NC0020737_WASTELOAD ALLOCATION_19930401

NPDES DOCYNBNT SCANNING COVER SMELT
NPDES Permit: NC0020737
Kings Mountain WWTP
Document Type: Permit Issuance
Casteload Allocation
Authorization to Construct (AtC)
Permit Modification
Correspondence
201 Facilities Plan
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: Aril 1, 1993
This documeat: s priated oa reuse]Paper-igaore aay
coateat on the reverse side

Ewa
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 1, 1993
MEMORANDUM
TO: Charles Lowe
THRU: J. Trevor Clements��
Ruth Swanek?6
Carla Sanderson
FROM: Jackie Nowell aM
SUBJECT: Mercury Limit for Kings Mountain-Pilot Creek WWTP
NPDES No. NCO020737
Cleveland County
Technical Support has reviewed the Oct. 21, 1991 memo on the subject facility.
Our comments and recommendations of that memo are the same with a revision of the
monitoring frequency. I have reviewed the 1992 DMR data for mercury and it shows that
Kings Mountain has reduced the mercury levels to detection or less than detection for the
past few months. All available information seems to indicate that the Town is trying to
correct the problem. On that basis,Tech Support now recommends monthly effluent
monitoring for mercury rather than weekly monitoring.
There is the possibility of two nearby industries (New Minnette Textiles and
Grover Industries)connecting to Kings Mountain's facility in the future. These industries
are having some compliance problems and are looking at alternatives to discharging.
If there are any questions concerning this matter, please contact me.
cc: Rex Gleason
Central Files
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DIVISION OF ENVIRONMENTAL MANAGEM NT�
February 15, 1993
MEMORANDUM TO: Don Safrit
FROM: D. Rex Gleason
PREPARED BY: Richard Bridgeman
SUBJECT: Request for permit modification dated 5/9/91
Kings Mountain - Pilot Creek WWTP
NPDES Permit No. NC0020737
Cleveland County
Enclosed please find a copy of a letter dated February 8, 1993
from the subject City, which was sent in response to a Compliance
Evaluation Inspection Report issued as a Notice of Violation. The
letter indicates that the City has yet to receive a response to a
Permit revision request (copy enclosed) dated May 9 , 1991 .
Be advised that comments from both the Instream Assessment
Unit and this Office, relative to the City' s , request, were
forwarded to the Permits and Engineering Unit in October, 1991, to
Charles Lowe and Dale Overcash, respectively.
Please consider our request to issue a final decision on this
matter to the City.
Should you have questions or require further input from this
Office, please contact either Richard or me.
Enclosure
RMB

DEPT.,OF NA.t.U�L .
THE CITY OF KINGS MOi�AT1 ; T D£S AND
NORTH CAROLINA -Lop'',Z�^T
Ij
P.O.BOX 429 • KINGS MOUNTAIN,NORTH CAROLINA 28086 • 704-734-0333
IMS101OFFIYIRORAIt1HFgr KWUW
YOORLSYIILE RE61Df(u E9
G. SCOTT NEISLER GEORGE A.WOOD
MAYOR CITY MANAGER
February 08 . 1993
N. C. Dept. of EH&NR
Environmental Management Div.
919 N. Main Street
Mooresville . NC 28115
Attn. M=. Richard Bridaeman
Subiect : Notice of Violation
Dear Mr, Bridaeman:
In reply to the Notice of Violation received January 13 , we
offer the following information for your consideration.
1 . On May 9 , 1991 , as soon as our new permit was received
and we had an opportunity to review it ' s contents . I wrote a
letter (copy enclosed) questioning the . 04ug/l limit for
mercury. We have received no answer.
This objection was based on two major factors . First is the
fact that this limit is unrealistic in view of laboratory
capabilities . I have enclosed a copy of the first page of an
article from the January 1993 issue of "Water Environment &
Technology (to which I am sure you have access ) concerning
this same matter. Second is the abruptness of the chance from
-not being required to run samples for mercury prior to 1989 ,
to this low limit . we feel the size of our dilution factor
was given no consideration in this limit .
2 . Of the thirteen occasions during the year when we
exceeded . tug/l (note absence of < ) none have occurred since
August 12th. As you will see from the latest Compliance
Evaluation Inspection report , we installed new sampling
equipment in August . We are not sure that the old equipment
was contributing to the problem, but o eel this is a
distinct possibility.
Also during the first half of the year we were working with
our industries to eliminate all possible sources of mercury.
Most of these t_ere_fs_un51 to be in contaminated material which
had been certified to the user as reagent grade . However, i
was found upon testing to be otherwise .
The Historical City

3 . We have taken numerous samples since the January NOV in
an attempt to pin down this problem , if it really exists . Of
the twenty-one samples which we have had run, and the twenty-
three which our industries have reported for the last three
months ( forty-four total ) , .five have been . 0002ug/l . thirty
-nine have been < . 0002 . None of the samples not having the <
sign has been from our effluent . Two of these samples were of
our effluent, split with the two labs we normally use ( four
reports ) . These were inconclusive as all four were < . 0002 .
We have made a great amount of progress with our wastewater
section in the past several years , as a comparison of the
Compliance Evaluation Inspection report of January 12 , 1993
with those from past years will demonstrate. We are working
hard on the last few problems , particularly those associated
with metals . We feel we have made significant progress on the .
mercury situation, in particular, and hope you will agree.
We believe the more recent monthly analyses support our
contention that we have a handle on the problem. We will
continue our efforts to further decrease the levels of
mercury in our effluent and hope to provide a margin for
error.
We are aware of only three POTW' s in this area who have
this low limit, although there may be others . We have
wondered about this since there are no downstream users of
Buffalo Creek for potable water to our knowledge .
We ask that you take into consideration the city, s ongoing
efforts to locate, isolate, and remove any problems . we have
purchased new sampling equipment , underwritten added lab
..testing, improved staff training. and have implemented an
aggressive pre-treatment program. All of these have addressed
the mercury problem, and have generated major improvement, as
is apparent since August, 1992 . We have not ignored this
situation but have pursued the source in a diligent manner.
Please call me if I can address any of these issues in
greater detail .
Sincerely,
Gala wa C�
Water/wastewa er Dir.
City of Kings mountain.

~XICS
I rig
Detecfion and
Quantl'tatl'on
ndustrial and municipal effluents are routinely monitored to en-
sure compliance with discharge permit limits. Permits can be written
as"zero"or"nondetectable"discharge, or contain set discharge limits
(a numeric value)not to be exceeded.What is"zero"or"nondetectable"
depends on the analytical method used to monitor the posed to an unacceptable concentration of pollutants
specific pollutant.For each method,concentration lev- in their effluents.
els can be defined at which the method can reliably de-
tect and quantify the pollutantofconcern. APPLYING DETECTION AND QUANTITATION
Over the years,many definitions of detection and LEVELS INAPPROPRIATELY
quantitation levels have been published without clear Many authors and organizations have defined detec-
specification of their intended end use,and,as a result, tion and quantitation levels. The common thread
some have been inappropriately applied in compliance among the definitions is the use of a factor multiplied
monitoring situations.An example of the latter is the by the standard deviation of the blank or of an analyte
use of the detection limits published without defini- concentration near the expecteddetection limit.The m
tion by the U.S.EPA in Methodsfor Chemical Analysis sulting definitions vary in their selection of the factor
of Water and Wastes (EPA-600/4-79-020). Unfortu- and consequently in the probability of seeing falseposi-
nately,these limits have been used in the regulatory tive errors(reporting something as present,when itisnt)
environment,where they were neither intended nor and false negative errors(reporting something as not
appropriate, because levels specific to compliance there when it is).It has long been recognized that more
monitoring had not been intro- clearly defined detection and quantitation levels are
Raymond F. Moddalone duced(Koorse,1989,1990). needed for compliance situations.The American Chemi-
When permit limits are set at cal Society Committee on Environmental Improvement
James K. Rice levels at which it is not possible to (ACS-CED(Keith, 1992)has recently proposed defini-
Ben C. Edmondson make reliable measurements,then lions based on EPA's existing Method Detection Limit
analytical variability alone can • (MDL)(Glaser,1981;FR 49,43430,1984)that are not
Babu R. Non cause a permit limit to be ex- appropriate for use in compliance monitoring situa-
Judith W. Scott ceded. When an inappropriate tons.The ACS-CEI definitions are inappropriate for
limit is incorporated into a compliance monitoring for three reasons.
facility's National PollutantDis- Using pooled single operator standard deviation.
■ charge Elimination System The ACS-CEI approach suggests that the precision as-
(NPDES)discharge permit,indus- sociated with MDLs from individual laboratories be
trial and municipal permittees may be subject to civil pooled to take info account interlaboratory variability.
and criminal enforcement actions for exceeding the This pooled precision is the square root of the average
Emit solely as a result of analytical variability,as op- standard deviation squared obtained by many single
January 1993 40

May 09 , 1991
N.C. Dept. of EH&NR
- Environmental Management Div.
Permits and Engineering Unit
P.O Box 27687
Raleigh, N. C. 27611-7687
Attn. Mr. Donald Safrit
SUBJECT: Permit No. NC0020737
Kings Mountain .Pilot Creek
Dear Mr, Safrit:
As you are aware , The City of Kings Mountain has two
wastewater treatment plants : Pilot Creek # NC0020737 and. .
McGill # NC0020745
Dilution factors established for the two plants due to
chronic toxicity testing are : McGill 91% effluent, Pilot
Creek 24% effluent . I note these dilution factors as I feel
they should have a definite bearing on the permit limits we
operate under. However, this seem not to be the case .
The limit I wish to address is that for mercury. At our
McGill Plant our limit is . tug/l . Prior to 1989 there was no
limit at Pilot Creek. In fact, we were not even required to
test for mercury.
The limit now in effect at Pilot Creek is . 04ug/l ,
sampled weekly.
Mr. Safrit, this limit is , in our opinion, unnecessarily
low.
We have neither the equipment nor the expertise to per-
form this test and the laboratories we have contacted quote
us in the range of $90--$100 per sample, and many would not
quote . This means we will spend some $5 , 000 per year on
testing for this one parameter.
We hereby request relief, either. by being allowed to run
the sample monthly, or that the limit be raised by a factor
of five

In all our sampling, both in-plant and in our pretreat-
ment program, we have never had any "test for mercury which
was not shown to be < . 2ug/1 .
Also, it is our understanding that the water quality
standards for freshwater are set at . tug/l .
Thank you in advance for your consideration in this
matter, and if we can be of assistance, or if you need
further information, please call either myself or ee Ron
Tignor at (704 ) 734-0736 .
Walt 011is
W�r/�wast.4_te �,
City of Kings Mountain
1