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HomeMy WebLinkAboutNC0020800_CORRESPONDENCE_20030812NPDES DOCYNENT SCANNIN& COVER SHEET NPDES Permit: NC0020800 Andrews WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Correspondence Speculative Limits Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: August 12, 2003 This document is printed on reuse paper - ignore P.ay content on the reverse side O Wn1F9 �.�'.h�-(a -i Michael Ladd Io%in of Andrews P O Bo\ 1210 Andre %N s, NC 28901 Dear NPDI S PUmltt(CC Michael F Easley Governor William G Ross Jr Secretary North Carolina Department of Environment and Natural Resources Alan W Klimek P E Director Division of Water Ouahty August 12 2003 Subject NPDI S Perim NCO020800 AIcrcury Requirement L.PA Method 1631 / Additionil Inform2non Andrews W\V 113 Chcrukcc County In a previous IUCU dttcd August 30, 2002, %our finhn wIS nouficd of bung subJcct to i ncNv low-ICVCI mcrcury inilysis (I -PA tAlcthod 1631) for NPDES monitoring rcguircnxnts bcguming September 1, 2003 1 he notification letter wis mmled to 155 subject facilities Since that mmlulg the Division his pirticipited u1 severil Nlercun 1631 Workshops to punidc rho, reguhtcd commui with mforminon on the new inihncil requirements ind glean sampling reconulluiclinons Biscd on comments recened it these workshops, ncc follo\%ing items are intended to clinfN cert un NPDI-S tequirements for the 155 subject ficilmes 1 Dlercury Sampling ind Comphinee It is recommuuled that facilities collect some cfflucnt simples for Method 1631 inilvsis prior to the 9/1/2003 effectne date, in order to gmn e\pencnce with the recommended clean sampling techniques is well is the inilosis requirements NPDES compliance Will be judged using the new method results beginning 9/l/2003 2 Whit Simples ire Subject to Method 1631 Beginning 9/l/2003 ill cfflucnt simples collected for mcrcury from the, subject ficihtN ire required to petform Iom Icvcl mcrcutN inil sis Ihis meludes effluent simples collcucd for inN of du following requirements i) monitoring spccificcl In tour "Lfflucnt Limititions ind Monitoring Rujmruncnrs" pige of vour NPDES permit b) monitoring ,pccificcl u1 lour NPDES Prctreitincnt Short Icrm Nlonnoung Plan (SINIP) or Long lcrm Monitoring Min (1,1NIP), and c) NPDL'S permit renewil recjuiruncnts I he cfflucnt simples must be miilvc d by a l ibor non certified bN the Division for Method 1631, ind effluent rcwits must be submrttcd with the ipphc ible monthly Dinh ir�e Monitoring Report (DNIR) 3 Grit) Smnplirw 1 he I nvironmentil Protection AgeneN (1, PA) currcnth reunnncnds that mereun simples foi Method 1631 in ilN sis be eolle eted is grab smnplcs smee iunimitie composite samplers may be more subject to contamination I hero -fore, the Division wdl illow permittecS to colleen single grib samples dirccrh into I ib- proNndcd sample bottles for permit requircinenn cNcn though the NPDES punnt mr1 specifN "composite" samples for mcrcury I he grib sample must be represcntanve of the chsehirgc 4 Libormoly Reporrin,g LeSel Based on the Division's review of conuneruil labowtorics currcnth perfotming Method 1631, 1 n1 yott i of libs Nierc reporting i minimum ILvo,l of cjuinntinon (NIL) of either 10 ng/I or less I he DiNnion sill ruluire m11V11 of 1 ng/I bcgmnmg 9/l/2003, which is considered reasonable ind economicilh achicvgblc 5 1 field Blink Colleenon Nlethod 1631 requires that i nur unurn of one flLld blank io,conipam each ser of sunpIcs collected from the smile site it the same rime I he field blank is stud to idcnnh contamination during sunplc collection and it Insputt actlN tires If mereun is pro -scut in the field blank it IeN els tlnt vMould comptomise rchiblc mcastrremcnt of mereun in the wastewater s unpie, 1ou should Issume that the cfflucnt sample Ras eormunulted during collection or transit ind Noll kill rleeel to clununtc '111N source of conimnmition chic his been idcntificcl the punuttcc shill Icputt ill effluent simple results on the Ipphelble mouthy DNIR If i field blink fills to meet cjuihtN conuuj unern, ncL permittee should note that fact Ill the EMIR comments Section and append ncL 111) shell III thu field hunk I or thou fieilims smnphng for muuuN under i Iunuccl monitoring flcquulev (qurrtuh of Icss such is Prcrreannenr I tNIP/SIMP numuoung) Noll nuiu Icsunplc if the field blanks tre outside qu tht% unmol uitun I IoWCV(r, foi thou fiuhnes %N lrh nuns Gequent cfflucnt monitoring rujuirunults ��• N C Division of Water Quality 1617 Mail Service Center Raleigh NC 27699 1617 (919) 733 7015 Customer Service 1 800 623 7748 N CUENR D NPDI S Mnuuv Rcquncntcnl Pdgc 2 of 2 (I c month% of more ficcluctat), Iesvnphng is not requucd It fidd blink yulhR control criteria atc not aehicaed to] I gis cn S Implc, cS cnt RCfu to Method 1631, Rcvsion I (5l.etlon 9 4 5 2 ( )uahq Contt0l- Field Blanks), for Speuhc yu Ihn conool uaena rcgvcling field blank acecpIabIhn and ctfluent sample reabilm 6 1icld Blink SUIMIC11011 Mlcthod 1631 piolicics for subtaction of field blanks (proSidcd thc% nxct yuahn contiol critun defined abo%c) from the effluent sample tesult if deenicd apptopnite bi a tcguhtori agena Upon ICSiew, the DIv1S10❑ Scdl not alloxt field blank subtraction from effluent samples for reporting purposes Bncd on I recent stud% using MlcthOd 1631 for wastewater svnplcS collected at 38 wastc%�itcr treatment plants, Field blink coneuurations %�crc general% bclov� the method duvltitation IClcl Ihuefote, beginning 9/1/2003, the penmttcc shall report the result of the effluent sample IS punndul bi the certified lab, without field blank subtaction on the month%, DMIR submission In the event of a mcrcun' hmits violation the pemlittce retvns the option to rcduest runisvon of am penaltN if the. perinittcc bd1eVCS that the viohnon resulted from b iekground contamination is indicated by the field blank, the pennittce will need to document chat fact with field bl Iol, qu Ihty control clan 7 Sunple PreServmon/I loldmg limes Samples for totd mcrcun vnlpvs bl Method 1631 must be collected in nghtk elppcd fhurropolvmcr or glass bottles and prcutvcd with BrCI or IIQ within 48 hours of slmplc. collccnon I he rime to S implc preservation mat be Lvtendcd to 28 d tvS if I Sample is ovdved in the Sample bottle SvnplcS nwst be vnIVied Svthm 90 dais of Sample collccnon if iou have ant qucStions about the contents of this letter, plcaSc contau the applicable Division staff listed below Nlcrcunv Method Qnnfied Libs for Method 1631 NPDI S Permitting NPDLS Compliance NPDLS Pretreatment Rov Bt rd Fred Bone Pom Belmck Vanessa Nlanucl Dana hollev SincercIv, 919-733-3908,cetcnsion 213 919-733-3908,extension 273 919-733-5083,cvtcnsion 543 919-733-5083,c\tension 532 919-733-5083,evension 523 Original Signed By David A Goodrich Al in W hhmck P L CC (h irdcopi) CI tANC c/o I cw 1 ticks Lm aonmeriml Chcmist Inc 6602 Windmill WIN Wilmington NC 28405 DWQ RegionalOfficcS WiterQualm CC (cm ul) 1 PA Rogion 4 Mladolm Domim M irshall f hair DWQ WItcr Qu ihn Sccnon Regional Office Supetr isors DWQ I ilimuon Sccnon Stese Pedder I arrN tAuslcl JIm Mlctcr, Rot Blrcl, 1 red Boric DWQ Mlodduig/ I MIDI Nltchellc Woolfolk DWQ NPDF" Comph race V In6Ssa Nlanucl DWQ PrUO-Itmun Unit DAVQ NPDLS Una NC I e IgUL of Mlumcipahtieo Anita Watkins NQ I ahS Ccrnficd for Method 1631c NCO020800 w9mst'�� -1 Michael F Easley Governor William G Ross Jr Secretary North Carolina Department of Environment and Natural Resources August30 2002 Subject NPDES Mercury Requirement Implementation of EPA Method 1631 Dear NPDES Permittee Alan W Klimek P E Director Division of Water Quality Mercury continues to be a water quality concern throughout North Carolina Fish consumption advisories and impaired stream segments as a result of elevated mercury levels have been issued for several locations NPDES perrmttees have worked with the state to reduce potential risks from this pollutant including tasks associated with collecting and reporting more accurate data The most commonly used laboratory analysts for total mercury (EPA Method 245 1) has a method detection level of 0 2 ug/1 while the current water quality standard is an order of magnitude lower at 0 012 ug/1 Thus true compliance with the water quality standard could not be judged A more recently approved laboratory method (EPA Method 1631) should produce a detection level below the water quality standard which would allow the Division to assess potential water quality impacts from dischargers more accurately Therefore this letter serves as notification to your facility that effective September 1, 2003 you will be required to begin using EPA Method 1631 (or subsequent low-level mercury methods approved by EPA in 40 CFR 136) when analyzing for total mercury Your facility is subject to this new requirement because either 1) your facility has a current total mercury Intuit in its NPDES permit that is <0 20 ug/1 or 2) your facility has limited mstream dilution (i a the mstream waste concentration (IWC) is >6%) This requirement complies with 15 A NCAC 2B 0505(e)(4) which requires that test procedures must produce detection and reporting levels below the permit discharge requirements Mercury Laboratory Analysis - EPA Method 1631 On June 22 1999 the US EPA approved a new analytical method (EPA Method 1631) for measuring very low concentrations of mercury in water Subsequent revisions to Method 1631 include Revision C (current approved method) and Draft Revision D (scheduled for promulgation in October 2002) Method 1631 has a rmmmum level of quantitation of 0 0005 ug/1 (0 5 ng/1) which is 400-times more sensitive than Method 245 1 The new method requires a clean laboratory environment which generally requires some lab retrofitting thus many permittees will likely contract a commercial lab to perform the analysis Based on data compiled by Ohio EPA commercial labs that are currently analyzing for EPA Method 1631 charge between $50 90 per sample with turnaround times ranging from 5-28 days Currently there is one commercial lab certified by North Carolina for EPA Method 1631 However it is anticipated that several additional labs will also offer this analysis in the future as the demand for this method increases When selecting a lab to perform low level mercury analyses the permittee should review the lab s performance experience and reliability with the method as well as cost considerations Attachment A provides additional information on this method Mercury Clean Sampling Techniques - EPA Method 1669 The greatest risk of contaminating the wastewater sample for low level mercury analysis is during the sample collection effort Thus those facilities subject to EPA Method 1631 will also need to evaluate clean sampling recommendations provided in EPA Method 1669 Attachment A provides highlights on this method NPDES Compliance All mercury monitoring data submitted to the Division will be reviewed for compliance with current effluent limits If the permit contains monitoring only the new method must still be used and the need for a permit limit will be evaluated at a later date by comparing a statistical evaluation of the effluent data with the water quality standard and corresponding allowable effluent concentration Therefore the potential problem of sample contamination cannot be overemphasized since it could result in NPDES effluent limits for total mercury increased monitoring costs and possibly unnecessary violations All data submitted to the Division for NPDES compliance monitoring requirements are the responsibility of the permittee Therefore facilities subject to this new method are strongly encouraged to begin evaluating sampling methods and commercial labs before the deadline date to ensure that field staff are properly trained in the use of clean sampling techniques and sampling and lab procedures are fully developed to minimize sample contamination AT'x N-C DENT N C Division of Water Quality 1617 Mail Service Center Raleigh NC 27699 1617 Customer Service 1 800 623 7748 (919) 733 7015 NPDES Mercury Requirement Page 2 of 3 Additional Information For additional information and guidance regarding EPA Methods 1631/1669 the permittee may consult the following resources North Carolina Division of Water Quality Laboratory Analysis Roy Byrd 919 733 3908 ext 213 Lab Certification Lab Staff 919-733-3908 Clean Sampling Sandy Mort 919 733-2136 ext 245 NPDES Perrruthng Tom Belnick 919-733 5083 ext 543 Pretreatment Tom Poe 919-733-5083 ttxt 522 US Environmental Protection Agency Method 1631 / 1669 Questions Maria Gomez Taylor 202 566-1005 EPA Sample Control Center 703-461-2100 Websites http //www ena state oh us/dsw/guidance/permdl0att3 odf The state of Ohio EPA provides an updated listing of laboratories providing contract services for EPA Method 1631 including costs turnaround time and lab contacts The labs are identified for informational purposes only and do not constitute an endorsement The listed commercial laboratories may also provide advice on training equipment and sampling techniques appropriate for Method 1631 http //www ena gov/ost/methods/ 1631 him] This EPA site provides information on the 1631 Method requirements and implementation guidance http //www esb enr state nc us/lab This DWQ site provides information on EPA Methods (including 1669 clean sampling techniques) and a listing of state -certified labs for EPA Method 1631 http //www h2o enr state nc us/NPDES/NPDESweb html click Documents This DWQ website includes a copy of this letter plus a list of facilities currently subject to EPA Method 1631 Conclusion The Division realizes that changing the method of mercury measurement will not be without difficulty on the part of the perrruttees The requirement Will affect approximately 155 facilities With mercury limits and/or monitoring requirements These permittees will need to evaluate available laboratories costs and sampling techniques For these reasons the implementation date for EPA Method 1631 was delayed until September 1 2003 The Division thanks you for your cooperation and understanding in this matter If you have any questions about the contents of this letter please contact the applicable staff listed above _ Sincerely ' JWilliam Reid PE Supervisor Point Source Branch cc (hardcopy) CLANG c/o Lew Hicks Environmental Chemistry Inc 6602 Windmill Way Wilmington NC 28405 cc (email) EPA Region 4 Marshall Hyatt Scott Gordan Roosevelt Childress DWQ Water Quality Section Coleen Sullins Regional Offices DWQ Laboratory Section Steve Tedder Larry Ansley Jim Meyer Roy Byrd Conine Brower DWQ Aquatic Toxicology Unit Sandy Mort DWQ Pretreatment Unit Tom Poe DWQ Modelmg/TMDL Michelle Woolfolk DWQ NPDES Compliance Unit Shannon Langley DWQ NPDES Unit MCIC Michael Johnson NC League of Municipalities Paula Thomas Clean Water Fund of NC Hope Taylor Severn Trent lab Ohio Mark Bruce NPDES Mercury Requirement Page 3 of 3 ATTACHMENT A Summary of EPA Methods 1631/ 1669 Effluent samples collected for mercury may become contaminated by numerous routes including 1) metal - containing labware reagents containers and sampling equipment 2) improperly cleaned or stored equipment and 3) atmospheric mercury inputs in dirt and dust Even human contact can be a source of mercury contamination (e g mercury amalgam fillings in the mouths of lab/field personnel can contaminate samples directly exposed to exhalation) Thus it is essential that every effort be made to minimize sample contamination dunng collection The US EPA provides recommendations to nummize contamination dunng sample collection in EPA Method 1669 Sampling Ambient Water for Determination of Trace Metals at EPA Water 9uaitty Cnteria Levels This guidance describes a clean hands/dirty hands sampling technique to collect mercury samples which is ideally performed with two people A designated clean hands sampler handles all operations involving direct contact with the sample bottle while the dirty hands sampler is responsible for all activities that do not involve direct contact with the sample bottle This team sampling technique is recommended as a means to minimize sample contamination but is not required The US EPA is developing a trace metal sampling guidance strictly for effluent collection (Method 1670) The perrmttee will need to evaluate the various sampling recommendations and develop a sampling strategy appropriate for their particular situation The overall philosophy behind any mercury sampling strategy should be to ensure that any object or substance that contacts the sample is nonmetallic and free from any material that may contain metals in order to produce a reliable mercury measurement Requirements and recommendations for EPA Method 1631 and clean sampling for low level mercury mciude • It is strongly recommended that the permdtee discuss sample collection preservation and shipping requirements with their laboratory to ensure that the most current requirements of Method 1631 will be met There have been several revisions to EPA Method 1631 and Revision D is proposed • Each laboratory must perform and meet the nummum requirements of Method 1631 Quality Control • Effluent samples for mercury analysis must be collected in clean fluoropolymer or borosilicate glass containers It is recommended that the permittee request appropriate clean sample bottles or a mercury sampling kit from their lab • Method 1631 requires that a nunimum of one field blank accompany each set of samples collected at a given site The field blank is used to identify contamination from sample collection and transport If mercury is present in the field blank at levels that would compromise reliable measurement of mercury in the wastewater sample you should assume that the sample was contaminated dunng collection or transit and you will need to eliminate any source of contamination that has been identified and possibly resample Including the field blank the perrmttee should budget for two samples per monitonng event • Samples must be preserved or analyzed within 48-hours after collection Samples do not need to be refrigerated/iced dunng shipment provided they are tightly capped shipped ovemight to the lab and preserved or analyzed by the lab within 48 hours of collection (per Draft Revision D) • If the samples are preserved within 48 hours then they have a maximum holding time of 90 days prior to analysis (per Draft Revision D) • Sampling personnel must wear clean non -talc latex gloves dunng sample collection and handling • EPA currently recommends that mercury samples for Method 1631 analysis be collected as grab samples since automatic composite samplers may be subject to contamination and loss of mercury via volatilization Therefore the Division will allow perrruttees to collect single grab samples directly into lab -provided sample bottles for pernut requirements The grab sample must be representative of the discharge • if the person collecting the sample cannot directly reach the wastewater stream a pole type sampler may be attached to the sample bottle to extend the reach for sample collection The pole and bottle clamp should be made of plastic and/or stainless steel and the mouth of the bottle should be held facing upstream of the pole The use of a transfer vessel should be avoided • All sampling equipment must be nonmetallic or free of material that may contain metals All materials that will directly or indirectly contact the sample must be cleaned using the procedures in Method 1631 • To minimize atmospheric contamination do not sample dunng rainy weather or when the wind could blow dust particles into the sample bottle To minimize human contamination do not breathe into the sample bottle if you have mercury amalgam fillings in your teeth • Sampling personnel should be trained in techniques for sampling mercury at low levels Sample collection via the clean hands/dirty hands technique is recommended but not required • Since Method 1631 is performance based there is some flexibility in Method requirements