NC0028169_Correspondence_19910404

NPDES DOCUMENT SCANNING COVER SHEET
Permit:
NC0028169
Aquadale Quarry
NPDES
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File
- Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental
Assessment (EA)
Permit
History
Document Date:
April 4, 1991
This document ifs printed on reuse pamper - ignore nay
content on the reYerse (side

MEMORANDUM:
TO:
FROM:
THROUGH:
SUBJECT:
DIVISION OF ENVIRONMENTAL MANAGEMENT
April
Dale Overcash
Permits and Engineering
Betsy Johnson
Technical Support Branch
1991
Mike Scoville �
Ruth Swanek
(eYD( C (Efftat
Clean Water Alt letter regarding Carolina Solite's draft permit.
NPDES No. NC0028687
Stanly County
I have reviewed the Clean Water Fund's letter commenting on Carolina
Solite's draft NPDES permit. I offer the following responses:
1. Carolina Solite's waste is hazardous and should be permitted as such.
I agree that this is a hazar us
permitted by the Hazardous Waste
laws, Carolina Solite is not required to obtain such a permit.
the Clean Water Fund lobby for a change to this law.
2. Weekly monitoring for VOC's.
waste incinerator and should be CG
However, under current state Qi
I suggest
Looking at past data, we have no basis for this requirement. A
quarterly priority pollutant analysis will be required.
3. The proposed permit conflicts with the SOC requirements.
The SOC requirements supercede the permit for the duration of the
SOC. The permit will not go into effect until the SOC expires.
4. Effluent limits for Lead, Fluoride, Cadmium, and Cyanide.
The limits for these constituents were derived taking Oakboro's
discharge into account. While the limits allow the use of a large portion
of the river's assimilative capacity, the state currently has no policy
for restricting allocations. However, the permit will be re-examined in
1994 when the permit must be renewed under the state's new basin planning
schedule and, a basin -wide allocation will be done in 1999 when the Yadkin
River Basin management strategy is implemented.
5. Quarterly Priority Pollutant Analysis.
A requirement for quarterly priority pollutant analyois should have
been included in the permit. This was an oversight by DEM. The permit
will be amended to include this requirement.

6. Monitoring Frequency
7. Discharge limits for monitored characteristics.
There is no basis utter DEM's SOP to assign discharge limits to those
parameters which receiv monitoring requirements. Effluent levels must,
be within 1/10 of the allowable level to warrant implementation of a \)E,,.,4-
limit. Monitoring is required when the effluent levels are between 1/10
and 1/100 of the allowable levels.
8. Selenium and sulfates.
A selenium limit of 113 ug/1 will be added to the permit based on the (\. Y'
state standard of 5 ug/1. Evidently, there was an oversight in the „,\1,�Y
wasteload allocation. There is no state standard for sulfate on which to \��� ` G,
,X base a limit. �U
9. Enforcement.
I have no comment.
If you have any questions regarding these comments, please let me know.
cc: Raleigh Regional Office
Central Files

pAk
Clean Water Fund of North Carolina
112 North Person Street • Raleigh, North Carolina 27601 • 919 832-7491
138 East Chestnut Street • Asheville, North Carolina 28801 • 704 251-0518
Dr.. George Everett
D•iviision of Environmental Management
P-.. 0. Box 27687
c .:2igh, NC 27611
C ;cue: Comments on NPDE,S.._pgm,
Dear Dr. Everett:
t{Q, NC0028169 f
APR 1 1991
R E C I J ? E'er'"
MAR 28 1991.
PERMITS . rr1( ?p,IrGRJt C
r ' caro!i na
APR 0 2 1991
The proposed permitF-AelfS ;t OtParalequately address , the fact
that Carolina Solite burns waste solvents for fuel. It seems 0"
to me that this hazwaste fuel is hazwaste when they burn it, 1 0
hazwaste when run through the wet scrubbers, hazwaste when (�
discharged into the settling ponds and hazwaste when
whatever is left is discharged into the Rocky River. Thus
there should be limits set and at least weekly monitoring
for contaminants (VOC's etc.) known to be in the wastes
Solite incinerates. 6,Ae`.,1.
The proposed permit is also in conflict with the recently
issued SOC. Solite has agreed to burn hazwaste fuel only in
units with new baghouses. The state has agreed that this is
the solution to the problems caused by Solites current
practices. But as of April 15, 1991 when this proposed
permit would go into effect, Solite will be allowed to
continue burning hazwaste in units with wet scrubbers...a
practice the state has in effect condemned in the SOC. If
the current practice was dangerous enough to require an SOC,
it is dangerous enough to be prohibited in this permit. The
state should prohibit the discharge of hazwaste derived
pollutants under this permit.
In addition, please consider the following:
1. The proposed effluent limits for Lead, Fluoride, Cadmium
and Cyanide should be lowered for outfall number 001.
Carolina Solite is just one of several dischargers into
the Rocky River (Oakboro is another) yet its proposed limits
would take up a high proportion of the instream limits for
these pollutants. For example, 368.0 ug/1 daily max. limit
for lead with a permitted discharge of .8640 mgd on a stream
with a summer 7Q10 of 29cfs translates into an instream
level of 17 ug/1. The recommended level for Class C streams
as I understand it is 25 ug/1; thus Solite's pollution will
take over half of the river's carrying capacity on this
element alone. According to the Compliance Evaluation
Analysis Report of 2/19/91 Solite has averaged .2510 mg/1 of
lead and has had levels as high as .8510 mg/1. While 368.0
ug/1 may represent a safety factor for Solite in terms of
compliance, it seems to represent a danger factor for the
Rocky River in terms of actual and potential pollution.
'VCYCMO p.pn

2. I agree with the staff report of March 19, 1990 that
recommends quarterly priority pollutant analysis to coincide
with toxicity tests. The proposed permit requires this
annually. I do not understand why the staffs' recommendation
has not been included in the draft permit and urge you to
support their recommendation. !
3. The frequency of monitoring is inadequate. Solite has had
a number of violations in the recent past and this track
record alone should require at least weekly monitoring.
Combine this with their continuous 24 hour a day production
and the necessity of more frequent monitoring is evident.
4. Discharge limits should be included for the monitored
characteristics listed in part a. for outfall 001.
In addition to daily maximum limits, there should be
Avg. limits.
monthly
5. Since this permit seems to be aimed at Solite's coal
burning operations, why is there no mention of selenium and
sulfates?
6. There is very little in the permit regarding enforcement.
Champion and Weyerhaeuser's permits are much more specific
in this regard. This vagueness should be corrected.
Finally, this permit depends upon self -monitoring, a process
that in the hands of Solite worries me. Is it not possible
to require that all testing be done in the presence of the
resident inspector soon to be installed by the state?
Sincerely,
•IA 04-4,
Ted Outwater
Director
Clean Water Fund -NC
3-28-91
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