a b1e collform density. Certainly
chlorination is the most widelyused meths of achieving this effluent quality.
However. alternative disinfectimethods are available. If problems associated
with chlorination are to be avoided, these other methods may need more consider-
ation. Therefore, in addressing the issue of disinfection of waotewater
discharges, it is necessary to consider this issue from the disinfection
technology standpoint as well as from the public health aspect.
Nr. E. L. Long
Page 2
March 28„ 1983
I think you can appreciate our desire to trove carefU ly en this issue. If
you have any questions concerning this natter, please let me knew.
Sincerely yours.
J R.
W. Zee Fleming* Jr., Chief
Voter Quality Section
cc: Forrest UUestal1
1HuiIiga►n
Steve Tedder
Alan Klimek
414 /
f - �,,.,( `L(j beet(
DIVISION OF Ei VIROi IEUTAL MANAGEMENT
March 25, 1933
! EMORAN!)UM
TO: Jim Mulligan, Regional Supervisor
Wasnington Regional Office
FROM: W. Lee Fleming, Jr., Chief
Rater Quality Section
SU3JECT: Disinfection Requirements for the
Lower Neuse River dear the Kinston Area
Attached for your review is information concerning this issue. Please
review in consultation with the Technical Services Unit and provide comments
concerning this no later than April 13. As you will note from the letter to
ifir. E. L. Long, ge need to determine our position before April 22. Your
assistance in this matter is appreciated.
If you have any questions, please let re know.
cc: Forrest testall
Flan Klimek
Steve Tedder
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 22, 1983
MEMORANDUM
TO: Forrest Westall, Head
Operations Branch
FROM: Randy Williams �,
Technical Services �" U
THRU: Steve Tedder 4),Xr
SUBJECT: Disinfection Requirements
DuPont - Kinston Plant
Mr. E. L. Long of DuPont has requested that the company be allowed
to discontinue the chlorination of its wastewater. This request was made
on the basis that the "Kinston Plant tradewaste facility effluent does not
require chlorination to protect public health" (see letter to Lee Fleming
dated January 5, 1983) since there are no drinking water intakes or public
beaches located downstream of this discharge. Further, only 5/ of the
feed to the facility is of domestic origin. Thus, low counts of fecal
coliform bacteria should be present in the plant's effluent even without
chlorination.
Kinston's Northside WWTP is located 4.5 miles below the city's
Peachtree Plant and 6 miles upstream from DuPont. Contentnea MSD is
located on Contentnea Creek 2.5 miles above the mouth of the creek, which
is 5 miles below DuPont. Presently, only Kinston Peachtree is not
required to disinfect its wastewaters, based on an analysis of fecal
coliform data supplied by its consultant, L. E. Wooten, and recent self -
monitoring data. The other three plants are required to meet an
effluent limit of 1000/100 ml.
The most recent data available on a yearly basis for both the
Kinston Peachtree and Northside Plants is that from 1981. From Table 1,
the average upstream fecal coliform value was 243/100 ml for that year
while the average value downstream of the Peachtree Plant was 330/100 ml.
This station corresponds to the upstream station for Northside. The average
value of fecal coliform below the Northside Plant was 465/100 ml. From
this data, it can be seen that the treatment plants exert little influence
on the values of fecal coliform in the river. In fact, fecal coliform
increases by over 25% between the stations above and below Northside,
even though the plant was providing disinfection.
Forrest Westall
March 22, 1983
- page two -
Recently, Kinston Peachtree's disinfection requirements were rescinded
on the basis of the plant's past performance with respect to fecal coliform.
At 7010 river flow, it was determined that an effluent concentration of
20,000/100 ml would protect. the standard if the mix time was instantaneous.
If the mix time was 6 hours, 50,000/100 ml would protect the standard.
Modeling shows that these values would also protect the river below North -
side and DuPont if applied to those discharges. According to E. L. Long,
5% of DuPont's wastewater is domestic. Assuming a typical undisinfected
wastewater concentration 'of 400,000/100 ml, a final effluent concentration
of 20,0007100 ml could be expected. Thus, it appears that none of the
discharges needs disinfection as long as these values can be maintained
in the effluents.
In summary, the fecal coliform levels in the Neuse near Kinston
appears to be a function of upstream conditions. Treatment plants, as
they are presently operated, exert little influence on these levels. If
disinfection were tc be discontinued at those plants discharging directly
to the river, little change in in -stream levels is expected, as long as
50,000/100 ml effluent limits are maintained.
Let me know if you have any questions.
RW:cs
Attachment
Table 1
Peachtree Northside
1981 Upstream Effluent Downstream = Upstream Effluent Downstream
Jan 318 30000 438 438 <10 650
Feb 78 24000 139 114 <10 145
Mar 280 ......... 10000 .. _ 628-.._ , ,. _ .._.....:.-628 , <10 : __, ,. __.-1319-
Apr 250 5000 190 190 <10 260
May 138 2000 193 193 <10 175
June 150 3000 140 162 <10 225
July ND ND ND:- 203 <10 180
Aug 100 4600 150 181 <10 185
Sept 173 100 240 5114 <10 318
Oct 700 3000 850 825 <10 1188
Average 243 9200 330 345 <10 . 465
f b
I, •
R.12003.K
vwar .•v s•
ESTUUSNED not
E. I. DU PONT DE NEMOURS & COMPANY
INCORPORATED
KINSTON PLANT
KINSTON, NORTH CAROLINA 28501
TEXTILE FIBERS DEPARTMENT
Mr. Lee Fleming
Chief, Water Quality. Section
N. C. Dept. of Natural Resources and
Community Development
P. 0. Box 27687
Raleigh, N. C. 27611
414c 14%1 /([ .1 — 6_,YA r
he
aft0
-ikt) L
114
C� 3�
>�j ,�Q►^ �� January 5, 1983
°)Y
C(1/
'474° 4 Ali g
WAY,
Lrkt.4"71,;_-
g'iejjrit�
4g. 4t
Ao3
Dear Mr. Fleming:
Ref.: Kinston Plant - Chlorination of Tradewaste Facility Effluent - NPDES
Permit No. NC 0003760
It has come to my attention that chlorination of tradewaste effluents is
a condition of receiving water flow and is not required in some wastewater
treatment plants in North Carolina.
The chlorination of wastewater effluents has become a matter of in-
creasing concern in recent years because of the potential for adverse effects on
aquatic life and human health from the chlorination of substances that can be
present in the receiving waters. Environmental Science and Technology reviewed
these concerns in a January, 1982 article, "The Chlorination Question" (Attach-
ment 1'), and stated that "Because the discharge of chlorine into surface waters
and the ocean damages aquatic organisms, some areas of the U.S. are seriously
considering banning wastewater chlorination." Several years ago, the U.S. EPA
removed the fecal coliform limitation from the Secondary Treatment Regulation
after an EPA Task Force formed to review
the use of chlorine concluded that: (a) the use of chlorine wastewatericy on disinfection and
to situations where it is necessaryto should be limited
exclusive use of chlorine for disinfection should not to be continued ealth, and , ( r the
of aquatic life is of primary consideration.(�g where protec-
tion
e Attachment 1 to addressee only.
(1) U.S. EPA, "Disinfection of Water --Task Force Report."
MCD-21, No. EPA-430/9-75-012, Centralized Mailing Lists
Services (8 FSS), Denver Federal Center, Denver, Colo. (1975).
R • •
Mr. Lee Fleming - 2 - January 5, 1983
More recently, the December, 1982 issue of "News", a publication of the
Water Resources Research Institute, pointed out that 25 states have now re-
vised its standard for chlorine disinfection in wastewater. In one state,
studies showed the requirement was excessive and it had a negative effect on
aquatic life. The article continues to point out only 88 of that state's 1600
treatment plants still require chlorination and this was because they were
located within 20 miles of a drinking water plant or a swimming beach.
Therefore, the need for fecal coliform limitations and resultant
chlorination should be determined on a case -by -case basis. We believe that
the Kinston Plant tradewaste facility effluent does not require chlorination
to protect public health. As in the case of the state pointed out in "News",
there are no drinking water intakes or swimming beaches below our plant. The
clarified effluent comes from a well -operated biological treatment system and
contains a low concentration of suspended solids. Only about 5% of the feed
to that system is sanitary wastewater. Even at low river flow, the site dis-
charge is less than 1% of the river flow. Therefore, we believe that the
residual fecal coliform content of the effluent would not have a significant
impact on the river. The Kinston Plant began chlorination about five years
ago to maintain a fecal coliform bacteria count of less than 1,000 colonies
per 100 ml as a permit requirement. The attached bacteria data (Attachment 2)
of the Neuse River for the past three years during the traditional low flow
months show our chlorinated tradewaste effluent has no effect on fecal coli-
form count when upstream and downstream values are compared.
Therefore, we question the continued need to chlorinate our effluent in
light of the concerns that have arisen regarding possible detrimental effects
of chlorination to aquatic life. We request that you and your staff perform
the necessary river quality analytical evaluation in our area so as to relieve
us of an unnecessary fecal coliform permit burden and enable us to cease
chlorination.
Your consideration of our request will be appreciated.
ELL:gs
M13/13
Attachments
Sincerely,
t
E. L. Long, Spec'3aQist
Environmental Con of
ATTACHMENT 1
0
The chlorination question
Highlights of the recent conference in California
Water chlorination is both a bane
and a benefit to man. Recognition of
some of the health problems caused by
chlorine in drinking water led to the
first water chlorination conference in
Oak Ridge, Tenn., in 1975. Since then,
a conference has been held every two
years. The last one took place in Pa-
cific Grove, Calif., at the end of Oc-
tober and was attended by about 200
persons. Seventy papers were pre-
sented and 38 poster presentations
were given.
Why does there continue to be so
much research in the area of water
chlorination? One reason is that
probably no other public health issue
affects a larger proportion of the U.S.
population. Another is that chlorine is
used to disinfect not only potable water
supplies, but the wastewater from
sewage treatment plants. It is also
added to the water circulating inside
the cooling towers of electric power
plants. In this way, lakes, streams, and
oceans annually receive a great deal of
chlorine, which undoubtedly affects
aquatic ecosystems. Chlorine is also
employed in food processing to control
the growth of bacteria and other
pathogens.
Recognition that water chlorination
causes health risks and harm to
aquatic life has not led to its demise.
Consulting ,engineer George White
said that chlorine use is 20-40%
greater than reported in 1975 and
growing steadily, especially in the area
of disinfection.
The many applications of water
chlorination and the fact that it pre-
sents complex and demanding scien-
tific problems have made it a subject
for much research. A great deal has
been learned in the past six years.
Toxicological information relevant to
drinking water disinfection was virtu-
ally nonexistent prior to 1976. How-
ever, according to James Fava of
Ecological Analysts (Sparks, Md.) and
William Davis (U.S. EPA), the basic
questions regarding chlorination have
not changed even though the experi-
mental evidence about the chemistry
of chlorination and its effects on man
and aquatic life has expanded greatly.
We are still asking, for instance, if
chlorination is the best treatment
method for drinking water. Would
another disinfectant be safer for
human health? Do we really need to
disinfect wastewater from sewage
treatment plants?
Other disinfectants
Alternative disinfectants that have
been considered are chlorine dioxide,
ozone, chloramines, UV irradiation,
iodination, or some combination of
these processes. The first three have
been given the most attention. How-
ever, as Richard Bull (U.S. EPA,
Cincinnati) pointed out, all forms of
disinfection commonly used alter the
composition of trace organic chemicals
because the efficacy of disinfectants
"depends on their ability to alter or-
ganic chemicals by either chemical or
physical means." This does not mean
that another disinfectant may never be
found safer than chlorine. At present,
not enough research has been done to
assess the relative hazards ofthe vari-
ous alternatives to chlorine.
An advantage of chlorine dioxide
(C102) is that it forms very few chlo-
rinated products. But this is probably
outweighed by many serious draw-
backs. C1O2 produces chlorite
(C102-), which presents an acute
toxicological hazard. Bull stated at the
conference that C102- has been shown
to oxidize hemoglobin to the non-
functional pigment methemoglobin; at
lower levels it produces hemolytic
anemia. It may also depress sperm
production. In addition, C102 itself
may possess activity as an antithyroid
agent, though the mechanism for this
is not yet understood.
Chloramines also have associated
hazards. A major concern is their
mutagenic properties. Bull said that
chloramine has been found to produce
methemoglobinemia when present in
water used for dialysis of patients with -
chronic kidney failure. However, when
animals are exposed to chloramine
orally, this effect has not been ob-
served.
Ozone is an effective disinfectant
and is used quite commonly in Europe.
But it is expensive and must be used in
combination with some other chemical
because ozone leaves no residual to
continue disinfection after water is
distributed into the system. Conse-
quently, a small amount of chlorine is
usually added to the water after ozo-
nation.
Health effects of chlorination
• What has been learned about the
adverse health effects of chlorine and
the nroductc it fnrmc9 Cnrnr a ,l,,
Bean: One or two key chemical
reactions may explain a great deal
the toxicological effects of chlorine
itself (technically a mixture of HOCI
and OCl— depending on pH) have re-
ceived almost no study —a major gap
in the presently available research.
There is only one long-term investi-
gation of chlorine toxicity, an experi-
ment by Druckery that indicates no
harmful effects from drinking water
containing 100 mg/L of chlorine pro-
vided to rats over seven generations.
Chlorinated water supplies do seem
to present a hazard. At the conference
Earle Nestmann (Canada Health and
Welfare) reported on a study of the
mutagenicity of 30 chlorinated water
supplies in Canada. Out of four sam-
ples taken from every water treatment
plant, he found at least one sample
from each to be mutagenic. He also
reported that compared with other
organics, trihalomethanes (THMs),
the regulated byproducts of chlorina-
tion in the U.S., did not seem to be well
correlated with mutagenicity.
The health effects of THMs have
been studied in some detail. Chloro-
form has been found to cause cancer in
both mice and rats. The carcinoge-
nicity of the other THMs has not been
established definitely, but is being ex-
amined in the national toxicology
carcinogenesis bioassay program.
Michael Pereira (U.S. EPA, Cin-
cinnati) discussed his research con-
cerning the ,mechanism by which
THMs induce cancer. The object of his
study was to determine whether they
are initiators or promoters of cancer.
If initiators, they would presumably
act by a genetic mechanism; that is,
they would act, through interaction
with genetic material of the target cell
and the effects would be irreversible.
If promoters, the THMs would act
through an epigenetic mechanism, and
the effect would be reversible, i.e., the
damage would stop once the promoter
was removed unless it bad already
caused an actual tumor.
Clarifying this is important: if a
carcinogen is an initiator, it is believed
Fava: The basic questions regarding
chlorination have not changed
to have no threshold level below which
it has zero effect; if it is a promoter, it
is thought to have a threshold level.
Therefore, such a study can aid in
formulating models that help to define
a level at which to regulate THMs.
Pereira's results are preliminary but
indicate that THMs are promoters of
cancer. They appear to have "the
weakest, if any, tumor -initiating ac-
tivity."
Besides THMs, chlorination also
produces other byproducts. Their
identification has been a relatively slow
process. And all of them —there are a
great many —have still not been iden-
tified.
The formation of chlorinated phe-
nols has been known for many years.
They show up in the chlorination of
wastewaters. 2,4,6-Trichorophenol has
been demonstrated to be a carcinogen
in both mice and rats, and Jerry Exon
of the University of Idaho has found
some evidence for the fetotoxic effect
of 2-chlorophenol at high doses in rats.
Haloacetonitriles are also products of
chlorination and a dichloroacetonitrile
has been shown to be mutagenic in the
Ames test. Preliminary data also in-
dicate that this chemical is a tumor
initiator. The formation of organic
N-chloramines has been postulated
and a model compound N-chloropip-
eridene has been shown to be formed
in aqueous solution. It has direct mu-
tagenic activity.
The treatment of wastewater is im-
portant because advanced treatment
is being studied as a potential source
for replenishment of groundwater
supplies. Martin Reinhard of Stanford
University found wastewater samples
only weakly mutagenic before disin-
fection but strongly mutagenic after
treatment with chlorine. He noted that
bromination occurred during chlorin-
ation and suspected a connection be-
tween bromination and increased
mutagenicity.
In a poster session, general chair-
man of the conference Robert Jolley
Jolley: Bromochloramines are important
halodmines in chlorinated seawater
(Oak Ridge National Laboratory)
reported on his study of the mutagen-
. icity and chemical characterization of
the nonvolatile organics in disinfected
wastewater effluents. Chlorine was
used as a disinfectant on some samples
and ozone was used on others. In both
cases, disinfection most often led to an
increase in the number of mutagenic •
materials. However, sometimes the
reverse was true, i.e., the mutagenicity
of a few samples was decreased by
disinfection. This inconclusive evi-
dence calls for a better understanding
that new research might provide.
In food processing, chlorine is ap-
plied directly to some foods, such as
fish and chicken, and indirectly to
others because it is employed to sani-
tize equipment. George Braude of the
Food and Drug Administration pre-
sented a paper about the lack of data
concerning the effects of chlorination
on foods. He said: "Very little infor-
mation is available regarding the
identity, exposure level, and potential
toxicity of chlorinated or oxidized re-
action products resulting from the use
of chlorine -containing sanitizers in
food processing."
Population studies
What epidemiological evidence do
we have that chlorinated drinking
water is causing increased cancer
rates? Kenny Crump, Science Re-
search Systems (Ruston, La.), stated
that "although a causal relationship
between chlorinated drinking water
and cancer has not been established, .
the evidence is to a considerable extent
suggestive of such a relationship for
rectal cancer and, to a lesser extent,
bladder and colon cancer." He listed
five case -control studies, conducted by
different investigators using data from
widely separated geographic areas of
the U.S., which found in each case el-
evations in cancer rates for one or more
types of cancer. He said that although
no single study is definitive, these in-;
dependent finclinac TPlin rP i}iP ,w
, bility that the increases arc clue to ei-
ther chance or confounding factors."
Some drawbacks of these studies are
that. the measures of water quality
were very crude and data to control for
confounding factors was limited to
those.previded by death certificates.
Theresa Young described a
matched -pair case -control study car-
ried on in Iowa in which "only colon
cancer mortality was found to be sig-
nificantly greater among those exposed
to chlorinated water." She indicated
that an important weakness was the
lack of individual 'water exposure
histories. She also found that when
THM levels were compared to cancer
rates, no dose -related risk gradient was
found, but that "when other variables
indicative of organic contamination
were considered, an interesting risk
gradient emerged." According to this
study, other contaminants present in
chlorinated water may be more carci-
nogenic than TH Ms.
Future epidemiological studies may
provide more definitive evidence. A
large case -control study of bladder
cancer, sponsored by the National
Cancer Institute, is nearing completion
in which interview data should provide
much more extensive control for con-
founding factors. In an epidemiology
overview, Kenneth Cantor, National
Cancer Institute, said that many
brominated analogs of chlorinated
compounds may have higher carcino-
genicity and may play an important
role as cancer agents.
Cost -benefit analysis
With such uncertainties about the
actual contribution of water chlorin-
ation to adverse health effects, it would
seem impossible to do a cost -benefit
analysis of the different methods of
water treatment. One conference
participant felt that such .analysis
could lead to investment in alternative
methods that would eventually prove
less advantageous.
In contrast, another participant,
Talbot Page of the California Institute
of Technology, said: "We .believe a
cost -benefit approach offers a useful
perspective to the problem of chemi-
cals in.:.drinking water." -He claimed
that cost -benefit analysis allows one to
• organize research around areas where
filling the gaps will have the most ef-
fect on decision making.
He pointed out that a "decision to
postpone action, awaiting better in-
formation, is just as much a decision as
one to undertake action," and said that
his analysis shows there would be a net
benefit associated with installing
granular activated carbon filters in
fAT11P (111PC If 4...s F:l�a�. ..-.. •.....7
before chlorination, they remove the
precursor substances that give rise to
chlorination byproducts.
Analytical measurements
Previously, there was no quick
method of measuring total residual
halogens (HOBr, HOCI, NH2C1, and
NHBr2) down to parts per billion lev-
els, and operators of power plants said
that a standard of 50 ppb residual
halogen would be unrealistic because
we -couldn'tmeasure it. At the con-
ference, • James Carpenter, now with
the Nuclear Regulatory Commission,
reported a simple fluorometric method
, that quickly measures total halogens
with an accuracy of ± 0.1 ppb and
distinguishes the different species by
adjusting the pH. Harvey Sellner of
the EPCO Company (Danbury,
Conn.) described an amperometric
technique of continuously monitoring
total residual chlorine at levels in the
region below 1 ppb.
The chemistry of chlorination
The reactions of chlorine with or-
ganic materials in natural waters are
extremely complex. In general, organic
materials in natural waters (loosely
referred to as humic substances) and
other organic materials derived from
natural sources are responsible for
most of the observed reactions of
chlorine with surface waters. Roger
Bean of Battelle, Pacific Northwest
Laboratories cleared up some of the
confusion about chlorine chemistry by
presenting a table called Low Level
Chlorination of Natural Waters (see
box).
Before the conference, it was
] iabacetonitrile ' -
p=:v ;formation - ,= ;
t `Formation of -'{, 74 -
onfiatoform:. : �� '
;�orgariichalogens'vz- v T:- :.--;1
thane ��i : � �
.7-::::'....,
.i. Cfs z`
E i-lalogenated phenol►'' +Vp
-#ormation ',,,
Low level chlorinati o
natural waters (wheredoes =:
::::''..***the 'chlorine
.• Process
_Haloform .formation 0:5-5"sed
.Organic oxidation to
— •
>�50=80
i1
-depotymerized
r Other react!
A rough estunatepl abeirrcer40t -used by each trievfloactio
,~
thought that approximately 80% of the
chlorine was used to oxidize organic
matter to CO2. However, George Helz
of Stanford University reported ex-
periments that suggest the figure is
closer to 50%. He postulated that at-
tack at certain labile amino acids in the
peptide chains initiated a series of re-
-actions resulting in CO2 production.
Another reaction that requires a weak
link in the peptide chain is the forma-
tion of haloacetonitriles, reported by
Theodore Bieber of Florida Atlantic
University (Boca Raton, La.). •
In the past, several scientists sug-
gested that phenolic components in
humic materials are the primary
• sources of halofdrms from water
chlorination. At this conference, Scott
Boyce of the California Institute of
Technology reported work with res-
orcinol, a 13C-labeled phenolic com-
pound, showing that the aromatic
carbon atom between two meta-hy-
droxy groups is the one incorporated
into the haloform product: Barry Ol-
iver (Canada Centre for Inland Wa-
ters) reported that the amount of
THMs produced from humic sub-
stances can be correlated with in-
creasing color if the primary THM
producers in' a water sample are
humics.
Bean reported that .his own work
suggested that phenols are important
substrates in water chlorination reac-
tions. He found more than 30 different
halogenated phenols produced by the
low level chlorination of power plant
cooling waters.
Jolley presented work showing that
bromochloramines should be included
along with monochloramine, dibro-
mamine, and tribromoamine as im-
portant haloamines in chlorinated
seawater.
Donald Johnson and coworkers of
the University of North Carolina
chlorinated natural aquatic humic
material and analyzed the products.
They found that except for chloroform
and choral, all chlorinated components
were carboxylic acids. Also, the ma-
jority of the components contained
chlorine; no chlorinated aromatics
were present. The experiment revealed
a great deal but did not tell how the
total amount of other chlorinated or-
ganics relates to the amount of chlo-
roform nor whether any of them are
present in actual drinking. water.
Johnson said that "if it is shown that
trihalomethanes are not the most
abundant chloro derivatives of aquatic
humic material which occur ubiqui-
. tously, then health effects data on
compounds such as di- and trichloro-
acetic acid will be needed in order to
•
risks from the consumption of chlori-
nated water."
Although the reactions of chlorine
are complex, Bean speculated "it is
possible that only one or two key re-
actions with a few key structural
components will be required to explain
the initiation of the reaction sequences
involved." Obviously much work re-
- mains to be done in this area before
even the most important reactions of
chlorine in natural environments can
be reasonably understood. -
Aquatic ecosystems
Because the discharge of chlorine
into surface waters and the ocean
damages aquatic organisms, -some
areas of the U.S. are seriously consid-
ering banning wastewater chlorination.
The EPA is now working on chlorine
water quality criteria for the protection
of aquatic life. It is anticipated that
draft chlorine criteria will be com-
pleted early-tbis year. Presently, many
regulators and environmental man-
agers feel sufficient research has been
completed to identify the hazards of
chlorination for aquatic life.
This chlorination conference, how-
ever, highlighted the fact that a great
deal is still unknown. Richard Vand-
erhorst of Battelle, Pacific Northwest
Laboratories performed a study that
examined the effects of low level
chlorination on open microcosms in
Puget Sound, Washington. He found
statistically significant differences in
the rates of growth; however, the
• meaning of these findings is question-
able because the "systems were dearly
in agrowth phase and had not reached
steady state at the experiment's con-
clusion?'
David Anderson of Envirotest
(Redmond, Wash.) presented infor-
mation to show that the interaction of
chlorination with nickel resulted in
increased accumulation of nickel in
rainbow trout. His data show how
important it is to evaluate the inter-
action of chlorination with other
chemicals known to have environ-
mental effects.
An overview of the effects of chlo-
rine -produced oxidants and THMs on
marine invertebrates was presented by
Geoffrey Scott of Research Planning
Institute (Meggett, S.C.). The mate-
rials he reviewed showed that many of
the effects are irreversible and that the
juvenile stages of the organisms are
more sensitive than the adult stages.
Scott also presented information on the
bioconcentration of bromoform in
American oysters.
Fava and Davis said.that the "inte-
gration of marine biological research
with identified technical needs could
be one of the true progressive steps to
achieve the benefits of chlorination
while at -the same time helping to pro-
tect sensitive environmental systems."
An example is using marine organisms
such as oysters to monitor for human
pathogens in the effluent from waste
treatment plants. Many investigators
said that additional field experiments
concerning the effects of chlorine on
aquatic life are needed to confirm what
has been learned in the laboratory.
Fava and Davis pointed out the need
for additional research when they said:
"As the use of chlorine continues to
grow, so does the potential for aquatic
-.effects. Ignoring the problem is not the
proper response front an intelligent
society. Instead,'we need to be pre-
pared to make educated technical de-
cisions based on experimentally proven 1
facts —not on ignorance and unproven
assumptions."
The proceedings of the conference
will be published this year by Ann
Arbor Science (Mich.). The ' next f
chlorination conference is scheduled
for October 1983 in the Maryland -
Virginia area. •
--Bette Hileman
ATTACHMENT 2
KINSTON PLANT BACTERIA ANALYSIS
OF THE MEUSE RIVER (COLONIES/100 ML)
MAY JUNE JULY AUG. SEPT.
• 1980
- Upstream 1300 1100 700 500 850
- Downstream 1050 1000 600 550. 1050
• 1981
- Upstream
- Downstream
• 1982
- Upstream
- Downstream
/1s
Misc.II12:5
300 1000 700 90b 1350
450 1200 800 800 1250
200 100 1150 350 200
400 150 1250 250 200
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 22, 1983
MEMORANDUM
TO: Forrest Westall, Head
Operations Branch
FROM: Randy Williams
Technical Services
THRU: Steve Tedder
Zit)1
SUBJECT: Disinfection Requirements
DuPont - Kinston Plant
Mr. E. L. Long of DuPont has requested that the company be allowed
to discontinue the chlorination of its wastewater. This request was made
on the basis that the "Kinston Plant tradewaste facility effluent does not
require chlorination to protect public health" (see letter to Lee Fleming
dated January 5, 1983) since there are no drinking water intakes or public
beaches located downstream of this discharge. Further, only 5% of the
feed to the facility is of domestic origin. Thus, low counts of fecal
coliform bacteria should be present in the plant's effluent even without
chlorination.
Kinston's Northside WWTP is located 4.5 miles below the city's
Peachtree Plant and 6 miles upstream from DuPont. Contentnea MSD is
located on Contentnea Creek 2.5 miles above the mouth of the creek, which
is 5 miles below DuPont. Presently, only Kinston Peachtree is not
required to disinfect its wastewaters, based on an analysis of fecal
coliform data supplied by its consultant, L. E. Wooten, and recent self -
monitoring data. The other three plants are required to meet an
effluent limit of 1000/100 ml.
The most recent data available on a yearly basis for both the
Kinston Peachtree and Northside Plants is that from 1981. From Table 1,
the'average upstream fecal coliform value was 243/100 ml for that year
while the average value downstream of the Peachtree Plant was 330/100 ml.
This station corresponds to the upstream station for Northside. The average
value of fecal coliform below the Northside Plant was 465/100 ml. From
this data, it can be seen that the treatment plants exert little influence
on the values of fecal coliform in the river. In fact, fecal coliform
increases by over 25% between the stations above and below Northside,
even though the plant was providing disinfection.
•
r
Forrest Westall
March 22, 1983
- page two -
Recently, Kinston Peachtree's disinfection requirements were rescinded
on the basis of the plant's past performance with respect to fecal coliform.
At 7Q10 river flow, it was determined that an effluent concentration of
20,000/100 ml would protect the standard if the mix time was instantaneous.
If the mix time was 6 hours, 50,000/100 ml would protect the standard.
Modeling shows that these values would also protect the river below North -
side and DuPont if applied to those discharges. According to E. L. bong,
5% of DuPont's wastewater is domestic. Assuming a typical undisinfected
wastewater concentration of 400,000/100 ml, a final effluent concentration
of 20,000/100 ml could be expected. Thus, it appears that non o± the
discharges needs disinfection as long as these values can be maintained
in the effluents.
In summary, the fecal coliform levels in the Neuse near Kinston
appears to be a function of upstream conditions. Treatment plants, as
they are presently operated, exert little influence on these levels. If
disinfection were tc be discontinued at those plants discharging directly
to the river, little change in in -stream levels is expected, as long as
50,000/100 ml effluent limits are maintained.
Let me know if you have any questions.
RW:cs
Attachment
Table 1
Peachtree Northside
1981 Upstream Effluent Downstream = Upstream Effluent Downstream
Jan 318 30000 438 438 <10 650
Feb 78 24000 139 114 <10 0 .145
Mar 280 10000 628 628 <10 1319
.
Apr 250 5000 190 190 <10 260
May 138 2000 193 193 <10 175
June 150 3000 140 162 <10 225
July ND ND ND:: 203 <10 180
Aug 100 4600 150 181 <10 185
Sept 173 .100 240 5114 <10 318
Oct 700 3000 850 825 <10 1188
Average 243 9200 330 345 <10 465
JN�SEOST .
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
J A N 3 1983
REF: 4WM-FP
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
Randy Williams
Environmental Engineer
NC Department of Natural Resources
& Community Development
Division of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Williams:
Enclosed are five runs of EPA's DOM model of the Kinston/Neuse River system.
Run 1 is a simulation of background conditions only with instream rates set as
in the DEM allocation run. Run 2 is a simulation of background conditions
with the same instream rates as in Run 1 except the reaeration rate was set at
twice the temperature corrected deoxygeration rate. Conditions in Run 3 were
set to be identical as in the DEM allocation run except the reaeration rate
was determined as in Run 2.
Conditions in Runs 4 and 5 were modified according to the State/EPA agreement
concerning wasteload allocations. Reaeration rates were adjusted to equal
twice the temperature corrected deoxygeration rates, and BOD inputs for
dischargers were split into NBOD and CBOD. Background conditions were
unchanged. The existing permit limitations for Dupont were used. After these
changes were made, allocations for the Peachtree, Northside, and Contentnea
Creek facilities were run.
Please rail me at (404) 881-2156 if you have questions about the model
outputs. Also, as we discussed on December 13, 1982 it may be fruitful to
review the water quality data available for stations upstream of the northside
discharge.
Sincerely yours,
ritz Wagener
Environmental Engineer
North Unit/Permits Section
Facilities Performance Branch
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