NC0072575_Staff Comments_19880308

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 8, 1988
MEMORANDUM %
TO: Arthur Mouberr /
THROUGH: Steve 'Cedder I {
FROM: Trevor Clements'+ `(_
ll i
SUBJECT: Letter from Mr. John Starkey regarding proposed
Golden Poultry NPDES Permit No. NCO072575
Lee County
Per your request, I have reviewed the letter from Mr. Starkey which
comments on the proposed NPDES Permit (NCO072575) for Golden Poultry. I am
prepared to comment on items 2, 4 and 5.
2. CBOD to BODs ratio
Mr. Starkey is correct in stating that DEM can consider an alternative
CBOD/BODS ratio to the default ratio of 3.0 used in the development of their
wasteload allocation, provided ample evidence for the alternative ratio is
provided. Although Goldkist is screening other poultry facilities for this
information, I recommend that no change be made until data can be collected
from this system. Given that the treatment system consists of overland
runoff, the ratio is likely to be affected by the idiosyncrasies of its
design (e.g. soil type, etc.). Following testing of their actual effluent,
we will be glad to re-evaluate their ratio.
4. Stream Monitoring Requirements
Instream monitoring requirements should be kept intact for the time
being. After 12 months of data have been collected, Technical Support will
re-evaluate the need for this data upon request from the permittee.
5. Trading off CBOD for NBOD
Mr. Starkey is correct in his expectation that an equivalent trade-off
between CBOD and NBOD can be accommodated through a permit modification.
The exact values can be determined through appropriate modeling analyses
upon request.
Please let me know if I can be of further assistance in this manner.
TC:gh
cc: Dale Overcash
Central Files

As
flohl RMI iRe'.. 244 Perimeter Center Parkway, N.E./P.O. Box 2210 Atlanta, Ga. 30301
February 229 1988
Mr. R. Paul Wilms, Director
Division of Environmental Management
North Carolina Environmental Management
Commission
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Wilms:
Re: Proposed NPDES Permit
Golden Poultry
Sanford, NC
This letter is to file comments on certain conditions of the
referenced permit, as well as methodologies employed to determine
permit conditions. We would like to review the following six
areas:
1. Wastewater treatment plant classification
2. CBOD/BOD ratio for treated poultry wastewater
3. Impact of rainfall on discharge flow
4. Stream monitoring requirements
5. Ratio of carbonaceous to nitrogenous oxygen demand
6. Chronic toxicity testing
Each of these items is discussed sequentially below:
1. Wastewater Treatment Plant Classification
The monitoring frequency indicated in the permit indicates
the plant has been classified as a Class III plant. Please
inform us of the process by which this classification was
made.
The land treatment process we have chosen is a simple, yet
efficient wastewater treatment system. It is neither equip-
ment oriented nor energy intensive. It is a very stable
treatment process not subject to frequent upsets. Granted,
meeting the proposed permit limits by any other means would
require a fairly sophisticated advanced wastewater treatment
system. However, given the relative simplicity of our pro-
posed system and our review of NCDEM's rating checklist, we
feel the system should be rated as Class II. Therefore, we
request consideration be given to changing this to a Class II
facility.

Mr. R. Paul Wilms
February 22, 1988
Page 2
2. CBOD/BOD5 ratio for treated poultry wastewater
The draft Level B Desktop Modeling Procedure developed by
NCDEM dated September 1987 states that "In the absence of
wastewater specific CBOD/HODS data..." a ratio of 3.0 can be
used for pure industrial wastewater. Chicken processing, by
the very nature of the industry, produces a readily
degradable food source for bacteria. There is no significant
presence of refractory compounds or petroleum oils that would
be difficult for a biological treatment system to break down.
Consequently, we would anticipate the ratio to be closer to
1.5 to 2.0. Obviously, such a ratio would significantly
alter the proposed BOD5 limits.
We are currently in the process of analyzing effluents from
two poultry plants and determining the actual CBOD/BOD5
ratio. These tests are being carried out in accordance with
NCDEM's methodology for determining the ratio.
In the event a lower ratio is confirmed with our submission
of the data, Golden would expect higher BOD5 levels to be
permitted. Golden would be willing to incorporate into its
monitoring schedule, on a quarterly or monthly basis,
performing the ultimate BOD test to insure conformance with
the lower ratio.
3• Impact of rainfall on discharge flow
In the overland flow system, precipitation falling on the
terraces will be collected and discharged through the outfall.
In order to prevent these events from skewing discharge flow
from the facility, Golden proposes to measure rainfall, apply
a runoff coefficient of 0.75 (for pastureland, Agricultural
Engineers Handbook, 1961) and subtract the quantity of rain-
fall from the recorded discharge flow.
4. Stream Monitoring Requirements
The proposed facility will be analyzing its effluent prior to
discharge for fecal coliform on a regular basis. As long as
we meet the proposed permit limits, we should not have any
significant impact on in -stream coliform counts. These in -
stream counts, we would anticipate, would be highly erratic
due to occurrence and conditions unrelated to the proposed
discharge. Consequently, we request the upstream and down-
stream monitoring for fecal coliform be deleted from the
permit.

Mr. R. Paul Wilms
February 22, 1988
Page 3
Also, we request stream monitoring for conductance be deleted
from permit monitoring requirements. Conductance is not
normally a required monitoring parameter for treated poultry
wastewater, and we question whether stream monitoring of
conductance will yield any useful information.
5. Ratio of Carbonaceous and Nitrogenous Oxygen
Based on our discussions with NCDEM personnel, the proposed
BOD5 and ammonia limits are a reflection of the total oxygen
demand being allocated for this facility. It is also our
understanding that adjustment of one parameter at the expense
of the other is allowable if the total oxygen demand allo-
cated is not exceeded. For example, if the facility easily
meets its BOD5 limits, but encounters difficulty in meeting
ammonia limits, we could modify the permit for a lower BOD5
limit and higher ammonia limit, as long as the allotted total
oxygen demand is not exceeded. If this is not correct,
please let us know.
6. Chronic Toxicity Testing
The draft permit states that the first toxicity test will be
conducted within one month of permit issuance. We request
this be modified to within one month of plant start-up.
To address the above issues, we request a meeting with appropri-
ate NCDEM personnel. We will be contacting the permitting office
shortly to arrange this meeting. In the meantime, if you have
any questions or comments, please call.
Sincerely,
9 "_L �' 5 L-- P-)"
John E. Starkey, Mana er
Environmental Engineering
[phone]
JESser
cc: Mr. Glenn Berry
Mr. James Brown
Mr. Don -Deemer
Mr. Arthur Mouberry
Mr*:.. --Dale..- Overcash