Loading...
HomeMy WebLinkAboutNC0004375_More Information (Received)_19840921NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0004375 Clariant Corporation Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Additional Information Received Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: September 21, 1984 This document is printed on reuse paper - ignore any content on the reYerse side 0 SODYECO INC Post Office Box 669246 Charlotte. North Carolina 28266 704/827-9651 Telex 810-649-2224 September 21, 1984 SUBJECT: NPDES Permit #NC0004375 Sandoz Chemicals Corporation Sodyeco Division Mecklenburg County Mr. William Mills Division of Environmental Management North Carolina Department of Natural and Economic Resources Post Office Box 27687 Raleigh, North Carolina 27611 Dear Mr. Mills: PLEASE NOTE OUR NEW COMPANY NAME SANDOZ CHEMICALS CORPORATION SODYECO DIVISION P.O. BOX 669246 CHARLOTTE N.C. 28266-9246 On September 11, 1984, Mr. Thurman Horne of the Mooresville office visited our plant to inspect our recently completed staged discharge facility. During his visit he provided "Attachment to DEM Form MR-1.1, Revised 3-78" for our use and indicated that hourly discharge limits were applicable to the staged discharge operation. We do not understand the staging requirements as imposing hourly limits on our discharge. Our understanding of the staging requirements is based on the following: 1. The waste load allocation on which the discharge limits were computed was on a daily basis for various daily average flows in the river. We under- stood that the model used was a dynamic model that took into account the intermittent operation of the turbines to arrive at the waste load allocation at various daily flows between 95 cfs and 329 cfs, as listed under the staging requirements. Therefore, the flow during the first hours or any hour of the day when no turbine is operating does not determine the impact on water quality, rather it is the total daily flow in the river and the total effluent discharge during a 24-hour period. s Division of Environmental Management North Carolina Department of Natural and Economic Resources September 21, 1984 Page 2 For example, on a day when the river flow is between 175 and 250 cfs the allowable summer discharge into the river is 1,044 lbs. average and 2,088 lbs. maxi- mum per day. The BOD5/NH3 discharge into the river during the hours of 7:00 A.M. and until a - turbine starts Is not the factor that controls the assimilative capacity of the river; it is the total daily river flow. When the flow is greater than 329 cfs, the staging formulas are not applicable and the discharge limitations (I-3 of the Permit) apply. Otherwise, the wastewater being stored for recycle through the treatment plant would be diffi- cult to discharge and still comply with the staging limits. 2. Sodyeco is using the staging requirements to control the discharge based on the latest BOD5/NH3 values to comply with the 95 cfs rate from 7:00 A.M. to the time a turbine starts. This provides protection to the river should a turbine not be operated by Duke Power. Should Duke only operate a turbine for a short period and the daily river flow is below 175 cfs, the discharge would be stored for the last 12 hours of the day to protect the river. Recent river flow data (1978-1980) indicate flows below 329 cfs occur approximately 30 days per year and flows of only 95 cfs occur approximately 5 days per year. These flows occur randomly through the year. 3. Under staging requirements, the parenthetical phrase "The hourly rates will be calculated dividing daily discharge by 24" appears. This phrase was added during permit development to clarify that hourly limits per se were not intended. We understand permit compliance for daily river flows less than 329 cfs is determined by dividing daily discharge of BOD5/NH3by 24 and comparing this value to the appropriate flow bracket determined by the total daily river flow. We understood the staging requirements to do two things: (1) require the wastewater discharge flow to be released based on the latest B0D5/NH3 information until a turbine runs, and Division of Environmental Management North Carolina Department of Natural and Economic Resources September 21, 1984 Page 3 (2) to provide a daily (24-hour) discharge limit for river flows less than 329 cfs. At no time did we understand that hourly limits were applicable to the wastewater discharge. Otherwise, hourly limits could have been written without reference to staged discharge requirements. We request your consideration of the above and would appreciate the opportunity to meet with you to resolve any misunderstanding and to clarify the monitoring requirements. We will contact you to arrange a meeting next week. Thank you for your consideration of this matter. Very truly yours, gccleA- E. J. Eccles, Jr. EJE/nt cc: F. Westall W. Rankin M. T. McCall M. J. Smith R. Pease T. Horne R. Gleason NOTES OF CONFERENCE CLIENT: Martin Marietta, Sodyeco Division PROJECT: NPDES Permit Negotiations Division: 30 Job No.: 3182-13-1 Serial No.: File No.: 106 Date. Issued: July 6, 1982 Pagel. of 4 Date of Meeting: June 25, 1982 Place of Meeting: Raleigh, N. C. Subject: Proposed Limitations Notes Prepared By: M. J. Smith Present: DEM Sodyeco Ogleetree, Deakins William Mills W. Rankin & Smoak E. Eccles Lewis Smoak Action MAIN By and Date M. J. Smith At the request of Lewis Smoak, a meeting was held to review the proposed permit, Section A, that will be the basis for the resolution of Martin Marietta's adjudication. Bill Mills provided an effluent limitation and monitoring requirement sheet with a description of the procedure for operating the staged discharge (copy attached). The following items were discussed. 1. BOD5 and ammonia willbe utilized to controlthe oxygen consuming substance discharge in lieu of ultimate BOD. Summer and winter limits were provided. Hourly guidelines (pph) are based on four equations, two for summer and two for winter, one at 329 cfs and one at 95 cfs. There was some discussion regarding whether the pph numbers repre- sented a permit limitation. It was understood that the hourly numbers did not constitute a limitation, but rather were to provide the basis for controlling the staged dis- charge. If these numbers are intended to be a limit, then a peaking factor is necessary. 2. A peaking factor of 2 is in the proposed permit. We requested that a higher number be provided that would allow the discharge of stored wastewater. A peaking factor of 3 was requested. Bill Mills indicated that DEM would eval- uate the need for a higher peaking factor. Martin Marietta Sodyeco Division June 25, 1982 Action By and Date 3. The proposed TSS limitation is from the old permit. This is lower than the October 16, 1980, limitations provided by DEM, which had indicated a limitation based on 30 mg/1 or 975.8 lbs/day for both the 95 cfs and 329 cfs conditions. The 30 mg/1 level is representative of best practicable treatment in a biological system. Mr. Mills indicated that he would review that previous allocation and make appropriate adjustments. 4. Phenols are limited based on the 95 cfs. Mr. Mills re- called that the Commission order was only for oxygen con- suming substances. Wilton Rankin requested a copy of the hearing transcript and Mr. Mills indicated this would be provided as soon as possible. M. Smith asked if the staff would support a request to the Commission to use 329 cfs for Phenol. This was based on the fact that the current levels which approximate the levels allowable using 329 cfs would be permissible. Mr. Mills indicated he would discuss this with the staff to determine their position. Deletion of the mg/1 limits was also requested. 5. Fecal coliform will be tested on a monthly basis. Also, residual chlorine will be deleted from the requirements. 6. The staged discharge procedure, as presently defined, does not allow for discharges between the 329 cfs level and the 95 cfs level. A request was made to allow the discharge to be made in stepped increments at the 96-175, 176-250, and 251-329 cfs daily average increments. This would allow better control of the system and reduce the storage/dis- charge of wastewater to better match the capability of the river to assimilate the additional BOD. Also, the use of the 9:00 PM day may need revision. Duke Power has indi- cated that the turbines are normally run between 1:00 AM and 1:00 PM in winter and 1:00 PM to 7:00 PM in the summer. Mr. Milts requested that Sodyeco review the draft procedure for operating the staged discharge and offer comments relative to functionality and monitoring protocol. These comments are to be ready for the July 21, 1982, meeting. Page 2 of 4 Martin Marietta Sodyeco Division June 25, 1982 Action B and Date 7. Analytical testing for phenols was also discussed. Ed Eccles indicated that the total phenol test picks up parameters that are not phenol based on gas chromatograph analyses. Martin Marietta requested that a GC analysis for phenol and chlorophenols be used in lieu of the total phenol analysis. Bill Mills indicated that this may be possible. 8. Sampling locations and frequencies were changed as follows: a. BOD5 + NH3 (winter) will be sampled daily instead of weekly and the upstream and downstream sampling will be for BOD5 only in both summer and winter. b. Phenols will be sampled by grab type samples in lieu of composite and upstream and downstream monitoring will be dele c. Coliform testing will be monthly in lieu of weekly and only the effluent will be sampled. d. COD testing will be on the effluent only. The upstream and downstream requirements were deleted. e. Residual chlorine testing was deleted. Bill Mills requested that a meeting be held on July 21st to discuss the technical details of the staged discharge and the development of the final numbers for the permit. A second meeting was held with the Division of Health Services Water Supply Section, Mr. Charles Rungren, W. Rankin, Ed Eccles, and M. J. Smith. Wilton Rankin reviewed with Mr. Rungren his memorandum of a meeting held in October 1981. Mr. Rungren had a copy of a Sept. 16, 1981, letter from a previous meeting, but was not sure of the current status of the sampling effort and any problems with chlorine uptake at the Belmont water supply. Mr. Rungren will discuss the chlorine uptake problem with Mr. Darrell Herndon. Mr.. Rankin stated that Mead Compuchem had developed procedures for testing the 13 organics listed in the NPDES permit. Mr. Rungren will advise Mr. Herndon to meet with Ed Eccles to take samples of Belmont's finished drinking water to be analyzed for the 13 chlorinated organics. Page 3 of 4 Martin Marietta Sodyeco Division June 25, 1982 Sodyeco has spent a lot ,of time and money working with Mead Compuchem to develop the procedures for analysis of these materials. Action By and Date Mr. Rungren was not able to.make a definitive statement about the need for the special conditions in the permit if the analysis results show the organics are below detectable limits. Mr. Rungren mentioned that additional sampling on a quarterly or semi-annual basis may be necessary. It was suggested if the first analyses do not show the organics, that the additional testing be handled by mutual agreement in lieu of a permit condition. No decision was reached on proceeding in the matter at this time, but would be deferred until the results are available. MJS/nt cc: W. Rankin 1.-1% Eccles B. Drum R. Turschmid Page 4 of 4 A. ( ). EFFI.IIENT LIMITATIONS AND MONITORING REQUIREMENTS -Final (1) Summer: (2) Winter: April 1-October 31 November 1-March 31 During the period beginnih g on effective date of the Permit and lasting Until expiration, permittee is authorized to discharge from outfall(s) serial number(s). ool. Such discharges shall be limited and monitored by the permittee as specified below: T f l;:ert Characteristics Kg/day ( l bs/day ) Daily Avg. Daily Max. Flow BOD5 + .45(NH3-N) {1} (2667) I30D5 + 0.5 (NH3-N (2 ) (4749) TSS 272(600' ��Phenols 0.25(0.55 ) Fecal Coliform Temperature Dissovled Oxygen (Minimum) COD Total Residue Settleable Matter (5334) (9498) 529.(116707 0.50(1.10) , Discharge Limitations Other Units (Specify) Daily Avg. Daily Max. 3.9 MGD 0017 mg/1 i ' 034 mg 1000/100m1 20p0/100m1 **** 5 mg/1 Monitoring Requirements ***Measurement Frequency Daily oleo, Daily Daily Weekly Week-lity0.4N Daily Daily Weekly weekly Daily -Da-i 3hr-_ ** Sample Type Continuous Composite Composite Composite composite r(4 Grab Grab Grab Composite Composite Grab Grab * Sample Location I or I,E ,D I•, E+ I,E E,$ E,U,D E,U,D E,U, D E, I,E E --1r— *Sample Locations: I -Influent, E-Effluent, U-Upstream, D-Downstream **A11 stream samples shall be grab. ***Daily means every day on which a discharge occurs except Saturday, Sunday, and legal holidays. Daily stream sampling may be reduced at each sampling station to one (1) time per week except during the months of June, July, August, and September when the frequency must be no less than three (3) times per week at each sampling station. ****The temperature of the effluent shall be such taht it will not cause a temperature in the receiving stream of more than 5oF above -ambient stream water temperature. fD o•1 g.�. Wz ve the pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample at I, E, U, and D. CV rt Discharges are to be released in accordance with the following: Staging Requirements If at least one turbine at Mt. Island Dam is operating at the beginning of each discharge day. BOD and NH33-N can be released in accordance with Equation No. 1 until 9:00 P.M. If no turbines are in operations at 9:00 A.M., BOD5 and N11,2can be released in accordance with Equation No.. 2 until turbine operation begins. When at least one turbine atMt. Island Dam begins operating, BODS and NH3 can be released in accordance with Equation No. 1 until 9:00 P.M. At 9:00 P.M. the total quantity of flow released from Mt. Island Dam during the 9:00 P.M. period will be determined. A 24-hour averagg discharge rate will be calculated which will include the minimum instantaneous flog quantity (i.e. if 30 x 10 ft was relsased from 9:00 A.M. to 9:00 P.M., the 24-hour average would be (30 x 10 + 80 x 3600 x 12); 24 =:3600 or 387 ft / sec). If the 24-hour average flow rate is greater than or equal to 314 cfs, BOD5 and NH3-N can be discharged from 9:00 P.M. to 9:00 A.M. in accordance with Equation No. 1. If the 24-hour average flow rate is less than 314 cfs, BODS and NH3-N can be discharged from 9:00 P.M. to 9:00 A.M. in accordance with Equation No. 2. EQUATION NO. 1 EQUATION NO. 2 Summer {1) BOD5 0. 45(NH3N)< 111.1 lbs/hr. BOD5 + 0.54(NH3 N)< 23.6 lbs/hr. BOD5 = BOD5 discharge rate, lbs/hr. NH3 N = NH3-N discharge rate, lbs/hr. Discharge Day begins at 9:00 A.M. Winter {21 BOI)5 + 0.5(NH3-N)< 197.9 lbs/hr. BOD5 + 0.31(NH 3 N)< 54.2 lbs/hr. PART I Permit No. NC Act used herein means the Federal Water Pollution Control Act, As amended. DEM used herein means the Division of Environmental Management of the Department of Natural Resources and Community Development "EMC" used herein means the North Carolina Environmental Management Commission. C. MONITORING AND REPORTING 1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge. 2. Reporting Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a Monthly Monitoring Report Form (DEM No. MR 1.0, 1.1, and 1.4) postmarked no.later than the 45th day following the completed reporting period. The first report is due on . The DEM may require reporting of additional monitoring results by written notification. Signed copies of these, and all other reports required herein, shall be submitted to the following address: Division of Environmental Water Quality Section Post Office Box 27687 Raleigh, North Carolina 3. Definitions Management 27611 a. The "daily average" discharge means the total discharge by weight during a calendar nont :.divide the number of days in the month that the production c ercial acility was operating. Where less than daily sampling is y this permit, the daily average discharge shall be determined by the summation of all the measured daily discharges by weight divided by the number of days sampled during the calendar month when the measurements were made. b. The "daily maximum" discharge means the total discharge by weight during any calendar day. 4. Test Procedures Test procedures for the analysis of pollutants shall conform to The EMC regulations published pursuant to N. C. G. S. 143-215.63 et seq.. The Water and Air Quality Reporting Act, Section 304(g), 13 USC 1314, of the Federal Water Pollution Control Act, As Amended, and Regulation 40 CFR 136. 5. Recording Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: Division of Environmental Management February 6, 1982 Mr. Mike Smith Charles T. Main, Inc. P. 0. Box 240 236 Two Fairview Plaza Charlotte, NC 28224 Dear Mike: Attached are the allocation graphs for Sodyeco we discussed. Please contact Mr. Randy Williams at 919/733-2930 if you have any questions. I am hopeful we can finalize the Sodyeco discharge conditions soon. Sincerely, Original Signed By FORREST R. WESTALL Forrest Westall, Head Monitoring & Technical Services Branch Attachment cc: Randy Williams FRW:an B 0 p 116 5 I N L B S P E R 114 - 112 - 110 108 106 104 0 U R 102 100 98 96 - SODYECO-SUMMER DAM FLOW-314 CFS 102.- 100 94 1 1 $ 1 0 5 10 15 20 25 30 NH3-N IN LEIS PER HOUR Minn 6 0 D 198 5 Z 196 N L 6 t94 S P E 192 R H 0 190 U R 188 186 SODYECO-WINTER DAM FLOW=314 CFS 184 1 t 1 1 t t 0 5 10 15 20 25 30 NH3-N IN OS PER HOUR 8 0 D 24 5 I N 22 L 28 S S P E R H 0 U R 18 18 14 12 10 8 1 SODYECO -SUMMER DAM FLOWm88 CFS 1 0 5 10 15 20 25 38 NH3-N IN LBS PER HOUR 6 0 p 56 5 = 54 L B S 52 P E R 50 H 0 U R 48 46 44 SODYECO-WINTER DAM FLOW=80 CFS 1 0 5 10 15 20 25 30 NH3-N IN LBS PER HOUR North Carolina Department of Natural Resources &Community Development James B. Hunt, Jr., Governor Joseph W. Grimsley, Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT January 20, 1982 Mr. Mike Smith Chas. T. Main and Associates P. 0. Box 240236 Charlotte, North Carolina 28224 R C 0 t= I,' Subject: Proposed Discharge Requirements Martin Marietta-Sodyeco Mecklenburg County Dear Mr. Smith: Please find attached a copy of our latest thinking on the proposed discharge requirements for Sodyeco. These requirements are not finalized, but we hope to finalize our requirements by the first of next week. Once finalized they will be submitted to our Office of Legal Affairs who will offer a proposed settlement to Sodyeco for their consideration to satisfy the adjudication. This copy is not official and is not sent to you for comment but only for information since you have requested it in order to assist in your planning for treatment improvements. When the Legal Affairs Office submits the proposed discharge requirements which have been finalized to Sodyeco for their consider- ation, comments could be submitted at that time. Attachment cc: Forrest Westall Dick Peace Sincerely, William C. Mills Environmental Engineer Permits and Engineering Branch wic-L tPl1/4' P. 0. Box 27687 Raleigh, N. C. 27611-7687 An Equal Opportunity Affirmative Action Employer BOD5 & NH3-N Limitations and Staging Requirments for Sodyeco BDD5 and NH3-N discharges must be made in accordance with the following: Daily Average Daily Maximum _ April 1 - October 31 BOD5 + 0.45 (NH3-N) 2667 lbs/day BOD+ 0.45 (NH3-N) <5334 11 s/day fo7z' November 1 - March 31 BOD5 + 0.5 (NH3-N) 4.4749 lbs/day BOD5 + 0.5 (NH3-N)4.9498 lbs/day 6•11, iv — rro6-61 Where: BOD5 = Daily BOD5 discharge rate, lbs/day NH3-N = NH3-N discharge rate, lbs/day These discharges are to be released in accordance with the following: Summer Period (April 1-October 31) - If at least one turbine at Mt. Island Dam is operating at the beginning of each discharge day (the "discharge day" begins at 9:00 AM), BOD5 and NH3-N can be released in accordance with the following equation until 9:00 PM: Equation 1: BOD5 + 0.45 (NH3-N) . 111.1 lbs/hr BOD5 = BOD5 discharge rate, lbs/hr NH3-N = NH3-N discharge rate, lbs/hr If no turbines are in operation at 9:00 AM (beginning of discharge day), BOD5 and NH3-N can be released in accordance with the following equation until turbine operation begins: Equation 2: BOD5 + 0.54 (NH3-N) < 23.6 lbs/hr BOD5 = BOD5 discharge rate, lbs/hr NH3-N = NH3-N discharge rate, lbs/hr When at least one turbine at Mt. Island Dam begins operating, GODS and NH3-N can be released in accordance with Equation 1, until .9:00 PM. At 9:00 PM, the total quantity of flow released from Mt. Island Dam during the period 9:00 AM to 9:00 PM will be determined. A 24-hour average discharge rate will be calculated (i.e. if 30 x 106 ft3aas released from 9:00AM to9:00 -2- . PM, the 24-hour average would be 30 x 106 : 24 : 3600 or 347 ft3/sec). If the 24-hoir average flow rate is greater than or equal to 314 cfs, GODS and NH3-N can be discharged from 9:00 PM to 9:00 AM (the beginning of the next discharge day) in accordance with Equation 1. If the 24-hr average flow rate is less than 3.14 cfs, BOD5 and NH3-N can be discharged from 9:00 PM to 9:00 AM in accordance with Equation 2. Winter Period (November 1-March 31) -.If at least one turbine at Mt. Island Dam is operating at the beginning of each discharge day (9:00 AM), BOD5 and NH3-N can be released in accordance with the following Equation until 9:00 PM: Equation 3: BODS + 0.5 (NH3-N). 197.9 lbs/hr. BOD5 = BOD5 discharge rate, lbs/hr. NH3-N = NH3-N discharge rate, lbs/hr. If no turbines are in operation at 9:00 AM, GODS and NH3-N can be released in accordance with the following Equation until turbine operatin beg ns: Equation 4: BODS + 0.31 (NH3-N) < 54.2 lbs/hr. BODS = BODS discharge rate, lbs/hr. NH3-N = NH3-N discharge rate, lbs/hr. When at least one turbine at Mt. Island Dam begins operating, BOD5 and NH3-N can be released in accordance with Equation 3, until 9:00 PM. At 9:00 PM, the total quantity of flow released from Mt. Island Dam during that discharge day will be determined. A 24-hour average discharge rate will be calculated. If the 24-hr average flow rate is greater than or equal to 314 cfs, BOD5 and NH3-N can be discharged from 9:;00 PM to 9:00 AM (the beginning of the next discharge day) in accordance with Equation 1. If the 24-hour average flow rate is less than 314 cfs, GODS and NH3-N can be discharged from 9:00 PM to 9:00 AM in accordance with Equation 4. -3- In additicn to monitoring for compliance with the daily average and daily maximum discharge limitations, adequate monitoring and. reporting will be maintained to insure compliance with the release requirements. Based on the most current effluent BOD5 and NH3-N data available, the company will c ntrol the average hourly discharge rates for 13D5 and NH3-N as specified by the appropriate equation. The average hourly dischargerate will be ca].culated based on the total discharge -of -HODS or NH3-N for a discharge period divided by the.hours in that period. The company will report their discharge control operating information as part of their compliance data a Division of Environmental Management January 18, 1982 MEMORANDUM TO: Lee Fleming FROM: Forrest Westall SUBJECT: Effluent Limitations, Martin Marietta Corp. Sodyeco Division Discharge to Catawba Effluent limitations for Sodyeco have been developed for several discharge situations. Based on EMC action, minimum daily average discharge from Mt. Island Dam (upstream of Sodyeco) rather than the minimum instantaneous discharge can be used for allocation purposes. The applicable limitations have been established through an April 14, 1981 memo and a May 7, 1981 letter (see attached). However, because special discharge requirements are proposed for this facility, I am requesting by copy of this memo that the Mooresville Regional Office review these requirements. The general aspects of the requirements have been discussed, but these specifics have not been reviewed by Regional Office staff. Comments from Mooresville should be directed to me by telephone no later than January 22nd. I will inform the Permits Branch of any necessary modifications. I have attached the recommended requirements for release of BOD5 and NH3-N from Sodyeco's wastewater treatment facility. In addition I have also attached copies of the allocation graphs for the four discharge situations. Combinations of BOD5 and NH3-N below (to the left) of the allocation line will result, under the listed stream flow conditions, in projected minimum dissolved oxygen levels >5.0 mg/1 (daily average in stream). The control equations in the attached requirements are based on these graphs. The discharge control operating information referenced in the requirements should consist at a minimum of discharge logs for the wastewater facility and Mt. Island Dam, BOD5 and NH3-N data used for determining average hourly release rates and daily 24-hour average discharge rates for Mt. Island Dam based on 9:00 am to 9:00 pm release volumes. Reporting frequency should be monthly. Other monitoring requirements should be consistent with existing regulations. Limitations on water quality limited parameters other than BOD5 and NH3-N are listed below: D.O. = 5 mg/1 (minimum) pH = 6-9 S.U. Total Phenols* = 0.544 lbs/day *phenols based on the minimum instantaneous release of 80 cfs from Mt. Island dam and 15 cfs 7/10 flow from Dutchman's Creek. If you have any questions concerning this information, please let me know. cc: Dick Peace L. P. Benton, Jr. Randy Williams MEETING OF THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Raleigh, North Carolina June 11,1981 MINUTES TABLE OF CONTENTS Agenda Item AUG 17 1957 PERMfTS & ENGINEERING No. Agenda Item and Action Taken Page No. Call to Order 2 Approval of Minutes 2 Revisions or Additions to the Agenda 2 Presentation of Summary of Approval Documents 3 812039 Consideration of Water Quality Special Orders by Consent 3 812040 Request by the Town of Yanceyville for a Special Order by Consent under NCGS 143- 215.67(b) 4 812044 812045 812046 812047 812048 Request by the Town of Gibsonville for a Special Order by Consent under NCGS 143- 215.67(b) Request by the Town of Kernersville for a Special Order by Consent under NCGS 143- 215.67(b) Request by the City of Roxboro for a Special Order by Consent under NCGS 143- 215.67(b) Request by the Town of Elm City for a Special Order'by Consent under NCGS 143- 215.67(b) Request by the Buncombe County Metropolitan Sewerage District for a Special Order by Consent under NCGS 143-215.67(b) 6 6 9 11 13 812037 Request for Remission of Civil Penalties by Mr. Alfred McPherson 13 Agenda Item No. Agenda Item and Action Taken Page No. 812049 Request for Remission of Civil Penalties by Pleasant Grove Senior Citizens Center, Inc. 15 812051 Request for Alternate Stream Flow -Martin Marietta Chemicals, Sodyeco Division, Mecklenburg County 19 8120 Approval of Supplemental EPA Federal Grants 25 812053 Report on Federal and State Grant Funds 26 III. 10. Resolutions Adopted by Brunswick County and Its Municipalities - Re. N.C. Barrier Island E.I.S. 28 III. 2. Civil Penalties Paid - May, 1981 29 III. 3. Civil Penalties Assessed - May, 1981 29 III. 4. Dam Safety Orders Issued -May, 1981 30 III. 5. Oil/Chemical Spills, Etc. 30 III. 6. Reclassification of Lake Hunt in Cape Fear 30 River Basin III. 7. Reclassification of Allen Creek in the Catawba River Basin 30 III. 8. Status of Outstanding Special Orders by Consent 30 III. 9. Update on the Yadkin -Pee Dee River Basin Study 30 III. 11. N.C. 2000 31 Remarks by Commission Members 31 MEETING OF THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Raleigh, North Carolina June 11, 1981 MINUTES The meeting of the North Carolina Environmental Management Commission was held in the NRCD Hearing Room, Archdale Building, 512 N. Salisbury Street, Raleigh, N.C., with Chairman H. W. Whitley presiding. The meeting was called to order and the Invocation was given Mr. P. Greer Johnson. The following persons were in attendance for all or part of the meeting: COMMISSION MEMBERS Chairman H. W. Whitley Dr. James C. Wallace, Vice -Chairman Mr. David H. Howells Mr. Marvin Gentry Mr. E. L. Harkey, Jr. Mr. James E. Harrington, Jr. Dr. Fred A. Barkalow, Jr. Mr. P. Greer Johnson Mr. Jerry D. Lewis Mrs. Clementine Shaw Mr. J. D. Shiffert Mr. William Sullivan Senator R. P. Thomas Representative Robie Nash Representative Roger Bone NRCD STAFF MEMBERS Dr. Neil S. Grigg, Asst. Sec. for Natural Resources Mr. Stuart George, Public Affairs Section DEM STAFF MEMBERS Mr. Bob Helms, Director Mr. L. P. Benton, Jr. Mr. James McColman Mr. Walter Taft Mr. Coy Batten Mr. D. L. Coburn Mr. Stan Taylor Mr. Ted Mew Mr. Arthur Mouberry Mr. Jerry Clayton Mr. Marshall Rackley Dr. Russell Hageman And Others -2- OFFICE OF LEGAL AFFAIRS Mr. Bill Ross, Director Mr. Bob Lehrer, Enforcement Officer OFFICE OF REGULATORY RELATIONS Mrs. Anne Taylor, Director OFFICE OF WATER RESOURCES Mr. John Wray, Deputy Director Mr. Perry Nelson, Hydrologist Ms. Reba Hill, Public Information Coordinator ATTORNEY GENERAL'S OFFICE Mr. Bill Raney, Special Deputy Attorney General Mr. Dan Oakley, Asst. Attorney General Approval of Minutes Mr. Shiffert moved that the Minutes of the May 14, 1981 meeting be approved. Mr. Harrington seconded the motion and it carried unanimously. Mr. Johnson remarked that several places in the Minutes were not clear, and there needed to be more explanation from the person doing the talking and why. He stated he would like the Director to be given permission to clarify one or two items in the Minutes. In particular, Chairman Whitley asked Dr. Wallace to take over the meeting and the Minutes never said Dr. Wallace did so. Chairman Whitley commented that it is so seldom this happens, but he felt sure the Minutes would be corrected to indicate Dr. Wallace chaired the meeting in his absence. Revisions or Additions to the Agenda Mr. Helms remarked that in the mailout relative to the 67(b) requests, there were no recommendations. The recommendations will be made by the staff with each presentation. This oversight will be corrected in the future. Mr. Harrington then suggested that in the staff presentations on the 67(b)'s that the person presenting each one give only the name and the request, thereby eliminating the preliminary information that was included in the mailout. If anyone has a question, it can be raised after the staff member has presented the municipality's request. Chairman Whitley commented that we would get to that shortly. - 19 - Mr.Raney pointed out that the remission request is on the basis of the record that is established. The individual has the right to a hearing in the event that the figure assessed originally is changed. If the amount of the fine is raised, once again the person requesting a remission would be entitled to request a hearing. At this stage, if the penalty were left the same or reduced, then there is no right to a hearing. That is the final decision. Mr. Shiffert commented that in this case he didn't think the fine was large enough. He moved that the remission request be denied. Dr. Barkalow seconded the motion and it carried unanimously. Mr. Tingen asked the Commission if he could serve his time in jail as he doesn't have the $1275? Chairman Whitley told Mr. Tingen that he would have to take that up with the Civil Courts. The Commission is only trying to uphold the laws of the State of North Carolina. 812051 Request for Alternate Stream Flow - Martin Marietta Chemicals, Sodyeco Division, Mecklenburg County Mr. Benton reported that the Martin Marietta Chemicals, Sodyeco Division, requested that the Company be allowed toappear before the Commission and present a justification for a higher stream flow in the Catawba River to be utilized in determining the effluent limits for the Company's wastewater discharge. The Code setting up water quality standards establishes two flows in cases where the flow is regulated. The Commission has, by regulation, established that the instantaneous minimum flow will be used as a basis upon which to determine effluent limits for wastewater discharges unless the Commission determines that the minimum average daily flow can be used as an alternate. In this case, Duke Power Company operates a hydroelectric dam upstream of the Martin Marietta operation. Duke Power has just over 80 cfs of leakdage through that dam, and has also agreed by letter to Mr. Everett Knight in 1977 that upon demand it will assure 314 cfs on a daily average discharge from that hydro installation. The Company, on the basis of this assurance from Duke Power Company, has requested that it be granted this 314 cfs flow as a basis upon which to establish effluent limits for their wastewater discharge. The standards contain no procedure for making the finding and require no specific determinations to be made by the Commission other than that the alternate flow may be used. Mr. Benton pointed out that this action has not been requested of the Commission previously. The staff has withheld their recom- mentation until after the Company has made their presentation. While the staff is looking at this matter, it is having a difficult time making a final decision on a recommendation. - 20 - Mr. Benton stated that Mr. John McLeod, an attorney represent- ing the Company, would like to speak to the Commission and introduce other representatives of the Company who are present. At this time Mr. McLeod introduced Mr. Lewis T. Smoak, a member of the South Carolina Bar Association, and asked that Mr. Smoak be allowed to appear on behalf of the Company in this case. Chairman Whitley remarked that the Commission would be glad to hear from Mr. Smoak. Mr. Smoak commented that he was appearing with Mr. Ed Eceles, the Environmental Manager of the Sodyeco Plant, Mr. Wilton Rankin, Counsel for the Sodyeco Division, and Charles Davis and Mike Smith of the Engineering firm of Charles T. Main in Charlotte. Mr. Smoak stated that renewal of the NPDES Permit has been filed by Sodyeco, and Sodyeco is asking the Commission to use the minimum daily average flow as allowed by the Commission's rules for a damned river. He then used an aerial photograph of the plant showing the Catawba River flowing from the north to the south of Mountain Island Dam as located about 4 miles above the bridge on Highway 27. The Sodyeco plant employs.about 812 people and is engaged primarily in the manufacture of 200 dyes serving the State's textile industry. The wastewater generated from the process is treated by a series of wastewater treatment techniques, including segregation of waste streams, neutralization, and settling of certain wastes, combination and equalization of all waste streams, pre -aeration, secondary biological treatment, clarification, final effluent polishing pond, post -aeration and finally discharge into the Catawba River. This treatment plant achieves approximately 95% average removal efficiencies for the waste- water. With the winter removal efficiencies being somewhat lessdue to the colder ambient temperature, the treatment plant cost approximately $5.7 million to construct. The Company has an additional yearly operating cost of $1.5 million and an additional $1.27 million has been appropriated and will be spent on the current treatment plant. Mr. Smoak remarked that the flow of the Catawba River is con- trolled by the Mountain Island Dam which is 4 miles above Sodyeco's discharge point. The Dam is operated by Duke Power Company. Dutch- man's Creek empties into the Catawba River at a point below the Mountain Island Dam .and upstream from Sodyeco. We will be talking about an additional 15 cfs per second of water that comes out of Dutchman's Creek at extreme low flow conditions. Based upon the instantaneous minimum flow of 80 cfs from the dam plus the 15 cfs from Dutchman's Fork, the DEM has also developed alternate limitations based on the required minimum daily discharge flow of 31t 4cfs 329 rom Mt. al Island Dam plus the 15 cfs from Dutchman's Creek for a cfs. The Commission can, in its discretion, grant to Sodyeco a wasteload allocation for permit purposes based on a total of 329 cfs. - 21 - At this time Mr. Charles Davis remarked that in January, 1971, 2850 cfs was the daily average flow. He then used a chart to show the daily average flow, and another chart to show the different ways in which the pertinent flows for this permit can be shown. The instantaneous minimum flow of 80 cfs is shown with respect to the graph and the next number is what Duke Power agreed to in their permit. Mr. Howells asked Mr. Davis how they arrived at the minimum daily average? Mr. Michael Smith with the Charles E. Main agencycommented that this was in the permit previously. The 314 cfs is the number that was agreed to between the Stream Sanitation Committee and Duke Power Company when the original license was issued. It would be the average of a discharge for twenty-four hours, divided by the seconds in the day. It is a daily average. Mr. Smoak pointed out that you would take the total flow through there during the day and divide it by the number of hours or seconds in the day. If none of the four turbines are running there, it is going to have the instantaneous minimum leakage of 80 cfs coming out of the dam itself. If one turbine in running, they have such a great flow that in about three hours of running one turbine they would generate enough flow through there to create an average of 314 cfs for the day. If they ran four turbines for just 30 minutes, they would generate enough flow through Mountain Island to create 314 cfs through the stream, an average for the entire day. If they are making any power at all, they are running a lot of water through that stream and that dam. Mr. Smoak further stated that the scientists tell him that the total flow through the stream during the day is a meaningful number in calculating the assimilated capacity of the stream even at its low flow conditions. The DEM and the Charles Main agency have done some studies that indicate that a permit based on the 314 cfs would not at any time degrade stream water quality standards in the Catawba River. Mr. Davis pointed out that the 314 cfs figure on this dam is exceeded by the next dam downstream which means that the lake does flow at these flows at all times. The other dams downstream would have the same requirements. Mr. Howells commented that if you calculate the flow on the basis of 83 cfs, the present situation, you always know you are going to have 83 cfs. If you calculate it on the basis of 314 cfs, and say for 8 hours you have nothing coming out other than that leak- age, then you have an increment of stream that is moving from source throughout the stream by the City to which you are discharging waste which the dilution may only be 83 cfs. So if you calculate your dis- charge on the basis of 314 cfs, you are going to have about 4 times the concentration that you currently have in that section of stream. 2 2 - Mr. Davis commented that there is an answer to that alternative which will be covered in the upcoming presentation. Mr. Lewis asked how many gallons per day are being discharged? Mr. Davis stated that the permit being proposed is based on 3.9 mgd, approximately 6 cfs. If the Commission grants the 329 flow for the permit, and based on discussions with the staff, we anticipate up to $3 million additional funds to meet the permit that would be based on the 329 cfs; however, if the permit were based on the 95 cfs, instantaneous flow of 80 plus 15 for Dutchman's Creek, this would require a super tertiary treatment plant at approximately $12 million or $22 million total. The present book value of the Sodyeco facility is approximately $55 million. We would have to spend another $12 milliont $15 million more than we have spent to date just to meet a leakage figure. The operating cost would be nearly $5 million for a facility based on this lower flow and.made up greatly of energy related items; i.e. power to run the plant, a carbon plant, etc. Mr. Harkey asked how much money was approved by the Mecklenburg County Pollution Control Bond and what was its purpose? Mr. Wilton Rankin, Counsel for Martin Marietta Corporation, stated it was $15 million. Its intent was to spend money on a wastewater treatment plant that would have to be built. The bond is based on the fact that the NPDES permit has not been issued and it is essentially unknown precisely how much will have to be spent. $15 million is the maximum figure. This figure was based on the 329 cfs or the $22 million total investment in which case the $15 million would be needed. Mr. Howells expressed concern over the statement in Duke Power Company's letter to Mr. Knight dated August 16, 1977 in which it stated that "It should be pointed out that the operation of these hydro plants as described above will result in a loss of energy which otherwise would be available at peak periods. The result is a significant economic impact to the Company which will ultimately be borne by the public." Mr. Rankin commented that when Mr. Knight got that letter he asked them to explain how that would be possible. Mr. Rankin stated he and Mr. Knight believed that if you put a cubic foot of water over the dam, you get a unit of electricity, and if you get it one time that is all you get. Therefore, when he asked Duke Power to explain why that would result in the loss of electricity or cost to the Company, Duke decided they couldn't answer that and agreed they would not lose the energy. Mr. Howells commented that it is the time of the release of that cubic foot that counts. - 23 - Mr. Rankin stated that Duke Power agreed to do this in order to get permission from the Federal. Power. Commission to build the dam on the river. If it wasn't for the dam, we would be entitled to 475 cfs: This is the price that Duke Power paid in their permit and the State assisted them in getting their permit. They agreed to provide a flow at 314 cfs when so requested. They have agreed to do it and they are doing it. Mr. Lewis asked if the system for the 329 cfs is a secondary treatment with continuous discharge into this river? Mr. Davis stated that it is. Mr. Lewis remarked that then you are going to the $22 million tertiary based on the low flow at a continuous discharge. Is this correct? Mr. Davis remarked that both are continuous unless we are asked by the staff to put in control releases. Mr. Lewis stated that is what he is getting at. You have an option between those two figures on control release which is utilized on the cost. There certainly wouldn't be $12 million difference, and asked if they had considered that? Mr. Davis commented that they have to treat the effluent regardless of how it is released; therefore, you have to put in the facilities to this amount. How it is released is another matter. Mr. Smoak stated that they have discussed this with the staff, and if they can achieve the 329 cfs minimum daily flow through the Commission's discretion not going through a formal variance pro- cedure and requesting the 460 7Q10 that would occur on the river or the actual 440 cfs, then they would stay away from the variance procedure. There was much discussion with the staff on control releases. Mr. Howells commented that the figure given ($22 million) is based on the capital cost of a uniform discharge of waste flow and concen- tration to 95 cfs of water. If you were to have a smaller facility and you were to store part of the time in your release as you have indicated in proportion to flow, then is that $22 million cost figure irrelevant? Mr. Davis stated that we are not talking about a regulated discharge where the treatment varies with the flow. The staff is insisting that we treat down to the numbers on thBpermit equal to this or that flow. How we release it is a small part of the cost, but we are willing to consider an engineering system that would release it when that river flows at whatever it is flowing at as long as the permit recognizes a treatment level for water quality based on this flow. - 24 - Mr. Smoak pointed out that just 40 miles below Sodyeco's discharge in South Carolina a large pulp and paper mill discharges to the Catawba River eight times the quantity of BOD that Sodyeco is requesting, and 51 times more BOD than Sodyeco would be permitted at 95 cfs. He stated the stream would be better protected under 329 cfs than under the normal 7Q10 low flow conditions on an unregulated stream. The cost is extremely high to go to the 95 cfs. The average stream flow is ten times what Sodyeco is asking that their permit be based on. If the staff thinks it is advisable Sodyeco is willing to put in control release so that the release is timed to Duke's generation of electricity at Mountain Island. Mr. Smoak thanked the Commission for allowing him and others to make presentations on behalf of Martin -Marietta Chemicals, Sodyeco's Division. Chairman Whitley thanked Mr. Smoak. At this time Chairman Whitley recognized Mr. Vernon Stevens, former Chairman of the Board .of Water and Air Resources. Mr. Benton commented that there has been some mention of an indication relative to an allowance for 30Q2 flow to accommodate the discharge of toxics in accordance with State standards. He stated that at the present time the Commission should defer any consideration of the 30Q2 question. The regulations clearly state that in cases where the stream flow is regulated, the governing flow for all water quality standards shall be the instantaneous minimum flow or if deemed appropriate by the Commission, the minimum daily average flow. In order for the Commission to allow a 30Q2 for toxics a variance procedure would be required. Secondly, for the proposed permit there are no toxics which would be subject to such 30Q2 determination anyway so there is no urgency on that score at this time. As the EPA develops toxic limits for this category of industry, the staff believes the industry will come back to the Commission and ask for consideration for 30Q2 or some higher flow for the long term impact of toxic materials on the aquatic life. Mr. Benton further stated that the staff sees no reason for not allowing the higher level of flow since the entire level of flow is guaranteed by Duke Power Company. From a technical standpoint, it is necessary to release the river water so that you are diluting the treated wastewaters with the higher flows as the higher flows are released so the Company should be required to put in a staged dis- charge system. Secondly, the Company should be required to retain their discharge or take such other measures as are necessary in the event that Duke Power Company must take the Mountain Island Dam out of service (stop discharging) for any reason at any time. - 25 - Dr. Wallace asked Mr. Benton if Duke Power Company has an etterde oftoday similarto the one 1977 concerning the loss oofgsome lofy eite ssed in their s le peaking water? l Mr. Benton stated that certainly they have an attitude that this requirement for discharge for minimum average daily discharge limits their alternatives dischargeltimeofrom 6hydro AM topower PM. They peaking. They g are saying that they are foregoing the ability to peak on the 23rd of July rather than the 24th of July, but they are reserving the right to peak anytime during the normal peak period. In reality, they are not losing this peaking power. They do not have all of the options available to them as to when to use it. There is a peak every day of the year. They are aware of this. Mr. Rankin commented that Duke Power Company is in full agreement with what Mr. Benton has just proposed. Mr. Harkey moved that the Commission approve the request by Martin Marietta Chemicals, Sodyeco Division, subject to the stipulations and recommendations of the staff. Mr. Lewis seconded the motion and it carried unanimously. 812052 Approval of Supplemental EPA Federal Grants Mr. Batten reported that the Resolution being considered is for six applicants: (1) Roanoke Rapids Sanitary District is asking for $19,252 to aid in the preparation of a 201 Facilities Plan and Phase I SSES; (2) City of Robbins - requesting $4,875 to aid in the development of a Phase I Pretreatment Program; (3) City of Wilson - requesting $12,931 to aid in site specific soils surveys for the proposed Elm City land application type wastewater treat- ment facility; (4) M.S.D. of Buncombe County - requesting $65,069 to aid in the development of a Phase II Pretreatment Program; (5) Town of Fountain - requesting $57,885 to cover costs for a 57,000 gpd land application type wastewater treatment facility; two lift stations, approximately 2,500 LF of 4-inch force main, and (6) Anson County - requesting $2,048,475 to aid in the construction of a regional wastewater treatment facility to serve the Towns of Lilesville, Morven and Wadesboro. Mr. Batten stated it is the staff's recommendation that the grant increases for the six applicants be approved. Mr. Shiffert moved that the grant increases be approved by the Commission. Mr. Harkey seconded the motion. Dr. Barkalow commented that he would like to make a substitute motion. He stated he was in favor of these projects but he would like to add one little community, Feltonsville. They appeared at the public hearing held on Wednesday, at which he was the Hearing (2%I.Aiiv) NOTES OF CONFERENCE CLIENT: Martin -Marietta Corp., Sodyeco Div. PROJECT: Proposed Effluent Limitations Date of Meeting: 1/21/81 Division Industrial Job No. 3182-10-1 Serial No. File No. Date Issued 1/23/81 Page 1 of 2 Place of Meeting: N. C. Department of Natural Resources Raleigh, North Carolina SubjectReview of the Proposed Effluent Limitations Notes Prepared by: Kris Turschmid Present: N. C. DNR L. A. W. B. R. R. D. K. P. Benton C. Turnage C. Mills K. Overcash Peace Williams Kuningham Cox SODYECO. MAIN W. Rankin C. H. Davis E. Eccles K. H. Turschmid On January 21, 1981 a meeting was held at the N. C. Depart- ment of Natural Resources in Raleigh, North Carolina to review the proposed effluent limitations for the Martin - Marietta Corp., Sodyeco Division in Mt. Holly, North Carolina, and our response to the proposed limitations included in Sodyeco's letter of November 14, 1980 and MAIN's letter of December 15, 1980. The meeting was requested by MAIN on behalf of Sodyeco. Mr. Wilton Rankin opened the meeting briefly describing Sodyeco's plans for construction of the new wastewater treatment facilities. The following subjects were discussed further: 1. The Duke Power Company letter of August 16, 1977 to W. E. Knight stating Dukes agreement to maintain a minimum average daily release of 314 cfs from the r< Mt. Island Dam. In•reply, Mr. L. P. Benton stated that the letter is an insufficient legal commitment JUL and that Sodyeco should either obtain an approval from the Commission for wastewater allocation basedCENTRA on the 314 cfs flow or enter into a contract with Duke Power Company obligating Duke to maintain the minimum average release of 314 cfs from Mt. Island Dam. Subsequently, legal aspects of the operating Action By and Date EIVED z ( 1991 FILE COPY NOTES OF CONFERENCE Martin -Marietta Corp: Sodyeco Div. 1/21/81 - - Page license for Mt. Island Dam were discussed. In conclu- sion; Mr. Wilton Rankin is to discuss the above problem with Bill Roney or Bill Ross. 2. In connection with the water quality criteria considera- tions and the flows in Catawba River, a possibility of application of staged discharge was discussed. It was concluded that staged discharge seems feasible, however, in this case the limitations would be based on mass (pounds per day, 30 day average) discharge and average flow in the river to ensure treatment requirements. Details of the staged discharge will have to be worked out at a later date. 2 of 2 Action By and Date 3. The applicable ultimate carbonaceous BOD/BOD5 ratio will R. Williams have to be resolved between Randy Williams and the wri- by 1/22/81 ter in view of the new data (maximum ultimate BOD of 189 mg/1) presented by the State. R. Williams to send K. Turschmid copy of wasteload allocation print-out amd notes. 4. Application of the maximum daily to average monthly ratio of 2.0 instead of 1.5 for limited parameters is acceptable. However, applicability of the ratio of 3.0 will have to be further investigated. 5. The seasonal variations for oxygen consuming wastes is acceptable and should be applied for with DNR simultan- eously with applications to the Commission for other variances. 6. The seasonal variations for TSS is not acceptable. 7. The Phenol limitation is based on water quality criteri of 1.0 ppb. The new water quality recommendations pub- lished in the Federal Register on November 28, 1980 are not applicable. An application for a variance in Pheno limitations will have to be submitted to the Commission with a proper documentation (possibly staged discharge). 8. The problems to be presented before the Commission are: applicable Catawba River flow (Duke Power agreement or operating license), staged discharge and Phenol limit tions. 9. June 30, 1981 is a deadline for issuing the new NPDES Permit. After this date new Permits will be issued 40 after promulgation of applicable Effluent Guideline Limitations KHT/nt cc: All Attendees ik-qi-tdefaAAS ris H. Turschmid JU ( 1ggi L FILE COPY . / /3.e„LJ r �, NIA I\' i . , CHAS. T. MAIN, I N C. TWO FAIRVIEW PLAZA, 5950 FAIRVIEW RD.. P. O. BOX 240236, CHARLOTTE, N. C. 26224, TEL. 704/664.1100 December 15, 1980 3182-10-1 SUBJECT: Proposed Effluent Limitations for Martin Marietta Corporation Sodyeco Division North Carolina Department of Natural Resources and Community Development Division of Environmental Management 1119 North Main Street Mooresville, North Carolina 28115 Attention: Mr. B. Keith Overcash Dear Mr. Overcash: rirt )� .• •' t 4. DEC 13u0 ENVIRONMFNTA[ OPEERATION3 We have reviewed the proposed effluent limitations and the report on wasteload allocation for the Martin Marietta Corporation. Sodyeco Division, in Mt. Holly, North Caro- lina. As a result of the review, we request on behalf of Sodyeco your consideration of the following: 1. The Duke Power Company letter of August 16, 1977 to W. E. Knight stated Duke's agreement to start maintaining the average daily release of 314 cfs from the Mt. Island Dam upon a notification by the Division of Environmental Management. Please advise whether any additional action by Sodyeco is necessary. 2. The wasteload allocation study laboratory data suggests use of an average ultimate carbonaceous BOD/BOD5 ratio of 2.0, rather than 3.0. This would result in a slight increase of the BON limitations. Our calculations are attached for y.our. consideraticip 3. The wide variety of products manufactured by Sodyeco results in a highly variable loading to the treatment facilities in spite of the fact that equalization is provided. We request your consideration of a maximum daily to average monthly ratio between 2 and 3 as suggestA r;, I`_ D J CENTRALUL27FILE COPY1991 NEW YORK, NEW YORK • BOSTON, MASSACHUSETTS • CHARLOTTE, NORTH CAROLINA • DENVER, COLORADO • PORTLAND. OREGON North Carolina Department of Natural Resources and Community Development December 15, 1980 Page Two the 303(e) Basin Plans, Appendix E - Assimilative Capacity - Wasteload Allocation Methodology. 4 We request your consideration of a staged discharge in proportion to the flow in the Catawba River. This technique is well known and accepted by the Region IV of the U.S. EPA. The Catawba River flow at Sodyeco is regulated by water releases from the Mt. Island Dam operated by Duke Power Company. The following table indicates the water release records maintained by Duke Power: Water Releases From Mt. Island Hydro Plant Monthly 11-Year Minimum -Median -Maximum July 1977-June 1978 July 1967-June 1978 CFS CFS July 1977 2433 July 1148 2648 3525 Aug. 1977 1810 Aug. 1141 2464 3525 Sept 1977 1164 Sept. 1164 2448 4725 Oct. 1977 1502 Oct. 233 2817 5178 Nov. 1977 7716 Nov. 1395 3271 7716 Dec. 1977 4432 Dec. 1256 2087 4432 Jan. 1978 3079 Jan. 2310 3248 4832 Feb. 1978 5917 Feb. 233 3809 5917 Mar. 1978 3079 Mar. 756 2702 6501 Apr. 1978 2517 Apr. 987 2494 5724 May 1978 3725 May 1264 2694 4786 June 1978 2756 June 1825 3563 6117 The discharge flow can be automatically controlled by the water releases from the Mt. Island Dam. 5. The Sodyeco wastewater treatment facilities include two polishing lagoons for the final effluent. These ponds may cause seasonal difficulties with the total suspended solids (TSS) concentrations in the effluent due to the biological growths. Therefore, we request consideration of a higher TSS limitation similar to the TSS limita- tions for lagoon discharges as TSS is not tied directly to water quality. RECEIVED J U L 27 1991 CENTRAL FILE COPY North Carolina Department of Natural Resources and Community Development December 15, 1980 Page Three 6. The Phenol Limitation is based on water quality criteria which was revised in the Federal Regis- ter on November 28, 1980. We request the Phenol limitation be reviewed in consideration of the new water quality criteria. We also request that the Phenol limitation be based on staged dis- charge criteria. The above is a supplement to Mr. E. J. Eccles'letter..to, you on November 14, 1980 responding to your 1etter=of October 16, 1980. We will be glad to discuss the above'et your convenience. With the holiday season here, we sug- gest a meeting be held in mid January, 1981. We will con- tact you later this month to set a date. We also want to discuss at the meeting your requirements and procedures for application for staged discharge, seasonal variations of limitations, and minimum average daily flow in the Catawba River as a base for the wasteload allocation. MJS/nt / cc: L. P. Benton/ A. C. Turnage E. Eccles C. H. Davis, Jr. Very truly yours, CHAS. T. MAIN, INC. Michael J. Smith, P.E. RECEIVED JUL 27199'1 CENTRAL FILE COPY