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HomeMy WebLinkAboutNC0066516_Staff Comments_19960730North Carolina Division of Environmental Management Water Quality Section / Rapid Assessment Group July 30, 1996 MEMORANDUM To: Greg Nizich From: Farrell Keo Through: Carla Sanderson Ruth Swanek l Subject: Instream Monitoring Location for Upstream Site Town of Fuquay-Varina / Terrible Creek WWTP, NC0066516 Wake County The Instream Assessment Unit has reviewed the letter from the Town of Fuquay-Varina's consulting engineer dated July 12, 1996, regarding relocation of the upstream monitoring location. We have no objections to this request and will concur with a change in the instream monitoring location to 100 feet above the discharge. DIVISION OF WATER QUALITY RALEIGH REGIONAL OFFICE July 29, 1996 M E M O R A N D U M TO Greg Nizich, Water Quality Permits and Eng. Through Judy Garrett, Water Quality Regional Supervisor FROM Randy Jones, Raleigh Regional Office SUBJECT Permit No. NC0066516' Town of Fuquay-Varina Terrible Creek WWTF Wake County The RRO has received a copy of the letter to you, dated July 12, 1996, from John Phillips with Diehl & Phillips. . This letter requests that two issues be clarified with regard to the NPDES permit for the subject facility. Those issues pertain to the requirement in the permit for monitoring and reporting total residual chlorine and the location of the upstream sampling point. I have also had conversations with John Phillips regarding the classification of the WWTF. This memorandum is intended to serve as the WQ RRO comments on these three issues. The first question concerns the requirement for total residual chlorine monitoring and reporting. Since the WWTF will have UV disinfection and is not intended to use chlorine, the WQ RRO recommends that this requirement be deleted from the permit, or that the permit be modified to state that sampling is required only if chlorine is used. The second question deals with the upstream sampling location. According to John Phillips' previous conversation with you, the upstream sampling location, which is identified in the permit as "Upstream at dam spillway", is located over 8400 feet upstream of the discharge point. John Phillips states that at this location the operator will either have to enter private property to collect the sample or will have to bail a sample from a narrow bridge. Mr. Phillips also has expressed concern that the DO levels at this point would not be representative of the DO levels 100 feet upstream of the discharge point. The WQ RRO does not object to modifying the permit to specify an upstream monitoring location fifty or one hundred feet upstream of the discharge point. r Terrible Creek Memorandum July 29, 1996 Page 2 The final point deals with the classification of the WWTF. At the time that the'RRO reviewed the A to C for the subject facility, it included a rating sheet with the staff report that indicated that the facility was a class IV facility. John Phillips has reviewed this situation and submitted a new rating sheet to the RRO which indicates that the facily is a class III WWTF. Upon review of this matter, it appears that the facility should be a. class III facility; therefore, I have included a revised rating sheet for this facility. In view of these circumstances, the RRO requests that you initiate the actions that are necessary to reissue the permit with the monitoring frequencies required for a Class III facility. I am sending a similar memorandum to Ron Ferrell in Water Quality Training and Certification pertaining to the,Water Pollution Control System Operators Certification Commission. If you have any questions, feel free to contact me at 571-4700. Attachment cc: Ron Ferrell,,WQ Training and Certification Kent Penny, Wake County Health Department file: FUQUAY.ME y Gouc-D tr() FIhvc- _GGc APAoNliAiE 'FIC-Aso/i DIEHL & PHILLIPS, P.A. c 2" CONSULTING ENGINEERS Telephone (919) 467-9972 Fax (919) 467-5327 July 12, 1996 WILLIAM C. DIEHL, P.E. JoHN F. PHa Lips, P.E. 219 East Chatham Street, Cary, North Carolina 27511 Mr. Greg Nizich Permits and Engineering Division of Environmental Management NC Dept Environment, Health and Natural Resources P.O. Box 29535 Raleigh, NC 27626-0535 Re: NPDES Permit No. NCO066516 Terrible Creek WWTP Town of Fuquay-Varina Dear Mr. Nizich: The Town of Fuquay-Varina has requested that we contact you to clarify two items in the referenced NPDES permit. 1. Total Residual Chlorine: The first phase of the treatment plant has been constructed, and the plant uses an ultra -violet disinfection system. There are no chlorine feed facilities constructed, and the Town will not be adding chlorine. Therefore, the Town requests permission to not sample, test, or report total residual chlorine as required by the current permit. 2. Upstream Sampling Point: The permit lists the upstream sampling location as "Upstream at dam spillway". Because I was not aware of any dam in the vicinity of the treatment plant, I called you for an explanation. You indicated the referenced dam was at Johnson's Pond, which is over 8,400 feet upstream of the discharge point (as opposed to 50 feet in the Town's other permit for the Kenneth Creek WWTP, and the 100 foot distance that is typically in most NPDES permits). Our concerns are 1.) that the indicated sampling location is not. convenient or safely accessible, and 2.) the sample results may not be indicative of the true upstream water quality within 100 feet of the discharge. The dam is adjacent to Johnson Pond Road, which is a two lane secondary road .carried over the stream by a relatively narrow bridge. To sample the stream at that location will require the operator to either leave the road right-of-way and enter private property, or he will have to attempt to bail a sample from the narrow bridge. The second concern is that the dissolved oxygen levels at this point may be high if the spillway is flowing water or low when there is no overflow, and neither condition would be m Mr. Greg Nizich July 12, 1996 Page 2 representative of the dissolved oxygen levels 100 feet upstream of the discharge point. Future modeling of the discharge may be skewed if the dissolved oxygen levels at the spillway are used as background levels in the model. The Town requests they be allowed to sample at a point 100 feet upstream of the discharge point, which would be on their property. Please advise if this is acceptable, and if it can be documented by a letter of agreement until the permit is renewed, or if a permit modification must be requested. The Town does not believe it is reasonable for them to bear the financial and manpower burden of sampling at such a remote location when it is not a procedure normally required of other NPDES permittees. I appreciate your help in this matter. Please call if I can provide any additional information. CC: Mr. Tom Fowler Mr. L.W. Bennett, Jr. Yours very truly, Diehl & Phillips, P.A. P- 4. fxw--; John F. Phillips, P.E.