NC0023981_staff comments_20190702

Weaver, Charles
From: Weaver, Charles
Sent: Tuesday, July 2, 2019 11:11 AM
To: Heim, Tim
Cc: Gore, Deborah; Fertenbaugh, Christyn L
Subject: RE: [External] permit question - NC0023981
Tim — it's helpful that Ms. Triplett has told us that Lenoir didn't comply with the permit. That will simplify the NOV they
should receive.
They have violated Part I. A. (6) 1. and I A. (6) 2. She doesn't think they will violate Part I. A. (6) 3., except they probably
will ("only 3 effluent samples would have violated the more stringent effluent permit Cu limits that
we have").
Her statement regarding metals is interesting:
"We have no incoming Cu or Cd to speak of , but there is a small amount of Cu that does come in
and a small amount of copper that does make it to the effluent"
Cadmium appears to not be an issue, or maybe it is, as they have not investigated it.
She says that Copper isn't an issue, except it is.
She's offered to submit a CAR (whatever that is), except it's not really a CAR. The permit requires a Corrective Action
Plan (CAP), which they don't have, and show little interest in preparing.
My recommendation is to send them an NOV for the existing violations. They should get to work on the required CAP
and source identification ASAP.
I've copied Deborah and Christyn in PERCS in case there are collection system/pretreatment issues that should also be
addressed. PERCS may need to help them with the source identification, as Lenoir may not know how to do that.
CHW
From: Heim, Tim
Sent: Monday, July 1, 2019 3:23 PM
To: Weaver, Charles <[e-mail]>
Subject: FW: [External] permit question
Hi Charles, hope you are well and looking forward to the Holiday. Do you have any thoughts on this one ... she has me a
little confused.
Thanks
-Tim
From: Triplett, Lisa R. <[e-mail]>
Sent: Monday, July 01, 2019 12:17 PM
To: Cantwell, Janet <[e-mail]>
Subject: [External] permit question
Hey Janet,
i

Hope your summer has been good so far. Pretty hot down this way. Anyway I have a question on
something I read on my Lower Creek NCO023981 permit. It is due for renewal Feb. 29, 2020 which
means I have to get it in by September, 2019. 1 have been working on it. As I was reading the
permit I know that we are going to have Cu limits added beginning September 2019, and the Cd
limits are going to be more stringent as well beginning in Sept. 2019.
With that being said, as I was reading some of the requirements I noticed that in A(6) there is a
schedule of compliance for hardness dependent metals, the permittee (me) was supposed to
perform source identification, and then to submit a CAR summarizing the actions to achieve
compliance with the total Cu and Total Cd limits by perform source identification of Cu, and Cd by
January 1 2019.
I didn't get a CAR submitted. I thought it was supposed to be included in the permit renewal
submission. Is this going to be an issue for us, or should I just go ahead and submit the CAR
now? Which I really don't have a corrective action to submit more of a statement type letter. We
have no incoming Cu or Cd to speak of , but there is a small amount of Cu that does come in and a
small amount of copper that does make it to the effluent, but out of the last 5 '/2 years of
influent/effluent data,(41 samples) only 3 effluent samples would have violated the more stringent
effluent permit Cu limits that we have.
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