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NC0034754_Permit (Issuance)_20070612
NPDES DOCUMENT SCANNINO COVER SHEET NPDES Permit: NC0034754 CommScope WWTP Document Type: ermit Issuance Wasteload AllocationW' Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: June 12, 2007 Thie document los printed on reins paper - ignore any content on the reirer,se 'side WAT NCDENR Mr. D. Scott Waddell, EHS Engineer CommScope 10660 CommScope Road Catawba, North Carolina 28609 Dear Mr. Waddell: Michael F. Easley Govemor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality June 12, 2007 Subject: Issuance of NPDES Permit Permit NC0034754 CommScope Catawba County Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended). This final permit includes the following major changes from the draft permit sent to you on December 7, 2005: • The compliance schedule of 18 months for TRC was added for Outfalls 002, 003, and 004 in response to your request. • Instream monitoring requirements for conductivity and fecal coliforms were removed from the permit based on the review of DMR data and in response to your request. • Air compressor condensate and stormwater were removed from the description of wastewater for Outfalls 002, 003, and 004 to correct an error. The Division reviewed your request to change BOD limit for Outfalls 002, 003, and 004. This request cannot be granted because BOD limit of 5 mg/L is necessary to protect instream dissolved oxygen standard. If any parts, measurement frequencies or sampling requirements contained in this permit are 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 Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Sergei Chernikov at telephone number (919) 733-5083, extension 594. Sincerely, cc: /.3 Central Files NPDES Files Mooresville Regional Office / Surface Water Protection Section Aquatic Toxicology Unit N. C. Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 Internet: h2o.enr.state.nc.us Coleen H. Sullins Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center: 1 800 623-7748 Permit No. NC0034754 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, CommScope, Inc. is hereby authorized to discharge wastewater from a facility located at 6519 CommScope Road Catawba, North Carolina Catawba County to receiving waters designated as an unnamed tributary to Terrapin Creek in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective July 1, 2007 This permit and the authorization to discharge shall expire at midnight on April. 30, 2010 Signed this day June 12, 2007 ti)- a, Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission Permit No. NC0034754 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. CommScope, Inc. is hereby authorized to: 1. Continue to operate an existing 0.020 MGD activated sludge wastewater treatment facility located at 6519 CommScope Road, Catawba, Catawba County, and consisting of the following treatment components: Outfall 001- (process and domestic wastewater) ■ manual/automatic bar screen • flow equalization basin • sodium hydroxide pH adjustment • dual train aeration basins, with two basins per train • dual secondary clarifiers • dual tertiary sand filters • sodium hypochlorite chlorination and contact chamber • sodium sulfite dechlorination • post aeration • aerobic sludge stabilization tank • sludge holding tank • instrumented flow measurement - Outfalls 002, 003, 004- (contact cooling water from cooling pit dump) ■ There are no treatment components for these outfalls. 2. Discharge from said treatment works and outfalls (via Outfalls 001, 002, 003, 004) into an unnamed tributary to Terrapin Creek, a Class WS-IV water in the Catawba River Basin, at the locations specified on the attached map. Outfall 001 Lat: 35°38'95" Long: 81 °01'84" Outfall 003 Lat: 35°39'02 " Long: 81°01'94" USGS Quad : E14NE (Catawba NC) Subbasin: 03-08-32 Receiving Stream: UT Terrapin Creek ctrenm C'lacc• WS-TV Outfall 002 Lat: 35°39'02" Long: 81 °01'90" Outfall 004 Lat: 35°38'87" Long: 81°01'90" LIA : ()3Jsd+v( CommScope NC0034754 Catawha County Permit No. NC0034754 A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge process (contact cooling water) and domestic wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMPI MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Flow 0.02 MGD Continuous Recording I or E BOD, 5-day, 20°C (Summer) 16.0 mg/L 24.0 mg/L : Weekly Grab E BOD, 5-day, 20°C (Winter) 30.0 mg/L 40.7 mg/L Weekly Grab E Total Suspended Residue 30.0 mg/L 39.2 mg/L Weekly Grab E NH3 as N (Summer) 2.0 mg/L 10.0 mg/L Weekly Grab E NH3 as N (Winter) 4.3 mg/L 21.5 mg/L Weekly Grab E Oil & Grease 29 mg/L Weekly Grab E Total Residual Chlorine 28 pg/L 2/Week Grab E Fecal Coliform (geometric mean) 200/100 mL 400/100 mL Weekly Grab E Dissolved Oxygen2 Weekly Grab E Temperature Daily Grab E pH3 Weekly Grab E Chronic Toxicity4 Quarterly Composite E Dissolved Oxygen Weekly Grab U, D Temperature Weekly Grab U, D Notes: 1. Sample locations: E- Effluent, I- Influent, U- Upstream at least 50-feet above ALL outfalls, D- Downstream at least 100-feet below ALL outfalls. 2. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L. .3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 4. Chronic Toxicity (Ceriodaphnia) at 34%; February, May, August, November; refer to Special Condition A (3). (Summer) = April 1- October 31 (Winter) = November 1 - March 31 There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit No. NC0034754 A (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge contact cooling water (pit dump water) from Outfalls 002, 003, and 004. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMIT MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Flow Per Event Instantaneous E BOD, 5-day, 20°C 5.0 mg/L Per Event Grab E Total Suspended Residue 19.0 mg/L Per Event Grab E Oil and Grease 29.0 mg/L Per Event Grab E Total Residual Chlorine2 28 -µg/L Per Event Grab E Temperature3 Per Event Grab E pH4 Per Event Grab E Acute Toxicitys 5 Grab E Notes: 1. Sample locations: E- Effluent. 2. Monitoring requirements apply only if chlorine is added to the cooling water. Facility is allowed 18 months from the effective date of the permit to comply with the total residual chlorine limit. This time period is allowed in order for the facility to budget and design/construct the dechlorination and /or alternative disinfection systems. 3. The temperature of the effluent shall not increase the temperature of the receiving stream more than 2.8° C and in no case cause the ambient water temperature to exceed 32° C. 4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 5. Acute Toxicity (Fathead Minnow, 24-hour) Monitoring, Episodic; refer to Special Condition A (4). The permittee shall obtain authorization from the Division prior to use of any chemical additive in the discharge. The permittee shall notify the Director in writing at least ninety (90) days prior to instituting use of any additional additive in the discharge, which may be toxic to aquatic life (other than additives previously approved by the Division). Such notification shall include completion of Biocide Worksheet Form 101 (if applicable), a copy of the MSDS for the additive, and a map indicating the discharge location. There shall be no chromium, zinc, or copper added to the discharge except as pre -approved additives to biocidal compounds. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit No. NC0034754 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A (3). CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)--- Outfafl 001 The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 34%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of February, May, August, and November. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The defmition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: Environmental Sciences Section North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit No. NC0034754 A (4). ACUTE TOXICITY MONITORING (QRTRLY, EPISODIC)-- Outfalls 002, 003, 004 The permittee shall conduct quarterly acute toxicity tests using protocols defined as definitive in E.P.A. Document EPA/600/4-90/027 entitled Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms.' The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. Sampling and subsequent testing will be performed upon the first discharge from the facility during each quarter, the quarters defined as January -March, April -June, July -September. And October -December. The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the quarter in which it was performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent to the following address: Attention: Environmental Sciences Section North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during any quarter, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require that a test be performed upon the next discharge event. NCDENR / DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT CommScope, Inc. NPDES No. NC0034754 Facility Information (1.) Facility Name: CommScope WWTP (2.) Permitted Flow,MGD: 0002-01-N0.02L MGD 003- NL 004- NL (6.) County: Catawba (3.) Facility Class: I (7.) Regional Office: Mooresville (4.) Facility Status: Existing (8.) USGS Topo Quad: E14NE (Catawba, NC) (5.) Permit Status: Renewal Stream Characteristics (1.) Receiving Stream: Unnamed tributary to Terrapin Creek (2.) Subbasin: 030832 (8.) Drainage Area (mi2): 0.30 (3.) Index No.: 11-81-(1) (9.) Summer 7Q10 (cfs) 0.06 (4.) Stream Class: WS-IV (10.) Winter 7Q10 (cfs): 0.1 (5.) 303(d) Listed: NO (11.) 30Q2 (cfs): 0.12 (6.) 305(b) Status: (12.) Average Flow (cfs): 0.30 (7.) Use Support: (13.) IWC (%): 001- (34%) SUMMARY ,LC L�� • This is a minor permit renewal for a 0.02 MGD WWTP serving the CommScope facility. The facility has 4 permitted outfalls (001-004). Presently there is no regional POTW to serve this facility. • The facility manufactures coaxial cable by extrusion of a plastic coating over copper -plated aluminum wires. Contact cooling water is generated from cooling pits used to cool the fabricated copper cable. • Outfall 001 discharges treated domestic watewater (90%) and cable extrusion contact cooling water (10%) on a continuous basis. Outfalls 002/003/004 previously discharged contact cooling water to an onsite 10-acre holding pond on an episodic basis (generally once per year), which occasionally overflowed to the same receiving waterbody as Outfall 001. Sludge residuals are removed offsite by Catawba Septic Tank Service. • This facility discharges to an UT Terrapin Creek (class WS-IV) which flows into Lake Norman, an oligotrophic man-made reservoir. The receiving stream originates immediately above the discharge point from an upstream impoundment. The receiving stream's assimilative capacity is limited due to relatively low flow. • Permit was modified in February 2004. Commscope wanted to "bleed in" contact cooling water to the existing treatment system. This contact cooling water was called process water in the description of Outfall 001 wastewater. Daily maximum values for BOD5 and TSS were reevaluated per effluent guidelines for 40 CFR 463 Plastics Molding and Forming Point Source Category, Subpart A — Contact Cooling and Heating Water Subcategory 463.12. Parameter Daily Max. BOD5 26 mg/L Oil and Grease 29 mg/L TSS 19 mg/L NPDES PERMIT FACT SHEET CommScope, Inc. Page 2 NPDES No. NC0034754 Calculations using domestic and contact cooling (process) flows at the time of 2004 permit modifications determined that the daily max. limit for summer BOD5 should not exceed the existing 24 mg/L. Daily max winter BOD5 limit was calculated to be 40.7 mg/L. A daily max. TSS limit of 39.2 mg/L was also calculated. These existing limits for Outfall 001 will be applied during this permit renewal. Limits for Outfalls 002, 003, 004. Existing limits will be recommended. BOD5 limit of 5mg/L is based on protections of dissolved oxygen standard instream, BOD5 of 26 mg/L would violate such standard. Previous model indicated that more protective limits shall be given. REASONABLE POTENTIAL ANALYSIS There are no metals limited or monitored in the current permit. RPA was not conducted. INSTREAM MONITORING: Currently Temperature, DO, Fecal Coliform and Conductivity are monitored. Analysis of instream data indicates that the facility has no significant negative impact on the water quality in the receiving stream TOXICITY TESTING: Type of Toxicity Test: Chronic P/F @ 34% for Outfall 001. February, May, August, November Acute Toxicity for Outfalls 002, 003, 004. No changes are recommended. COMPLIANCE SUMMARY: This facility has a good compliance record and appears to be well operated. Limits for BOD5, TSS, 086G are consistenly met. One violation of fecal Coliform limit occurred in 2002, and two violation of chronic toxicity limits: 02 / 2001 and 09 / 2004. PROPOSED CHANGES: • Limits. Weekly average limits for ammonia nitrogen have been added to the permit based on the new DWQ policy adopted October 2002. The TRC limit for cyanide has been added to the permit. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: December 12, 2005 (est.) Permit Scheduled to Issue: January 30, 2006 (est.) STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Sergei Chernikov at (919) 733-5038 ext. 594. CHANGES IN THE FINAL PERMIT: • The compliance schedule of 18 months for TRC was added for Outfalls 002, 003, and 004. • Instream monitoring requirements for conductivity and fecal coliforms were removed from the permit based on the DMR data and in response to permittee's request. • Air compressor condensate and stormwater were removed from the description of wastewater for Outfalls 002, 003, and 004 to correct an error. • Commscope also requested removal of Chronic Toxicity testing for Outfall 001, but after the visit to the plant and telephone discussion on 06/11/2007 Scott Waddell requested that this requirement remains in place to give CommScope the option of treating contact cooling water at their WWTP. Page 2 Version: June 12, 2007 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0034754 Facility Information Applicant/Facility Name: CommScope Applicant Address: 6519 CommScope Road Catawba NC 28609 Facility Address: 6519 CommScope Road Catawba NC 286 Permitted Flow 0.020 MGD Type of Waste: Domestic and Industrial Process Water Facility/Permit Status: Renewal Facility Classification II County: Catawba Miscellaneous Receiving Stream: UT Terrapin Creek A Regional Office: Mooresville Stream Classification: WS-W USGS Topo Quad: E14NE/Catawba, N.C. 303(d) Listed?: No Permit Writer: Jackie Nowell Subbasin: 03-08-32 Date: 12/ 1 /2005 Drainage Area (mi2): 0.3 li- Summer 7Q10 (cfs) 0.06' Winter 7Q10 (cfs): 0.10 i Average Flow (cfs): 0.12 f� a IWC (%): 34 Primary SIC Code: 3357 SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION CommScope is requesting renewal of its existing NPDES permit with no modifications. The facility discharges domestic and process wastewater. The application states sanitary flow is 165,000 gal/month (-5500 GPD) and the process water is 45,000 gal/month (-1500 GPD). CommScope produces coaxial and trunk cable. The main process is plastic extrusion. Raw materials consumed are copper, aluminum, PVC & PE Plastics. CommScope has 4 outfalls. Historical info states that 001 discharges domestic and process water. Outfalls 002, 003 and 004 discharge contact cooling water from cooling pit dump. Permit was modified in February 2004. CommScope wanted to "bleed in" contact cooling water to the existing treatment system. This contact cooling water was called process water in the description of Outfall 001 wastewater. Daily maximum values for BOD5 and TSS were reevaluated per effluent guidelines for 40 CFR 463 Plastics Molding and Forming Point Source Category. Subpart A- Contact Cooling and Healing Water Subcategory 463.12 Parameter Daily Max. BOD5 26 mg/1 Oil& Grease 29 mg/1 TSS ' 19 mg/1 pH 6-9 SU Calculations using domestic and contacting cooling (process) flows at that 2004 permit modification determined that the daily max. limit for summer BOD5 should not exceed the existing 24 mg/1. Daily max. winter BOD5 limit was calculated to be 40.7 mg/1. A daily max. TSS limit of 39.2 mg/l was also calculated. These existing limits for Outfall 001 will be given in this permit renewal. Limits for Outfalls 002, 003, 004 Existing limits will be recommended. BOD5 limit of 5 mg/1 is based on protection of dissolved oxygen standard instream, BOD5 =26 mg/1 would violate.. Previous model that indicated that more protective limits must be given. CormScope Fact Sheet NPDES Renewal Page 1. RECEIVING STREAM INFO All the Comm Scope outfalls discharge to an unnamed tributary to Terrapin Creek in CTB32. The stream has a WS-IV classification. The receiving stream has low 7Q10 flow but it is considered positive flow, i.e. > 0.05 cfs. The stream has not been evaluated for use support and there is no biological data on the stream. Further downstream Terrapin Creek drains into Lake Norman. TOXICITY TESTING: Outfall 001 Current Requirement: Chronic Toxicity P/F @ 34%; February May August November Since January 2001, facility has had two FAILs in February 2001, and in August 2004. Recommend continuation of Chronic Toxicity P/F © 34%; February May August November Outfalls 002, 003, 004 Current Requirement: Acute Toxicity (Fathead Minnow, 24-hour) Monitoring: Episodic For the most part, these outfalls are active but not discharging. Outfall 002 discharged once from January 2001 to Sep 2005: in Sep 2004 at 32.5% Outfall 003 did not discharge from January 2001 to Sep 2005 Outfall 004 last discharged in March and April 2003; at >100% and 46.3%. Did not discharge any others Recommend continuation of Acute Toxicity Monitoring (Episodic)- Fathead Minnow) COMPLIANCE SUMMARY: Facility appears to be well operated. Limits for BOD5, TSS, O&G are consistently met. One violation of fecal coliform limit in 2002. A violation of chronic toxicity limit in 2004. INSTREAM MONITORING REQUIREMENTS: Current requirements: Temperature, DO, Dissolved Oxygen, Conductivity Recommendation: Renewal of all instream monitoring requirements REASONABLE POTENTIAL ANALYSIS. There are no metals limited or monitored in the current permit. No RPA was run. PROPOSED CHANGES: The following modifications have been made to the permit: • The addition of a Total Residual Chlorine limit of 28 ug/1 to all outfalls based on DWQ procedure for all facilities that use chlorine for disinfection. Eighteen month compliance schedule will be given_ • Weekly average limits for NH3 of 10 mg/1 (summer) and 21.5 (winter) will be given based on DWQ procedure. Limits were calculated at 5 times the existing monthly NH3 limit. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: 12/07/2005 Permit Scheduled to Issue: Tentatively 01/30/2006 STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Jakie Nowell at (919) 733-5083 ext. 512. NAME* . DATE: I Z ( t0( 4-Ali4v C;onzrnScope Fact. Sheet NPDES Renewal Page 2 AMENDMENT TO THE FACTSHEET Comments received from CommScope - Asked for 18 month schedule to achieve TRC limit DWQ will concur with this request because schedule was omitted from draft permit. Asked that "air compressor condensate and Stormwater" be removed from description of wastewater from 002, 003 and 004. DWQ will concur because this description was taken from very outdated permit copy and inadvertently included. Asked that chronic tox testing be deleted since facility has not received contact cooling water for 14. months. Hardpiping still connected and CommScope will remove after tox test is eliminated. NPDES consulted with Aquatic Toxicity and Matt M. stated that test cannot be eliminated until hardpiping has been disconnected and the tox test failure in August 2004, gives them concern with eliminating the chronic test. Recommends continuation of tox test for two years after disconnection from source of contact cooling water. Request deletion of fecal, pH and conductivity instream monitoring. DWQ will concur. It should be noted that there was no requirement for instream pH monitoring. Requests that BOD5 limit be modified from 5 mg/1 to 26 mg/1 (effluent guideline) at outfalls 002, 003, 004. DWQ response; WLA notes shows that BOD5 limit based on protection of DO standard instream. BOD5=26 mg/1 will violate DO standard in the stream segments that have very low summer 7Q 10 flow. DATE y9/Zac, CommScope Fact Sheet NPDES Reriew<at Page }. Friday, January 13, 2006 CERTIFIED MAIL RETURN RECEIPT REQUESTED # 7005 1820 0006 4094 9001 N.C. Dept. of Environment & Natural Resources Division of Water Quality NPDES Unit Attn: Jacquelyn Nowell 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Draft Permit Response CommScope, Inc. Catawba, North Carolina Catawba County NPDES Permit Number: NC 0034754 Dear Mrs. Nowell; CommScope 6519 CommScope Road P.O. Box 199 Catawba, North Carolina 28609-0199 Tel 800 438 3335 828 241 3142 Fax 828 241 6168 www.commscope.com JMN 1 8 2006 This letter is in response to the Draft NPDES Permit received by my office on December 12, 2005. In review of the draft permit several items arose which are of concern. 1) While the new chlorine residual limit of 28 ug/I was added to outfalls # 1, 2, 3, & 4 along with new weekly average limits for ammonia nitrogen for outfall #1, no schedule of compliance was mentioned. While the ammonia nitrogen limit doesn't really affect our daily operation of the plant, the chlorine limit is substantial. We are unclear if the current technology employed at the plant can reduce chlorine to the permit limit without jeopardizing other analytical monitoring (i.e. chronic toxicity testing — Ceriodaphnia dubia). As a result, CommScope is requesting a schedule of compliance date of no less than 18 months from the start date of the new NPDES Permit. CADocuments and SatingsWnradddMlY DocumeatstENS FILING SYSTET102CaawbaU-Emirauomnl - Wma132 Wastewater Isua\NCDENR - Co,. .L..ADM Pencil Rnpaoe - N00034754 (Jm. 13. 2005).doc 1 of 3 2) It was noted on page #2 "Outfalls 002, 003, 004 " and in section A (2) that "air compressor condensate, and Stormwater" was added to the wording to the Effluent Limitation s and Monitoring Requirements section for Outfall #2, 3 & 4. CommScope is already monitoring Stormwater through its Stormwater Permit (Certificate of Coverage # NCG030078) and feels that this requirement is redundant and unjustified. Also, this requirement would require monitoring every quarter during the 1S` rain event of that quarter. I feel that the requirement to monitor Stormwater and air compressor condensate (while not listed on our prior permit) is unjustified and should be removed from the permit. 3) CommScope is requesting to eliminate Chronic Toxicity testing. The WWTP has not received contact -cooling water for approximately 14 months. Due to the elimination of this wastestream, Chronic Toxicity should not be required. Hard piping at this time has not been disconnected, however, if the Chronic Toxicity requirement is removed, CommScope will proceed in making the necessary physical changes needed to ensure full compliance. 4) As a result of removing the Chronic Toxicity requirement, CommScope requests that the following upstream and downstream testing requirements be removed from the permit: a. Fecal b. pH c. Conductivity We ask that upstream and downstream sampling consist of DO and Temperature. 5) CommScope's EHS department (Catawba Facility) on several occasions has had conversations with the state concerning the BOD5 limit for an episodic contact cooling water discharge to our receiving pond. Please note that these conversations were informal in nature. Our concern is with the strict BOD5 limit placed on this discharge. The limit is currently set at 5 mg/1 per event with a sample to be taken upon the first discharge from the facility during each quarter. C.4Docvma is and SePingeNdswacklelDNIy DocumetstakEliS FILING SYS ET4102Lauwba 3-EavitoomwWl - WYd13.2 Wa,tcwatcr IssusWCDENR - C , o \Droll Permit vc - I3. 2005).doc orrespo Respot NC0074754IJm 2 of 3 Quarter is defined as a calendar quarter. EPA's subpart A, section 463.12 "Contact Cooling and Heating Water Subcategory" notes BOD5 concentrations at 26 mg/1 to calculate BPT effluent limitations. Discharge of contact cooling water to outfall # 2, 3 & 4 is not normal practice. The only time when this occurs is during a process upset where the cooling pits are overfilled with water and thus will discharge. This will usually happen in the event of a float malfunction. The pits are cleaned out on an annual basis and the water is hauled off for treatment. (Bills of Lading documentation is available upon request). As such, it is the request that the BOD5 limit be raised from 5 mg/1 to 26 mg/1 as referenced in section 463.12 Subpart A. Thank you for your time in reviewing these requests. If you should have any questions please feel free to contact me @ 828-241-6147. Sincerely, f, Waddell Environmental, Health & Safety Engineer OA, D6/11/ 2- Sc1i61 �-t 1:1 p-f^ I cc: David H. Sherrill — Operations Manager (Catawba Facility) John E. Moore — Corporate EHS Manager (CommScope Inc.) C:sDoc rmcnts and SdtingsIcs}saddellUM, Documcnts\F.)IS FILING SYSR•7.P42LNassba13•ErniromteNal • Watcrl3 2 Wastcssnter Isla s1NCDENR - Corrcg ondrncc`Drall Puma Rcspc sc - NC0031754 (Jan II, 2005).dnc 3 of 3 Draft Permit Reviews (3) Subject: Draft Permit Reviews (3) From: John Giorgino <john.giorgino@ncmail.net> Date: Tue, 20 Dec 2005 11:40:36 -0500 To: Jackie Nowell <Jackie.Nowell@ncmail.net> Hi Jackie, I have reviewed the following: NC0034754 CommScope NC0036196 Newton NC0060534 Brevard a have no comments. Thanks for forwarding them. John Giorgino Environmental Biologist North Carolina Division of Water Quality Environmental Sciences Section Aquatic Toxicology Unit Mailing Address: 1621 MSC Raleigh, NC 27699-1621 Office: 919 733-2136 Fax: 919 733-9959 Email: John.Giorgino@ncmail.net Web Page: http://www.esb.enr.state.nc.us 1 of 1 12/20/2005 1:25 PM ATA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor MEMORANDUM To: From: December 7, 2005 Britt Setzer NC DENR / DEH / Regional Engineer Mooresville Regional Office Jackie Nowell NPDES Western Program Subject: Review of Draft NPDES Permit NC0034754 CommScope Catawba County 13 William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director RECEIVED Mooresville• ofn,,;, DEC 082005 Public Water Supply Please indicate below your agency's position or viewpoint on the draft permit and return this form by December 7, 2005. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address listed at the bottom of this page. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of the above permit, provided the following conditions are met: Opposes the issuance of the above permit, based on reasons stated below, or attached: Signed Date: /Z /V05- 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 512 (fax) 919 733-0719 VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES Jackie.nowell@ ncmail.net An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper 'VP ruPlala 1110.1•.• STATE OF • NORTH CAROLINA ENVIRONMENTAL ' • ' MANAGEMENT COMMISSIONINPDES UNIT. .1617 MAIL SSIVICE • :CENTER • • RALEIGH, NC 27699-1.817 NOTIFICATION'. OF Atagt.iT '! • ,TO ISSUE A NPDES • - WASTEWATERPERMIT On the bass of thorough -staff review and -application of NC • General Statute '143.21, Pub- lic law 92.500 and other laitil* standards and :iegidations, the North Carolina Environmental Management Commission proposes Int 18$110 a National. Pollutant.Discharge Elimina- don :System (NpDES) waste- water 'discharge .perrnft to' the person(s) listed below ,effe. ttve 45 days from the .publish date of this notice. f Written '-oarriments regarding the *proposed. . permit .vli be. licaiipfeCtatli:,44Alys: after the publishilate'or this lidice• At comments- retched Otiet,tO that date are.s,considered Inlhe final detiwa11frattroiiic.0a9 the Iiropisect pennit. TheDl. rector.ot;the NC,.,DhAsion•-.:of 3N01rialitYmayAtec1de •-•to liold a publlc neeting`foi:the permit . On receive :a significant degree of public Interes1,,;`,,IJ4 • ;'- • Ccples P1 ttte.-dratt pennnd other' 403017 1.00 oh file:OPOO Oho coo' :draft Per. ';:•Lieitueet Yale!itr -63-ete'el ihenialeats Ao•:..11ikKavlOKIANt... glii&olltart:.$30utrotrinZA • Branch a ,(sip 733-5083,- ex- Mei* -520' of:34 -Please In- -akide Abe' NPDEG,gerrnit num- itlerted) any _coma*, estod person jimylalso ZAN Wator.Ot01uty ,a14121.N. SaCl ari-f..Street;-:;:Ralaigh,:;Ittq,; 7604414S:ktretiresk.,the hourdlf. 8:0Q-. efsiv7arid )maiiii (PO. Box 125; -.Maiderf,..,NCi, 28650) has oppUed• • for Arrant of NPDEG NC0039594 for • the Maft WWTF, In Cater - Iv. Cqunty.-1This permitted fa- . cilift .,thchargss- •'MGD "treated. ,wastewater •-• to Cfark /Creek.. irr the, ..;Citanta River 4011k4ota!, tesich4i.d ! 7friti;CSOto• sCebiturtf,,ailoz.. cafiorifiqh' this r porilon. of the ipatawba Rhier Basin, . • NODES.,:"Pormit"‘41uMbir .NC0034754:',•Cor,OniScope, bas*Pledjklii0,011. Its !.,ircieted proceavand,domesdeivisie;. *ter to the unnamed tributary': to Terta,ohiktiekilt awba. 'Riot! BasIii.urrenttv BOK s,h913-K; Mtar `suspdnd id ‘2sogd3,:.'fecid :.cogentr, and' tOtatteekteal..attleriee are wa- ter-qitaCttyUrn.ted:lhla ' dts- charge reey'offect. futixo alto - cations in • this-401ton, recelvirig streani: .PUBLISH: December 9, 2005 C) 09 (LI 217 23511 NORTH CAROLINA CATAWDA COUNTY INS,- she is .. . e l'of the Hickory Daily Record, a news aper pub- lished at Hickory, North Carolina; that in the issues of the said newspaper for the following days, to wit: CR IY\6 c CI, .. being first d ly sworn, • That he or i... there appeared lines of advertising as per attached named advertiser: The Hickory Daily Record is a qualified news- paper within the meaning of,action 1-597 of the General tatutes of N. C. spaced Affiant Sworn to and subscribed before me, this ,Re'V'•6) day of My Commission Expires // 20 0.5- 20 ‘77 To: Permits and Engineering Unit Water Quality Section Attention: Jackie Nowell SOC PRIORITY PROJECT: No Date: May 11, 2005 NPDES STAFF REPORT AND RECOMMENDATIONS County: Catawba NPDES Permit No.: NC0034754 MRO No.: 04-112 PART I - GENERAL INFORMATION 1. Facility and address: CommScope, Inc. 6519 CommScope Road Catawba, N.C. 28609 2. Date of investigation: May 4, 2005 -1)) 11WN Li MAY 1 8 2005 DEER - WATER QUALITY POINT SOURCE BRANCH 3. Report prepared by: Michael L. Parker, Environmental Engineer II 4. Person contacted and telephone number: Scott Waddell, (828) 241-6356. 5. Directions to site: From the jct. of Hwy. 150 and Sherrills Ford Road in southeastern Catawba County, travel northwest on Sherrills Ford Rd. 5.9 miles to the junction with Joe Johnson Rd. Turn right on Joe Johnson Rd and travel 0.3 mile and turn right onto Long island Rd. Travel 0.2 mile on Long Island Rd. and turn right onto CommScope drive. CommScope is located at the end of this road. 6. Discharge point(s), list for all discharge points: - outfall 001 outfall 002 outfall 003 outfall 004 Latitude: 35 ° 38' 57" 35 ° 39' 05" 35 ° 39' 03" 35 ° 38' 58" Longitude: 81 ° 01' 52" 81 ° 02' 05" 81 ° 02' 03" 81 ° 02' 01" Attach a USGS Map Extract and indicate treatment plant site and discharge point on map. USGS Quad No.: E14 NE 7. Site size and expansion area consistent with application: Yes. There is area available for expansion, if necessary. 8. Topography (relationship to flood plain included): The WWTP site is not located in or near a flood plain. 9. Location of Nearest Dwelling: None within 1000 feet of the WWTP site. Page Two 10. Receiving stream or affected surface waters: U. T. To Terrapin Creek (all Outfalls) a. Classification: WS-IV b. River Basin and Subbasin no.: Catawba 030832 c. Describe receiving stream features and pertinent downstream uses: the receiving stream originates immediately above the discharge point and is made up primarily by flow from an upstream impoundment. Minimal flow observed in the receiving (above the discharge point) at the time of the site inspection. Downstream uses are agricultural in nature. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater: 0.020 MGD (Design Capacity - outfall 001 ), no flow limit for Outfalls 002, 003, and 004. b. What is the current permitted capacity: 0.020 MGD c. Actual treatment capacity of current facility (current design capacity): 0.020 MGD d. Date(s) and construction activities allowed by previous ATCs issued in the previous two years: There have been no ATCs issued in the past two years. e. Description of existing or substantially constructed WWT facilities: The existing WWT facilities at outfall 001 consist of a manual bar screen followed by a flow splitter box, an aerated 9000 gallon storage/equalization tank, dual aeration basins, sodium peroxide pH adjustment, dual secondary clarifiers, tertiary filters, diffused post aeration, a liquid chlorine contact basin (with tablet back-up), dechlorination, cascade aeration, two (2) sludge holding tanks (one aerated), and instrumented flow measurement. There are no treatment facilities for Outfalls 002, 003, and 004, which consist of cooling water, air compressor condensate, and stormwater. f. Description of proposed WWT facilities: There are no WWT facilities proposed at this time. g• Possible toxic impacts to surface waters: Chlorine is added to the waste stream; however, dechlorination is provided. 2. Residual handling and utilization/disposal scheme: Waste residuals are removed by Catawba Septic Tank Service and are taken to the City of Newton's Clark Creek WWTP for disposal. 3. Treatment plant classification: Class II (no change from previous rating). 4. SIC Code(s): Wastewater Code(s): 02 MTU Code(s): 05107 Page Three PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved? Public monies were not used in the construction of this facility. 2. Special monitoring or limitations (including toxicity) requests: It is anticipated that a residual chlorine limit will be added to the permit at reissuance. 3. Important SOC/JOC or Compliance Schedule dates: This facility is neither under an SOC nor is one being considered at this time. 4. Alternative analysis evaluation a. Spray Irrigation: Insufficient area. b. Connect to regional sewer system: Presently there is no regional sewer system available to serve this facility. c. Subsurface: Insufficient area. PART IV - EVALUATION AND RECOMMENDATIONS The permittee, CommScope, has requested renewal of the subject permit. There have been no changes to the permit since the permit was last renewed, however, there were some additions to the WWTP that were approved in ATC No. 034754A01 (issued December 18, 2001), which were implemented during the term of the current permit. CommScope has been advised of the impending inclusion of a total residual chlorine (TRC) limit added to the permit upon renewal. Mr. Waddell informed the writer that their current testing equipment was not capable of detecting TRC at levels consistent with the anticipated limit. Mr. Waddell then asked that additional time be provided in the renewed permit to effect equipment upgrades necessary to meet the new limit. However, subsequent conversations with MRO staff revealed that CommScope's existing equipment may indeed be capable of reading TRC levels consistent with the Division's new TRC policy. It is, therefore, recommended that clarification be provided by CommScope as to their ability to analyze TRC at the levels anticipated in the renewed permit before any consideration is given to providing additional time for CommScope to make any equipment changes and/or upgrades. CommScope is also considering removing the process water component from the wastestream tributary to outfall 001. This would result in the existing WWT facilities discharging through outfall 001 treating purely domestic wastewater. If this occurs, CommScope has indicated that they may request that toxicity testing be removed from the monitoring requirements at this outfall. If such as request is submitted, the Aquatic Toxicology Section will need to determine whether such a request is justifiable. It is likely, given the low flow in the receiving stream (CommScope's effluent typically dominates normal stream flow), and the fact that CommScope has had toxicity failures in the past, that elimination of the toxicity testing requirement would not be granted. Page Four It is recommended that the NPDES Permit for this facility be renewed as requested pending receipt and approval of the draft permit. r Signature of Report eparer D0_ . . .e.( "v. Water Quality Renal Supervisor h:ldsr dsr05\commscpe.sr ate Date 0 CommScope Tuesday, October 19, 2004 CERTIFIED MAIL RETURN RECEIPT REQUESTED # 7001 1940 0004 7534 6980 N.C. Dept. of Environment & Natural Resources Division of Water Quality Attn: Central Files 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: 2005 Permit Renewal Request CommScope, Inc. Catawba, North Carolina Catawba County NPDES Permit Number: NC 0034754 To Whom It May Concern: 6519 CommScope Road P.O. Box 199 Catawba, North Carolina 28609-0199 Tel 800 438 3335 828 241 3142 Fax 828 241 6168 www.commscope.com CommScope wishes to renew the current NPDES Permit # NC0034754. There are no known facility changes since the issuance of the last permit. Attached you will find the completed Application Form (Short Form C). Sludge Management Plan: CommScope's WWTP does create solids from it's operation. All sludge from the WWTP operation is pumped to a sludge holding tank where it is pumped out and transported to the City of Newton WWTP for further processing. If you should have any questions concerning information contained in the report, please feel free to contact me @ 828-241-6356.. Sincerely, ((/;,6),%&" D. Scott Waddell Environmental, Health, & Safety Engineer C:\Oneomemt and SettingstdswaddellrMy Docomems\ERS FILING SYSTEMl02-CalawEe3- moomeSW- Wua13.2 Wastewater ItatesWermit Fees\2005 Permit Application Corer dor 1of 1