NC0023965_Correspondence_19901015

NPDES DOCUWENT SCANNIMIS COVER SHEET
NPDES Permit:
NCO023965
Wilmington - Northside WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Engineering Alternatives Analysis
201 Facilities Plan
Instream Assessment (6713)
Correspondence re: OAH petition
Permit History
Date Range:
Document Date:
October 15, 1990
THIS DOCYHENT IS PRINTED ON RffYSE PAPER - IONORE ANY CONTENT ON THE
REVERSE SIDE

r, _
DIVISION OF ENVIRONMENTAL MANAGEMENT
October 15, 1990
MEMORANDUM
To: Don Safrit fI
Permits and Engineering II
From: Dave Adkins �t��UL
Through: Preston H: ?rd!
Regional Supervisor
PR ff fi��1V
OCT 1 8 1990
Subject: City of Wilmington �0t� TECHNICr". SUPPOORT RANCH
Request for Adjudicatory Hearing"
NPDES Permit No. NCO023965
NPDES Permit No. NCO023973
New Hanover County
In correspondence received in this Office on June 19, 1990,
the City of Wilmington has indicated it would be in a position to
dismiss the appeal of conditions contained in the subject
permits if certain modifications could be made in the permits as
issued effective February 1, 1990. Subsequent correspondence
dated July 17, and September 26, 1990, provided data on influent
BOD and TSS. The following comments are offered regarding the
City's appeal:
1. Classification of the Cape Fear. River at the point of
discharge from the Southside Wastewater Treatment Plant -
The City has indicated it -is willing to accept the
classification as indicated in the existing NPDES Permit.
2. The pH limitation contained in the permits - Ambient data
collected by this Office has shown the pH of the
receiving waters to be less than 6.5 standard units. This
Office has no objection to the pH limitations being
revised to a range of 6.0 to 8.5 standard units.
3. Fecal coliform limitation and toxicity testing - The City
has agreed to accept the fecal coliform limitation and
has asked to change organisms for the toxicity testing.
It is the understanding of this Office that Mr. Ken
Eagleson has reviewed this request and is prepared to
respond to this issue.

Memo to Don Safrit
October 15, 1990
Page Two
4. Percent removal requirement - The data submitted by the
City to support its contention the influent strength is
routinely below 200 mg/l and the 85 percent removal
requirement would be more restrictive than the effluent
limitation of 30 mg/l. There were no monthly average
influent TSS or BOD values at either the Northside or
Southside plant greRter than 200 mg/1 during the period
January, 1985 to August, 1990. A tables summarizing the
data is included as Attachment A. The monthly average
influent values for the Northside plant are
BOD - 172 mg/l and TSS - 113 mg/l. The percents
reduction necessary to comply with the effluent
limitation of 30 mg/l are 82% and 73% respectively .
The monthly average influent values for the Southside
plant are BOD - 156 mg/l and TSS - 159 mg/l. The
percent reducLon necessary to comply with the effluent
limitation of 30 mg/1 is 81% for both parameters.
The City has underway a corrosion control/odor abatement
project as required in the SOC. The efforts have involved
a chemical feed system which has resulted in fluctuating
influent BOD and TSS values at the Southside plant. The
City has requested allowance be made for these
fluctuations by removing the percent removal requirement
for the Southside plant. The request has merit especially
when considered in light of the fact the permit will
expire June 30, 1991. If the percent removal requirement
must be included; it is recommended the percent removal
be based on the data collected during the pilot testing.
This data (May to August 1990) indicates a percent
removal for BOD of 79% is appropriate and the TSS
percent removal 5should remain at 81%.
5. Time limits (term) of Permits - The City has dropped
their objection to the term of the permit.
6. The City had requested the name of the facility covered
by NC0023965 be revised to read "James A. Loughlin
Wastewater Treatment Plant". It is recommended this be
included in any modification to the Permits as appealed.
6

It is recommended a modified permit be prepared for both
facilities including Mr. Eagleson's recommendations on item 4,
the recommendations of the Technical Support Branch, and the
Regional Office recommendations in items 2, 3, and 6. This should
be presented to the City as a settlement to the request for a
contested case hearing filed with the Office of Administrative
Hearings.
Attachment
da008.jun
cc: Mr. Dave Heeter
Mr. Ken Eagleson
CMr--.—T� r__Clements+
WiRO
Central Files

ATTACHMENT A
INFLUENT VALUES (mg/1)
Northside
Monthly Average
BOD
TSS
1985
1675
129
1986
151
83
1987
153
104
1988
173
110
1989
192
126
1990*
199
129
Average
172
113
Southside Monthlv Average
BODS
TSS
168
186
130
99
149
165
170
193
160
150
161
163
156
159
* increased concentration considered by City to be a
combination of accomplishments of sewer rehabilitation
efforts and climatic conditions.

CITY of WILMINGTON
North Carolina
P.O. BOX 1810
28402
September 26, 1990
PUBLIC UTILITIES DEPARTMENT
Dave Adkins
Division of Environmental Management
7225 Wrightsville Avenue
Wilmington, NC 28403-3696
Dear Mr. Adkins:
As we discussed yesterday, I am providing you information
which you requested in support of the City's request to modify
the percent removal requirement for the Southside Wastewater
Treatment Plant's NPDES Permit:
1989 1990
Influent BOD May 195 159
30 Day Average June 162 135
July 187 129
August 150 140
As you are aware, during the above -referenced months in this
calendar year, the City has been experimenting with chemicals in
the Northeast Interceptor in order to reduce odor and corrosion.
Our continued use of such chemicals is being evaluated and our
conclusions will be reported to you this year.
By this letter, I am also formally advising you of the
following:
1. Emergency sewer pipe replacement to 800 linear feet of the
Burnt Mill Creek Sewer Outfall was completed September 12,
1990. The previously reported spill into the creek (from
Bauer to Steve Long on 9/6/90) was not entirely correct. To
relieve flow in order to insert a by-pass plug, the
wastewater was allowed to run into the new pipeline and the
pipeline's trench. The trench and the new pipeline
contained the sewage and I would estimate a small quantity
leaked into the creek. I inspected what had occurred after
it had been reported late to me and the stream was not
discolored, there was no odor, nor any fish IPll.
REGEIVF-0
OCR' 0 i 1990
Wilmington Regional Office

Dave Adkins
September 26, 1990
Page 2
2. The City is undertaking a Wastewater Sludge Master Plan with
the firm of Camp, Dresser & McKee hired to provide
consulting services. Scheduled for completion in December,
1990, the City will submit this plan to DEM for review &
comment. It is our current thinking to dewater wastewater
sludge at the NSWWTP and alum sludge and possibly co-dewater
and blend both sludges.
3. It is my understanding from you that DEM wants the
Scotchman near Johnny Mercer's Pier by Wrightsville Beach to
clean-up its underground leaking fuel tank. DEM wants the
City to accept the filtrate. I would ask that the Scotchman
and DEM work directly with our Wastewater Treatment Division
(Pretreatment. Section) in order to follow our Sewer Use
Ordinance requirements. All costs associated with this
request are to be paid for by the applicant. The City will
cooperate with DEM, but I am concerned, as I am sure you
are, at a proliferation of these requests coming to the
City. I believe each of these situations needs to be handled
on a case -by -case basis and that a NPDES permit should not
be out of the question.
It is my understanding from our telephone conversation that,
under emergency conditions, DEM will allow dewatered sludge to be
stock piled at both treatment plants until suitable land
application sites are found. You want plastic sheeting to be
placed underneath the sludges. It is further my understanding
that you will not allow chemically stabilized sludge to be plowed
into the Southside WWTP's grounds under any conditions.
I am hopeful this letter summarizes our telephone
conversations as well as information you requested.
Respectfully, / (g
J h Bauer
D ector of Public Utilities
JB:ph
CC,. W.T. Anderson
Doug Carter
William Farris
Tom Pollard

1- 39
CITY of WILMINGTON
North Carolina
P.O. BOX 1810
28402
July 17, 1990
Mr.. Preston Howard
Division of Environmental Management
7225 Wrightsville Avenue
Wilmington, North Carolina 28403-3696
Dear Mr. Howard:
PUBLIC UTILITIES DEPARTMENT
According to Mr. Dave Adkins, the U.S.E.P.A. is unwilling to
exempt the City of Wilmington from the percent (%) removal
requirements proposed to be contained in the City's NPDES permits
for both plants. The City has previously submitted data in
support of this exemption.
As you are aware, the City is experimenting with a
nitrate -based product, known by the trade name "bioxide", for use
as an odor/corrosion control enhancer for the Northeast Sanitary
Sewer Force Main. Preliminary data indicates that this product
may have some beneficial pretreatment impact, thereby reducing
influent BOD strength. See attached comparative chart.
We may or may not continue with bioxide as a permanent
odor/corrosion control strategy. If we do use it, I respectfully
request some consideration be provided by the DEM with respect
to the percentage removal requirement at least until the permit
is projected to expire (June 30, 1991). In that way, we would
begin to build a better data base for any pretreatment which
bioxide'or any other chemical may provide to the Southside
Wastewater Treatment Plant System.
I await hopefully your favorable response to -my request.
Respectfully,ouz-�
N�,�
J n Bauer
Director of Public Utilities
JB:ph
cc: Dave Adkins
W.T. Anderson
Tom Frederick
Tom Pollard

Influent DOD Reduction
Southside WWTP
1. Average influent DOD - 1990
Jan., Feb., March, April ----- 181.75 mg/l - non-bioxide
May & June ----- 149.5 mg/1 - bioxide
Difference 32.25 mg/1
This represents a reduction of 17.7%
2. Comparison of May -June 1989 to May -June 1990
Non-bioxide 1999 ----- 173.5 mg/1 average inf DOD
Dioxide .1990 ----- 149.5 mg/l average inf DOD
24.0 mg/l average reduction
I

DECEIVE©
J U N 19 1990
Wlfmington Offics
CITY of WILMINGTONV
North Carolina
P.O. BOX 1810
28402
June 15, 1990
Mr. David G. Heeter
Agency Legal Specialist
North Carolina Department of Environment,
Health and Natural Resources
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Re: City of Wilmington v. DEHNR 90 EHR 0147
Dear Dave:
LEGAL DEPARTMENT
[phone]
This will follow up the meeting between representatives of
the City and the Department of Environment, Health and Natural
Resources concerning the City of Wilmington's appeal of several
of the conditions on the renewed NPDES permits for the Northside
and Southside Treatment Plants. This letter will attempt to
outline the City's understanding concerning the status of the
issues raised in the City's appeal and provide a basis for
resolving this appeal.
1. Classification of the Cape Fear River at the location
of the Southside Plant discharge: Based upon the information
provided to the City at our.meeting, the City understands that
the Cape Fear River at the point of the Southside Plant discharge
has been classified as Class SC.
2. Limits on pH: Based on the characteristics of the Cape
Fear River at the points of discharge for both the Northside and
Southside Plant, the City understands that the DEM staff is
prepared to recommend that the permit be modified to provide that
the pH of the discharge shall not be less than six standard units
nor greater than eight and one-half standard units.
3. Percent Removal Requirement for BOD-5 and Total
Suspended Residue: It is the City's understanding that the DEM
staff would recommend an exception to the percentage removal
requirements for BOD-5 and total suspended residues upon a
showing by the City that the concentration of the influent

Mr. David Heeter Page 2 June 15, 1990
waste water averaged less than 200 mg/l per month for these
parameters. Pursuant to the provisions of 40 CFR 133.103(d), the
City hereby requests DEM to delete the percentage removal
requirements for BOD-5 and total suspended residue for both the
Northside and Southside Plants.- In support of this application,
the City submits the enclosed information that shows the influent
concentrations for BOD and suspended solids from 1985 to the
present for both plants. This information clearly shows that the
average influent concentrations are below 200 mg/l for these
plants. As stated in the City's appeal, the design of the
Northside and Southside Treatment Plants as approved by the
Division of Environmental Management is based upon an average
influent BOD-5 and average total suspended solid loadings of 200
mg/l, and it is not reasonable to achieve the 85% removal
requirement at varient influent loadings. This information
clearly shows that to meet the percentage removal requirements,
the City would have to achieve significantly more stringent
limitations than would otherwise be required by the concen-
tration -based standards. Based upon this information, the City
would request the elimination of the percentage removal require-
ments for BOD-5 and total suspended residue from the permits.
4. Fecal Coliform Limits and Toxicity: The City under-
stands that the fecal coliform limits are mandated by the
Environmental Protection Agency and thus will accept the fecal
limits in the permits. The City is concerned about potential
problems with toxicity testing that may result from the City's
attempts to meet the fecal limits. Based upon the City's
experience to date with toxicity testing, a reasonable compromise
on this issue would be to allow the City to use Daphnia Pulex in
lieu of the Fathead Minnow as the test organism in its toxicity
tests. The City hereby requests the use of the Daphnia Pulex in
its toxicity tests.
5. Time limits on renewed permits: Although the City
still contends that the brevity of the rere:aal permit effective
dates penalizes the City, we understand that DEM has chosen this
method for establishing a basin -wide permittee program, and the
City can expect to obtain a five-year permit at the next renewal
date.
If we can reach an agreement on the above issues, the City
would be in a position to dismiss its appeal of the permit
conditions. The City understands that the permit conditions
can be adjusted administratively to address these issues, and the
City would be prepared to dismiss its appeal upon receipt of
evidence of the modification of the permit conditions. In
dismissing this appeal, the City does not intend to waive any
rights that it may have under G.S. 143-215.2 to require the
Environmental Management Commission to fix a fair and reasonable
period of time in which the'City shall not be required to
undertake any additional improvements to the Northside and

Mr. David Heeter Page 3 June 15., 1990
Southside Treatment Plants after completion of any improvements
to the plants in compliance with any NPDES permit or special
orders by consent for the plants.
In order to expedite the review of these issues, I am
forwarding a copy of this letter and the enclosed information to
Preston Howard for his review. I hope that we will be able to
resolve these issues as outlined above. If you have any
questions, please let me know.
Sincerely yours,
C A& -
Thomas C. Pollard
City Attorney
TCP/dbl
cc: John Bauer, Director of Public Utilities
William B. Farris, City Manager
A. Preston Howard, Regional Supervisor
Division of Environmental Management

NORTHSIDE
SOUTHSIDE.
1985
Inf. BOD
Inf. SS
Inf. BOD
Inf. SS
JAN
172
132
193
198
FEB
139
130
199
259
MAR
166
132
198
295
APR
193
144
183
243
MAY
176
177
170
233
JUNE
179
130
186
207
JULY
188
115
170
142
AUG
158
149
139
134
SEPT
164
111
162
159
OCT
161
—11-4-
132
114
NOV
143
89
137
118
DEC
166
126
149 /
137
'
19 6
JAN
158
98
142
109
FEB
162
109
159
140
MAR
148
111
145
120
APR
176
1.13
141
110
MAY
162
110
136
105
JUNE
152
101
119
101
JULY
132
85
144
74
AUG
107
62
96
79
SEPT
137
70
116
86
OCT
149
74
123
B3
NOV
150
84
119
85
DEC
150S,I
801�
121
136
9�'
1987
JAN
140
90
118
96
FEB
143
91
130
109
MAR
134
79
113
94
APR
154
89
138
99
MAY
159
86
149
136
JUNE
139
106
168
210
JULY
113
93
139
180
AUG
141
108
153
191
SEPT
143
117
144
166
OCT
178
146
191
308
NOV
184
131
154
151
DEC
:_203
116
189
241/

JAN
FEB
MAR
APR
MAY
JUNE
JULY
AUG
SEPT
OCT
NOV
DEC
1989
JAN
FEB
MAR
APR
MAY
JUNE
JULY
AUG
SEPT
OCT
NOV
DEC
1990
JAN
FEB
MAR
NORTHSIDE
Inf. BOD
145
101
152
191
210
204
191
132
163
172
211
200
Inf. SS
81
105
72
106
122
119
127
101
91
—124-
140
133
I? D. -'g
. SOUTHSIDE
Inf. BOO
121
203
220
197
251
159
155
112
133
155
167
164
l'A-�)
Inf. SS
115
207
233
288
438
226
170
119
104
114
127
1 �•
1�3
194
140
158
134
202
155
163
155
188
125
162
101
ISO
120
159
140
198
136
185
194
205
125
162
183
207
136
187
226
187
125
150
137
177
110
155
142
179
108
139
136
204
127
154;
133
182
103
144
1
tgtRL
(1i•�'
��'
I�
182
106
I81
179
209
128
174
170
213
121
189
186