NC0024236_Wasteload Allocation_19940411

NPDES DOCUMENT !CANNINO COVER SHEET
NPDES Permit:
NC0024236
Kinston Regional WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
201 Facilities Plan
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 11, 1994
This document is printed on reuse paper - ignore any
content on the rezrerse side

North Carolina Division of Environmental Management
Water Quality Section / Rapid Assessment Group
April 11, 1994
MEMORANDUM
To: Charles Alvarez
From: Farrell Keough
Through: Carla Sanderson
Subject:
Kinston - Northside WWTP NC0024236
Lenoir County
addendum to April 5, 1994 memorandum: Permit Requirments
The City of Kinston sent a letter dated February 10, 1994 questioning the necessity for Oil and
Grease monitoring. At most municipal plants, Oil and Grease are primarily from animal sources and
therefore a matter of plant efficiency; if these types of oils and greases are not removed the BOD and
ammonia removal efficiencies are severely diminished.
The Technical Support Branch included this monitoring in the Kinston - Northside WWTP due to
Region indication that Oil and Grease influent to this facility is from machining industries and not domestic
in nature. These types of oils and greases can pass through a plant more easily without affecting the
BOD and ammonia removal processes. The Region felt that weekly monitoring of this parameter would
be acceptable, ('rf a precedent already exists for relaxing the frequency of this type of requirement). But
weekly monitoring would be the absolute minimum requirement we should impose upon this facility. The
Technical Support Branch concurs with the Regions recommendations.
cc:
Don Safrit, Asst. Chief TSB
Dave Goodrich, P and E
Julia Storm, Pretreatment
Central Files

MEMORANDUM
To:
From:
North Carolina Division of Environmental Management
Water Quality Section / Rapid Assessment Group
April5, 1994
• Charles Alvarez
1
Farrell Keou
Through: Carla Sanderson
Subject: Kinston - Northside WWTP NC0024236
Lenoir County
Permit Requirements
The City of Kinston sent a letter dated February 10, 1994 questioning the necessity for
monitoring of Chromium, Copper, Nickel, Lead, Zinc, Silver, and Arsenic. The letter also requests a
monthly average limit for Cadmium, Cyanide, and Mercury. Along with this letter, the facility sent in
effluent data for the period of August 20 - 26, 1990. Unfortunately, current Toxics SOP requires a
minimum of twelve data points over the coarse of at least one full year, thus this data is not valid for any
changes in the toxicity analysis. The following represents the rational and recommendation for these
various parameters:
Request for deletion from Permit
Chromium: the monitoring requirement for this parameter is based upon Pretreatment "permitted"
values. Technical Support would recommend dropping the NPDES monitoring requirement as
we will be able to obtain monitoring data through the Pretreatment Long Term Monitoring Plan
(LTMP).
Copper: the monitoring requirement for this parameter is based upon Pretreatment data as well as
facility effluent monitoring data. Technical Support would recommend dropping the NPDES
monitoring requirement as we will be able to obtain monitoring data through the Pretreatment
Long Term Monitoring Plan (LTMP).
Nickel: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).
Lead: the monitoring requirement for this parameter is based upon Pretreatment "permitted"
values. Technical Support would recommend dropping the NPDES monitoring requirement as
we will be able to obtain monitoring data through the Pretreatment Long Term Monitoring Plan
(LTMP).
Zinc: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).
Silver: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).
Arsenic: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).

Kinston - Northsiide WY.'
NCoo24 ..
Request for reduced monitoring freayencies
Cadmium: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points over a period of
one week exist for the effluent monitoring and a minimum of twelve point over the coarse of one
year is required. The limit itself was based on other interacting facilities in that area, (i.e. Kinston -
Peachtree and DuPont). We can offer a limit of 34.5 µg/l weekly average and 138 Ng/1 daily
maximum. Our recommendations for monitoring frequency requirements will follow the
requirements for this type of limit and the facility's classification.
Cyanide: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points over a period of
one week exist for the effluent monitoring and a minimum of twelve point over the coarse of one
year is required. The limit itself was based on other interacting facilities in that area, (i.e. Kinston -
Peachtree and DuPont). Pretreatment is adamant that the facility's effluent cyanide data is based
on erroneous analysis and in fact should be either below detection or very low. Since no hard
data exists for this facility and Pretreatment has worked so closely with them and is aware of their
influent and effluent discharge values, the Technical Support Branch will defer to their
recommendation of dropping the NPDES requirement for cyanide and obtaining our analysis
information from the Pretreatment Long Term Monitoring Plan (LTMP).
Mercury: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points over a period of
one week exist for the effluent monitoring and a minimum of twelve point over the coarse of one
year is required. The limit itself was based on other interacting facilities in that area, (Le. Kinston -
Peachtree and DuPont). We can offer a limit of 0.2 wg/I weekly average and 0.8 WI daily
maximum. Our recommendations for monitoring frequency requirements will follow the
requirements for this type of limit and the facility's classification.
The following represents our position in brief:
Parameter; Current Requirement:
Chromium monitor per NPDES Permit
Copper monitor per NPDES Permit
Nickel monitor per NPDES Permit
Lead monitor per NPDES Permit
Zinc monitor per NPDES Permit
Silver monitor per NPDES Permit
Arsenic monitor per NPDES Permit
Cadmium Limited per NPDES Permit
Cyanide Limited per NPDES Permit
Mercury Limited per NPDES Permit
cc:
Don Safrit, Asst. Chief TSB
Dave Goodrich, P and E
Julia Storm, Pretreatment
Central Files
Recommendation:
drop NPDES requirement: will be monitored per
Pretreatment LTMP
drop NPDES requirement: will be monitored per
Pretreatment LTMP
drop NPDES requirement: will be monitored per
Pretreatment LTMP
drop NPDES requirement: will be monitored per
Pretreatment LTMP
drop NPDES requirement: will be monitored per
Pretreatment LTMP
drop NPDES requirement: will be monitored per
Pretreatment LIMP
drop NPDES requirement: will be monitored per
Pretreatment LIMP
Limit with weekly average [ 34.5 µg/l ] and daily maximum
[138 Aga
drop NPDES requirement: will be monitored per
Pretreatment LTMP
Limit with weekly average [ 0.2 mil ] and daily maximum
[ 0.8 µg/i ]

MEMORANDUM
To:
From:
Through:
Subject:
North Carolina Division of Environmental Management
Water Quality Section / Rapid Assessment Group
March 23, 1994
DRAFT • Mptn,
Charles Alvarez
Farrell Keoug
Carla Sanderso
Kinston - Northside WWTP NC0024236
Lenoir County
Permit Requirements
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The City of Kinston sent a letter dated February 10, 1994 questioning the necessity for Peet- —
monitoring of Chromium, Copper, Nickel, Lead, Zinc, Silver, and Arsenic. The letter also requests a
monthly average limit for Cadmium, Cyanide, and Mercury. The following represents the rational and r l
recommendation for these various parameters: 1 yt - �os�
Request for deletion from Permit d,p�NsAn,,
try, �y
Chromium: the monitoring requirement for this parameter is based upon Pretreatment "permitted" Pe-cL l7ANq
values. Technical Support would recommend dropping the NPDES monitoring requirement as A' Jr' q�
we will be able to obtain monitoring data through the Pretreatment Long Term Monitoring Plan cdidU1
(LTMP).
Copper: the monitoring requirement for this parameter is based upon Pretreatment data as well as
facility effluent monitoring data. Technical Support would recommend dropping the NPDES a'V 3/3f
monitoring requirement as we will be able to obtain monitoring data through the Pretreatment
Long Term Monitoring Plan (LTMP).
c• re_____
Nickel: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility MO�� d'A
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).
Lead: the monitoring requirement for this parameter is based upon Pretreatment "permitted"
values. Technical Support would recommend dropping the NPDES monitoring requirement as
�.X we will be able to obtain monitoring data through the Pretreatment Long Term Monitoring Plan
(LTMP).
,)14)---- Zinc: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
21\ Monitoring Plan (LTMP).
Silver: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
\ effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).
Arsenic: the monitoring requirement for this parameter is based upon Pretreatment data as well as facility
effluent monitoring data. Technical Support would recommend dropping the NPDES monitoring
requirement as we will be able to obtain monitoring data through the Pretreatment Long Term
Monitoring Plan (LTMP).

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Kinston - Northside WWTP
NC0024236
Request for reduced monitoring frequencies
Cadmium: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points exist for the
effluent monitoring and a minimum of twelve is required. The limit itself was based on other
interacting facilities in that area, (i.e. Kinston - Peachtree and DuPont). We can offer a limit of
34.5 µg/I weekly average and 138 WI daily maximum. Our recommendations for monitoring
frequency requirements will follow the requirements for this type of limit and the facility's
classification.
Cyanide: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points exist for the
effluent monitoring and a minimum of twelve is required. The limit itself was based on other
interacting facilities in that area, (i.e. Kinston - Peachtree and DuPont). We can offer a limit of
85.8 µg/I weekly average and 343.2 Ng/I daily maximum. Our recommendations for monitoring
frequency requirements will follow the requirements for this type of limit and the facility's
classification.
Mercury: The decision to limit this parameter was based solely on the Pretreatment 'permitted' values.
Current spreadsheet analysis cannot be performed as only seven data points exist for the
effluent monitoring and a minimum of twelve is required. The limit itself was based on other
interacting facilities in that area, (i.e. Kinston - Peachtree and DuPont). We can offer a limit of 0.2
µg/I weekly average and 0.8 µg/I daily maximum. Our recommendations for monitoring
frequency requirements will follow the requirements for this type of limit and the facility's
classification.
The following represents our position in brief:
Parameter;
Chromium
Copper
Nickel
Lead
Zinc
Silver
Arsenic
Cadmium
Cyanide
Mercury
cc:
Current Requirement:
monitor per NPDES Permit
monitor per NPDES Permit
monitor per NPDES Permit
monitor per NPDES Permit
monitor per NPDES Permit
monitor per NPDES Permit
monitor per NPDES Permit
Limited per NPDES Permit
Limited per NPDES Permit
Limited per NPDES Permit
Don Safrit, Asst. Chief TSB
Dave Goodrich, P and E
Julia Storm, Pretreatment
Central Files
Recommendation:
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
will be monitored per Pretreatment LTMP
Limit with weekly average [ 34.5 µg/I ] and daily maximum
[138µg/I]
Limit with weekly average [ 85.8 Nil ] and daily maximum
[ 343.2 µg/l ]
Limit with weekly average [ 0.2 Nil] and daily maximum
[0.8µg/I]

Page 1
Note for Farrell Keough
From: Dana Folley
Date: Apr 5, 1994 5:18 PM
Subject: Kinston-Northside
To: Farrell Keough
As you and I just discussed, the available effluent data for Northside for cyanide is suspect
due to the question of failure to properly preserve the effluent samples to address the chlorine
(and also becuase it from 7 consecutive days 4 years ago!). I believe this is supported by the
fact that all influent (and uncontrollable!) samples are <0.01 mgll. We decided to abandon
making a limits decision based on effluent data. You discussed going back to a decision
based on pretreatment data. Here are my thoughts about that:
I strongly recommend that since we have no valid effluent data and all we have is
pretreatment data, that you address cyanide as an LTMP requirement only, as you would do
if you were to do this WLA today based on the new policy.
However, if you do not like this, I would next be in favor on NPDES monitoring only, say
monthly or quarterly (in addition to the LTMP requirement).
If you still want to consider pretreatment data, consider the following: I went back to look at
the pretreatment data to address BDL data (not done before because we were going to just use
the effluent data). The domestic/uncontrollable data is all BDL, so please use 0 instead of
0.01 lbs/day. The permitted industrial of 0.7570 lbs/day is correct. I computed a new actual
industrial of 0.0972 lbs/day. Please note the actual indusrial in an order of magnitude less
than the permitted. This is because the POTW has assigned categorical limits (very high)
when they didn't need to. If you do decide to make a decision from the pretreatment data, I
strongly, strongly, strongly recommend you only consider actual industrial and not permitted
industrial.
Thanks for the opportunity to get my two cents in (or is this more than two?)!

Page 1
• Note for Farrell Keough
From: Dana Folley
Date: Apr 5, 1994 10:46 AM
Subject: Kinston-Northside Cyanide
To: Farrell Keough
Kristin Jarman with Kinston called about the cyanide. She pointed out that the influent
samples were all BDL, so she was first postulating that the influent and effluent samples
were switched. I need to look at the rest of the data to see if this is true (please call me when
you get back). She also asked that we consider APAM data which was BDL. However, she
just recently found out (during EPA PAI) that her lab was not using ascorbic acid on
chlorinated cyanide samples (i.e. effluent), so this is the more likely explanation of the
"influent BDL and effluent 60 ug/l." Let's discuss what to do. I'm still in favor of just
putting it in the LTMP, or monthly or quarterly NPDES monitoring rather than a limit, but
would not oppose a limit. I told her the worst case would be they get a limit, monitor for the
first year (or less), get all BDLs and apply for a modification to delete the limit.
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Page 1
From:
Date:
Subject:
To:
Note for Farrell Keough
Dana Folley
Mar 22, 1994 11:28 AM
RE: Kinston - Northside
Farrell Keough
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s
Northside does not have an LTMP yet... their NPDES permit renewal will require one.
They do not land apply sludge. I think what little they generate at the Northside WWTP is
put into a lagoon and I heard from the POTW pretreatment person a few weeks ago when she
was here doing the Peachtree HWA that they may go to marketing and distribution for both
WWTPs, but please check with the WARO (Barry Adams) about this. If they do M&D or
land apply, they will have an LIMP for the metals you listed. If they continue with the
lagoon, they will have all the metals you listed except As.
As far as the limits, I say - do whatever the application of the NEW policy says. I generally
have no problem with daily/weekly limits combinations, especially if they help a POTW be
able to comply with a limit that they must have. If we can take the limit out altogether (under
the new policy) and either have just NPDES monitoring or LTMP monitoring, I prefer that.
From: Farrell Keough on Wed, Mar 16, 1994 12:36 PM
Subject: Kinston - Northside
To: Dana Folley
NC0024236
Do they have a LTMP with sludge disposal and are monitoring; Cr, Cu, Ni, Pb, Zn, Ag, and
As?
Also, what is your recommendation on them have limits of:
Cadmium: 34.5µg/1 [wkly ave] and 138µg/1 [dly max]
343-Z
Cyanide: 85.8µg/1 [wkly ave] and9g/1 [dly max]
Mercury: 0.211g/1 [wkly ave] and 0.8µg/1 [dly max]
the daily maximum limit is up for discussion as to whether the standard we used is
applicable.
Please respond to this by mail as I need some type of decision making tracking device in the
file.

Facility Name a
NPDES 0 a
OW (MOD) a
701or(ah)a
IYYC (%) a
Kinston - Northslde WWTP
NC0024236
4.5
283.1
2A0
Arsenic
Max. Pred Cw
Allowable Cw
Cadmium
Max. Pred Cw
Allowable Cw
Chromium
Max. Pred Cw
Allowable Cw
Copper [AO
Max. Pred Cw
Allowable Cw
Cyanide
Max. Pred Cw
Allowable Cw
Lead
Max. Pred Cw
Allowable Cw
Mercury
Max. Pred Cw
Allowable Cw
Nickel
Max. Pred Cw
Allowable Cw
Sliver [AL]
Max. Pred Cw
Allowable Cw
Zinc [AL]
Max. Pred Cw
Allowable Cw
FINAL RESULTS
3.3
2079.4
3.3
83.2
6.5
2079.4
72.0
291.1
128.0
207.9
3.3
1039.7
0.13
0.50
26.4
3659.7
325
2.50
35.1
2079.4
Parameter- Arsenic
Standard. 50 µgfl
n BDL=1/2DL 'if 1/2 DL RESULTS
1 2.5 Std Dev. 0.00
2 2.5 • Mean 2.50
3 2.5 C.V. 0.00
4 2.5
5 2.5
8 2.5 ' Muit Factor. 1.3
7 2.5 • Max. Value 2.5 µgA
8 Max. Prod Cv 3.25 mil
9 Allowable Oh 2079.4 PO
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
28
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
Parameter• Cadmium
Standard• 2
n BDL=1/2DL 'If 1/2 DL RESULTS
1 2.5 • Std Dev. 0
2 2.5 • Mean 2.5
3 2.5 C.V. 0.00
4 2.5
5 2.5
6 2.5 • Mult Factor = 1.3
7 2.5 • Max. Value 2.5 µgrl
8 Max. Pred Cv 3.25 µgo
9 Allowable C% 83.2 nil
10
11
12
13
14
15
18
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
PAGE 1

Parameter. Chromium
Standard • 50 Aga
n BDL=1/2DL if 1/2 DL RESULTS
1 5 • Std Dev. 0.00
2 5 • Mean 5.00
3 5 • C.V. 0.00
4 5
5 5
6 5 • Mutt Factor. 1.3
7 5 * Max. Value 5 ma
8 Max. Pred Cv 6.5 pen
9 Allowable Cw 2079.4 pgA
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
Parameter. Copper [All
Standard . 7
ma
n BDL=1/2DL if 1/2 DL RESULTS
1 21 Std Dev. 8.62
2 20 Mean 22.57
3 26 C.V. 0.38
4 30
5 5
6 27 Mutt Factor • 2.4
7 29 Max. Value 30 µgA
8 Max. Pred Cv 72 pgA
9 Allowable Cw 291.1 µglI
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
Parameter• Cyanide
Standard• 5
PO
n BDL=1/2DL 'if 1/2 DL RESULTS
1 69 Std Dev. 11.14
2 67 Mean 65.14
3 70 C.V. 0.17
4 70
5 80
6 50 Mutt Factor. 1.6
7 50 Max. Value 80 NA
8 Max. Prod Ca 128 NA
9 Allowable Cw 207.9 NA
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
28
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
PAGE

Parameter. Lead
Standard. 25 µfill
n BDL=1/2DL *if 1/2 DL RESULTS
1 2.5 • Std Dev. 0.00
2 2.5 • Mean 2.50
3 2.5 C.V. 0.00
4 2.5
5 2.5
6 2.5 • Mutt Factor = 1.3
7 Max. Value 2.5 µgil
8 Max. Pred Cv 3.25 pall
9 Allowable Cvr 1039.7 Nil
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
Parameter. Mercury
Standard. 0.012 µ01
n BDL=1/2DL "If 1/2 DL RESULTS
1 0.1 • Std Dev. 0.00
2 0.1 • Mean 0.10
3 0.1 ▪ C.V. 0.00
4 0.1 •
5 0.1 •
6 0.1 • Mutt Factor = 1.3
7 0.1 • Max. Value 0.1 pen
8 Max. Pred Cv 0.13 NO
9 Allowable Cv. 0.5 µfill
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
Parameter. Nickell •
Standard. 88 µgA
n BDLs1/2DL •if 1/2 D L RESULTS
1 5 Std Dev. 2.70
2 11 Mean 6.57
3 10 C.V. 0.41
4 5 •
5 5
6 5 • Mutt Factor = 2.4
7 5 • Max. Value 11 NA
8 Max. Pred Cv 26.4 µel!
9 Allowable Cw 3659.7 NA
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
PAGE

Parameter. Silver [AL]
Standard . 0.06 µgo
n BDL=1/2DL if 1/2 DL RESULTS
1 2.5 Std Dev. 0.00
2 2.5 • Mean 2.50
3 2.5 C.V. 0.00
4 2.5 '
5 2.5
e 2.5 • MultFactor = 1.3
7 2.5 • Max. Value 2.5 µg+l
8 Max. Pred Cv 3.25 go
9 Allowable Cvr 2.5 Ag+i
10
11
12
13
14
15
16
17
18
19
20
21
22
23
.24
25
26
27
28
29
30
31
32
33
34
35
38
37
38
39
40
41
42
43
44
Parameter. Zinc [AL]
Standard. 50
Ma
n BDL=1/2DL if 1/2 DL RESULTS
1 24 Std Dev. 3.15
2 26 Mean 22.71
3 22 C.V. 0.14
4 27
5 22
6 19 Mull Factor+ 1.3
7 19 Max. Value 27 NA
8 Max. Pred Cv 35.1 µgd1
9 Allowable Cv► 2079.4 KO
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
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PAGE L

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality
Permits and Engineering Unit '` 3\��
March 7, 1994
To: Farrell Keough, Mad Modeler 40`)-°
c
From: Charles Alvarez, Environmental Engineer, NPDES Permits, WQ
Subject: Kinston Northside WWTP, NC0024236, Lenoir County
Attached please find a copy of a comment letter sent to us by
the City of Kinston. Please comment on the questions raised by the
facility.
If you need any more information please call me at 733-5083
ext 553.
S t, p arxct Vail. 51Uc!,1c WAnhorm.N0bToin},
. 'ts�^1 A ha Lti ill tic. "^p %e d 1/44,A c,
(�°trc_ kl/wtv,J-PT-Act tRE.c4 ""coo
)

t..ttv of 7IcEimtrat
p epartmext# of public tilitits
Post Office Box 339
2517 Richlands Road
Kinston, North Carolina 28502
Administration Operations
[phone] [phone]
Fax: [phone]
February 10, 1994
Mr. Dave Goodrich
NPDES Permits Group
N. C. Division of Environmental Management
P. 0. Box 29535
Raleigh, North Carolina 27626-0535
Re: NPDES Permit NC 0024236
Kinston, North Carolina
Dear Mr. Goodrich:
P. r ulatioz"cli
JIi3
0act
RONALD D. WICKER
Director
MITCHELL KEEL
Assistant Director,
Electric System
HAROLD HERRING
Assistant Director,
Water Resources
Li/ 16010 14r.
c.
The City of Kinston has reviewed the draft permit referenced
above and asks that several changes be made. Requested changes
deal with the frequency of sampling and testing for certain
pollutant parameters, and the use of daily maximum limits for
others. Specifically requested changes are:
1. Oil and Grease. The draft permit calls for daily
monitoring of oil and grease, (O&G). O&G testing takes
up a large amount of laboratory bench space, and is
expensive to do either in-house or by contract. Our
final clarifiers are equipped with skimmers, and oil and
grease levels should be low. We asked that oil and
grease testing be reduced to monthly or quarterly. If
t z. dat4
h Ape.1, f94't
CPe, n,r3 pNt.hq� 6fc;ry5f
r5
ls5tx- pia* Ql-tc. , the State has some particular need for oil and grease
Iwo o to c effluent data, we ask that we be contacted, as it should
NECE.5310XTi moo be possible to provide this data in a much more cost
effective manner than daily monitoring. Daily oil and
grease testing is expected to add $14,000 to $18,000 per
year to the City's costs.
50./'3 w(-rAcL-..
6C
(dc bc�e2w
,:,nc.i., r u53) four
KW ON
5o
'r l ory
Chromium, copper, nickel, lead, zinc, silver, and arsenic
are now to be tested twice per month. Chromium, lead,
silver, and arsenic were not detected in the Northside
effluent during our last priority pollutant scan, even at
detection limits of 5 ug/L. The twice per month
monitoring is expected to add at least $4,000 annually to
P.7 2s the City's costs. The City asks that sampling for these
'2Gircto� dam-' pollutants be changed
1.,*(O" _ Ads
dA t`od N5,
I dVSt04l �E i3
_
P(n,-_._ Fg"c
to quarterly.
ELECTRIC, WATER, AND WASTEWATER SERVICES FOR THE
BENEFIT AND PROSPERITY OF OUR COMMUNITY
r.',

Mr. Dave Goodrich
Page 2
February 10, 1994
3.
0
,4
Weekly monitoring and daily maximum limits are proposed
for cadmium, cyanide and mercury. Weekly monitoring for
these pollutants is expected to cost $4,600 per year.
The City requests that the minimum monitoring frequency
be changed for these pollutants to monthly, and that the
limits listed as daily maximum be changed to monthly
average. This latter change is particularly requested
with regards to mercury. The mercury limit set is the
detection limit. With the limit set as a daily maximum,
any detection_ of mercury would be a violation of the
NPDES permit. The City does not anticipate any mercury
being detected in its effluent, and wishes to avoid
limits that could result in a single laboratory error
causing the City to be in violation of its permit.
The City does not object to the level of treatment required in
the permit, nor does it dispute the State's need for gathering
laboratory data on its effluent. However, it does wish the State
to be aware that the increased monitoring called for in the draft
permit would increase the City's costs by $22,000 to $26,000 per
year. The less frequent monitoring suggested by the City should
provide ample data for the State's purposes, particularly, since,
based on past results, it is expected that much of testing will
only confirm that the pollutants of concern if present are present
at less than detectable limits. This information does not seem
worth the cost involved.
Sincere
2t
Ronald D. Wicker
Director of Public Utilities
RDW:dt