NC0064246_Staff Comments_19940406

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 6, 1994
Memorandum
To: Jay Lucas
From: Carla Sanderson
Subject: Pace Mobile Home Park
NPDES Permit No NCO064246
Johnston County
This memo is in response to the letter send February 21, 1994 from Mr. Jerry Pace
concerning the Draft permit for the Mobile Home Park. I will address the request to drop
instream monitoring. The instream monitoring parameters requested by the Instream
Assessment Unit were in accordance with normal requirements for facilities discharging
domestic wastewater and permitted with water quality limits. The Pace Mobile Home Park
has received water quality limits for BOD5, NH3N, DO and Fecal Coliform. Instream
monitoring is required for DO and Fecal Coliform. Additional monitoring of Temperature
and Conductivity are required for which we do not have limit in the permit. Instream
temperature monitoring is necessary since dissolved oxygen and temperature are directly
related. Instream conductivity monitoring is necessary since the downstream measures of
conductivity can be related back to the measure of the conductivity upstream of the
discharge and in the effluent. In other words, the measure of conductivity can be used as
an indicator of wasteflow.
In addition to the reasons stated above, the Pace Mobile Home Park discharges to a zero
flow stream where impacts of wastewater are more greatly noticed. This facility has been
violation ammonia (which is oxygen consuming) and the fecal coliform standard in the
effluent. These violations could be causing a direct impact to the system and therefore
recording of the effects should be noted.
The second question in the letter is regarding the sampling frequencies for BOD5, TSS,
NH3N and Fecal Coliform. If these frequencies changed from the old permit, then I
assume it was due to the new 2B.0500 Regs. or the facility class changed from class I to
class 11.
Overall I do not recommend dropping any instream requirements and I concur with the
required effluent monitorimg frequencies as the 213.0500 regulation requires.
cc: Central Files

MEMORANDUM
North Carolina Division of Environmental Management
Water Quality Section, Permits and Engineering Unit
TO: Carla Sander on
FROM: Jay Lucas //�j
SUBJECT: Pace MobIl Acres NCO064246
DATE: March 1, 1994
Please comment on this request and call me if you have any questions.
0�\

i
Dave Goodrich
NC DEM, Water Quality Section
PO Box 27687
Raleigh, NC 27611-7687
RE: Draft Permit No. NC0064246
Dear Mr. Goodwich:
Jerry G. Pace
Pace Mobil Acres
13356 Buffalo Rd.
Clayton, NC 27520
21 February 1994
As a follow-up to my letter of 11 February 1994, I am writing again to express my
concerns over the monitoring requirements listed in draft Permit No. NC0064246.
Specifically, I would like a written response to the following:
1. Remove all Upstream and Downstream Monitoring Requirements -
The draft permit contains upstream and downstream monitoring
requirements for,four parameters with no enforceable limits. There-
fore, these monitoring requirements are an unnecessary burden
to my operating costs.
2. Reduce Sampling Frequency for BOD, TSR, NH3 and F. Coliform -
The draft permit increases the sampling frequency of the above para-
meters from my current requirement of'twice per month to once per
week. I have yet to receive any, documentation from your office as to
the scientific and regulatory reasoning supporting this increase.
Your immediate attention to this serious matter is much appreciated, for the costs
associated with these proposed monitoring requirements will result in a 350+ % increase
over my 1993 monitoring costs. As you can understand, an increase in operating costs of
this magnitude threatens the existence of Pace Mobil Acres and the homes of 45 lower
income families.
Sincerely,
Jerry G. Pace, Sr.