NC0086550_Landfill Leachate_20101007

Ay ;
NCDENIR
North Carolina Department of Environment and Natural Resources
Division of Water•Quality
Beverly Eaves Perdue • Coleen H. Sullins Dee Freeman
Governor Director Secretary
October 7, 2010
Mr. H. Blake Proctor
Town Manager
Town of Fairmont
POBox248
Faiuiiont, NC 28340
Subject: Questions about leachate from Robeson County Landfill
Town of Faiuiiont
NPDES Permit # NC0086550
Robeson County
. Dear Mr-. Proctor,
It has come to DWQ's attention that the Fairmont Wastewater Treatment Plant
began accepting leachate from the Robeson County Landfill in June 2010. Please see the
attached page from the Fairmont NPDES permit (Part IV, Section C, 2, c, 4) that states,
in part: "Prior to accepting wastewater from any significant industrial user, the Permittee
shall either develop and submit to the Division a new Pretreatment Program or a .
modification of an existing Pretreatment Program, for approval as required under section
D below as well as 15A NCAC 2H .0907 (a) and (b). [40 CFR 122.44 (j) (2)]".
Please provide this Office with written documentation on the Landfill's
application for permission to discharge, including volume and character of all pollutants
reasonably expected to be present. Please describe the Town's evaluation of the
proposal, including the Town's determination that the discharge did not meet the criteria
of Significant Industrial User as defined in the Town's Sewer Use Ordinance and the
State Pretreatment Rules. Please send this Office the written permission to discharge to
Fairmont that the Town gave to the Landfill.
The Town failed their NPDES limit for Whole Effluent ' Toxicity (WET) in
August 2010. This was the first "Fail" for the WET for this wastewater treatment plant
(NC0086550), which began discharging treated wastewater on June 12, 2002. We
acknowledge that there were many WET "Fail" results before the year 2000 with the
wastewater from the "old" treatment plant (NC0021059), located within the .city limits of
Fairmont. Please provide this Office with a written explanation of how the Town
evaluated the leachate to determine whether it caused or 'contributed to the August 2010
WET violation, along with any enforcement actions and/or changes that the Town has
made or plans to make in the Landfill's permission to discharge.
225 Green St, Suite 714, Fayetteville; NC 28301-5043 •
Phone: [phone] ` FAX: [phone]\ Customer Service: 1-877-623-6748 One.
iniernet:www.ncwaterquality.org North. Carolina
An Equal Opportunity' ffhiative Action Employer

f- J
Mr. Blake
October 7, 2010
Page 2
Please send the above requested infoiniation to this Office by October 27, 2010,
with a copy to Dana Folley of the PERCS staff. If you have any questions, please do not
hesitate to contact me at [phone].
Sincerely,
Dale Lopez
Environmental Specialist
Enclosure: Section C, 2, c, 4 of Fairmont's NPDES pennit, Part IV
cc: Nadine Blackwell, United Water
Dana Folley, PERCS — Pretreatment

NPDES Permit Standard Conditions
Page 16of18
and times; and if the discharge has not ceased, the anticipated time it is expected to continue; and steps
taken or planned to reduce, eliminate, andprevent reoccurrence of the noncompliance,
3. With regard to the effluent requirements listed in Part I. -of this permit, it Maybe necessary for the Permittee to
supplement the requirements of the Federal Pretreatment, Standards (40 CFR, Part 403) to ensure compliance
by the P ernittee with al]. applicable effl.u.ent limitations. Sild. actions by the P ermittee may be 'necessary
regarding some or all of the industries discharging to the municipal system.
4. The Pern:uttee shall require any industrial discharger sending its effluent to the perrnitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act as amended (which
includes categorical standards and locally derived limits and narrative requirements). Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the Division a
new Pretreatment Program or a modification of an existing Pretreatment Program, for approval as required
under section D belowas well as 15A NCAC 2H.0907 (a) and (b). [40 CFR 122.44 (j) (2)]
5. This perrnit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a POTW
Pretreatment Program as required under Section 402 (b) (8) of the CWA and implementing regulations or by
the requirements of the approved State pretreatment program, as appropriate.
Section D. Pretreatment P mats
Under authority of sections 307 (b) and (c) and 402 (b) (8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3 (14) and implementing regulations 15A N CAC 2H.0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the Pretreatment
Prograrn Submittal are an enforceable part of this permit. [40 CFR 122.44 (j) (2)]
The P errrtittee shall operate its approved pretreatment program in accordance with Section 402 (b) (8) of the CWA,
40 CFR 403, .15A N CAC 2H.0900, and the legal authorities, policies, procedures, and financial provisions contained
in its pretreatment program submission and Division approved modifications thereof. Such operation shall include
but is not limited to the implementation of the following conditions and requirements. Terns not defined. in Part II
or Part IV of this permit are as defined in 15A NCAC 2H.0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 2H.0905 and .0906; 40 CFR 403.8 (f) (1) and 403.9 .(1), (2)]
2. Industrial Waste Survey (IWS) •
The permittee shall implement an IWS consisting of the survey of users of the POTW, as required by 40 CFR
403.8 (f) (2) (i-iii) and 15A NCAC 2H.0905 [also 40 CFR 122.44 (j) (1)], including identification of all industrial
users and the character and amount of pollutants contributed to the POTW by these industrial users and •
identification of those industrial users meeting the definition of SIU. The Permittee shall submit a surnxnary of
its IWS activities to the Division at least once every five years, and as required by the Division. The IWS
submission shall include a summary of any investigations conducted under paragraph B, 2, c, of this Part.
3. Monitoring Plan . .
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data
to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific
pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Part II,
Section D, and Section E .5.). [15A NCAC 2H.0906 (b) (2) and .0905]
4. Headworks Analysis .(HWA).and Local Limits
The Permittee shall obtain Division approval of a HWA at least once everyfive years, and as required by the.
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a -written technical evaluation of the need to revise local limits (i.e., an
Version 5/2009

TOWN OF FAIRMONT
OFFICE OF THE TOWN MANAQER
POST OFFICE BOX 24$, FAIR.MONT, NORTH CAROLINA 28340
TELEPHONE: [phone] EXT 910-628-60255
October 26, 2010
Mr. Dale Lopez
Environmental Specialist
DWQ/Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Re: Town of Fairmont NPDES Permit No. NC0086550
DENR-FRO
OCT 2 8 2010
DWQ
Dear Mr. Lopez,
This correspondence is in reply to your letter dated October 7, 2010 concerning the leachate from the
Robeson County Landfill. The Robeson County Landfill was discharging to the City of Lumberton until
the City proposed a substantial fee increase. The County Landfill made request to several local municipal
treatment plants to accept the leachate. The Town of Fairmont agreed to accept the leachate on a
temporary trial basis.
The Town of Fairmont began accepting the leachate during the month of June. Currently, the County is
disposing of the leachate in the sand drying beds of the "old" wastewater treatment plant. The filtrate is
conveyed to ` the : wastewatertreatment plant via the sewer collection system along with the other
wastewater.' Attachment I' provides a summary of the leachate discharge volumes. In addition, Attachment
II provides a summary o'f'the " leachate analytical testing compared to the 5% Maximum Allowable
Headworks Loading (MARL'): .As you will note, the discharge does not exceed 5% of the MAHL and the
discharge volume is less than 25,000 gpd. As a result, the discharge is not classified as a Significant
Industrial User.
In reference to the August toxicity failure, we do not attribute the leachate as a contributor to the failure.
We have reviewed the operational and DMR data for the month of August and could not determine any
abnormal conditions. The follow-up toxicity tests collected during the months of September and October
passed.
Currently, the Town and the County are working on a contract agreement for the disposal and treatment of
- the leachate. The contract will require the County -sample the-leachate on a monthly basis.- I -will keep -you
informed of the progress.
Very, cordially yours
H. Blake Proctor, Town Manager
cc:
Dana Folley, DWQ/PERCS Unit
:Ronnie Seals Public' Works` Director_
Johnny Britt, WWTP ORC
NadineBlackweh; UnitedW ter

ATTACHMENT I
DISCHARGE VOLUME OF LEACHATE
Month
Total for the Month
June
24,000 gallons
July
30,700 gallons
August
30,700 gallons
September
65,000 gallons
ATTACHMENT II
ANALYTICAL "1'bSTING OF LEACHATE
ROBESON COUNTY LEACHATE
SAMPLE: Sept 10, 2010
Average Daily
Discharge
0.002167 MGD (based on 65,000 gal/month)
Pollutant
mg/1
lb/day
5%of
MAHL
Is Discharge
>5%of
MAHL
BOD
7.1
0.0641
89.00
No
TSS
244
2.2045
139.00
No
Ammonia
168
1.5179
18.05
No
Arsenic
0.037
0.0003
0.0416
No
Cadmium
< 0.002
0.0000
0.2017
No
Chromium
0.018
0.0002
0.1640
No
Copper
0.163
0.0015
0.1998
No
-Cyanide
< 0.005
0.0000
0.0416
No
Lead
0.004
0.0000
0.2081
No
Mercury
Molybdenum
Nickel
0.022
0.0002
0.1040
No
Selenium
Silver
< 0.002
0.0000
0.1040
No
Zinc
0.073
0.0007
0.4162
No
Total Nitrogen
Total Phos.
0.552
0.0050
Oil & Grease