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LMAC
16701 Airport Rd
Maxton, NC 28364
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T.L'"�ry41,) NORTH CAROLINA DEPARTMENT OF
b"*v"c_',i.. ENVIRONMENT AND NATURAL RESOURCES
225 GREEN STREET —SUIT 714
` FAYETTEVILLE, NC 28301-5043
Pat_ tot 7--
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IVIIGIIAGI r. L'HSIGy, vovernor
William G. Ross Jr., Secretary
North Carolina Department o,`EnviroIarment and Natural Resources
Coleen H. Sullins., Director
Division of Water Quality
November 12, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7008 1300 0001 1492 1746
Paul Davis
Executive Director
Laurinburg-Maxton Airport Commission (LMAC)
16701 Airport Road
Maxton, NC 28364
Subject: Reply to LMAC's November 4, 2008 Correspondence
Laurinburg-Maxton Airport Commission (LMAC)
NPDES Permit No. NC00044725
Scotland County
Dear Mr. Davis:
On November 4, 2008, this Office received part of the,Meritech, Inc. October 28, 2008
Toxicity Evaluation Report from JoAnn Gentry concerning the status of the LMAC Whole
Effluent Toxicity Investigation and the Proposed Action Plan for resolving the Whole Effluent
Toxicity (WET) failures. After a review of the Toxicity Evaluation Report that was sent, this
Office understands that 1) it appears that organic contaminants as found in the LMAC
collection system do not play a. significant role in the effluent toxicity, 2) elevated
concentrations of metal contaminants appear to be the main reason for LMAC effluent
toxicity, 3) High sulfate levels from the Umicore sampling site are also a possible source of
toxicity in the LMAC effluent, 4) Umicore, Railroad Friction, and Scotland Manufacturing
samples showed high toxicity and will be subject to additional testing, 5) LMAC WWTP
effluent, South Manhole, and North Manhole also showed significant toxicity and will
continue to be tested, 6) House of Raeford and Butler Manufacturing did not show toxicity,
and these two sites will no longer be tested in the investigation, 7) the toxicity .influence of
sulfate and silica are being investigated. After reviewing the above mentioned report, it is
also the understanding of this Office that the Proposed Action Plan is 1) to continue isolation
of high toxicity factors, 2) to investigate the role that high sulfate levels may contribute to
toxicity, 3) to investigate the role that silica may contribute to toxicity (mostly coming from
Railroad Friction and Scotland Manufacturing), 4) to divide into smaller sections, the
Northern segment of the collection system and the Railroad Friction/Scotland Manufacturing
section of the collection system, and to isolate the sources of maximum toxicity.
As stated in the report: "The picture which emerges at this time is that metals are the
key toxicity factor, primarily those discharged from Umicore and RR & Scotland sites."...
"Although it appears that Umicore and Railroad Friction may be the main contributor to the
toxicity problem, we propose to monitor other elements in that part of the system to eliminate
them as possible sources of toxicity."
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
NorthCarolina
rNaiira/1y
225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone (910) 433-3300 Customer Service
FAX (910) 486-0707 1-877-623-6748
An Equal Opportunity/Affirmative Action
Employer — 50% Recycled/10% Post Consumer Paper
Mr. Davis
November 12, 2008
Page 2
The POTW now has a history of Whole Effluent Toxicity failures that started during
March 2007, and included the months of April and May of 2007. This time period was
followed by two quarterly periods of "Pass". Afterwards, the following months resulted in
WET failures: December 2007, January 2008, February, March, April, May, June, July,
September, and October 2008. Please note that August 2008 resulted in a "Pass" condition
(<10.4%). However, in the last eleven months of consistent WET testing, only one has met
the NPDES permit chronic limit of 2.6%. This Office stresses that it is a condition ;that needs
to be corrected in an urgent manner. The WET failures should be treated with firm
seriousness to resolve this toxicity condition. This Office stresses that the sources of toxicity
must be identified and the toxicants reduced to levels that result in WET chronic values of
2.6% or greater.
In order for this Office to keep abreast of the Toxicity Identification Evaluation, please
frequently keep Dale Lopez or me updated. Please investigate all possible sources for the
WET failures, including the possibility of additional toxicity due to leakage of swamp
spill/sludge from inactive Basin #1 'into the active part of the wastewater treatment plant.
Thank you for your update of information. If you have any questions or comments, please
feel free to contact Dale Lopez or me at (910) 433-3300.
Sincerely,
Belinda S. Henson
Surface Water Protection Section
BSH:DL/dl
cc: Dana Folley, PERCS Unit
Cindy Moore, ESB Aquatic Toxicity Unit
FRO Files
November 18, 2008
Ms. Belinda Henson
NCDENR
N.C. Division of Water quality
225 Green Street — Suite 714
Fayetteville, N.C. 28301-5043
Subject: LMAC
NPDES Permit:- NC00044725
Scotland County
Dear Ms. Henson,
LAURINBURG - MAXTON
AIRPORT COMMISSION
(910) 844-5081
®ENR-FRO
NOV 2 1 201.3
MAIO,
I am in receipt of your letter dated November 12, 2008 concerning the Whole Effluent
Toxicity test failures we are experiencing at our wastewater plant. We understand the
serious condition this problem causes and the violations of our permit limits. Please be
assured we are working daily to correct this problem. We are following the advice
received from your office and our consultant Meritech, Inc. to identify and correct this
problem.
We have check on several occasions to see if there may be a leak from basin #1 where
the•wastewater is being stored from the old closed plant. We do not feel that any leakage
is occurring. However, we are in the process of arranging to land apply this product to
dispose of this water and eliminate this as a suspect and to make this part of the plant
available for future treatment service.
In line with your request we will keep you or Dale Lopez advised of any action we are
taking concerning this issue to include reports on additional test results. We appreciate
any additional suggestions you and your staff may have.
Sincerely,
Po lr bG•j
Paul G. Davis
Executive Director
•
PD/jg,q :c,1:7r,
16701 AIRPORT ROAD:• MAXTON, _N.C:.28364