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
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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