NC0021369_Corespondence_19900321

NPDES DOCIMENT !;CANNIN` COVER !;ciEET
NC0021369
Columbus WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Corres ondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
March 21, 1990
This document is printed on reuse paper - igxiore any
content on the reirerse side

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
March 21, 1990
George T. Everett, Ph.D.
Director
Mr. Clyde Smith
Town Administrator
Town of Columbus
P.O. Box 146
Columbus, N.C. 28722
Re: Permit Modification Requests i n Re ests for Town of Columbus WWTP
NPDES Permit No. NC0021369
Polk County
Dear Mr. Smith:
Your permit modification request for the subject facility has
been reviewed by the staff of the Division of Environmental Manage-
ment (DEM). Please be assured that your concerns regarding newly
assigned effluent limitations and monitoring frequencies have been
given due consideration. The Division's recommendations for the
items addressed in your letter are as follows:
1. The revision of the North Carolina water quality standard
for fecal coliform to 200/100m1 is cited in North Carolina regula-
tion 15 NCAC 2B.0211 (3) (E) and became effective in October, 1989.
Your request for a time allowance for construction of a chlorination
system in order to comply with the new fecal coliform is valid based
upon review of your submitted daily monitoring reports. We recom-
mend that you contact our Asheville Regional Office and discuss the
option of entering into a Special Order of Consent (SOC). This
would afford the Town of Columbus a schedule period with interim
effluent limitations until your•treatment plant can meet the fecal
coliform standard.
2. Effluent samples for total nitrogen and total phosphorus
will continue to be required semi-annually. The Division's Per-
mits and Engineering Group follows the guidance of ,North Carolina
regulation 15 NCAC 2B .0500 in determining monitoring frequencies
for surface water dischargers.
3. The recommended effluent limitations for cadmium, chromium,
nickel, lead, cyanide and mercury included in the Town's NPDES per-
Poliudon Prev endon Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]

mit will remain intact. The Clean Water Act requires that toxics be
limited to nontoxic amounts before discharge to the surface waters
of the State. The Town of Columbus' pretreatment headworks analysis
indicates the presence of these substances and subsequent mass bal-
ance analyses indicated the need to place limits in your permit.
These limits were based upon standard Division operating procedures
that are approved by the U.S. Environmental Protection Agency and
are meant to prevent instream water quality standard violations from
occurring.
4. The inclusion of effluent monitoring requirements for copper,
zinc, and silver, is substantiated by the fact that the State has
action levels for these toxic substances. These action levels have
been determined by The Division's wasteload allocation to be
exceeded under low flow conditions in the receiving water'due to the
Columbus WWTP discharge . Based on North Carolina regulation 2B.
0211 (b)(4), " the discharger will be required to monitor the chemi-
cal and/or biological effects of the discharge". In addition, the
monitoring requirements may be revised to effluent limitations, if
sufficient data indicates that water quality problems are being
caused.
The evaluation of additional factors contributed to our decision
to include these limits in the NPDES permit. First, the Pretreat-
ment Headworks Analysis (HWA) submitted by Columbus used default
data for removal efficiencies and domestic contributors, therefore
the fact that the industry is in compliance with its pretreatment
permit does not necessarily mean that water quality standards for
the constituents are being met. Since no influent or effluent samp-
ling was conducted for the HWA, the Division still has no evidence
that standards are being protected.
Secondly, the industry permit and approved pretreatment program
only require a certain number of metals samples to be collected at
the industry. The assignment of effluent limitations and monitoring
to the permit of the publicly owned treatment works (POTW) will help
ensure that selective sampling by the industry is not allowing unde-
tected pass -through. The variability in textile wastewaters because
of changes in process chemicals, dyestuffs, etc., also supports the
Division's request for increased monitoring of the POTW effluent.
Finally, if it is the contention of Milliken & Company that the
imposition of effluent limits on the Town of Columbus "will result
in greatly reducing our discharge levels", this admission gives cre-
dence to the Division's decision to apply these limits.
5. Theltoxicity test requirements for the Town of Columbus
should be clarified. According to Division records, the Town is to
continue acute toxicity testing using the Daphnid 48 hour LC50 test
until October 31, 1990. Beginning on November 1, 1990, the Town
should start the Ceriodaphnia chronic effluent toxicity testing on a
quarterly basis. The Town is not required to perform both tests at
the same time.

If this decision in unacceptable to you, you have the right to
an adjudicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be in the form
of a written petition, conforming to Chapter 150b of the North Caro-
lina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 11666, Raleigh, North Carolina 27604.
Unless such a request is made, this decision is final and binding.
Should you have any questions regarding this matter, please contact
either Don Safrit or Trevor Clements at [phone].
cc:
Trevc.r:Clements
Don Safrit
Roy Davis
James W. Ashcraft
Central Files
Steve W. Tedder, Chief
Water Quality Section

Paul T. Smith
Mayor
Mr. Dale Overcash
NPDES Permits Group
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Overcash,
ju"rt,40--
AAA', (ct.,to
TOWN OF COLUMBUS ea.,
P.O.BOX 146 De-
COLUMBUS, NORTH CAROLINA 28722
704-894-8236 Councilrnecnbers:
%+over W. Hutcherson
..-, Robert E. Ormand
M
RECEI`;..' Dr. Thomas V. Bolling
0 21990
I am submitting this letter in reference to the Draft NPDES Permit No. NC0021369
proposed for the Town of Columbus, North Carolina.
There are several items in this Draft Permit which differ significantly from our
current NPDES Permit, and these items are of concern to us. The items that are of most
concern are as follow:
1. The Fecal Coliform limitation has been reduced from 1000 col/100 ml to 200 col/
100 (monthly geometric average basis). We understand that this is being im-
plemented statewide, however, our concern is that we will have to install a
new chlorination system to consistently comply with this regulation. We re-
quest that an allowance be made for a construction period.
2. As a point of note, there were no measurement frequencies listed for either
Total Nitrogen or Total Phosphorus. We assume these are to measured Semi -
Annually, as in our current Permit.
3. The parameter of Cadmium, Chromium, Nickel, Lead, Cyanide, and Mercury were
not regulated in our previous permit. Why are these parameters included in
this permit? We have not had any problems with these particular parameters.
Additionally, we believe we have resolved the toxicity problem in our effluent.
We request that the aforementioned parameters be deleted from this permit.
4. The parameters of Copper, Zinc, and Silver are included in our permit with
monitoring requirements only. We have not experienced any problems with
these particular parameters and request that they be deleted. These analyses
along with the previously mentioned metals will represent a significant cost
to !' the Town.
5. We do not understand the rationale for including both the Acute and theChronic
Toxicity Tests. We request that the Acute Toxicity Testing requirement be de-
leted. Again this testing represents a significant cost for the Town.

Paul T. Smith
Mayor
TOWN OF COLUMBUS
P.O. BOX 146
COLUMBUS, NORTH CAROLINA 28722
704-894-8236 Councilmembers:
Grover W. Hutcherson
Robert E. Ormand
Dr. Thomas V. Bolling
We are unclear as to the procedures for requesting changes to our NPDES Permit.
Will this letter suffice or should we make a separate request for a hearing? Please
advise us on the correct protocol.
Thank you for your consideration in this matter and we look forward to a favorable
response.
Town Administrator
cc: C.D. Malone
Jeff Green
Gary Tweed
Roy Davis
SENT CERTIFIED MAIL

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MILLIKEN
Mr. Dale Overcash
NPDES Permits Group
P. 0. Box 27687
Raleigh, NC 27611-7687
Dear Mr. 0vercash:
March 1, 1990
Milliken & Company, Hatch Plant, located near Columbus, North
Carolina is the sole permitted industrial user of the Town of
Columbus Waste Water Treatment Plant (Draft NPDES No. NC 0021369).
As such we are vitally interested in and concerned about the draft
permit. We concur with the concerns expressed by the Town of
Columbus in its recent letter to you regarding the draft permit.
The metals levels in the 'draft permit will result in
reducing our discharge levels. greatly
g At this time we do not know the
levels which will be proposed by the Town in our permit. Some
levels will apparently be below the detection limits. With these
metals not being previously regulated, and not having had any
problems associated with these metals, we request that they be
removed from the draft permit.
We do not understand the reasons for including both acute and
chronic toxicity monitoring. These tests will most likely be
applied to our user permit on a more frequent basis and will
result in substantial testingcosts. cos . We request that the acute
toxicity monitoring parameter be eliminated from the draft permit.
The testing which will be required for metals as well as toxicity
will substantially increase the costs to the Town and the Hatch
Plant.
We respectfully request you consider our comments as well as those
from the Town and revise the draft permit. We would welcome the
opportunity to meet with you and discuss our concerns. Please
assured of our desire to work with the Town and the State to keep
our environment clean. P
Sincerely,
awes W. Ashcr/t
Manufacturing Manager
JWA/bg
cc: Mr. Clyde Smith
Mr. Gary Tweed
Mi. C. D. Malone
Hatch; Plant, Columbus, North Carolina 28722, "telephone [phone]

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