NC0020231_SPECULATIVE LIMITS_19930215

NPDES DOCUWENT SCANNINS COVER SHEET
NPDES Permit:
NCO020231
Louisburg WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Data Monitoring Report
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
February 15, 1993
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DIVISION OF ENVIRONMENTAL MANAGEMENT
February 15, 1993
MEMORANDUM
TO: Charles Lowe
FROM: Z.usan,A—. W.iIson
THROUGH: Ruth Swanek R�
Carla Sanderson
SUBJECT: Town of Louisburg (NPDES No. NCO020231)
Tar River, Tar River Basin
Franklin County
The Technical Support Branch (TSB) has received the Tar Pamlico Basin Association's
request, on behalf of the Town of Louisburg, to delete the permit limit for total
phosphorus. The Basin Association also requests that the BOD5 limit be expressed as a
C130D5 limit.
The TSB concurs with the Basin Association's request to delete the permit limit of 2 mg/l
total phosphorus for all wasteflows in the Town's permit. Standard language pertaining to
the Town's participation in the Association should be inserted as a special condition in the
permit as follows:
Limitations on total nitrogen -and total phosphorus have not been included at this
time since this facility is participating in the nonpoint source trading option outlined
in the Tar Pamlico NSW Implementation Strategy adopted December 14, 1989 by
the EMC. If any element of this strategy is not complied with, the Division
reserves the right to reopen this permit to include nutrient limits.
In addition, a CBOD5 limit may be substituted for the BOD5 limit listed in Louisburg's
permit, if the Town agrees to the CBOD5 limit. The following limits may be substituted
for BOD5:
Wasteflow CBOD5 (mg/1)
sum/win
0.8 MGD 25/25
1.1 MGD 8/16
1.37 MGD 8/16
After the expanded plant is built, the Town may collect split CBOD5/BOD5 samples if they
wish TSB to consider the possibility of a higher CBOD5 limit.
Also, based on new information from the Pretreatment Unit, the monthly metals monitoring
requirement at the 1.37 MGD wasteflow may be dropped [ref. letter to Mr. Lee Smith
10/31/91). The monitoring requirement for lead should remain for both the 1.1 MGD flow
and the 1.37 MGD flow, as is standard procedure for any municipality over 1 MGD. The
monitoring frequency for lead should remain consistent with the classification of the
facility. Should the composition of the wasteflow change in the future, the permit may be
reopened to include other metals limits.or monitoring requirements.
cc: Tim Donnelly, RRO
Dana Folley, Pretreatment Unit

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cohey, Jr., Secretary Director
October 31, 1991
Mr. Lee Smith
RegionalOfficespublic Works Director
Asheville 1100 West Nash Street
701251,6208 Louisburg, North Carolina 27549
Faymcville
919/486-1541 Subject: Industrial Waste Survey Review
SOC 90-05
Monre.ville Town of Louisburg
704i6 i3-1699
Franklin County
Raleigh
9191733-2314 Dear Mr. Smith:
V'a,hingion
919,94(,6491 The pretreatment staff of the Division of Environmental
Wilmington Management has reviewed the additional Industrial Waste Survey
9191395-39W information submitted by Peirson & Whitman on behalf of the
Town of Louisburg and received by the Division on August 30,
Winston-Salem 1991. The submittal was made at re irbd b) (4)
919�s96-7«r7 � b Y paragraph ra h g P 2 (
of SOC 90-05, and more specifically in response to the
Division's June 19, 1991, letter reviewing the previously
submitted Industrial Waste Survey.- While review of the entire
survey does indicate that the POTW feels the discharges from the
two food processors, Cal -Maine Food and Murphy House Barbecue,
are at times having an adverse impact on the POTW, the Division
feels that these discharges do not represent Significant
Industrial Users, and thus will not require the POTW to proceed
with the development of a Division approved pretreatment program
at this time. Therefore the request from the Town for
modification of its NPDES permit to require development of a
pretreatment program, as required in SOC item 2(b)(5), is -not
necessary. The basis for this judgement is as follows:
The -process wastewater discharge from Murphy House Barbecue and
Cal -Maine Foods combined represents less than 1% of the flow
to the POTW. The difficulty with Murphy House Barbecue appears
to be slug loading of Oil & Grease. This pollutant is easily
removed by proper installation and maintenance of a grease trap,
which can be required by the POTW under its Sewer Use Ordinance
according to Mr. Acquesta of Peirson & Whitman. The POTW
should proceed with enforcement of this Ordinance in order to
protect its WWTP and collection system from upset and
interference. This enforcement could include requiring the IU
to establish a written schedule for regular pumping and other
PO. Bux 29535, Raleigh, North Carolina 2702611535 Telephone [phone] ! Pollution Prevention Pay,
.An Equal Opp>miniry Artvmati%e Acti-i Emnlr r

maintenance activities of the trap, and provide written
documentation to the WWTP operator for each maintenance event.
The difficulty with Cal -Maine Foods appears to be from slug
loads of BOD and from odor problems. Again, both of these
issues can be resolved by enforcement of the POTW's Sewer Use
Ordinance to require installation of equipment to prevent slug
loads. Additionally, it is understood from Mr. Acquesta that
the new WWTP to be built by the Town will need the BOD organic
loading from this facility in order to improve performance. The
POTW should review its SUO to determine if a locally issued
variance of the BOD limit found in the SUO will be needed.
Should the Town wish to pursue development of a Division
approved pretreatment program, either now or at a later date,
please contact this office.
One other issue of concern was discovered during the review of
the additional Industrial Waste Survey information. It was
confirmed that only the Franklin Regional Medical Center used
additives for water treatment in its non -contact cooling water
and/or boiler/tower blowdown. MSDS sheets were provided, and
review indicates at least one of the chemicals (CWT-501) added
is a biocide. The POTW should investigate the use of all of
these compounds, but most especially the biocide, to determine
the potential for impact on the POTW. The most efficient way of
doing this is to require the IU to contact the manufacturer of
the chemicals to obtain the purpose of the chemical additives
(biocide, descalers, corrosion oinhibitbrs, etc.), a list of
the active and hazardous ingredients, and the toxicity of the
compounds to aquatic life. This information, along with dosing
rates the IU uses for the compounds, can then be used in the
attached biocide/chemical treatment worksheet to evaluate the
chemicals. Also attached please find'some toxicity information
for CWT-501 provided by the Division's Environmental Sciences
Branch. (A copy of the form and the toxicity information were
also provided to Mr. Acquesta during a recent meeting.) Ms.
Dana Folley of the Division's Pretreatment Unit may be contacted
for assistance in completing and evaluating this information.
Should use of the chemicals at current dosages indicate a
potential for impact on the POTW or its receiving water, the
POTW can then prohibit use of the chemical at those doses by
authority of its SUO.

Please review the above comments and if you have any questions
or need assistance, -please feel free to call me at
919/733-5083. Thank you for your continued cooperation with
pretreatment program requirements.
Since ly,
J. T evor Clem s, Asst. Chief
to Quality Section
DRE
with attachments
cc's without attachments
CC: Kent Wiggins
Regional Supervisor
Central Files
Michael S. Acquesta, P.E. Pei-rson & Whitman

I r U l�
TAR PAMLICO BASIN ASS(
POST OFFICE BOX 1
GREENVILLE, NORTH CAROM
January' 21, 1993
Mr. Steve Tedder, Chief
Water Quality Section
Division of Environmental Management ; �.
512 N. Salisbury Street - -• _.
Raleigh, North Carolina 27604
Dear Mr.der:
The Town of Louisburg has recent informed the Tar amlico
Basin Association that i s NPDES permit contains total
phosphorus limits. As y u--kiow, Louisburg is a member of
the Tar Pamlico Basin Association, and, as a member, its
permit should not contain a numerical phosphorus limit. The
permit, which became effective January 1, 1992, contains a
quarterly average phosphorus limit of 2.0 mg/1 year round.
I am writing to request that, pursuant to the Tar Pamlico
Agreement, the numerical phosphorus limit in Louisburg's
NPDES permit be removed. We request that the standard
language that has been included in part III of the NPDES
permits of Association member facilities be added in lieu of
the phosphorous limits as follows:
Limitations on total nitrogen and total
phosphorus have not been included at this
time because this facility is
participating in the nonpoint source
trading option outlined in the Tar Pamlico
NSW Implementation'Strategy adopted
December 14, 1989 by the Environmental
Management Commission. If any element -of
this strategy is not complied with, the
Division reserves the right to re -open this
permit to include nutrient limitations.
Additionally, in keeping with the best available science,
Louisburg's permit should be modified to express permit
limits as CBOD , not BOD . If not, difficulties are
expected with accurately reporting organic discharges
because of the nitrification requirement now in the permit.
(See -enclosed article).

Mr. Steve Tedder
January 21, 1993
Page 2
Thank you for your attention to these matters. Please let
me know if you have any questions. I look forward to
hearing from you or Louisburg that thepermit has been
modified.
Sincerely,
Malcolm A. Gre n, Chairman
Tar Pamlico River Basin Association, Inc.
MAG:cds
cc: Lee Smith; Director of Water Resources
Town of Louisburg
Enclosure
q

r tt
RECEIVED
ROUGH
SEP 0 1 1992 DRAFT
TECHNICAL SUPPORT BRANCH
x
tLrshall'Staton
Peirson & Whitman Architects and Engineers P.A.
5510 Munford Road
Raleigh, NC 27612
Dear Marshall:
8/28/92
2:45 p.m.
As requested, we have considered your inquiry regarding the
proposed 2,000,000 gallons per day withdrawal by the Franklin
Water & Sewer Authority from the Tar River at a point near the
intersection with US Highway #1, where the drainage area is about
328 square miles . We believe the information provided below is
suitable for use in the preparation of a draft environmental
assessment.
The environmental assessment (EA) will be reviewed by a
number of State and federal agencies. It may be useful to
confer with the Wildlife Resources Commission and the Division of
Environmental Management, prior to submitting a draft
environmental assessment to the Division of Environmental Health
for Departmental review.
For planning purposes, with a 2,000,000 gallons per day
water withdrawal rate, an off -stream usable storage capacity of
about 115,0001000 gallons should be adequate to avoid a condition
that would reduce streamflow below 7Q10 flow values on the Tar
River at the point of withdrawal. This storage capacity will
also allow for increased municipal withdrawals at Louisburg up to
the reported water treatment plant capacity of approximately

(2)
2 MGD. This is based on USGS streamf low records and operating
criteria that calls for the withdrawal of 2 mgd to cease when a
staff gage located upstream from the withdrawal point indicated
that flows were at or below 9 cfs.
We believe these figures are suitable for preliminary
planning purposes; however, as discussed, this proposal will be
subject to review and comment by various agencies. There could
be certain conditions that would be unanswered by this withdrawal
proposal such as critical habitat concerns by the Wildlife
Resources Commission and water quality considerations by the
Division of Environmental Management. Thus, further review could
result in more restrictive withdrawals. Therefore, preparation
of final plans and specifications -should be held in abeyance
until the Environmental Assessment is approved.
If you have any questions regarding the above, please let me
know.
Very truly yours,
John D. Wray
JDW/bb
cc: John Morris
Fred Harris, WRC
Trevor-Clemdnts_; -DEMV
bcc: John Sutherland
Steve Reed
Tom Fransen
Tony Young
Woody Yonts
Lisa Routh