NC0028916_NonCompliance_20040123

TOWN OF TROY
INCORPORATED 1852
Public Services Dept.
315 N. Main Street
Troy, NC 27371-2799
Phone: [phone]
Fax: [phone]
01/23/04
NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301
Fax: [phone]
Att: Paul Rawls
Paul:
•
As' the:Town ofTroy' s Engineer; I'have;had to work:closely-With our industries when pretreatment compliance
issues"havearisen. As well, I have:monitored-very closelythe effects of industrial waste streams.on.outplant
when the industries werein and out of compliance. In the year 2003; the -Town has-been facedwith several
potential compliance issues as a result of industry process changes that forced us to increase the number of
parameters that we monitor for and frequency with which we monitor. In addition, 2003 was the year for
renewal of our NPDES permit and also the year to do a new headworks analysis. All these items have been done
and as a consequence a rather large amount of information has been collected and analyzed. This has really
helped us be well in tune with the operation of our facility.
One of the compliance issues that came into question during 2003 was chronic toxicity. The Town failed its
chronic tox in July. However, the failure was due entirely to low pH values that occurred during the time when
one of our industries switched from 70% bleaching to 100% dyeing and began using ammonium sulfate in its
dyeing operation. Ammonia was coming into our facility at 135 mg/L and when it hit our plant's DO it used up
all our alkalinity in the ammonia reduction process and thereby lowered our pH. We always met our ammonia
limit but we had to start adding caustic and soda ash to increase our alkalinity and stabilize our pH. All the
ensuing mandatory monthly chronic toxicity testing passed at 100%. The industry consequently switched to
acidic acid and that cured our alkalinity/pH problems.
Before we figured out what was causing the pH drop, we started looking at conductivity and TDS, among other
parameters, coming into our plant from the industry. TDS coming from the industry was as high as 10500 mg/L
*hen tests were rurrin August and September: The industry's flow during this period was runiiiing around
55,000. gallons<perday and the plant's flow was running about:550000. gallons per day which represented, about
10% of our flow. During those months we were running chronic toxicity because of the July failure and we were
consistently passing. In October, when we were also doing chronic tox testing the industry's flow moved up to

17% of our total flow (where it has stayed to date) and the TDS was running around 8000 to 9000 mg/L. We
still passed chronic toxicity at 100% and we were also running second species toxicity for the NPDES permit
renewal as well. The December flow from our industry represented 16% of our flow and the TDS was 6500
mg/L and during December we again ran a chronic toxicity test and a second species toxicity and again passed
them at essentially 100%.
The point of providing you with this plethora of information is to propose the following course of action
regarding the investigation for potential toxicity problems that might result if Star, Biscoe, and Troy combined
their waste streams to form a regional wastewater treatment facility. Let me set up a few more parameters first,
regarding Star, Biscoe, and Clayson Industry. Star's average daily flow at this time is approximately 110,000
gallons per day, Biscoe's ADF is approximately 250,000 GPD and Clayson's contribution to Star's flow is
approximately 50,000 to 60,000 GPD roughly 50% of their total flow. In addition, Clayson's flow has a TDS
that ranges from 3500 to 5000 mg/L. If you add approximately 350,000 gallons per day to Troy's flow that takes
our flow to approximately 850,000 gallons per day. If you then add our industry's flow to Clayson's flow those
two industries represent approximately 135,000 GPD or 16% of Troy's total flow. Clayson's TDS (if we use
that as an indicator of Chronic Toxicity) is 33% lower than our industry and the flow ratio is exactly the same as
it is right now. Again Clayson's TDS is only approximately 5000 mg/L worst case and our industry's is closer to
8000 mg/L worst case. It is my conclusion, from the information and data above, that the Troy facility should be
able to treat the combined waste streams without chronic toxicity being a problem. Again there are no
guarantees but our plant has performed well when the industry was a 22% contributor to our plant. I did not use
these numbers because I did not know the exact make-up of the industry's waste stream. I do believe these
numbers to be conservative and I know our plant has performed well with regard to toxicity throughout all this
time. We have been using UV Light as our disinfection since June of 2003 and that also reduces the potential for
chlorine induced chronic toxicity.
These flow numbers could also change for the better since we may very well add Handy Sanitary's flow to our
facility and that would drop the % of industry flow to 14% of total flow even if the additional flow only
amounted to 100,000 GPD of domestic wastewater. We realize that these numbers are no iron -clad guarantee
but neither is any kind of testing procedures dilution or bench. I would propose that we do some additional
dilution testing to reinforce the first dilution test that indicated the chronic toxicity would pass with the
proportioned dilutions combined. If we conduct chronic toxicity testing using the proportioned effluents, 2 per
month, for the months of February, March, and April that should raise everyone's confidence level and support
the conclusion I have drawn from the numbers presented above.
I would respectfully request that the towns be allowed to continue with the regionalization efforts during the
testing time for the following reason. We believe that the best chance for Clayson's doors to remain open with
process production unchanged is the dilution represented by the mixing of the three towns. If a bench toxicity
test was conducted and failed what would change with regard to regionalization being the right solution for the
three towns? It would still be millions of dollars less expensive to combine the waste streams and come to Troy.
If Troy has a toxicity problem after combining the waste streams then any other scenario would have as well.
Meanwhile we just removed two plant discharges from two zero flow streams. That has to be the right solution.
No test is going to 100% guarantee that a toxicity problem will not exist. Why not spend the money required to
run a "bench test" ($25,000 minimum with town participation) and use it to try one last time (with additional
dilution present [better scenario]) to save the industry if a chronic toxicity problem does appear. What will
regulators propose if the bench test fails? I have maintained and re -built this plant for the last ten years and
continue to improve it and until the biological process tells me that it can or cannot handle these additional
waste streams I will not know for sure and frankly neither will anyone else. No bench will duplicate this plant. It

is a living breathing entity that is in constant change. When the industry changed its process our bugs were not
happy. After about four weeks they began to adapt and our plant settled down. The change was from hydrogen
peroxide to dyeing chemicals. Those organisms evolved and adapted to what they were given and they will
continue to evolve and adapt if we give them a chance. Let's deal with the real world in lieu of an attempt at the
real world.
I would be remiss if I did not add at this point, that we have requested speculative limits for a new discharge
point in the Little River just below the location where the "high quality" waters classification is dropped to class
"C" waters. We believe this location is where NC-24 & 27 crosses the Little River. At present, our discharge
point is on Densons Creek where the flow is 1.03 MGD. The new discharge point in the Little River has a flow
of 77 MGD. This should drastically alter our chronic toxicity percent of discharge flow relative to the
discharge waters.
You have my word that if we have a chronic toxicity problem as a regional plant I will attack it in the same
manner and with the same zeal that I have each time a problem has arisen in Troy. I will not rest until I have our
plant well in compliance. This is possible because I have the full support of the Manager, Mayor, and Town
Board. I can assure you that the industry that had to eliminate ammonium sulfate was not happy with me and
threatened me with talking with the Mayor but they didn't because they knew it would do no good. The
Manager, Mayor and Commissioners know how badly we all need industry but they also know that compliance
isn't one alternative, it is the only alternative. If that premise isn't a part of the regionalization agreement then I
am sure Troy will not be a participant. I am equally sure that all parties understand that compliance must be
obtained and maintained
To sum up, I request that all regulator agencies involved allow us to proceed with regionalization efforts without
"proof -positive" that no toxicity problem will exist. We will conduct proportional dilution testing as outlined
above concurrent with finalizing a regionalization plan and proceeding with grant funding options and all
designs required to make regionalization a reality. I look forward to your reply as soon as possible.
Sincerely,
zeJceatoiv
E. Gray Walls, P.E.
Town Engineer/
Public Services Director