NC0020451_Wasteload Allocation_19940630

m
DIVISION OF ENVIRONMENT MANAGEMENT
June 30, 1994
TO: Charles Alvarez
THRU: Ruth Swanek2i�5
Carla Sanderson Ce
FROM: Jacquelyn M. Nowell !'�V
1�J
SUBJECT: Request for modification of effluent limits for West Jefferson WWTP
NPDES Permit No. NCO020451
Ashe County
The Instream Assessment Unit has reviewed the subject facility's request for
deletion of effluent limitations for metals to effluent monitoring only. West Jefferson
indicates that their plant's compliance with the "restrictive" limits is unlikely. The draft
permit has the following limits recommended for metals:
Cyanide =l Igg/l Cadmium = 0.8 µg/l
Chromium = 102 µg/l Nickel = 180 µg/1
Lead = 51 µg/l Mercury = 0.025 µg/l
The limits were developed using the mass balance equation, where the design wasteflow
and the 7Q10 flow of the receiving stream are used to calculate the allowable discharge
concentration of the industrial constituents, based on the guidelines in North Carolina
Regulation 15A NCAC 2B .0206 (a). Accordingly, "water quality based effluent
limitations are developed ...so that the designated uses of receiving waters are protected."
A reevaluation of the effluent data through a revised toxicity analysis was completed
to determine if changes to the limits was warranted. Based on self monitoring data
collected in 1993 and 1994, it was determined that effluent limits for cadmium. mercury
and nickel should be retained. The Division can offer West Jefferson the option of limits
permitted in 1) daily maximum limits only or 2) weekly averages and higher daily
maximum limits. The daily maximum limit should be established to provide protection
from acute toxic effects.
Compliance with the weekly average limit is determined by the average of the daily
samples for that week. For the purposes of this calculation, samples listed at less than
analytical detection will be assumed to be zero. The permittee may choose to collect 5
samples for the week and base the number of analyses run on the outcome of the first
sample. If the fast sample is in compliance with the weekly average limit, then no more
analyses need be run for that week. However, if the first sample is above the weekly
average, then more samples should be analyzed and the permittee must comply with both
the weekly average and daily maximum limits. The limits options offered are as follows:

Memo to Charles Alvaraz
- page 2 -
Option 1
Daily Maximum
Cadmium = 0.8 µg/1
Mercury = 0.025 µg/l
Nickel = 180 µg/l
Option 2
Weekly Avg,
Cadmium 0.8 µg/1
Mercury 0.025 µg/l
Nickel 180 µg/l
Daily Maximum
3 µg/l
0.1 µg/1
720 µg/1
The data show several readings for cadmium and mercury below detection level, and the
Town should be aware that data values reported as below detection will be considered in
compliance with the NPDES pernut limit.
On the other hand, the data indicate that limits for cyanide, chromium and lead can
be deleted from the NPDES permit. These parameters will be monitored quarterly in the
long term monitoring plan per the pretreatment program
Regarding the Town's request for reevaluation of the C Trout classification for the
UT Little Buffalo Creek, Steve Zoufaly of the Standards and Classification Group of the
Division has been notified. He indicated that a review could be done but it would take
some time. West Jefferson should contact him for any progress reports on the results of
this reevaluation.
If there are any additional questions concerning these recommendations, please
contact me.
cc: Steve Mauney
Jeff Poupart
Dave Goodrich
WLA File

All
Zcv L

TOXICANT ANALYSIS
Facility Name
West Jefferson
NPDES #
NC0020451
Qw MGD
0.369
7QIOs cfs
IWC %)
Rec'vin Stream
_.._.._.._.._0:6
48.80
UT Little Buffalo Creek
Stream Class
C-Tr
FINAL RESULTS
Cyanide
Max. Pred Cw
9.6
Allowable Cw
10.2
Cadmium
Max. Pred Cw
71.4
Allowable Cw
0.8
Mercury
Max. Pred Cw
0.57
Allowable Cw
0.0
Chromium
Max. Pred Cw
20
Allowable Cw
102.5
Nickel
Max. Pred Cw
420
Allowable Cw
180.3
Lead
Max. Pred Cw
19.8
Allowable Cw
51.2
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw,
0
Allowable Cw
0.0
6/13/94 PAGE'

West Jefferson 6/13/94
UT Little Buffalo Creek JMN
050702
The Town has requested revision of the numerical limits for metals given in their
draft permit. Instream Assessment completed the WLA in February 1994. Limits are
given for the following:
Cyanide =1 Igg/l
Cadmium = 0.8 µg/1
Chromium =102 µg/l
Nickel =180 µg/1
Lead = 51 µg/l
Mercury = 0.025 µg/I
A review of the self monitoring data for 1993 and 1994 was done and the toxicity
analysis spreadsheet was done. Results of the review indicated that effluent limits for
cyanide, cadmium, mercury and nickel should be retained and limits for chromium and lead
an be revised to monthly monitoring only. The Town had also requested that the
monitoring frequency be reduced and we are in agreement that these parameters can be
monitored twice a month."Pretreatment should be notified and their input given on these
recommendation, however Jeff Poupart is out of the office until next week.\
obs.
BDL
max. value
Cyanide
125
48
8
Cadmium
34
10
21
Mercury
11
4
0.3
Chromium
31
15
10
Nickel
31
5
140
Lead
31
6
9
Talked with Steve Z. about the town's request for reevaluation of the C-Tr stream
classification of UT Little Buffalo Creek. Letter indicated that there are no trout in the
stream, mostly made up of stormwater runoff and underground streams. Z said that
Jefferson or West jefferson had made this type of request before for Naked Creek. He
asked for a copy of the letter and said he would notify Jimmy Overton about setting up a
use attainability study. Said that a reevaluation would not happen overnight, it may take
some time but that the UT was probably classified as trout because the mainstem has that
classification. West Jefferson request for review may be valid.
6/20/94
Talked with Julia Storm of Pretreatment she recommended that cvanide be revised to
monitoring -because main industry is cheese and not sure where cyanide is coming from.
Also told me to check how many of the values were below detection and if a majority were
below detection should probably consider monitoring only. Recommended that frequency
for c, awe. chromium, and lead be quarterly to correspond to long term monitoring
pro am. Told her that for limited metals, cadmium, nickel and mercury would
be recommending that frequency be reduced from weekly to twice per month, She
concurred with this recommendation.

West Jefferson Notes
page 2
Called George Smith of WSRO, did not think that Region had seen the letter from the
Town. He will review their file and get back with me this afternoon with their
recommendations. Indicated that there may be some problems with the West Jefferson
facility.
6/21/94
Lee Spencer of WSRO called and said he concurred with all recommendations except the
quarterly monitoring for cyanide. He thought that since cyanide had previously been
limited he thought that quarterly monitoring would not be sufficient at this time and
recommended twice a month monitoring for cyanide to collect enough data to look at in the
future. Town had problems with cyanide previously and couldn't account for where it was
coming from.Asked me to confer with Julia Storm about changing the monitoring
frequency for cyanide to monthly.
6/22/94
Jeff Poupart of Pretreatment called said 1) Lead- said that he could go along with keeping
the limit or monitoring. Since the limit of 51 ug/1 was so high, could see going with
monitoring only. Told him that tox analysis indicated that only monitoring was needed.
Said that could be our call. 2) He recommends quarterly monitoring for cyanide because
the industries in West Jefferson, cheese factory and furniture manufacturing, are not
permitted (for pretreatment) above domestic concentrations. Cyanide is limited because
EPA says that every pollutant must be listed, but it is not a pollutant of high concern. He
does not think it's necessary to have them monitor more than quarterly. In addition, so
many of the Cn values are below detection (5 ug/1) or at detection level of 5 ug/1. The
laboratory readings for Cn are often inaccurate, so he questions whether the reported
reading of 8 ug/1 is correct. Does not think that a small town like West Jefferson should be
penalized by having to sample so often for cyanide when probably not present that often.
Called Lee Spencer with Jeffs info, he says that if we feel comfortable with quarterly
cyanide monitoring then WSRO will go along with it.
4�
CV C P

TOXICANT ANALYSIS
Facili Name
West Jefferson
NPDES #
NC0020451
Qw MGD
0.369
7Qi0s cfs
Iwc %
RecVing Stream
0:6
48.80
UT Little Buffalo Creek
Stream Class
C-Tr
FINAL RESULTS
Cyanide
Max. Pred Cw 9.6
Allowable Cw, 10.2
Cadmium
Max. Pred Cw
71.4
Allowable Cw
0.8
Mercury
Max. Pred Cw
0.57
Allowable Cw
0.0
Chromium
Max. Pred Cw
20
Allowable Cw
102.5
Nickel
Max. Pred Cw
420
Allowable Cw
180.3
Lead
Max. Pred Cw
19.8
Allowable Cw
51.2
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw,
0.0
6/9/94 PAGE

TOXICANT ANALYSIS
r--Fagilt Name
West Jefferson
NPDES #
NCO020451
Ow MGD
0.369
7Q10s cfs
IWC %
Rec'ving Stream
_ _0.7
44.97
UT Little Buffalo Creek
Stream Class
C-Tr
FINAL RESULTS
Cyanide
Max. Pred Cw
9.6
Allowable Cw
11.1
Cadmium
Max. Pred Cw
71.4
Allowable Cw
0.9
Mercury
Max. Pred Cw
0.57
Allowable Cw
0.0
Chromium
Max. Pred Cw
20
Allowable Cw
111.2
Nickel
Max. Pred Cw
420
Allowable Cw
195.7
Lead
Max. Pred Cw
19.8
Allowable Cw
55.6
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0
Max. Pred Cw
0
Allowable Cw
0.0
0197Q10(!nl
6/9/94 PAGE -

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality
is and Engineering Unit
March 21, 1994
J r
To: Ru wanek,,Suuppervisor, Instream Assessment Unit
z, Environmental Engineer, NPDES Permits, WQ
From: Charles Alvare
Subject: West Jefferson WWTP, NC0020451, Ashe County
Attached please find a letter from Michael Dixon, town
manager of West Jefferson. The manager has several concerns about
the new permit in relation to metals monitoring. Please comment on
the metals monitoring requirements.
If you need any more information please call me at 733-5083
ext 553.

.40
MANAGER:
Michael Dixon
CLERK:
Shelia K. Sturgill
gown of west jrcffcrson
"Prosperity, Growth, Achievement"
March 17, 1994
Mr. Dave Goodrich
NPDES Permit Group
Environmental Management Commission
PO Box 29535
Raleigh NC 27626-0535
Dear Mr. Goodrich,
MAYOR:
A. B. Weaver
ALDERMEN:
Brett T. Summey
Dennis E. Houck
Earnest E. South
Teddy R. Huffman
Earl F. McNeill
The Town of West Jefferson presently holds NPDES Permit No.
NCO020451, and discharges treated wastewater effluent to an unnamed
tributary of Little Buffalo Creek in the New River Basin. The Town
received notification from the North Carolina Division of
Environmental Management of its intent to issue the town a new NPDES
Permit along with a copy of the draft permit. We have reviewed the
draft permit and with this correspondence, we are formally
registering our concerns and observations.
Specifically,' the items we are concerned with are:
1. In the Public Notification of intent to issue a State
NPDES Permit under the heading of "NPDES Permit No.
NCO020451, Town of West Jefferson", the 7Q10 flow of
Little Buffalo Creek in the New River Basin was listed
as 0.06 cfs. We believe this to be a mistake. The
7Q10 of Little Buffalo Creek should be 0.6 cfs.
P.O. BOX490, FIRST STREET AND THIRD AVENUE
WEST JEFFERSON, N.C. 28694
PHONE: [phone]

9
2. There are some very significant changes between our
current NPDES Permit and the draft permit. The draft
permit has an expiration date of December 31, 1995,
resulting in a permit life of only twenty months. We
understand the need to synchronize the issuance of
permits throughout the river basin. However, the Town
of West Jefferson would like some assurance from DEM
the conditions (some of which we cannot comply with) in
the draft permit would not undergo significant changes
again. The Town has just recently (within the past 12
months) completed an extensive upgrade of the WWTP to
comply with all the conditions of the existing NPDES
Permit and construction will probably be required if
the Town has to comply with all the conditions of the
draft permit. The prospect of undergoing possible
construction again in twenty months is not acceptable.
The shortened permit life is for the convenience of DEM__
and since permits are normally issued for a five year 3
period, the Town feels consideration on this matter is
in order. We also feel a pro -rated permit fee is in °-:D
order due to this shortened permit life.
3. The Town's major concern with the draft permit is the
inclusion of specific metal limitations. On previous
permits, metals were required to be monitored only,
once per month, where as in the draft permit, metals
are required to be monitored once per week and specific
numerical limitations are included.
In addition to the four fold (4 analysis per month
rather than one per month) increase in cost for metals
analysis, we cannot consistently comply with Daily
Maximum Limitations, particularly at the levels
established in the draft permit. The metals data
(monthly analyses and long term monitoring data)
collected during 1993 indicates the Town would
consistently violate both the Cadmium and Mercury
limitations set forth in the draft permit.
4. The Daily Maximum Limitation established in the draft
permit for Cadmium is 0.8 micrograms per liter.
Currently, the lowest detection level for Cadmium is
2.0 micrograms per liter. Obviously, we cannot comply
with the Dai y aximum 0.8 ug/l Cadmium limitation.
�\ During 1993, there were a total of 27 Cadmium analyses
completed, both for the routine monthly sampling events
and the long term monitoring events. There would have
been a total of 19 violations of the 0.8 ug/1 Cadmium
`�-standard. Of the 19 exceedences, 14 analyses were
reported as 1.0 ug/l, the lowest detection level of the
test procedure.

The less obvious and more onerous problem is with the
Headworks Calculations and the resultant allowable
loading for Cadmium to the WWTP. The Headworks _
Analysis predicts that maximum allowable loading to the
,WWTP would be 0.0075 lb/day at the Permit Flow
Limitation of 0.369 GPD. At current conditions, the -�
actual domestic loading to the WWTP is 0.013 lb Cd/day; -
which is approximately twice the maximum allowable
influent loading. This implies the two industrial
users on our pretreatment program would have to be
effectively limited to zero pounds of Cadmium per day
discharge.
5. The daily maximum limitation established in the draft
permit for Mercury is 0.025 ug/l. Currently the lowest
detection limit for Mercury is 0.2 ug/l. The same
problems that exist for Cadmium will exist for Mercury.
6. It is the Town's understanding the very restrictive
metals limitations proposed in the draft permit are the
result of discharging to an unnamed tributary of Little
Buffalo Creek, which is a Class C Trout Stream. The
majority of the stream flow coming by the WWTP
represents storm water run off and underground springs
located through and under the Town which discharge
through the storm drainage system. There is no
discernable stream above the Town. Further, we are not
aware of any trout or trout fishing occurring in this
unnamed tributary of Little Buffalo Creek.
The Town of West Jefferson cannot comply with the restrictive
limitations established in the draft NPDES permit, particularly the
Cadmium and Mercury limitations. We respectfully request numerical
metals limitations be deleted from the proposed NPDES permit. It
would also be our desire for the sampling frequency to be set at one
time per month as opposed to one time per week.
If granting these changes would require a reevaluation or
reclassification of the unnamed tributary discharging into Buffalo
Creek, from a Class C Trout Stream to some other designation, then
the town formally requests that an evaluation of the stream be made.
If you have any questions or require additional information,
please contact me at your convenience. The Town is very anxious to
resolve these issues.
Sincerely,
Michael Dixon
Town Manager

North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
August 26, 1993
MEMORANDUM
To:
Ruth Swanek
Through:
Jay Sauberd
From:
Howard Bryant /14,Kf13
Subject:
Long-term BOD Analysis forWest Jefferson WWTP
County: Ashe
NPDES # NC0020451
.Receiving Stream:
Little Buffalo Creek
Sub -basin: 050702
DAY
BOD NH3-N
TK_N--N
OX-N
TN_-N
0
0.03
3.4
0.59
4.0
5
3.07
0.17
2.3
0.58
2.9
10
4.97
0.34
0.9
0.61
1.5
15
6.32
0.36
0.9
0.65
1.6
20
8.19
0.12
0.6
0.86
1.5
25
9.82
30
10.43
0.04
0.7
1.10
1.8
35
11.11
40
11.75
50
12.86
60
13.45
0.02
0.4
1.30
1.7
70
14.15
80
14.86
90
15.27
0.04
0.3
1.40
1.7
100
15.74
110
16.09
120
16.42
0.03
0.4
1.40
1.8
140
17.03
Date Collected: February 9, 1993
Collected by: Johnston Test evaluation: excellent
0800-0800
pH: 8.4
Seeded:
seeded
cc: Central Files
Regional Water Quality Supervisor
a