NC0024881_Staff Comments_20020606

Re: [Fwd: [Fwd: Envision Plastics]]
Subject: Re: [Fwd: [Fwd: Envision Plastics]]
Date: Thu, 06 Jun 2002 11:25:27 -0400
From: Coleen Sullins <[e-mail]>
Organization: NC DENR DWQ
To: Alan Klimek <[e-mail]>
CC: Susan A Wilson <[e-mail]>
Alan - that is the information that you needed on this one. Let us know if you
need more detail. Coleen
Alan Klimek wrote:
> per my voicemail
> ------------------------------------------------------------------------
> Subject: [Fwd: Envision Plastics]
> Date: Thu, 06 Jun 2002 08:16:04 -0400
> From: Kent Wiggins <[e-mail]>
> Organization: N.C. Dept. of Environment and Natural Resources
> To: Alan Klimek <[e-mail]>
> More info on Envision.
>----------------- -------------------------------------------------------
> Subject: Re: Envision Plastics
> Date: Wed, 05 Jun 2002 18:41:58 -0400
> From: Dana Polley <[e-mail]>
> To: Kent Wiggins <[e-mail]>, Tom Poe <[e-mail]>
> References: <[e-mail]>
> Just to clarify one small fact - the Town has already relocated to the Haw
> River, and so now their NPDES limit is 0.000019 mg/l. We would allow
> Reidsville to raise Envision's limit to this or possibly other even higher
> values, but even these higher values still wouldn't be enough to get the
> limit to above detection unless the uncontrollable were dealt with.
> After Kent left, I ran some "other possibly even higher numbers" just for
> the sake of argument. if the Town reduced their uncontrollable to zero, and
> limited all other SIUs to zero, and gave Envisions the Town's entire
> allowable load, then the highest limit they could give to Envisions would be
> about 0.0015 mg/l or 1.5 ug/l. In other words, even then Envisions would
> still have to operate their pretreatment unit to meet the limit, but it
> would probably get rid of most of their current 10-15% violations.
> If the town were to do a treatability study to demonstrate their WWTP could
> remove significantly better than the literature removal rate of 60%, that
> would create even more allowable load. But the Town would have to
> demonstrate greater than 90!& removal to give Envisions 7.5 ug/l. Greater
> than 959 would get Envisions 13 ug/l. If Envisions did some serious source
> control, they maybe could avoid pretreatment.
> Kent Wiggins wrote:
> > I talked to Dana Polley in pretreatment. She knew them well. They are
> > an indirect discharger to Reidsville. They have a tight limit because
> > Reidsville discharges to a small creek, moving to the Haw River soon
> > though. The current limit for Reidsville is the same as the Water
> > Quality Standard-0.000012 mg1l and that is the limit Reidsville has
> > given to Envision. Current detection levels only go down to 0.0002 mg
l of 2 6/6/02 11:32 AM

Re: [Fwd: [Fwd: Envision Plastics]]
> > so as long as they are below detection they are considered to be
> > compliance. EPA is soon to require a more sensitive method which will
> > probably pick up many of the "less than values" Envision now reports and
> > show them in noncompliance.
> > They are having to pretreat and that is probably where their
> > $20,000/month is going to. That and the extra sampling they are having
> > to do.
> > In California, they probably have the same standard, but Envision may
> > discharge to a treatment system with a better instream waste
> > concentration or to a City that has done a better job of handling their
> > "uncontrollable mercury"(household, dentist office, etc.). If the towns
> > handle the uncontrollable portion, they would have more to allocate to
> > the industries.
> > Envision is compliant for approx 85$ of the time with the current
> > detection limit and Reidsville has not had a NPDES violation since 8/00.
> > Dana will be out on Thursday, but if you need more please contact Tom
> > Poe or myself
> Dana Rees Polley
> Environmental Chemist II
> Division of Water Quality
> Water Quality Section
> Pretreatment Unit
> 1617 MAIL SERVICE CENTER
> RALEIGH, NC 27699-1617
> telephone: [phone] x523
> facsimile: [phone]
> http://h2o.enr.state.nc.us/Pretreatlindex.html
2 of 2 6/6/02 11:32 AM

Re: Envision Plastics
Subject: Re: Envision Plastics
Date: Wed, 05 Jun 2002 20:18:29 -0400
From: Tom Poe <[e-mail]>
Organization: NC,DENR,DWQ, Pretreatment
To: Kent Wiggins <Kent.Wiggins @ ncmail.net>
CC: Alan Klimek <[e-mail]>, Dana Folley <[e-mail]>,
Bill Reid <[e-mail]>
I will be on the road giving a presentation to the Western Piedmont WW
Operators in Statesville all day Thrusday.
Dana Folley is knowledgable, and familiar with the industry, the City, the
history, the discharge into the headwaters of the Haw,
Mercury is and will be a pollutant that generates a lot of "concern" at many
POTWs as we move to the more sensitive method EPA 1631. etc.
2 will be back in the office on Friday.
Kent Wiggins wrote:
> I talked to Dana Folley in pretreatment. She knew them well. They are
> an indirect discharger to Reidsville. They have a tight limit because
> Reidsville discharges to a small creek, moving to the Haw River soon
> though. The current limit for Reidsville is the same as the Water
> Quality Standard-0.000012 mg/1 and that is the limit Reidsville has
> given to Envision. Current detection levels only go down to 0.0002 mg
> so as long as they are below detection they are considered to be
> compliance. EPA is soon to require a more sensitive method which will
> probably pick up many of the "less than values" Envision now reports and
> show them in noncompliance.
> They are having to pretreat and that is probably where their
> $20,000/month is going to. That and the extra sampling they are having
> to do.
> In California, they probably have the same standard, but Envision may
> discharge to a treatment system with a better instream waste
> concentration or to a City that has done a better job of handling their
> "uncontrollable mercury"(household, dentist office, etc.). If the towns
> handle the uncontrollable portion, they would have more to allocate to
> the industries.
> Envision is compliant for approx 85-W of the time with the current
> detection limit and Reidsville has not had a NPDES violation since 8/00.
> Dana will be out on Thursday, but if you need more please contact Tom
> Poe or myself
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