NC0005126_Staff Comments_19970617

NPDES DOCIMENT SCANNING) COVER SHEET
NPDES Permit:
NC0005126
Harmony Rendering Plant
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
k..,........14#1 (04olfel?
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
June 17, 1997
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Date sent: Tue, 17 Jun 1997 10:24:27 -0600
To: [e-mail]
From: [e-mail] (Kevin Bowden)
Subject: Tyson Foods NC0005126
Per your request to Matt Matthews, please find below information on Tyson
Foods.
HOLLY FARMS POULTRY aka Tyson Foods (NC0005126)MRO, permit chronic limit:
7% Q P/F 9/1/89
4/17/97-Call from Darlene Koucken concerning Tyson's compliance record.
Discussed most recent tox testing data and the information we had rec'd
from the facility relating to the facility's TRE.
1/28/97-Ltr from MRO (Rex) to fac. (Mark Johnson) transmitting our review
comments for report #3. The comments are paraphrased from our 1/21/97
memo.
1/21/97-Memo from ASTU (KB) to MRO (Rex) concerning TRE report #2 for WTC.
Comments are as follows:
This office has completed a review of Tyson Food's third "Toxicity
Evaluation" report submitted by the facility's contractor, Water Technology
and Controls (WTC). This report was received by ESB on December 18, 1996.
Report No. 3 summarizes the facility's investigation to determine if
ammonia is a toxicant and presents additional results of monitoring -
activities conducted on Tyson's effluent.
The 1.7 MGD treatment system components consist of an aerated
lagoon with mechanical aerators, effluent disinfection, chemical pH
adjustment and flow measurement. The NPDES permit which reissued July 24,
1994, specifies quarterly (January, April, July, and October) P/F toxicity
tests be conducted at an effluent concentration of 7.0%.
Several recommendations were offered by the facility in its WOMA
previous progress report to reduce effluent toxicity and included: Pm' +/ monitoring of WWTP influent, minimizing salt and ammonia/nitrite
concentrations entering the WWTP, increasing system biomass by adding
municipal activated sludge or by returning the lagoon to a facultative
state, and minimizing the recycling of residuals from the chlorine contact
chamber to the lagoon. The facility's contractor evaluated detention time
in the lagoon and determined that twenty days was sufficient for
nitrification and denitrification. Aerators were also added to the system
to "increase activity of the nitrifying bacteria to oxidize the ammonia and
nitrites present."
Ammonia concentrations analyzed for two composite samples taken on
July 29 and August 1 measured 42.1 mg/1 and 48.6 mg/1, respectively. These
two samples were used for the facility's NPDES toxicity compliance testing
for July 1996. Nitrite concentrations in these samples measured 10.3 mg/1
and 11.0 mg/1, respectively. Results of a graduated pH acute test
conducted on the effluent at a 28% test concentration yielded the following
results; no mortality at pH concentrations of 6.5 or 7.5 and complete
mortality at pH 8.5 suggesting ammonia to be a potential toxicant. A
second graduated pH test (5 replicate chronic test conducted at a 7%
effluent concentration) produced similar results. Average reproduction
numbers for the control and the 7.5 pH concentration measured 29.2 and
26.3, respectively, while an average reproduction of 13.5 neonates was
recorded at a pH of 8.5. The facility mentions that chronic test results
support the assumption that ammonia contributes to toxicity when the pH is
greater than 8.0.
The facility mentions that it has been conducting monthly pass/fail

chronic tests since July. Table 3 of the report presents the results of
ammonia and nitrite concentrations from August through October. For
August and September grab samples were pulled. Composite samples were
pulled for the October test. Overall, a trend of increasing ammonia
concentrations was observed in the samples from August through October
while the October 31 composite sample exhibited a significant decrease in
nitrite concentrations. The August test result was "Pass" while ammonia and
nitrite concentrations measured 34.1 mg/1 and 20.4 mg/1, respectively.
September's toxicity test result was "Fail" with measured ammonia and
nitrite concentrations of 33.1 mg/1 and 31.4 mg/1, respectively. The
October composite test result was reported as "Pass" with an average
combined ammonia concentration of 82 mg/1 and an average combined nitrite
concentration of 14.5 mg/1. Previous progress reports (No. 1 and 2) have
implicated nitrite as a potential toxicant. The report mentions that data
obtained from these most recent tests suggest that nitrite remains a
contributor to toxicity.
On Page 4 of the report, Future Work and Consultation, the facility
states that "nitrite concentrations measured in the effluent are generated
in the lagoon." The facility will attempt to "restore" biological activity
in the lagoon by introducing municipal sludge. In the past, the facility
had been pumping chlorinated sludge and chlorinated effluent back to the
lagoon whenever the chlorine contact chamber was cleaned out. This
practice will cease. The facility also mentions that salt concentrations
will be reduced. In the previous progress report, inconclusive test
results were reported in a "companion" inhibition study conducted on
Tyson's aeration basin water and respiration inhibition testing. The
current progress report does not mention any attempt to reschedule these
tests or offer any explanation why the results were not meaningful.
In previous comments to you concerning the facility's TRE work, we
cited the facility's TRE efforts as having a narrow focus. Again, based on
the information we have received to date, we have not seen this focus
broaden. We note that the facility's specific conductivity values reported
on its 10/30/96 AT test form (1st sample - 1905 pmhos/cm, 2nd sample - 1950
pmhos/cm) represent the highest conductivity values reported on AT test
forms to this office since the facility began testing for toxicity.
A chronic value of 9.9% was obtained and recorded during July and
October 1996 for NPDES compliance purposes. Although this value represents
compliance with the permit chronic limitation of 7.0%, the facility has a
very small safety margin. We encourage toxicity source reduction
activities and suggest the facility consider a thorough engineering
evaluation of the existing treatment system.
9/16/96-Memo from ASTU (KB) to MRO (Rex) concerning TRE report # 2 by WTC.
Comments are as follows:
This office has completed a review of Tyson Food's second "Toxicity
Evaluation" report submitted by the facility's contractor, Water Technology
and Controls (WTC). This report was transmitted by cover letter dated
August 12, 1996, from the facility to Mr. John Lesley in Mooresville. In
this cover letter, the facility indicates that representatives from Water
Technology and Controls have visited the facility since completion of Phase
I activities and have prepared the subject "Phase II" TRE report. On June
10, the facility met with representatives from the Office of Waste
Reduction and is currently "following up on" suggestions made by OWR
personnel. The facility indicates that it has reduced its daily water
softener regeneration to three times per week which would reportedly reduce
salt contribution to the treatment system by an estimated 66,560 pounds of
salt per year. The company states that salt was contributing to toxicity
and has retained the services of BRI to assist with future TRE studies.

The 1.7 MGD treatment system components consist of an aerated
lagoon with mechanical aerators, effluent disinfection, chemical pH
adjustment and flow measurement. The NPDES permit which reissued July 24,
1994, specifies quarterly (January, April, July, and October) P/F toxicity
tests be conducted at an effluent concentration of 7.0%.
Since the initial progress report was submitted, WTC staff learned
about an additional wastestream entering the Harmony WWTP which is
suspected of containing high concentrations of salt and other compounds.
The report mentions that a pattern of toxicity noncompliance was observed
beginning January 1996. It is estimated that this additional wastestream
began discharging to the facility during December 1995.
A meeting was held at the facility on July 10 with WTC staff and
Tyson personnel to discuss "toxicity evaluation and treatment schemes to
reduce effluent toxicity." Discussion points included an overview of
influent wastestreams to the Harmony WWTP and actions which may be
undertaken to "revive the lagoon microbiology." A plan to assess nitrite
and ammonia concentrations was discussed. The facility does not believe
that "salt levels" are the principle toxicant but mentions that "salt
content" may adversely affect the microbiology of the treatment system.
WTC's evaluation of the treatment system concluded that twenty days of C=c'
detention time in the lagoon should be adequate to promote nitrification
and denitrification. The facility added additional aerators to the lagoon
in response to suggestions by WTC. The purpose of this action was to
"increase aeration and increase activity of the nitrifying bacteria in the
lagoon to oxidize the ammonia and nitrites present." The report notes some
improvement in effluent quality but the facility remains unable to achieve
compliance with its 7.0% chronic limitation. Two potential mechanisms to
increase biomass in the lagoon were discussed and included the addition of
municipal activated sludge to the treatment system and returning the lagoon
to a facultative state. A suggestion was made to reduce or eliminate
residuals from the chlorine contact chamber which are currently being
returned to the system. No modifications to the system were made in July
to allow the system to stabilize. The report states that outlined
suggestions will be implemented after the July 1996 toxicity test.
Effluent ammonia and nitrite concentrations continue to remain
variable. To determine potential effect(s) of aeration on nitrite
concentrations, the facility conducted an experiment in which an effluent
sample was aerated with 2.0 mg/1 Dissolved Oxygen, 6.0 mg/1 Dissolved
Oxygen, and a control (non -aerated). The report mentions that aeration did
not significantly affect nitrite concentrations indicating insufficient
microbial activity even at high dissolved oxygen concentrations. The
facility also investigated potential "inhibitory effects" of sodium nitrite
on activated sludges. The results from these tests suggested that the
ability of either municipal or industrial sludge to oxidize nitrite was not
affected by nitrite concentrations.
The report cites a "companion" inhibition study which was conducted
on Tyson's aeration basin water. Results from this study were
inconclusive.
A final set of experiments was conducted on Tyson's influent to
assess the influent's ability to inhibit respiratory activity of activated
sludges. The results from these trials were also inconclusive.
The facility tested a treatment method using hydrogen peroxide to
chemically oxidize nitrites. The report states that hydrogen peroxide
chemically oxidized the nitrites (initial nitrite concentration of 25 mg/1,
nitrite concentration following treatment was 1 mg/1) yet acute toxicity
(24-h) was evident at all test concentrations. The report notes that
toxicity tests were conducted with solutions of hydrogen peroxide which had

not undergone biological treatment and the facility proposes additional
bench -scale treatment scenarios to more accurately assess treatment
efficacy.
In the final section of the report entitled, Future Work and
Treatment Recommendations, the facility emphasizes the importance of
increasing microbial numbers/microbial activity in the lagoon. The
facility states, "Toxicity cannot be eliminated without the improvement of
the microbial health of the lagoon. The additional monitoring of salt
input and nitrite and ammonia concentrations will better characterize waste
entering the treatment plant." The report mentions that nitrite
concentrations have decreased to 20 mg/1 while ammonia concentration have
increased to > 40 mg/1. The report mentions that a pH gradient test will
be run on the July 1996 toxicity sample to determine ammonia toxicity. The
facility proposes to repeat respiration inhibition testing and to test
individual instream influent wastestreams for toxicity.
The report concludes that changes need to be made in the monitoring
of influents entering the lagoon and in minimizing salt and ammonia/nitrite
concentrations entering the system which inhibit microbial activity.
Biomass should be increased and recycling of residuals from the chlorine
contact chamber to the lagoon should be minimized.
In summary, we acknowledge positive actions on behalf of the
facility to invite representatives from OWR to visit the facility and
suggest waste minimization concepts/techniques. An estimated reduction in
salt loading to the treatment system of 66,560 lb/yr is impressive and
should benefit the company economically as well as reduce the amount of
toxicants entering the system.
In previous comments to you concerning the facility's TRE work, we
cited the facility's TRE efforts as having a narrow focus. At this time,
we see no broadening of this perspective. While previous testing suggested
a reduction in toxicity via zeolite treatment, the facility has not
implemented broad -based toxicity characterization testing. Although the
recommendation to include a graduated pH treatment has been suggested, we
feel that application of this characterization test would have been more
appropriate at the onset of the TRE. We are curious if the facility has an
explanation as to why test organism reproduction numbers for municipal
treated lagoon water (companion nitrite inhibition study) remained
identical to those for the dilution water. Even though activated sludge
respiration inhibition testing of individual wastestreams may be a logical
step and may provide useful information to Tyson, we suggest the company
consider the following activities in its future TRE work: source reduction
activities, broad -based effluent toxicity characterization testing, and
continue efforts to evaluate wastewater treatment plant performance.
As a final note, we comment on a statement appearing in the
facility's August 12 transmittal letter which reads, "Mr. Matt Matthews
instructed us on the avenues we should follow and suggested we seek the
help of Rick Diehl of Burlington Research, Inc." This statement is
incorrect. As you know, our past and continued policy does not allow us to
endorse a toxicity consultant for TRE activities. We quite often provide
some questions to be posed by a noncompliant facility searching for a
toxicity consultant. These questions are designed to assist the facility
in assessing the consultant's level of expertise and success in conducting
toxicity reduction evaluations.
8/26/96-NC NOV for 6/96
7/26/96-NC NOV for 5/96
6/25/96-NC NOV for 4/96
6/3/96-Meeting in Raleigh WQ Laboratory at 1:00 pm attended by Tyson (Mark
Johnson -Plant Manager, and Danny White -Environmental Affairs), BRI-John

Sledge, and MM, KB and SM. Meeting focused on activities completed by fac.
and proposed activities for upcoming TRE work. Fac. invited BRI for second
opinion and will meet with Sam Moore and Rick Diehl next week. May test
results have not been reported. Danny White indicated that effluent
quality has improved since January. Fac. met with MRO last week concerning
possible enforcement. Fac. asked about SOC and MM indicated that if the
May test shows improvement that they may want to reconsider entering into
SOC. Discussed Source Reduction, increase in TDS, WWTP efficiency,
thorough WWTP evaluation, etc. KB called John Lesley and informed him
about meeting contents. Meeting started and ended on a good note.
5/24/96-NC NOV for 3/96
5/16/96-Memo from ASTU (KB) to MRO (Rex) transmitting review comments of
fac 's TRE. Comments are as follows:
This office has completed a review of Tyson Food's "Toxicity
Evaluation" report submitted by the facility's contractor, Water Technology
and Controls. The report briefly describes the results of effluent
treatment manipulations conducted in an effort to characterize potential
toxicants. Potential toxicants singled out by the facility include organic
compounds, nitrogenous compounds, and metals. The report also presents
recommendations for future TRE work and provides a "preliminary treatment
suggestion."
The 1.7 MGD treatment system components consist of an aerated
lagoon with mechanical aerators, effluent disinfection, chemical pH
adjustment and flow measurement. The NPDES permit which reissued July 24,
1994, specifies quarterly (January, April, July, and October )P/F toxicity
tests be conducted at an effluent concentration of 7.0%.
In the results section, the report mentions that acute toxicity has
occurred in "the two test concentrations above the 7.0% IWC limit" but
fails to clarify whether all test results submitted for compliance purposes
have exhibited this trend. From April 1995 to date, the facility has
submitted eight multiple concentration toxicity test results for NPDES
compliance purposes and five of these test results have not met the
required 7.0% chronic limit established by the Permit.
To examine potential toxic effects from organic compounds, the
facility conducted several C-18 manipulations including C-18, zeolite/C-18,
and C-18/methanol eluate. Filtered effluent was used as a control. All
test procedures were conducted at a 10% effluent concentration. The report
mentions that the filtered effluent and the post column C-18 effluent was
toxic. The report also mentions that C-18/methanol eluate test result was
not significantly different from the control, indicating that removal of
non -polar organics alone does not reduce toxicity.
To examine potential toxic effects from nitrogenous compounds,
ammonia was removed via a zeolite column. The report indicates basically
the same test results for the zeolite treatment and zeolite followed by
C-18 treatment (ie, no reproduction). The following statement is made,
"Together the results confirm that ammonia nor organics play a significant
role in toxicity." Initially nitrite concentrations were not considered as
being problematic. First and second sample nitrite concentrations in
Tyson's effluent for February 1996 measured 36.9 mg/1 and 9.8 mg/l. The
report suggests that nitrite concentrations were non -detect and no toxicity
was observed after the zeolite/mixed bed ion -exchange treatment. The
report states, "The result indicates that nitrite levels are the primary
toxicant in Tyson effluent." We question whether toxicity would reappear
upon nitrite addition back to the zeolite/resin treatment. The facility
should carefully consider whether nitrites are the "primary toxicant" in
the effluent and consider all the advantages/disadvantages of using a mixed
bed ion -exchange resin to evaluate' potential toxicants.

To examine potential toxic effects from metals, zeolite-treated
effluent was treated with 8.0 mg/1 EDTA and tested for toxicity. Test
organism reproduction was "greatly reduced" in the EDTA treatment versus
the control suggesting no reduction in effluent toxicity.
The facility proposes to conduct additional ion -exchange resin
treatments with resins which more selectively bind the nitrites. Tyson
anticipates this testing to positively identify nitrites as the primary
toxicant. The facility proposes to conduct an "inhibition study" to
ascertain nitrification capabilities of Tyson's residuals in conjunction
with a study to evaluate the effects of increased aeration and detention
time in the WWTP. As a preliminary suggestion, the facility's contractor
has recommended increasing the treatment system aeration and detention time
to assist in toxicity reduction.
Several issues were not discussed in this submittal which should
deserve consideration in future TRE work. We note that total dissolved
solids concentrations have steadily increased at the facility over the past
two to three years. Average effluent conductivity concentrations
(pmhos/cm) have increased almost 60% since 1994, yet the report fails to
address any potential contribution to toxicity from increased TDS
concentrations. The report fails to address the potential for surfactants
or disinfectants to affect toxicity. Our experience with food processing
facilities in the past has shown that a considerable degree of washdown
activities occur due to various food handling requirements and regulations.
Washdown activities would most likely include the use of detergents which
may contain surfactants. There is no mention of housekeeping operations or
if the facility has conducted an inventory of chemical usage. The facility
should also consider evaluating the toxicity of individual sidestreams
which ultimately enter the lagoon for biological treatment and consider a
complete evaluation of organic waste loading to the treatment system.
In summary, while nitrites may represent a potential toxicant, we
point out that the TRE work to date has an extremely narrow focus. The
submittal does not discuss the facility's intent to conduct broad based,
biological effluent manipulation tests which may assist in characterizing
potential toxicants. The submittal does not provide information on current
treatment system operation, although from the suggested recommendation,
there is a concern that the system is not receiving sufficient aeration or
detention time. Treatment plant optimization is critical to producing a
quality effluent. The report fails to address toxicity persistency and
whether a thorough review of all effluent data and plant processes has been
performed. The report provides no discussion of plant process
modifications which may have occurred in the past and which may have
affected toxicity. Although the NPDES permit specifies single
concentration testing, the facility has been conducting multiple
concentration testing since the spring of 1993. This activity is
commendable and should assist in evaluating toxicity reduction efforts over
time. Although violations of the NPDES permit limitation for toxicity have
occurred and continue to occur, we acknowledge the facility's actions to
commence TRE activities. Since source reduction activities should be
considered paramount in the TRE process, we would suggest the facility
contact representatives from the Office of Waste Reduction to schedule a
no -cost, site evaluation and take advantage of waste reduction information
and measures provided by OWR.
5/3/96-NOV Notice of Recommendation for Enforcement ltr from MRO (Keith
Overcash) to fac. (Mark Johnson) for FC violation and toxicity violations.
Response due within 10 days receipt of NOV.
5/2/96-Ltr from MRO (Rex) to fac.(Mark Johnson) transmitting results of CBI
conducted on 3/5/96. Test failed at 7% effluent concentration. Facility Q

= 1.7 MGD, rec. stream flow = 38.0 cfs (Hunting Creek)
4/25/96-NC NOV for 2/96
3/22/96-NC NOV for 1/96
12/29/95-NC NOV for 10/95
6/23/95-NC NOV for 4/95
12/20/94-NC NOV for 10/94
4/1/92-NOV from region for failure to submit tox results.
1/7/91-Due to time lapse of Oct test and performance of Dec tes
is waived. New contact is Danny Wyatt.
5/4/90-SETTLEMENT, COMPROMISE AND WITHDRAWAL Agreement for the
stating facility shall monitor for tox June 1990 to March 1991.
not be an enforceable limitation.
3/22/90-DWW spoke with R. Bridgeman of MRO. He will send this
letter reminding them of their monitoring requirement. DW also spoke with
LA who said permit in adjudication.
Kevin Bowden
[e-mail]
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