NC0025909_Correspondence_19991105

NPDES DOCUMENT SCANNING COVERSHEET
NPDES Permit:
NC0025909
Rutherfordton 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:
November 5, 1999
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content on the reverse side

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
Ms. Karen Andrews
Town Manager
Town of Rutherfordton
134 N. Washington Street
Rutherfordton, North Carolina 28139
T; 4;1 ri
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 5,1999
Subject: Pretreatment Unit Review of Industrial User treatment Permit (11JP)
Town of Rutherfordton (NPDES # NC002 909)
Rutherford County
ler ``6
Dear Ms. Andrews:
The Pretreatment Unit and the Aquatic Toxicology Unit of the Division of Water Quality have performed
additional review of the report entitled "Toxicity Investigation of Spring Ford Industries Wastewater, Spindale
and Rutherfordton, NC, December 1998 — February 1999." This report was prepared by ETT on behalf of
Spring Ford with revisions dated May 14, 1999, and was submitted by Town of Rutherfordton in relation to
a submittal of an Industrial User Pretreatment permit (IUP) for the following Significant Industrial User (SIU).
This report was received by the Division on March 25, 1999, with revisions received June 4,1999.
loam
Spring Ford Industries
The following comments are made based on the review. In general, these concerns must be resolved prior to
the Division's approval of a full scale IUP for this SIU, as well as Division concerns in our April 23, 1999,
letter. However we recognized that the SIU may have made significant progress on its pilot scale operation
and accompanying toxicity reduction investigations. It is possible that this work may have made some of the
specific concerns moot. Please feel free to contact me to discuss any issues. Due to the complexity of this
SIU's investigations, we will not establish any specific due date for a response to these concerns or for
submittal of `full scale" IUP, or related Headworks Analysis submissions. the Town may resubmit these items
as they are ready.
a) The report could benefit from an "executive summary" section at the beginning.
b) The investigation limits itself from the beginning to three toxicant classes: chemical dyes, salts, and
surfactants. Further, this list was narrowed to salts and surfactants with minimal explanation. There is
no discussion or evaluation of the toxic potential of other process chemicals, other process lines (are there
any?) or non process waste sources. While these other potential sources of toxicity may be more difficult
to evaluate prior to the plant coming on line, it should be recognized that they could conceivably contribute
to toxicity at both the Rutherfordton and Spindale WWTPs.
c) The report refers to 7-day LC50's as "acute" data (see second paragraph, page 3). This is not correct.
Acute effects in the whole effluent toxicity (WET) world are generally restricted to four days. A 7-day
LC50 is a chronic survival measure for Ceriodaphnia. The investigators seem to be using "acute" and
"chronic" toxicity as synonyms for chronic lethality and chronic sub -lethal effects, respectively. In almost
all cases in the text when the term "acute" is used, the data referred to are seven-day chronic survival data.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
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Although these nomei#clatuie issues don't seem to affect the conclusions of the investigation, it can make
for confusing reading and difficult interpretation of conclusions.
d) The report refers to LC5ovalues as toxicity thresholds. This is incorrect. The LC50-is a standard measure
meaning the concentration of toxicant that produces the observed effect (usually death or immobilization)
on 50% of the test organisms over the test period. To use a specific example from' the report, 40%
mortality at a given toxicant concentration should not be considered "insignificant" just because an LC50
value is not produced. In fact, Fisher's Exact test indicates that 40% mortality in a treatment compared
to a control with no mortality is significant.
e) The Division's April 23,1999, letter requested several revisions to the original March report. Review of
the May 14, 1999, revisions indicates that some changes requested in item 1, b+c, were not thoroughly
carried out for each initial calculation through each subsequent calculation. Of most concern were an error
in the SIU's percent flow to the WWTP was still present on the first page and several errors are still
present on the conclusion page (p38) as discussed in item z below. These computations are very critical
to the entire meaning of the report, and errors in them affect all other conclusions. Additionally, item 1,d,
of our letter was not addressed. We ask that the SIU once again review the entire report for these errors.
Also please revise the report to show all math for how all calculations, percents, mg/1, etc. Additionally,
please list the ChV, IC25, and LC50 derived for each test, along with 95% confidence intervals and
Fisher's Exact test results as appropriate.
f) One of the goals of the overall report is to gather sufficient information to develop an MARL for sodium
(see item 1,a, of the Division's April 23'I letter). Please ensure the final report addresses this.
g) Page 1: The document uses 43.5 percent SIU flow in POTW. How was this number derived? Why did
it not change when the SIU flow changed? Correct this as necessary, plus correct all other applicable
calculations in the document.
h) Page 2: What is the source of the NaCI acute and chronic thresholds? How were the NaCI concentrations
in the <100% test solutions derived? Were they measured or calculated? If they were calculated, please
show the math.
i) Page 5-6: Please explain more about why sodium increased with the addition of sulfuric acid? Also,
please explain more about the chemistry of sulfuric acid and sulfate so that we may better understand your
statements about the addition of sulfuric acid causing the sulfates to increase, especially about whether the
increase seemed to be the right amount. Finally, please provide 95% confidence intervals for all IC25s.
j) Page 7: What is the source of the threshold levels in paragraph 2?
k) Page 7-8: It appears that salt in feedwater is more toxic than salt in their standard dilution water.
However, there is no feedwater control. How do we know that toxicity is not being contributed by the
feedwater itself? The point may be moot for the purposes of the investigation as the issue the report seems
to be trying to get to is the salt level that is toxic in that water. Please include documentation (the test
results) of the toxicity of NaCI at the hardnesses displayed in the graphs on page eight, particularly the "0"
hardness test.
1) Page 10: Please include the background data supporting the conclusions in the last paragraph.
m) Page 11-12: Spindale's new IWC is 26%, not 24%.
n) Page 12: The survival NOEC for the simulated Spindale treatment test is 50% as opposed to 73% per
Fisher's Exact test.
o) Page 14: Please show how you derived the NaCI values (i.e., show your math).
p) Page 16: Please provide more detail on how the various percents of solutions used to make up bench scale
reactor and feed were derived.? Please do this throughout the rest of the document.
q) Page 18: Please explain the conclusions in paragraph 2 in more detail. For example, how do we know
all of the surfactant toxicity is gone? Why didn't the SIU run the treated effluent through the anionic
column to verify that salt is the post -treatment problem? We also would like to see where the data came
from for the "toxic level of NaCl" line in the graphs.
r) Page 18: How were the critical NaCI levels of 300 mg/L and the 971 mg/L derived? Please show the
math. Also, from above, 43.5 % is wrong.
s) Page 19: How were the 307 mg/L Na concentration and the 486 mg/L Cl concentration derived? Please
show the math.
t) Page 19: Provide documentation and/or explanation of the data in the graphs, showing your math were
appropriate. Please explain the conclusions in the last sentence in more detail.
u) Page 22-23, and 27-29: Provide documentation and/or explanation of the data in the graphs, showing your

math where appropriate. Please explain the conclusions in more detail. How can the cause of toxicity not
be salt, and not be chlorides, but be sodium? Perhaps the first conclusion actually refers to the "salt drop"
portion of the effluent rather than "salt."
v) Page 20-33: Please provide more discussion on the ChVs for the salt drops versus the surfactant drops.
For example, what does it mean if the ChVs for Spindale are the same [salt drop ChV is 60.4 (p 21) and
surfactant drops ChV is 60.4 (p31)] whereas for Rutherfordton they are very different [salt drops ChV is
24 (p27) but surfactant drop ChV is 84.3%(p33)]? It seems to us that this does not support the case for
the salt portion of the effluent being the only source of post -treatment toxicity. The test results for
Spindale look almost identical: both tests had 70% & 0% survival in the 73% and 100% concentrations,
respectively; both tests had reproduction LOECs of 50%. In terms of reproduction at this concentration
one test's 50% animals produced 25% less than the control and the other 26% less. The clues that the salt
drops portion may be more toxic after treatment are the spotty mortalities in lower concentrations and the
similarity of the "patterns" of toxicity as illustrated by the graphs on page 22 and 31. Please comment on
this.
w) Page 24: Should the listing of dye drops 1-7 about 2/3 way down the page should be 7-14?
x) Page 31: Please provide more discussion on your conclusions in last paragraph. It seems to us that this
test makes a weak case for surfactant toxicity being "substantially removed" by treatment. See item v
above.
y) Page 34: A ChV was reported for a test having only have two test concentrations. This is inappropriate.
Please either correct the report, including any conclusions based on the ChV, or alternatively provide
other explanation.? Also, we question whether 40% mortality is "marginal." Fisher's Exact test applied
to this dataset would flag it as significant. Also, their datasheet in the appendix has a typographical error.
It specifies that survival is 40%; actually, it's 60%. Again, we wouldn't call the observed a 30% reduction
from control reproduction "marginal." Finally, please expand on your conclusion about toxicity in the
RAS.
z) Page 38+39: These pages still need revision. Rutherfordton's toxicity test percentage is 71%, not 54%.
Also, what is the SKr correct percentage of the POTW flow (see item a above)? Finally, the NaCI to
pass must be 971 mg/I, not 1277 mg/1. What effect will the changes make on these very critical conclusion
pages? I assume the allowed NaCI number needs to be 977 mg/1. Since the calculations on page 38 show
the expected NaCI concentration to be 1265 mg/1, this causes us concern. Even of more concern is the
SIU's March 16 letter to Rutherfordton indicating their pilot scale pretreatment unit will produce 1576.3
mg/l. See item 7 of our April 23rd letter. Additionally, we noted that though the report states on page 38
that nanofiltration should resolve Rutherfordton's potential toxicity problem, however this is not repeated
in their summary.
Please note our new mailing address and fax number on the bottom of the first page of this letter.
Thank you for your continued cooperation with the pretreatment program. If you have any questions or
comments, please contact Dana Rees Folley at [phone] (ext. 523) or Tom S. Poe (ext. 522), Supervisor
of the Pretreatment Unit.
Sincerely, /� _ [j�
ILGIJK� I "e 041
pn Kerr T. Stevens
DRF/rutherfordtoniup.005
cc: Ms. Nadine Blackwell, Hydro Management Services
Mr. Paul Rhodes, Hydro Management Services
DRF, Pretreatment Unit
Central Files
Dave Goodrich, NPDES Unit
Matt Matthews/Kevin Bowden, Aquatic Toxicology Unit
Roger Edwards, Asheville Regional Office

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
July 23, 1999
Ms. Karen Andrews
Town Manager
Town of Rutherfordton
134 N. Washington Street
Rutherfordton, North Carolina 28139
Agc'A
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Pretreatment Unit Review of Industrial User Pretreatment Permit (RIP)
Town of Rutherfordton (NPDES # NC0025909)
Rutherford County
Dear Ms. Andrews:
The Pretreatment Unit of the Division of Water Quality has reviewed the Industrial User Pretreatment permit
(IUP) submitted by the Town of Rutherfordton for the following Significant Industrial User (SIU). This IUP
was received by the Division on June 22, 1999, with additional information received on various dates between
March 25, 1999 and May 5, 1999.
FO-El Spring Ford Industries
The IUP submission consisted of a IUP for a temporary IUP for 0.05 MGD for the operation of one dye
machine and a pilot pretreatment unit, hereafter referred to as the "pilot scale IUP."
The review indicates that, with the observations outlined below, the "pilot scale IUP" will resolve the
Division's concerns expressed in our June 8, 1999, 1999, letter, and that the IUP is adequate and the
minimum requirements of 15A NCAC 2H .0905 and .0916 and 40 CFR 403.8(f)(1)(iii) is met.
Concerns noted that do not require re -submission this time are as follows. However, they must be corrected
in or with the next IUP modification.
1. Schematic and Monitoring Locations: Comprehensive Guide, Appendix 6-B, page 4
A diagram or sketch which shows the industrial site, process areas, important plant pipes, flow
direction, connection to the sewer, direction to the POTW, and sampling points must be included
in the IUPs. The diagram should be concise, but complete enough so that a person unfamiliar
with the particular plant could identify the sampling point. The diagram included in the IUP does
indicate the order of the treatment units and the sample point, but it does not actually show where
these units are on the overall site, especially the sample point itself. Please ensure future IUPs
include either wording or a supplemental diagram with this information.
Please note all Division concerns in our April 23, 1999, letter must be resolved prior to Division approval of
an IUP for full scale operation of this SIU.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Thank you for your continued cooperation with the pretreatment program. If you have any questions or
comments, please contact Dana Rees Folley at [phone] (ext. 523) or Tom S. Poe (ext. 522), Supervisor
of the Pretreatment Unit.
Sincerely,
PCPs"'
Kerr T. Stevens
DRF/rutherfordtoniup.004
cc: Ms. Nadine Blackwell, Hydro Management Services eJ
Mr. Paul Rhodes, Hydro Management Services
DRF, Pretreatment Unit
Central Files
Dave Goodrich, NPDES Unit
Matt Matthews/Kevin Bowden, Aquatic Toxicology Unit
Roger Edwards, Asheville Regional Office

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
June 8, 1999
Ms. Karen Andrews
Town Manager
Town of Rutherfordton
134 N. Washington Street
Rutherfordton, North Carolina 28139
Akvg";'A
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Pretreatment Unit Review of Industrial User Pretreatment Permit (IUP)
Town of Rutherfordton (NPDES # NC0025909)
Rutherford County
Dear Ms. Andrews:
The Pretreatment Unit of the Division of Water Quality has reviewed the draft Industrial User Pretreatment
permit (IUP) submitted by the Town of Rutherfordton for the following Significant Industrial User (SIU). This
draft IUP was submitted by Hydro Management Services and received by the Division on May 5, 1999.
0001
Spring Ford Industries
The IUP submission consisted of a draft IUP for a temporary draft IUP for 0.05 MGD for the operation of one
dye machine and a pilot pretreatment unit, hereafter referred to as the "pilot scale IUP."
The review indicates that, with the corrections outlined in a telephone call between Dana Folley of the
Pretreatment Unit and Nadine Blackwell of Hydro Management Services, the Town's consultant (copies
attached), the draft "pilot scale IUP" will resolve the Division's concerns expressed in our April 23, 1999,
letter, and that the IUP will be adequate and the minimum requirements of 15A NCAC 2H .0905 and .0916
and 40 CFR 403.8(f)(1)(iii) will be met.
As you know, the POTW will not be authorized to issue the above approved IUP until it has received Final
Approval of its Pretreatment Program from the Division. All that remains for completion of Final Approval
are submittal of the Industrial Waste Survey and preparation of the final approval package for signature by the
Division Director. It is anticipated this will be complete this week or early next week. Please note all Division
concerns in our April 23, 1999, letter must be resolved prior to Division approval of an IUP for full scale
operation of this SIU.
Please forward a copy of the final issued "pilot scale IUP" upon issuance.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycledll0% post -consumer paper

Thank you for your continued cooperation with the pretreatment program. If you have any questions or
comments, please contact Dana Rees Folley at [phone] (ext. 523) or Tom S. Poe (ext. 522), Supervisor
of the Pretreatment Unit.
Sincerely,
Kerr T. Stevens
DRF/rutherfordtoniup.00 I
enclosures: marked up IUP pages
cc with enclosures:
Ms. Nadine Blackwell, Hydro Management Services
DRF, Pretreatment Unit
cc without enclosures:
Mr. Paul Rhodes, Hydro Management Services
Central Files
9Jeff Myhra/Dave Goodrich, NPDES Unite
Mau Matthews, Kevin Bowden, Aquatic Toxicology Unit
Roger Edwards, Asheville Regional Office
DENR - WATER QUALITY
POINT SOURCE BRANCH
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