NC0023965_Correspondence_19891017

NPDES DOCYNENT SCAMMIMO 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 (67B)
Correspondenc re: draft permit
Permit History
Date Range:
Document Date:
October 17, 1989
TOMS DOCUMENT IS PRINTED ON REUSE PAPER - ICNORE ANY CONTENT ON THE
REVERSE SIDE

0
a
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W Cobey, Jr., Secretary Director
October 17, 1959
Mr. John Bauer
Director of Public Works
City of Wilmington
Wilmington, NC 28402
Subject: Comments on NPDES Draft Permits
NPDES No. NCO023973 - M'Kean Maffit WWTP
NPDES No. NCO023965 - Northside James A. Loughlin WWTP
New Hanover County
Dear Mr. Bauer,
I am writing in response to your letter dated September 15, 1989, regard-
ing the NPDES Draft penaits for Wil.ninyton's wastewater treatment facilities.
My comments addressing your concerns are as follows:
M'Kean Maffit Wastewater Treatment Plant
1. The supplement to the permit cover sheet does not require the use of
short-term activated sludge, but merely lists the components of the wastewater
treatment plant.
2. The Division of Environmental Management (DEM) has double-checked the
classification of this segment of the Cape Fear River and determined that
"SC -Swamp" is the correct stream class. The permit will be modified to this
effect.
3. The fecal coliform limit was reduced from 1000/100 ml to 200/100 ml in
accordance with revisions of the North Carolina water quality regulations
(NCAC .0212(b)(3)(E)). These revisions went into effect October 1, 1989, and
are consistently applied to dischargers state-wide.
4. The Code of Federal Regulations (40 CFR 133.102) requires the 85%
removal rate for BOD5 and total suspended solids for all municipalities in
order to insure optimum efficiency of wastewater treatment plants even when
the concentrations of these parameters in the influent are low.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

5. The acute toxicity testing requirement applies to the Southside WWTP
to protect against local impacts in the mixing zone. Due to the significant
tidal flow in the lower Cape Fear River and the unlikelihood of rapid complete
mixing, a chronic toxicity test is not appropriate. You should be aware, how-
ever, that acute toxicity test is less sensitive than the chronic; it is a 24
hour bioassay whereas the chronic is a seven day bioassay. The City of Wil-
mington may substitute daphnia in lieu of fathead minnows for the toxicity
requirement, but the fathead minnow is generally less sensitive to toxicity
than is daphnia. DEM recommends the fathead minnow be maintained as the test
organism for this permit requirement.
6. The pH limit is in the form of an acceptable range. For saltwater
this range is 6.8 to 8.5 standard units, in accordance with NCAC
.0212(b)(3)(G). This regulation includes a provision for swampwaters with
naturally low pH. A review of instream pH data from the lower Cape Fear River
indicated that a pH limit of 6.5 to 8.5 standard units is acceptable.
7. Current Division procedure is to require monitoring of a parameter if
its predicted effluent concentration is within 1/100 of the maximum allowable
concentration, and to limit a parameter that is predicted to be present at a
concentration greater than 1/10 of the maximum allowable concentration. Based
on the pretreatment headworks analysis submitted to DEM for the Southside
facility, nickel and cyanide are present in the wastewater in great enough
concentrations to warrant effluent monitoring. These requirements will not be
changed at this time. However, after 12 months of effluent monitoring, Wil-
mington may request that this requirement be re-evaluated by DEM based on the
data collected.
8. Standard Division procedure requires all major facilities (including
all municipalities >1.0 MGD) to perform an annual priority ;_ollutanc an.alyzjis.
This requirement is routinely applied across the board and will not be modi-
fied in the Southside WWTP permit.
Northside James A Loughlin WWTP
1. The comments addressing activated sludge in the Southside permit (No.
1 above) are applicable for the Northside permit as well.
2. The comments addressing the fecal coliform, percent removal, and pH
limitations for the Southside WWTP (Nos. 3, 4, and 6 above) are applicable to
the Northside WWTP as well.
3. The comments addressing the pollutant analysis for the Southside WWTP
(No. 8 above) are also applicable the Northside WWTP.
I hope this letter adequately addresses your concerns. However, if these
decisions are unacceptable to the City, you have the right to an adjudicatory
hearing upon written request within thirty (30) days following issuance of the
final permit. This request must be in the form of a written petition, con-
forming to Chapter 150B of the North Carolina General Statutes, and filed with
the office of Administrative Hearings, Post office Drawer 11666, Raleigh,
North Carolina 27604. If we do not receive any response to the changes pro-
posed above, the Draft permit will become final and binding.

If you have any questions or comments regarding this matter, please con-
tact either Dale Overcash or Trevor Clements of my staff at [phone].
Sincerely,
� 1 ,/
R. Paul Wilms
cc: Don Safrit, Wilmington Regional Office
Dale Overcash
.Trevor=Clements.
Central Files

CITY of WILMINGTON
°f North
1739 CarOliM77
P.O. BOX 1810 SEP 22 PHSYC UTILITIES DEPARTMENT
I 28402
WATER QUALITY
SECTION
September 15, 1989 5h
Mr. R. Paul Wilms, Chairman���
Environmental Management Commission IV/����YYYJJJ jlll/1
Division of Environmental Management ILLY\� .�gypp
Department of Natural Resources and
Community Development gota Nn P. 0. Box 27687
Raleigh, North Carolina 27611-7687 OVUM
RE: Comments with respect to Draft NPDES Permits:
No. NCO023973-M'Kean Maffit Wastewater Treatment Plant
No. NCO023965-NCSR1302 Wilmington, New Hanover County
Dear Mr. Wilms:
The comments included in this letter represent City of
Wilmington concerns and critique of the above -referenced draft
permits. It is hoped that these comments can be discussed and
evaluated with the Wilmington Regional Office as well as your
office. These comments are:
M'Kean Maffit Wastewater Treatment Plant NPDES NCO023973:
1. On the Supplement to the Permit Cover Sheet, we note that the
permit authorizes us to operate short-term activated sludoe.
Is it mandatory that this be operated? It was fully our
intention and it was expressed during design and
construction of the newly expanded M'Kean Maffit Wastewater
Treatment Plant, that the short-term activated sludge would
only be operated when flows to the wastewater treatment
facility were such that other structures could not adequately
provide treatment to meet our permit requirements. It has
been fully our understanding that at current average flows of
six (6) MGD we do not need to use the short-term activated
sludoe process with all other facilities ooeratin❑
adequately. We certainly had net anticipated uhis action
by the Division. We have not budueted funds for the extra
costs in operating the short-term activated sludoe since we
can provide adequate treatment without its utilization.

Page 2
2. On the same Supplement to the Permit Cover Sheet, item no. 2
specifies that the classification of the waters in the Cape
Fear River basin as: "Class SC waters". Our current permit
specifies that we are discharging into Class SC -Swamp waters
in the Cape Fear River basin. When did this change in the
classification take place? We were never advised of this
/ change.
J 3. With respect to lowering the fecal coliform "geometric
mean" monthly and weekly averages respectively from 1000/100
ML and 2000/100 ML to 200/100 ML and 400/100 ML, we were
never previously advised that these would be the "more
stringent" discharge limitations placed on us during the
course of design and construction of the expansion of the
plant which has recently been completed. Now we are faced
with attempting to meet the standards when notification to u=_
at an appropriate point in time would have allowed us to
include the capital cost in the expansion project. It is
certainly anticipated at the operational level that we cannot
meet the fecal coliform discharge limitations as well as
achieve acceptable toxicity results without dechlorination
facilities and/or alternative disinfectants. Out of
necessity we would have to chlorinate more in order to _meet
these discharge limitations. In point of fact, we would be
out of compliance the minute this permit was issued and we
ask for clarification on the time frame with which to allow
us to get in compliance. Further, it is our understanding
that these limits were established because of the
characteristics of the Cape Fear River. We would like data
from the Division to support this contention.
4. It is noted that it is a requirement that the monthly average
effluent BOD 5 and total suspended residue concentrations
shall not exceed 15% of the respective influent value (85%)
removal. It is our contention that this is an unreasonable
requirement. If it is the division's intention to protect
the stream, then what does e5% removal have to do with that
goal? In point of fact, if the City had influent values of
300 milligrams per liter, then with e5% removal the City
would still be in excess of monthly average discharge
limitations of 30 milligrams per liter. What does this
requirement have to do or-otectinq the stream's needs and how
does it equate to assisting in that endeavor'

Page 3
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vIl 5. With respect to acute toxicitv. it was fullv our
understanding that there would be no enforcement of toxicity
requirements until we were put on the chronic toxicity
standard. The standard which is included in the permit of No
Significant Mortality at 90% wastewater is unreasonable given
the fact that it is not equivalent to stream conditions. We
do not have 90% concentration of wastewater (in the river)
nor does it take into account dilution factors.
We would further suggest and request that we substitute
daphnia in lieu of the fathead minnows as they are more
representative of our localized conditions. I would again
urge that we be put on the chronic toxicity standard for this
plant.
6. We are completely at a loss to understand the limitation that
PH not be less than 6.8 standard units. In our existing
permit there are no pH limits, although there is a range
between 6 to 9 which we have been consistently achieving.
Again,.we had no prior notification during design and
construction of the expanded facilities that this type of
stringent standard would be a requirement. Further, it would
be extremely difficult to achieve a 6.8 on a daily basis.
Again, we would enjoy receiving data in support of the
contention by the Division that the stream itself has pH
between 6.8 and 8.5 standard units. Our recommendation is
that with additional capital expenditure and the obvious
purchase of additional chemical feed, we may be able to
adjust for pH towards a lower limit of 6.5 standard units.
7 7. There is really no possibility
. cyanide problems at the plant.
""
of us having nickel or
Yet 'we are required to
A -Y�
monitor for these chemicals on
for justification behind this requirement.
program and our sludge testings
a monthly basis. We ask
Our pretreatment
show that we do not need to
'
Gjv
absorb the additional costs for
We feel that such requirements
these unnecessary requirements.
should be based on potential
4�✓
chemicals coming into the plant.
These are not evidenced by
nickel or cyanide.
B. Finally, the last paragraph in the permit (Section J2). is
both unreasonable and unachievable. Can we possibly sample
or test to a sufficient decree in trying to identify specific
synthetic organic chemicals. We would respectfully ask for
modification of this requirement, again based on some degree
of justification from the Division.

Page 4
Northside James A. Loughlin Wastewater Treatment Facility:
NPDES Permit No. NCO023965
1. There is no mention of operating dual secondary clarifiers
or anaerobic sludge digesters in the Supplement to the
Permit Cover Sheet. We believe this mention should be made.
2. The same comments we issued with respect to the fecal
coliform limits, the percent removal limitation, as well as
the pH standard, which are expressed above, apply equally to
the Draft Northside Permit.
3. We have the same comments with respect to Section J2
of the draft permit in that this testing requirement would be
extremely difficult to ever achieve, and its reasonability is
certainly a question for us.
In summary, we understand and philosophically agree with the
Division with respect to protecting the water quality of the
stream to which we are discharging. We would, however, wish to
discuss with the Division the reasonableness, achievability, and
scheduling of the permits' requirements which have been presented
in draft form to us.
Respectfully sub�m�i�ttteed,
�.
h� n Bauer
Director of Public Utilities
JB:ph
wilms4
cc: William B. Farris
Preston Howard
Donald Safrit
W. T. Anderson

Date: August 25, 1989
NPDES STAFF REPORT AND RECOMMENDATIONS
County: New Hanover
NPDES Permit No. NC0023965
REVIEW ENGINEER: Lula Harris
PART I - GENERAL INFORMATION
1.
Facility and Address:
City of Wilmington
James A. Loughlin (Northside) WWTP
Post Office Box 1810 �j
i
Wilmington, North Carolina 28402
� AWE'
2.
Date of Investigation: August 24, 1989
AUG 2 a 196,
3.
Report Prepared by: Dave Adkins
BRANC
TECFit41CAL SUppURT
4.
Persons Contacted and Telephone Number:
Mr. W.T. Anderson
Plant Superintendent
919/ 341-7890
S.
Directions to Site: Travel north from Market
Street on 23rd
Street (NCSR 1302) across Smith Creek.
The site is located
0.4 miles north of Smith Creek on the
right side of NCSR
1302.
6.
Discharge Point - Latitude: 34014126.511
Longitude: 77057/10/1
USGS Quad No.: K 27 NW USGS Quad Name: Wilmington
7. Size: Site consists of approximately 23 acres. There is
adequate area for expansion of the facility to 24.0 MGD.
8. Topography: Relatively level sloping south and ,.nest toward
Smith Creek.
9. Location of nearest dwelling: None within 500 feet.
10. Receiving stream or affected surface waters:
Cape Fear River
a. Classification: SC -Swamp Waters
b. River Basin and Subbasin No.: CPF 17
C. Describe receiving stream features and pertinent
downstream uses: Coastal river having downstream uses
of commercial ship traffic, pleasure boating, and some
commercial crabbing.
I

PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater: 96 % Domestic
04 % Industrial
a. Volume of Wastewater: 8.0 MGD
b. Types and quantities of industrial wastewater.:
0.070 MGD from soft drink bottlers, 0.060 MGD from an
optic fibers producer, and 0.055 MGD from an industrial
launderer.
C. Prevalent toxic constituents in wastewater:
Application indicates varying amounts of the following
metals/compounds are received from industrial users:
chromium, zinc, nickel,cyanide,boron and germanium.
d. Pretreatment Program has been approved.
2. Type of treatment:
The existing 8.0 MGD wastewater treatment facilities include
an influent pump station, a flow meter, a communitor, grit
removal, dual primary clarifiers, dual trickling filters,
dual secondary clarifiers, disinfection facilities
(chlorination), and an effluent pump station.
All of the improvements included in the recently issued
Authorization to Construct will not be constructed. The City
is currently evaluation immediate needs and will submit
revised plans and specifications for the improvements on
August 25, 1989. The proposed improvements will not increase
the design capacity of the facility.
3. Sludge handling and disposal scheme:
The sludge generated at the Northside WWTP is stabilized in
an aerobic digester and then land applied to farm land under
the auspices of Non -discharge Permit No. WQ001271.
4. Treatment plant classification: Class IV
5. SIC Code: 4952, 2086, 3676, 7218
Wastewater Code: 01
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grants
Funds ? No
2. Special monitoring requests: The self monitoring should be
consistent with the monitoring included in the existing
Special Order by Consent (EMC WQ No. 88-61).

PART IV - EVALUATION AND RECOMMENDATIONS
The existing wastewater treatment facilities are
incapable of producing an effluent which can consistently
comply with the terms and conditions of the existing NPDES
Permit. The facility is currently operating under the terms
and conditions of Special Order by Consent EMC WQ No. 88-61..
The facility is in compliance with the limitations contained
in the Order.
It is recommended a draft permit be prepared
at public notice. If no significant adverse public
is received; it is recommended NPDES Permit No./NC
re -issued for a five (5) year period. 1t
re of Repo
Quality Regi
DA00002.AUG
cc: WiRO
Central Files
fT�'17ni'cal Services
and placed
comment
0023965 be
rer
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