NC0021920_Compliance_20040921

NPDES DOCUMENT :MCANNIN`: COVER SHEET
NC0021920
Whiteville 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
Compliance (Mercury)
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 21, 2004
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September 21, 2004
SUSAN D. RHODES
City Manager
Coleen H. Sullins, Deputy Director
Division of Water Quality
NC Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: City of Whiteville, NC
NPDES Permit No. NC0021920
Notice of Violations - Mercury
Dear Ms. Sullins:
1
317 S. Madison Street y�
P.O. Box 607 .¢TV=`11".
Whiteville, North Carolina 28472
Phone: [phone]
Fax: [phone]
[e-mail]
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•C- 0 7 2004
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On August 10, 2004 the Wilmington Regional Office of the NC Department of Environment and
Natural Resources, Division of Water Quality (DWQ), issued a Notice of Violation (NOV) and
Assessment of Civil Penalty in the amount of $1,054.83 to the City of Whiteville for Daily
Maximum mercury violations. The NDPES permit limit for mercury that was exceeded was a
TMDL mass loading limit of 0.004 grams / day.
The issuance of a NOV and penalty was contrary to a November 18, 2003 DWQ memorandum
in which DWQ determined that it would withhold the assessment of civil penalties for violations
of the total mercury limit for samples collected during September 2003 through August 2004
provided the samples were analyzed using the new method. The NOV and penalty mentioned
above was assessed for samples taken in May 2004 and analyzed according to EPA TM 1631.
The City of Whiteville pointed this out to DWQ and the NOV was subsequently retracted.
The City of Whiteville is in the Lumber River basin and understands the importance of mercury
in our environment. We are doing everything we can to address the mercury issue. Plant
personnel have attended all state sponsored seminars on Mercury, complied with the new EPA
test methods and have begun a sampling regime to determine the extent and possible sources of
mercury in our system. The results of initial sampling are presented in following table.

Coleen H. Sullins
September 21, 2004
Page 2
Table
Mercury
Location
Sample Date
Result
nanograms / L
Sample
Test Blank
Plant Effluent
9/8/04
1.29
1.18
Plant Effluent
9/14/04
<1.00
<1.00
Upstream
9/8/04
7.83
1.06
Potable Water
9/8/04
1.07
<1.00
Please note that the test result for potable water was 1.07 nanograms / L. Using the formula
provided in the NPDES permit (see below) the mercury loading from potable water is 0.0057
grams / day. The sample for potable water exceeds the NPDES effluent mass loading limit
of 0.004 grams / day.
Effluent Concentration (ug/L) X Daily Flow (MGD) X 3.785 (conversion factor) = grams /day
0.00107 ug/L X 1.4 MGD X 3.785 = 0.0057
It is of concern to the City of Whiteville that our potable water exceeds the NPDES loading rate
for mercury derived from the TMDL allocation. It raises a concern as to the practicality of the
TMDL.
It is also the City's concern that since the evaluation period for mercury compliance terminated
in August 2004 subsequent violations of this parameter are imminent and future NOV's could be
forthcoming.
It is the City of Whiteville's understanding from DWQ's November 18, 2003 memorandum that
Phase II of the Mercury Compliance Strategy is currently underway. The City would greatly
appreciate DWQ extending the evaluation period until Phase II has been completed. Hopefully a
result of the Mercury Compliance Strategy will be a revision of the TMDLs in the Lumber River
Basin.
Please let us hear from you on this urgent issue.
V; ry truly yours,
Susan Rhode,
City Manager
Attachments — mercury data

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P.O. BOX 7085, 114 OAKMONT DRIVE
GREENVILLE, N.C. 27835-7085
CITY OF WHITEVILLE
MR. ASURE SPIVEY
P.O. BOX 607
WHITEVILLE ,NC 2847
PARAMETERS
Mercury (Method 1631), ng/1
SEP 201
\21)01
Trade Matt
021
PHONE [phone]
FAX [phone]
Drinking Water ID: 37715
Wastewater ID: 10
ID#: 8525 A
207 NO.J.K.POWELL BD
DATE COLLECTED: 09/08/04
DATE REPORTED : 09/16/04
REVIEWED BY:
Field Analysis Method
Blank Date Analyst Code
1.07 <1.00 09/15/04 JSM EPA1631
Laboratory Analyses — Environmental Consultants

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P.O. BOX 7085, 114 OAKMONT DRIVE
GREENVILLE, N.C. 27835-7085
CITY OF WHITEVILLE
MR. ASURE SPIVEY
P.O. BOX 607
WHITEVILLE ,NC 28472
Upstream
sr 29AA1i1
PHONE [phone]
FAX [phone]
Drinking Water ID: 37715
Wastewater ID: 10
ID#: 885 Z
DATE COLLECTED: 09/08/04
DATE REPORTED : 09/16/04
REVIEWED BY:
Field Analysis Method
PARAMETERS Blank Date Analyst Code
Mercury (Method 1631), ng/I
7.83 1.06 09/15/04 JSM EPA1631
Laboratory Analyses — Environmental Consultants

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P.O. BOX 7085, 114 OAKMONT DRIVE
GREENVILLE, N.C. 27835-7085
CITY OF WHITEVILLE
MR. ASURE SPIVEY
P.O. BOX 607
WHITEVILLE ,NC 28472
Effluent
PHONE [phone]
FAX [phone]
Drinking Water ID: 37715
Wastewater ID: 10
ID#: 885
DATE COLLECTED: 09/08/04
DATE REPORTED : 09/16/04
REVIEWED BY:
Field Analysis Method
PARAMETERS Blank Date Analyst Code
Mercury (Method 1631), ng/I
1.29 1.18 09/15/04 JSM EPA1631
Laboratory Analyses — Environmental Consultants