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HomeMy WebLinkAboutNC0074454_Permit (Modification)_20120910NPDES DOCUMENT SCANNING COVER SHEET Permit: NC0074454 Ramseur WTP NPDES Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Staff Report Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Permit History Document Date: September 10, 2012 This document is printed oa reuese paper - igrnore sixty content on the relirersse 'side AwA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, RE, Dee Freeman Governor Director Secretary September 10, 2012 Mr. Jim McIntosh, Director of Public Works Town of Ramseur P. O. Box 545 Ramseur, NC 27316 Subject: Correction of NPDES Permit NC0074454 Town of Ramseur WTP Randolph County Dear Mr. McIntosh: Having received more detailed information regarding frequency of discharge events at the Town of Ramseur WTP, Division personnel have reviewed the terms and conditions of the subject permit. Accordingly we are forwarding the attached modified permit pages. Please remove the existing pages and replace them with the ones attached to this letter. This correction c anges thew ole of l uent toxic' to be performed by the facility from a 7-days, chr_oni� pass/fail test to a 48 hour acute test. The test organism shall remain ceriodaphnia dubia. This change has been ma ecause routine operations at the water treatment plant do not create a wastewater discharge with a frequency that allows the facility to monitor in adherence with the established protocols for chronic toxicity testing. This correction is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919) 807-6398 or via e-mail at bob.sledge # ncdenr.gov. ely, U Charles WakiTd, P.E. cc: Central Files Winston-Salem Regional Office/Surface Water Protection Section NPDES Permit File ec: Aquatic Toxicology Unit Steve Meads — Town of Ramseur WTP 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-6492 Internet: www,ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer Noe -thCarolina aturally Permit NC0074454 1 \\�\`: \ ) lro 11\: ,f:-.)!''lf� 'rr-.J;I \ `\ ;, l'i:, 11 ��,�\ : •, , 11 i t, /°,�!`r\ „., `, L�/� �J/ -.' �� f :11• 1 f ".' 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Town of Ramseur WTP State Grid/Quad: E 20 NW / Ramseur, NC Facility `��"• `-% ". w:4 J Location Latitude: 35° 44' 23" N Longitude: 79° 40' 43" W not to scale ' Receiving Stream: Sandy Creek Sub -Basin: 03-06-09 Drainage Basin: Cape Fear River Basin Stream Class: C NPDES Permit No. NC0074454 North Randolph County Permit NC0074454 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: Et`FLUENT CHARACTER1STiCS ParameferCode� ''n � ' � Limits ` � �. � -. Mon t&mg Requirements raj* , �._Average:'_y , Dar,� ,. .'Fi akiiiium• r<Mleas remer�i� � __ Fiaquec._ y -_f fi Sain Ia L_!_- ' Type :S_ample . Locat_ion. Flow . 50050 Weekly Instantaneous Effluent Total Suspended Solids C0530 30.0 mg/L 45.0 mg/L 2/Month Grab Effluent pH 00400 6.0 s.u. and <_ 9.0 s.u. 2/Month Grab Effluent Total Residual Chlorine1 50060 28 pg/L 2/Month Grab Effluent Turbidity 00070 2/Month Grab Effluent Aluminum 01105 • Quarterly2 Grab . Effluent ►-Totallron-- 01045 Quarterly2 Grab Effluent Total Copper 01042 Quarterly2 Grab Effluent —Manganese 01055 Quarterly2 Grab Effluent Fluoride 00951 Quarterly2 Grab Effluent Total Phosphorous (TP) C0665 Quarterly2 Grab Effluent Total Nitrogen (TN) C0600 Quarterly2 Grab Effluent Whole Effluent Toxicity Monitoring3 TGA3B Quarterly Grab Effluent Footnotes: 1. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µme• 2. Monitoring should be performed in conjunction with toxicity testing. 3. Ceriodaphnia dubia 48 hour acute pass/fail test @ 90% concentration. See Condition A. (2.) for toxicity testing requirements. Toxicity testing should be performed during the months of January, April, July and October, and sampling should coincide with sampling for parameters covered by footnote 2. All samples must be collected from a typical discharge event. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NC0074454 A. (2.) ACUTE TOXICITY PASS/FAIL MONITORING (QUARTERLY) The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall be performed as a Ceriodaphnia dubia 48 hour static test. The effluent concentration at which there may be at no time significant acute mortality is 9 0% (defined as treatment two in the procedure document). Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The tests will be performed during the months of January, April, July and October. These months signify the first month of each three month toxicity testing quarter assigned to the facility. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGA3B. Additionally, DWQ Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a single test is passed. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified above. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. Should it be determined by the North Carolina Division of Water Quality that the facility's discharge frequency and duration enable chronic sampling according to either the North Carolina Ceriodaphnia Chronic Whole Effluent Toxicity Procedure or to Section 8.3, in Methods EPA-821-R 02-013, the permit may be re -opened and modified to include chronic toxicity tests. Permit NC0074454 A. (3.) PERMIT RE -OPENER: NUTRIENT MONITORING Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II sections B- 12 and B-13 of this permit, the Director may reopen this permit to require supplemental nutrient monitoring of the discharge. The purpose of the additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may require that limits for Total Nitrogen and Total Phosphorus be imposed in this permit upon renewal. Sledge, Bob From: Sent: To: Subject Attachments: Sent from my iPhone Begin forwarded message: Grzyb. Jute Friday. August 10, 2012 8:15 AM Sledge. Bob; Matthews. Matt; Be!nick, Tom; Poupart, Jeff Fwd: Ramseur WTP - NC0074454 Alt Chronic WTP-Acute Limit PF Cerio 48h .doc; ATT00001.him From: "Moore, Cindy" <cindv.a.moore@ ncdenr.eov> Date: August 10, 2012 8:12:50 AM EDT To: "Guerra, Bob" <bob.euerra@ncdenr.eov>, "Grzyb, Julie" <julie.erzyb@ncdenr.gov> Subject: FW: Ramseur WTP - NC0074454 Carol is off today. If ya'll have any question, please let me know Thanks Cindy From: Hollenkamp, Caro! Sent: Thursday, August 09, 2012 6:05 PM To: Moore, Cindy Subject: RE: Ramseur WTP - NC0074454 Cindy, As we discussed with ATU today, and with Jay and Matt Matthews in the past, ATU has come to the consensus that assigning acute pass/fail Ceriodaphnia 48 hr at 90% to facilities that cannot meet the chronic discharge schedule is the most appropriate approach based on all the options. When (and if) the monitoring for WTPs changes to a permit limit, then a failing result would require follow up testing as acute pass/fail 48 hr at 90% until they pass, which will be consistent with the acute compliance policy. However, we also discussed with Jay that this currently will iust be for WTPs, which right now are just monitoring so the follow-up testing won't apply until the WTP's have limits assigned (if this happens in the future). Attached is a modified Acute Pass/Fail monitoring template that can be used for Ramseur WTP. This template may also be used for other WTP's that would be assigned chronic testing, but whose routine operations cannot meet a chronic test schedule. This is NOT a standard template for acute testing, and it should only be used for WTPs that would be assigned chronic testing but cannot meet the chronic schedule. For NC, this is two samples a week, typically on Tuesday & Thursday. We will follow-up with a memo that will 1.) amend the WTP permitting strategy to include this alternate approach for facilities that cannot meet the chronic schedule; 2.) explain the reasoning behind this approach and other states with similar policies; 3.) include a more concise definition of what it means to not be able to meet a chronic schedule. Please forward the template to Julie and Bob if this at looks good to you. We can at least get Ramseur squared away for now, and follow-up with the memo in the next couple of weeks. Thanks, Carol From: Moore, Cindy Sent Tuesday, July 31, 2012 4:15 PM To: Grzyb, Julie Cc: Belnidc, Tom; Hollenkamp, Carol; Giorgino, John Subject: RE: Ramseur WTP - NC0074454 We've discussed it but need to come to a final decision. I'm out tomorrow and Thursday let me talk with Carol and John and we will have something for you first of the week - From: Grzyb, Jute Sent: Tuesday, July 31, 2012 4:12 PM To: Moore, Cindy Cc: Belnidc, Tom Subject: RE: Ramseur WTP - NC0074454 Cindy, Any progress on how ATU would like to address the Ramseur WTP toxicity monitoring? Julie From: Moore, Cindy Sent: Thursday, July 12, 2012 8:44 AM To: Giorgino, John; Hollenkamp, Carol; Meadows, Susan Cc: Grzyb, Julie Subject: RE: Ramseur WTP - NC0074454 Thanks, John! From: Giorgino, John Sent: Thursday, July 12, 2012 8:35 AM To: Hollenkamp, Carol; Meadows, Susan Cc: Moore, Cindy; Grzyb, Julie Subject: RE: Ramseur WTP - NC0074454 I do not think random (not consecutive) non -compliant events (Fails) should be a consideration. Taking into account the many variables that can produce a Fail, a single event should not be cause to attach it to another single event that happened 3-11 months distant (or more). When a facility Fails 2 months in a row, that indicates more of a trend, in which a possible plant upset needs to be addressed. In a nutshell, consecutive Fails are of more concern to me than an occasional blip that can be attributed to the science of tox testing. Secondly, consecutive Faits also parallels our existing enforcement policy, which triggers our action level policy and possible Civil Penalty Assessments. John Giorgino Environmental Biologist North Carolina Division of Water Quality Environmental Sciences Section Aquatic Toxicology Unit Mailing Address: 1621 MSC Raleigh, NC 27699-1621 Office: 919 743-8441 Fax: 919 743-8517 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Hollenkamp, Carol Sent: Wednesday, July 11, 2012 3:53 PM To: Meadows, Susan; Giorgino, John Cc: Moore, Cindy Subject: FW: Ramseur WTP - NC0074454 John and Susie, Cindy and I were just talking about Julie's last paragraph below (highlighted in yellow). We were thinking that a WTP that has failed 2 quarters in 1 year should be considered as "failing". These quarters don't need to be consecutive. What do you guys think? Talk with Cindy or me for more info, but basically, the idea/potential approach behind this is: Future WTP strategy may require failing WTPs to follow a compliance/alternative schedule to figure out how to reduce/eliminate/or pass toxicity. This schedule still needs to be drafted, but would likely include something like: • Reduced/altered frequency of monitoring so they can focus $ resources on solutions. (We know they are failing, so they don't have to keep demonstrating this every quarter) • Evaluating and finding solutions such as discharging to a larger stream, sending to a WWTP, mixing in source water with discharge, changing plant operations The more stringent approach of categorizing failure as being failing 2 quarters in one year is because: 1) discharge is variable and difficult to collect representative samples; 2.) this is monitoring only, so they don't have any follow up testing for compliance. From: Grzyb, Julie Sent: Friday, July 06, 2012 2:37 PM To: Moore, Cindy; Sledge, Bob Cc: Meadows, Susan; Hollenkamp, Carol Subject: RE: Ramseur WTP - NC0074454 Thanks Cindy, Since we have a number of these facilities, we will need ATU to revise the appropriate toxicity sheet with what test to run if failure occurs and who to submit the results too. However, I am not completely clear on the purpose of the 5 dilutions — would you be able to determine an acute to chronic ratio based on this test? Would additional testing be required depending on the results? I would assume this path of testing would only be offerred to facilities with an intermittent discharge to a non -zero low flow stream — Correct? At this point, intermittent meaning— unable to meet the criteria/protocol for replenishing the chronic test. We have one other pending question 1 have posed to Carol and need ATU's help. If NPDES is to put a compliance schedule in WTP permits that are failing tox tests (an alternatives schedule as Matt proposed while ATU and NPDES approach stakeholders), can you help us define failing. For example, would it be any WTP that has failed two consecutive Toxtests in the past 1, 2 or 3 years? Thanks for looking into this, Julie From: Moore, Cindy Sent: Friday, July 06, 2012 2:05 PM To: Sledge, Bob Cc: Meadows, Susan; Grzyb, Julie; Hollenkamp, Caro! Subject: RE: Ramseur WTP - NC0074454 I think what we discussed finally was to put in a Pass/Fail Ceriodaphnia and if they failed they would need to do a 5 dilutions test the next month! Everybody should be back next week so let us collectively look at our notes and we will respond appropriately. Thanks Cindy From: Sledge, Bob Senb Friday, July 06, 2012 1:53 PM To: Moore, Cindy Cc: Meadows, Susan; Grzyb, Julie; Hollenkamp, Carol Subject: FW: Ramseur WTP - NC0074454 Hi Cindy, Susie told me that y'all were feeling lonesome over there this afternoon, so I thought I'd spice up your life with an e-mail about the Ramseur WTP and toxicity monitoring. I appreciate Susie sending the lab the note about the WTP's July testing. I did want to make sure I was clear about where we go from here with regard to the permit. The conversation we had on 6/20 with Carol, Susie and Julie took a few different twists and turns. As you may recall, I originally permitted the Ramseur WTP with a 7 day chronic toxicity test using ceriodaphnia. They discharge into a stream with a consistent flow, downstream of the outlet for the reservoir. The IWC was calculated at 6%. After the permit was issued we were told the WTP only discharges intermittently, and is unlikely to meet the criteria/protocol for replenishing the chronic test. They've been performing the acute 24 hour test using the fathead minnow at a 90% concentration for the past few quarters. We talked about making that the permanent test in a "correction" of the permit, but other options were also discussed as an alternative or in conjunction to the fathead. There was some question as to whether they should perform a 48 hour acute test using ceriodaphnia at 5 different dilutions and report the LC50. This would provide longer exposure and a more sensitive species. Then there was discussion about requiring the acute fathead test at 90%, with the LCSO analysis required in the future if the first test resulted in a "fail." If they "passed" at 90%, all would be fine; if they didn't, we'd call for testing that would provide more information regarding the extent of toxicity problems. This last option seemed a little tricky since WTPs have only a monitoring requirement and technically don't fail, even with a bad result. As I recall, the brain trust at ATU was going to continue to look into the matter and recommend a plan for permitting this facility. This might include determining the proper test organism and method, and developing some permit language that fits the circumstance. Would we create a conditional toxicity condition, or go with standard toxicity condition language, and add a toxicity reopener that would allow us to call for another test if poor results warrant the change? Sorry for the long note. Y'all set me straight and I'll ship the permit. Thank you for your patience and your help. Have a fine weekend. Bob From: Meadows, Susan Sent: Monday, June 25, 2012 2:20 PM To: Pamela Cotten Cc: Meads, Steve; Sledge, Bob; Moore, Cindy Subject: Ramseur WTP - NC0074454 Hi Pam, Since Lab scheduling is necessary now for July testing, ATU is suggesting Ramseur WTP (NC0074454) continue running a Fathead 24 Pass/Fail test for July 2012. The next testing month will be October, at that time testing changes can be made to reflect the New Permit Modification. Susie Susan Meadows, Environmental Biologist Aquatic Toxicology Unit DWQ/Environmental Sciences Section 4401 Reedy Creek Road Raleigh, NC 27607 susan.meadows(5 ncdenr.Aov t: (919) 743-8439 f: (919) 743-8517 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. 5 u Sledge, Bob From: Meads, Steve [Steve.Meads@unitedwater.com] Sent: Tuesday, April 10, 2012 2:59 PM To: Sledge, Bob Cc: Blackwell, Nadine Subject: RE: Ramseur NPDES NC0074454 Follow Up Flag: Flag Status: Follow up Flagged Bob, That sounds good to me. Thank you for your time and patience. Steve From: Sledge, Bob [mailto:bob.sledoeCtncdenr.00vj Sent: Tuesday, April 10, 2012 11:50 AM To: Meads, Steve Subject RE: Ramseur NPDES NC0074454 Hi Steve, I'm sorry for not responding promptly to your original note. I was away from the office when your e-mail first arrived, and for some unknown reason, it settled in a junk e-mail folder, so I was even slower in being aware of it. 1 believe what we'd agreed to do was (first) for you to declare which way the Town wanted to go with the toxicity test, then if you were ok with the acute test at a 90% concentration, I would send out a revised permit as a correction to the original, stating the acute test is more appropriate due to the intermittent nature of the discharge. Since y'all are ok with the acute test, I'll go ahead and make the change, keeping the same testing schedule. Does this sound correct, and is it agreeable with you? Thank you, Bob From: Meads, Steve f m ilto:Steve.Meads@unitedwater.coml Sent Tuesday, April 10, 2012 11:39 AM To: Sledge, Bob Cc: Blackwell, Nadine Subject FW: Ramseur NPDES NC0074454 Bob, I did not receive a response from you so 1 wanted to be sure you got my previous email indicating we were going to use the acute toxicity method. Steve From: Blackwell, Nadine Sent: Monday, April 02, 2012 9:39 AM To: Meads, Steve Subject: RE: Ramseur NPDES NC0074454 Please let me know their response. From: Meads, Steve Sent Thursday, March 29, 2012 9:57 AM To: Sledge, Bob; Blackwell, Nadine Subject Ramseur NPDES NC0074454 Bob, We have been in discussions with our Lab and decided for the way we discharge the Acute toxicity test will be best for us. Could you please let me know what we need to do to amend our permit. Thank you. Steve Sledge, Bob From: Meadows, Susan Sent: Tuesday, January 17, 2012 12:24 PM To: Sledge, Bob Subject: RE: NC0074454 Town of Ramseur Hey Bob, It's Tuesday 1/17/12, I tried calling you, but did not leave a voicemail. I figured it would be just as easy to email you. Regarding: Ramseur WTP The Laboratory contacted me wondering at what concentration to run the Acute test? The permit has, for the chronic 7 day pass/fail test, a limit concentration of 6%. So, would the Acute test also be run at 6%? Or is there a different calculation you use for figuring acute test concentrations? Thanks. Susie Susan Meadows, Environmental Biologist Aquatic Toxicology Unit DWQ/Environmental Sciences Section 4401 Reedy Creek Road Raleigh, NC 27607 susan.meadows@ncdenr.gov t: (919) 743-8439 f: (919) 743-8517 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Sledge, Bob Sent Wednesday, January 11, 2012 1:57 PM To: Meadows, Susan Subject: FW: NC0074454 Town of Ramseur Hi Susie, I enjoyed talking with you today. Thanks for the information. Look! It seems I actually sent this one over, but of course it's the one with the wrong address, so I've opened myself up for more ridicule. Talk/type to you later. Bob From: Sledge, Bob Sent: Wednesday, December 14, 2011 7:24 AM To: Meadows, Susan Subject NC0074454 Town of Ramseur Hi Susie, Here's a copy of a final permit that should be going out this week. We're having trouble scanning over here, so the attached does not depict the actual signed copy, but does represent the final version of the permit. Bob S. Bob Sledge Environmental Specialist Compliance & Expedited Permits Unit NC Division of Water Quality bob.sledgeencdenr. gov (919) 807-6398 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. Sledge, Bob From: Meads, Steve ISteve.Meads@unitedwater.com] Sent: Thursday, January 12, 2012 10:59 AM To: Sledge. Bob Cc: Blackwell, Nadine Subject: RE: Toxicity Testing Bob, We have discussed this and we believe the acute fathead minnow test would be best. Please let us know if that is the way you wish for us to proceed for the January sample. Also thank you for taking time to get us where we need to be. Steve From: Sledge, Bob Imailto:bob.sledoekancdenr.gevl Sent: Wednesday, January 11, 2012 1:51 PM To: Meads, Steve Subject Toxidty Testing Hi Mr. Meads, I spoke with the folks at our Aquatic Toxicology Unit about the situation you're facing. They agreed that the more appropriate test under the circumstances would be a 24 hour acute toxicity test using the fathead minnow as the test organism. It may not mean much, but I've attached a generic version of the toxicity condition we would place in the permit for your review and for you to share with your advisors in this matter. If you believe the change needs to be made, please let me know and I'll figure out a strategy for getting the permit modified/corrected. Thank you, Bob Bob Sledge Environmental Specialist Compliance & Expedited Permits Unit NC Division of Water Quality bob.sledge@nedenr.eov (919) 807-6398 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. t Sledge, Bob From: Meads, Steve [Steve.Meads@unitedwater.com] Sent: Tuesday, January 31, 2012 1:27 PM To: Sledge, Bob Cc: Blackwell, Nadine Subject: New NPDES permit Bob: Thanks so much for your help with our new NPDES permit. To summarize our conversation, the issuance of our new NDPES permit was delayed due to a delay in the public notice process. We received verbal notice of the final permit approval the first week in January and began to implement the new parameters immediately. During the first month's implementation, the footnote indicating the quarterly metals "should be performed in conjunction with toxicity testing", was missed. We conducted the metals testing and the toxicity testing but not on the same day. It was my understanding that you did not feel it was necessary for us to redo these tests for this quarter, (consideration given to the shortened notice of a final draft of our permit); and we have made a note that these test should be done simultaneously from here on. It was also determined the Toxicity Lab agreed we could use the acute toxicity test in place of the chronic toxicity test if we determined our discharge schedule would not allow for the chronic test and that choice would be finalized and the permit modified by April, (the date which the permit indicates our next toxicity test is required). You indicated you will determine the percent dilution factor for the acute toxicity test as it may differ from the current percentage of 6% for the chronic and let us know before the next quarterly test schedule. Bob, if I have misstated anything please let me know so I can correct my records. Again, thank you for your helpfulness. Steve Meads Ramseur WTP NC0074454 1