NC0036196_Staff Comments_19930217

NPDES DOCUMENT !MCANNINO COVER :SHEET
NC0036196
Clark Creek WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
11
5'7111
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 17, 1993
This document is printed on reuse paper - ignore any
content on the resrerse side

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
TO: Randy Kepler
THRU: Trevor Clements
Ruth Swanek ao
Carla Sanderson
FROM: Jackie Nowell
February 17, 1993
gc5 fa'
SUBJECT: Comments on Draft Permit for Newton -Clark Creek WWTP
NPDES Permit No. NC0036196
Catawba County
The Technical Support Branch has reviewed the letter from Rick French con-
cerning the draft permit for Newton and has the following comments and recom-
mendations for selected items.
Item 1. Effluent Limitations and Monitoring requirements recommended for
Cadmium, Chromium, Nickel, Lead, Cyanide, and Toluene at the expansion flow of
7.5 MGD, remain the same as the limits recommended at previous flow of 5.0 MGD
until the Catawba Basin Management Plan in 1995. - Technical Support recommends
that if the expansion to 7.5 MGD is completed, the limits for the metals and
other toxicants in the September 1991 wasteload allocation be applied. North
Carolina Regulation 15A NCAC 2B .0206(a) provides the basis for assignment of
effluent limitations and "the flow design criteria is used in the development of
water quality based effluent limitations...".
It should be noted that recent compliance data for Newton, do not indicate
that the City has been monitoring for Cd, Cr, Ni, Pb, CN, or Toluene at the
current design flow of 5.0 MGD. The City should be monitoring for these parame-
ters. Without reported data, the Division is unable to determine compliance
with recommended effluent limitations.
The previously recommended limits for the parameters are as follows:
Ow = 5.0 MGD 7.5 MGD
Cadmium = 3.5 ug/1 3.0 ug/1
Chromium = 89 ug/1 76 ug/1
Nickel = 156 ug/1 133 ug/1
Lead = 44 ug/1 38 ug/1
Cyanide = 8.9 ug/1 7.6 ug/1
Toluene = 19 ug/1 17 ug/1
Items 3 & 4. Explanation of instream monitoring locations and why cadmium is
being monitored at a different location than the other parameters? - Cadmium
should be monitored at downstream site D1-State Road 2012, while all other par-
ameters would be sampled at downstream site D2-State Road 2007. Effluent data
have indicated that the Newton facility may be discharging levels of cadmium
that could be violating the instream standard of 2.0 ug/l. Because cadmium is

Memo to Randy Kepler
-page 2-
highly toxic, Technical Support recommends instream sampling closer to Newton's
outfall rather than further downstream at site D2 to better determine effects on
water quality. North Carolina Regulation 15A NCAC 2B .0505 (c)(2)(B) allows the
establishment of one or more downstream monitoring locations to determine the
impact of the discharge on receiving waters.
Item 5. Technical Support acknowledges that the Bills Branch tributary
flows into Clark Creek above the second downstream site. However, the modelling
analysis indicates that the dissolved oxygen sag is predicted to occur below the
confluence of Bills Branch. The Bills Branch trib inputs less than 1 cfs of
flow and oxygen demand levels are nearly to background default values when
entering Clark Creek. Therefore, the impact of this tributary will be negli-
gible on instream monitoring for the Newton facility.
Item 6. Chronic Toxicity based on actual flow during test instead of design
flow - According to Division Standard Operating Procedure (SOP), whole effluent
toxicity limitations and monitoring requirements will be based upon the instream
waste concentration (IWC) at permitted wasteflow and design streamflow.
Technical Support defers to Permits and Engineering for decisions on the
remaining items listed.
If there are any questions on these items, please contact me.
cc: Rex Gleason
WLA File

CITY OF
WHERE THE HEART IS!
December 7, 1992
P.O. Box 550 • Newton, N.C. 28658 • [phone] • Fax: [phone]
Ms. Coleen Sullins
NCDEHNR
NPDES Permits Group
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Subject: Request for Amendments and Clarification to Sections of
the Purposed Draft NPDES Permit #NC0036196, Clark Creel<
WWTP, Clty of Newton
Dear Ms. Sullins:
The City of Newton is requesting the Division to amend items that
are listed below:
1. The City requests Effluent Limitations and Monitoring
requirements concerning Cadmium, Chromium, Nickel, Lead,
Cyanide, and Toluene remain the level that is proposed
for the 5 MGD flow. The City is requesting the levels
to remain until 1995, at which time basin permitting will
be in effect. The Division has authorized the City to
expand the plant from 5 MGD to 7.5 MGD and construction
is to be completed December 31, 1993. The low monthly
average flow for the plant has been 3.3 MGD to a high
maximum average of 4.5. MGD. Due to the lagging economy,
flows are not expected to exceed the 5 MGD monthly
average before 1995.
2. Compliance for parameters in Part I -A. be judged by
Monthly Average instead of Daily Maximum.
3. Explain why the stream sampling locations are listed in
Part I -A. as follows:
U-Upstream, NCSR 2014
D1-Downstream, NCSR-2007
D2-Downstream, NCSR 2012
The present permit stream monitoring points are as
follows:
U-Upstream, NCSR-2014
DN-Downstream, NCSR-2012
4. Part I -A. Effluent Limitations and Monitoring
Requirements
Explain why Cadmium is to be sampled at a different point

from the other required parameters?
5. Reminder to the Division: Precedent Furniture, located
on Settlemyre Road, SR-1884 has a package WWTP
discharging into Bill's Branch that flows into Clark
Creek before the downstream monitoring point NCSR-2007.
6. Part III-F.& H. - Chronic Toxicity
Request the dilution factor for the test, be based on
actual flow during the testing period instead of design
flow.
7. Part II-A.-10 - Definitions
Please explain specifically what is the correct and
accepted procedure to determine a calendar week and day.
The City monitors Monday through Friday starting
samplers at Sunday, midnight and stopping them on Friday,
midnight. This procedure is also for each day.
8. Part II -Section E-6-b.(c) 24 Hour Reporting
Remove this requirement if daily maximum requirement is
changed to monthly average.
9. Part II Section A-8(b) - Grab Sample
Please explain how this will relate to the PH and CL2
to the effluent daily monitoring and reporting. Example:
four samples collected, report the maximum, or average
the four samples and report this value?
10. Part IV -A Annual Administering and Compliance Monitoring
Fee Requirement
Explain what type monitoring is required and amount of
fees for budgeting purposes.
Your respopse to these requests of consideration and questions
concerning the Draft Permit will be appreciated. If you have any
questions concerning this matter please contact me.
Sincerely,
1L;4
Rick French
City Manager
c: Dwight Wilson, Director of Utilities
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State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
MEMORANDUM
To: J. Trevor Clements
Through: Julia F. Storm
From: Joe Pearce • Ae
Subject: City of Newton's NPDES Permit #NC0036196
Date: February 9, 1993
Dist: Jackie Nowell
Randy Kepler
Keith Haynes
Kim Colson
Jonathan B. Howes, Secretary
On February 4, 1993 Mr. Keith Haynes of the Mooresville Regional Office (MRO) and I
completed a pretreatment compliance inspection and provided headworks analysis
technical advice to the City of Newton. During our discussions, several potential problems
were discovered related to the reissuance of the permit. Per Mr. Dwight Wilson, the City's
ORC, the permit is drafted for 5 MGD until completion of expansion and 7.5 MGD post
completion of expansion. However per Mr. Dwight Wilson, the expansion is not being
completed per the plans submitted to the Division, 50% of the plan is not being
constructed. Also, discussion with Kim Colson of MRO indicates that the Authorization
to Construct was not issued for a 7.5 MGD expansion, but only for a "more flexible" 5.0
MGD plant. It was apparent from our discussions with Mr. Wilson relating to the draft
NPDES permit that he believed that the City of Newton would have a 7.5 MGD permit
pending completion of the current construction activities. It appears that the City does not
understand the "draft" NPDES permit and its A-C permit. The City is completing the
headworks analysis using the 7.5 MGD permit limits pending clarification of the NPDES
permit. It must be noted that the City is operating under a extended expired permit, due to
a previous "adjudication?"of a 5 MGD permit. These apparent discrepancies between the
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

City and DEM must be reconciled in order for completion of headworks analytisis review.
Requests for more info on four IUP permits submitted between Jan. -June 1992 are pending
final approval based upon overallocation determination. IUP's need to be resolved ASAP
due to 60 day schedule resulting from PCI. In addition, this may be an existing versus new
or expanded issue. Please advise how to proceed.