NC0072575_Staff Comments_19930125

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DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section/Rapid Assessment Group
January 25, 1993
MEMORANDUM
TO: Greg Nizich
THROUGH: Carla Sanderson&
FROM: Dave Goodrich�v\
SUBJECT: Comments on Requested Modification for Golden Poultry W WTP
NPDES Permit No. NCO072575
Lee County
030611
This is in response to your request for cmmments on the requested modifications
for the NPDES permit held by Golden Poultry (Gold Kist Inc.). In a letter to Don Safrit
(dated September 25, 1992) Mr. Steven R. Woodruff requests three changes upon
reissuance of this NPDES permit:
1. Chlorination of the effluent should be discontinued.
2. The limit for fecal coliform should be elirr-nated.
3. Calculations of mass loadings should ' e based on the amount of flow produced
from the facility (i.e. sprayed to the overland flow system) during periods of rain instead of
total flow discharged from the outfall.
As I discussed with Mr. Woodruff by telephone (12/92), the fecal coliform limit
must be kept in the permit since the discharge emanating from this facility still has potential
to impact levels of bacteria in the Deep River. I explained that a dilution factor of >331:1 is
required in order to eliminate the requirement for fecal coliform as an effluent limit. The
dilution at this site for the pemtitted discharge under low -flow (S7Q10) is only 11:1.
Chlorination could only be discontinued at this facility if an alternate means of disinfection
was provided after first obtaining an Authorization to Construct permit from your branch.
Additional information was collected in a field trip to the facility by you, Charles
Alvarez, Steve Bevington, and me on January 13, 1993. Upon initial review, the request
to calculate mass loadings using only the amount of flow discharged to the spray fields

ea.
seems reasonable since DEM would not want to penalize a facility for failing to meet limits
caused by "natural sources" of pollution. However, a
when such violations were actually
site visit was made to answer two questions. First, were Melds which were not currently
being used in the wastewater treatment process representative of natural sources? Also, did
the system encourage runoff to the point of abnormally increasing the flushing -of pollutants
off the fields which were not being sprayed?
Mr. Woodruff and Mr. Bruce Morgan, Plant Engineer, accompanied us to several
different spray fields both active and inactive which all showed signs of increased BOD in
the forms of animal feces, dying or dead cover crop, and mats of live and dead algae.
Other than the animal feces, these indicators lead me to believe that even a field which was
temporarily not in the rotation of spray fields may add oxygen -consuming wastes as a
result of previous spraying episodes. Furthermore, it was obvious that the entire system
was designed to facilitate runoff from the fields at high rates. Canals which channeled
water from the fields were flowing approximately one foot per second and totalled about
one million gallons per day according to the flow meter at the outfall.
In short, it is the recommendation of Technical Support that the request for the
modified calculation method be denied given. thatthis system was constructed in such a
way that it is designed to cause larger amounts of runoff than would occur if the fields were
otherwise undisturbed, and this runoff washes pollutants from fields which have been
loaded with pollutants by the wastewater generated from the plant even in fields that are not
currently being used in the application. of wastewater. If you have questions, please contact
me.
cc: Tun Donnelly