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Home My WebLink AboutNC0020664_Request For Time Extension_20200109 CAR0 Z ..o.. a PECE\VED „Nil of Spinda/e JAN 13 2020 Najaf NCDEQIDWRINPDES PO Box 186 . 125 Reveley Street• Spindale,NC 28160 Phone: (828) 286-3466 • Fax: (828) 286-3305 January 9, 2020 NCDEQ/DWR NPDES Permitting Branch 1617 Mail Service Center Raleigh,NC 27699-1617 Attn: Gary Perlmutter Re: Town of Spindale NPDES No.NC0020664 Comments and request for time extension Dear Mr.Perlmutter, The Town of Spindale is in receipt of your email dated December 19,2019 in response to our comment letter dated November 26,2019. Thank you for providing the public notice affidavit and for your comments and clarifications. I am attaching metal testing that has been conducted on the influent and effluent of the plant. As can be seen,the silver was non-detect and the copper was 28.6 µg/L. I wanted to point out that the test limits for silver were 0.5 µg/L,which is above the proposed effluent limit of 0.3 µg/L. This is the lowest detection level that the Town of Spindale has access to. Based on the regulation you specified in your email, 15A NCAC 2B .0505,we would presume that a non-detect for silver in this case would be considered in compliance with the proposed permit limits. We are in the process of taking additional samples to gauge the pollutant concentration levels. The results of these test will provide monthly average discharge data that the NC DEQ can use to update the RPA. The test procedures currently being used have minimum detection limits that align with the proposed silver and copper limits in question. This testing will also determine if compliance is possible and to identify the sources of pollutants to allow us to take actions to reduce the pollutant concentration levels if necessary. The Town is requesting a six month period to perform the additional influent and effluent testing. We will provide the test results to NC DEQ for the purpose of updating the RPA and reassessing the potential for contamination. We have identified potential sources of the pollutants in our sewer shed and are in the process of testing samples taken from the respective SIU's and or commercial users. We are performing a mass balance analysis with the results to determine the primary sources of the containments. One of the SIU's that we have identified as a potential principal source of the pollutants has shared with us that its silver and copper discharge change with the staffmg and manufacturing processes and that these fluctuate during the year,especially in the four quarter. Namely,the current SIU sampling is expected to yield lower concentration levels due to a reduction in production at this time of year. We are requesting an additional six month time period following the six month intensive data collection period and re-evaluation of the RPA to investigate methods of pollutant reduction if the study finds that to be necessary. In light of the above fmdings,we would like to request that a one year"grace period"before the copper and silver effluent limits are put into effect to complete the two tasks discussed above. During that time the Town will: (1)generate valid monthly average Cu and Ag data of at least 4 samples a month(always using clean techniques,of course),(2)investigate possible sources of these pollutants,including both SIUs and possible commercial sources,and(3)investigate methods of pollutant reduction if necessary. We would also ask that the permit allow that the copper and silver limits could revert to"monitor only"if the sampling and updated RPA demonstrate that they are not necessary. In response to your comments on the proposed sampling point,I am attaching a pdf taken from Google Earth showing the current and proposed sampling points. From this aerial view,as well as from discussions with the town staff,the current sampling point is the closest to the actual discharge point with safe access. We would request that the new permit would allow the current discharge point to remain as the designated NPDES upstream sample location. I realize that this is upstream of the convergence of Hollands Creek and Cathey's Creek. Unfortunately the effluent line coming from the WWTP parallels Hollands Creek and discharges at the convergence of the two creeks. This and the issues related to the sampling from the bridge, as mentioned in the previous letter,make a pristine sample point unavailable. To summarize our request in conclusion,we are requesting a one year delay in the implementation of the proposed silver and copper limits. During this time,the town will engage in 4 tests a month for the first six months to determine influent and effluent pollutant concentrations. These tests will be conducted using sampling and testing procedures with minimum detection limits that correspond to the proposed NPDES limits. This data can be used by NCDEQ to reassess the RPA and to reassess the proposed NPDES limits. If the reassessed RPA validates the proposed silver and copper limits,we are requesting an additional six month period to investigate methods of pollutant reduction. Very Truly Yours, Ca- Scott Webber Town Manager Pace Analytical Services,LLC aceAnalytical 8701 Conference Drive Rablgh,C 27607 www.pacelebs.cam (919)834-4984 Page 1 of 2 Laboratory Report Mr. Tony Gragg Report Date: 12/18/2019 Water Tech Labs Date Received: 12/06/2019 PO Box 1056 Granite Falls, NC 28630 Projoct: TOWN OF SPINDALE Pace Project No.:92456380 Sample: SPINDALE INFLUENT Lab ID: 92456380001 Collected: 12/03/19 09:00 Matrix: Water Method Parameters Results Units Report Urnit Analyzed Qualifiers EPA 200,8 Arsenic ND ug/L 0.50 12/17/19 15:30 EPA 200.8 Cadmium 0.21 uglL 0.080 12/17/19 15:30 EPA200.8 Chromium 35.2 ug/L 0.50 12/17/19 15:30 EPA 200.8 _ Copper 33.5 uglL 1.0 12/17/19 16:30 EPA200.8 Lead . 2.8 ug/L 0.10 12/17/19 15;30 EPA 200.8 Molybdenum 5.3 ug/L 0.50 12/17/1915:30 EPA 200.8 Nickel 5.9 ug/L 0.50 12/17/19 15:30 EPA200.8 Selenium ND ug/L 0.50 12/17/19 16:30 EPA200.8 Silver ND ug/L 0.50 12/17/1915:30 EPA 200.8 Zinc 169 ug/L 5.0 12/17/19 15:30 EPA 245.1 Rev 3.0 1994 Mercury ND uglL 0.20 12/12/19 12:28 Samplo: SPINDALE EFFLUENT Lab ID: 92456380002 Collected: 12/03/19 09:07 Matrix: Water Method Parameters Results Units Report Limit Analyzed Qualifiers EPA 200.8 Arsenic ND ug/L 0.50 12/13/19 01:32 EPA 200.8 Cadmium ND ug/L 0.080 12/13/19 01:32 EPA 200.8 Chromium 11.4 ug/L 0.50 12/13/19 01:32 EPA200.8 Copper 28.6 ug/L 1.0 12113/1901:32 EPA 200.8 Lead 0.43 ug/L 0.10 12/13/19 01:32 EPA 200.8 Molybdenum 1.1 ug/L 0.50 12/13/19 01:32 EPA 200.8 Nickel 2.2 uglL 0.60 12/13/19 01:32 EPA200.8 Selenium ND ug/L 0.50 12/13/1901:32 EPA200.8 Silver ND ug/L 0.50 12/13/19 01:32 EPA 200.8 Zinc 82.8 ug/L 25.0 12/13/19 20:14 Reviewed by: ""'.- - " Chris Derouen for Lorrl Patton 1(828)254-7176 lorri.patton@pacelabs.com Pace Analytical Services Minneapolis A2LA Certification#:2926.01 Connecticut Certification#:PH-0256 Alabama Certification#:40770 EPA Region 8+Wyoming DW Certification#:via MN 027- Alaska Contaminated Sites Certification it: 17-009 053-137 Alaska DW Certification#:MN00064 Florida Certification#:E87605 Arizona Certification#:AZ0014 Georgia Certification#:959 Arkansas DW Certification#:MN00064 Guam EPA Certification#:MN00064 Arkansas WW Certification#:88-0680 Hawaii Certification#:MN00064 California Certification#:2929 Idaho Certification it:MN00064 CNMI Saipan Certification it:MP0003 Illinois Certification#:200011 Colorado Certification#:MN00064 Indiana Certification#:C-MN-01 Page 1 of 5 Spindale WWTP I� ' Legend Current and Proposed Sample Points J ) Point II • Current Upstream Sample Pont I// ' ` .. •dip: H Proposed Upstream Sample Point Plant Effluent Foi /111 1/.. Google Earth 400 ft