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HomeMy WebLinkAboutNC0024244_Permit (Issuance)_19921104NPDES DOCUHENT =CANNINI; COVER MEET NC0024244 Albemarle / Long Creek WWTP NPDES Permit: 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: November 4, 1992 Thins document is printed on reuse paper - iippaore any content on the rreszerse aide Adjudications 1 Albemarle, City of Permit No. j'NC0024244 WQRS: Rex Gleason Issued:12/20/91 County: Stanly 'Reviewer:Dale Overcash Mooresville Regional Office Petition Date: 1/21/92 Attorney: Billy Godwin :Case No. 92 EHR0069 Memo to AG: Region Req 1/24/92 Env Sci Req:;; 1/24/92 :>A::; Resolved: Recv: 2/14/92;;:;,;:;. Recv.i 2/3/92,,,.Revised Permit:`:.: .;:<}T;T::{:;}}:}::;.;} ech Sup Rego! 1/24/92`€€>' GH2O Req:<............./00/ Items Adjudicated: ;>}?>»aa> »> > }s }s: Recv. 2/22/92;.}}.}} Recv..; 00/00/00 Suspended Solids removal limits of 62 %. Downstream sampling point at SR1960. Chronic toxicity limits. ..................... ...................... ..................... ...................... ..................... 3/2/92 11/4/92 :y:' T�$'• vi2{'tS.:�}:$%::#<�;,;•. 'i n 4k•T;{.rt.•ne$'t: �:#..; ' t•:y{i#i}#•c Ti• i4;T::}'T. y Y%>{ ..:..:T, tiRq'a}{':$.. T:: ::.•y .;�;�::•'}}£;;•}:: gy•4t?E•: . ti} ;.J.:• •' y} 7.0.:•S ::llllj .::r.rT:Ta:4i.n+::$.•{ AtT. i. ::;<'.,v:::a::;:}:}T}S#}:n;:TTf:v#..:r{{;;.::Xii:{: 11 ';>3: --yy.. 'L, ,ti..12.ja t :: ...:. t•.vv;`{y.;.;:ir.fS.' .Ct:•.. h.y '{}:::ia +per .. State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor A. Preston Howard, Jr., P.E. William W. Cobey, Jr., Secretary Acting Director November 4, 1992 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Don P. Duncan City of Albemarle P.O. Box 190 Albemarle, NC 28002 Subject: NPDES Permit No. NC0024244 Albemarle Wastewater Treatment Facility Stanly County Dear Mr. Duncan: In accordance with your Petition for Contested Case Hearing filed on January 21, 1992, and subsequent Notice of Withdrawal dated March 2, 1992, we are forwarding herewith the subject permit. The permit has been modified as follows: • Modification of the whole effluent toxicity testing requirement to 90% • Relaxation of the instream monitoring at the end of NCSR 1960 to only monthly monitoring during the months of June, July, August and September. All other terms and conditions contained in the original permit remain unchanged and in full effect. These modifications are 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 December 6, 1983. It is our understanding that this modification will resolve all items contained in the Petition for Contested Case Hearing. If this is not the case, the City of Albemarle should notify us immediately, but no later than ten (10) days following receipt of this letter. Unless such demand is made, this decision shall be final and binding. • 44. Pollution Prevention Pays ,„X P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-715 4!' An Equal Opportunity Affirmative Action Employer ," Mr. Duncan Page Two If you have any questions concerning this permit, please contact Randy L. Kepler at telephone number 919/733-5083. Sincerer A. Preston oward, J cc: Permits and Engineering Unit Office of the Attorney General Permit No. NC0024244 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, City of Albemarle is hereby authorized to discharge wastewater from a facility located at Long Creek WW'TP NCSR 1900 Southwest of Albemarle Stanly County to receiving waters designated as Long Creek in the Yadkin -Pee Dee River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof. This permit shall become effective November 4, 1992 This permit and the authorization to discharge shall expire at midnight on May 31, 1994 Signed this day November 4, 1992 A. Preston Howard, Jr. iing'Director Division of Environmental Management By Authority of the Environmental Management Commission Permit No. NC0024244 SUPPLEMENT TO PERMIT COVER SHEET City of Albemarle is hereby authorized to: 1. Continue to operate and maintain the existing wastewater treatment facilities consisting of mechanical bar screens, dual gravity grit chambers, influent lift station, parshall flume with instrumental flow measurement, preaeration basins, primary clarifiers, trickling filters, mechanical aeration basins, secondary clarifiers, gravity tertiary filters, chlorine contact basin, instrumental effluent flow measurement, twelve in -plant screw lift pumps, aerobic digestors, dissolved aeration floatation units and sludge holding tanks located at Long Creek WWTP, NCSR 1900, Southwest of Albemarle, Stanly County (See Part IlT of this Permit), and 2. Discharge from said treatment works at the location specified on the attached map into Long Creek which is classified Class C waters in the Yadkin -Pee Dee River Basin. A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below: Effluent Characteristic. Discharge Llmltationi Monitoring Requirements Measurement Sample *Samale Monthly Avg Weekly Avg. Daily Max Frequency Iype Location Flow 16.0 MCA Continuous Recording I or E BOD, 5 day, 20°C** 10.0 mg/I 15.0 mg/I Daily Composite E, Total Suspended Residue** 30.0 mg/I 45.0 mg/I Daily Composite E, I NH3 as N 2.0 mg/I 3.0 mg/1 Daily Composite E Dissolved Oxygen Daily Grab E, U, D Fecal Coliform (geometric mean) 200.0 /100 ml 400.0 /100 ml Daily Grab E, U, D Total Residual Chlorine Daily Grab E Temperature Daily Grab E,U,D Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite E Total Phosphorus Monthly Composite E Chronic Toxicity** Quarterly Composite E *Sample locations: E - Effluent, I - Influent, U - Upstream above discharge point, D - Downstream (1) at the end of NCSR 1960 and (2) - 3.9 miles below discharge at NCSR 1967. Upstream and downstream samples shall be grab samples. Stream samples shall be collected once per month in the winter (October through May) and once per week during the summer (June through September) at the upstream site and at the downstream site 3.9 miles below discharge at NCSR 1967. Once -per -month monitoring shall be conducted during the summer (June through September) at the downstream site at the end of NCSR 1960. **See Part III, Condition F; Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, and December. ***See Part III, Condition G. ****The monthly average effluent BOD5 concentrations shall not exceed 15% of the respective influent values (85% removal). The monthly average effluent Total Suspended Residue concentrations shall not exceed 38% of the respective influent values (62% removal). *****The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. (Continued) Effluent Characteristic. Pollutant Analysis**** Conductivity Cadmium Chromium Nickel Lead Copper Zinc Discharge Limitation: L nits (specify Monthly Avg Weekly Avg. Daily Max 2.0 ug/I 52.0 ug/I 53.0 ug/I 26.0 ug/I Monitoring Measurement Frequency Annually Weekly Weekly Weekly Weekly Monthly Monthly Requlrementz Sample Type Grab Composite Composite Composite Composite Composite Composite "Sample Location E U, D E E E E E E A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below: Effluent Characteristic. Discharge Limitation: Monthly Avg Flow 1 6. 0 MGD BOD, 5 Day, 20 °C***" 20.0 m g / I Total Suspended Residue*" 30.0 mg/I NH3 as N 4.0 mg/I Dissolved Oxygen***** Fecal Coliform (geometric mean) 200.0 /100 ml Total Residual Chlorine Temperature Total Nitrogen (NO2 + NO3 + TKN) Total Phosphorus Chronic Toxicity** Weekly Avq. Daily Max 30.0 mg/I 45.0 mg/I 6.0 mg/I 400.0 /100 ml Monitoring Measurement Frequency Continuous Daily Daily Daily Daily Daily Daily Daily Monthly Monthly Quarterly Requirements SamDIQ Tyoe Recording Composite Composite Composite Grab Grab Grab Grab Composite Composite Composite *Sample Location I or E E, I E, I E E, U, D E, U, D E E,U,D E E E *Sample locations: E - Effluent, I - Influent, U Upstream above discharge point, D - Downstream (1) at the end of NCSR 1960 and (2) - 3.9 miles below discharge at NCSR 1967. Upstream and downstream samples shall be grab samples. Stream samples shall be collected once per month in the winter (October through May) and once per week during the summer (June through September) at the upstream site and at the downstream site 3.9 miles below discharge at NCSR 1967. Once -per -month monitoring shall be conducted during the summer (June through September) at the downstream site at the end of NCSR 1960. **See Part III, Condition F; Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, and December. ***See Part III, Condition G. ****The monthly average effluent BOD5 concentrations shall not exceed 15% of the respective influent values (85% removal). The monthly average effluent Total Suspended Residue concentrations shall not exceed 38% of the respective influent values (62% removal). *****The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/I. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. (Continued) Effluent Characteristic. Pollutant Analysis*** Conductivity Cadmium Chromium Nickel Lead Copper Zinc Discharge Limitation: Units (specify Monthly__gyg Weekly Avg,. Daily Max 2.0 ug/I 52.0 ug/I 53.0 ug/1 26.0 ug/I Monitoring Measurement Frequency Annually * Weekly Weekly Weekly Weekly Monthly Monthly Requirements Sample Type Grab Composite Composite Composite Composite Composite Composite *Sample Location E U, D E E E E E E Part III Permit No. NC0024244 F. a - IRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY) The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in: 1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay Procedure - Revised *September 1989) or subsequent versions. The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is 90% (defined as treatment two in the North Carolina procedure document). The permit holder shall perform quarterly monitoring using this procedure to establish compliance with the permit condition. The first test will be performed after thirty days from the effective date of this permit during the months of March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. 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 TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Environmental Sciences Branch North Carolina Division of Environmental Management 4401 Reedy Creek Road Raleigh, N.C. 27607 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 any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute noncompliance with monitoring requirements. G. POLLUTANT ANALYSIS MONITORING CONDITION The permittee shall conduct a test for pollutants annually at the effluent from the treatment plant. The discharge shall be evaluated as follows: 1) A pollutant analysis of the effluent must be completed annually using EPA approved methods for the following analytic fractions: (a) purgeables (i.e., volatile organic compounds); (b) acid extractables; (c) base/neutral extractables; (d) organochlorine pesticides and PCB's (e) herbicides; and (f) metals and other inorganics. The Annual Pollutant Analysis Monitoring (APAM) Requirement Reporting Form A and accompanying memo, to be provided to all discharges affected by this monitoring requirement, describes the sampling and analysis requirements and lists chemicals to be included in the pollutant analysis. This monitoring requirement is to be referred to as the "Annual Pollutant Analysis Monitoring Requirement" (APAM). 2) Other significant levels of synthetic organic chemicals must be identified and approximately quantified. For the purpose of implementing this requirement, the largest 10 GC/MS peaks in the purgeable, base/neutral extractable, and acid extractable fractions (or fewer than 10, if less than 10 unidentified peaks occur) for chemicals other than those specified on the APA Requirement Reporting Form A should be identified and approximately quantified as stated in the APAM Reporting Form A instructions. This part (item 2) of the APAM requirement is to be referred to as the "10 significant peaks rule". /2z 0X07k-, d6c,4 1.0,4 ,Q_c --7as 74(6e44/tat/We (.5 . "-st J eauA vi— A0,t1 14/42-t% Gelz,t;./ 14,4 it).c lb ISSve' 4,/ i2e/1,4i-qc Jt s-o Z9,,g J emu-- 7 wide-, f 4 J I( I a/ccr7C5 Aha,v., Ig1/7„---t-,_ Adjudications 1 Permit No. iiNC0024244 Issued: -• 12/20/91 :Reviewer: Dale Overcash WQRS: Rex Gleason Mooresville Regional Office Attorney: Billy Godwin Region Reg: 1/24/92 Recv: 2/14/92 Petition Date: 1/21/92 Memo to AG:j 3/2/ Recv 2/3/92 Revised Permit::= Tech Su R 1/24/92 GH2O R O0700/00 Recv: 2/22/92; Recv Items Adjudicated00/00/00... . . rrrrrrrrr:<;r:,�r::rr.;att::a:•;::::•rrrr:r:a.>r;r:<.:rrr>rrrrrr: > ....•.....................:... : ...... Suspended Solids removal limits of 62 %. Downstream sampling point at SR1960. Chronic toxicity limits. Case No. 92 EHR0069 Env s 1/24/92 Resolve >w• i�: ir:: '` :.: arrrr• r��{•r {.• :... :^:•.' : • . rr rr.... r %i�`'% . nYh . . •�{•iry {•rr:•:;:{f •: r i5�..• :G � �;: ti,�.•rf�,� r [,,,,' "Y . , .»rm:•:rr rr �:\rom:{•:ti r , '•'�l'�o'.hd:,�;?fe'���. yt ' : : f{: i . 11)) it ki � :{wrr,,k +4jr rY. i { }. �'.2t�be: •8. �a::i{7e�v 'aaee6aac�: ....; . • `}Yv`J >T°'o-?..{x 1 d....:-•. ;. ¢ <tS t{�r. x:$. �th;t� .. nj (2 ((tz, c-‘e/ Cigeti) STATE OF NORTH CAROLINA COUNNTY OF STANLY CITY OF ALBEMARLE Petitioner, v. IN THE OFFICE OF TM ADMINISTRATIVE HEARINGS FILE NO. 92 EHR 0069 ) a Veil. ) ) NOTICE OF WITHDRAWAL ) OF PETITION DEPARTMENT OF ENVIRONMENT, ) D� �i�l HEALTH, AND NATURAL RESOURCES ) i DIVISION OF ENVIRONMENTAL MANAGEM) NT E Respondent. ) MAR 6199:icEGMAn: 14111 Div. cr �r c4TON�6E a!r�Fcra�s Petitioner hereby withdraws its petition for a contested case hearing. No further proceedings are needed or required to resolve the contested case captioned above. This the 2nd day of March ,1992 Petitioner/Authority for Petitioner CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the attached NOTICE OF WITHDRAWAL on by having same placed in the United States Mail bearing sufficient postage for delivery by first class mail and addressed as follows: Attorney General's Office Environmental Protection Section PO Box 629 Raleigh, NC 27602-0629 March 2 , 1992 (Date) Petitioner/Attorney for Petitioner State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor William W. Cobey, Jr., Secretary Mr. Don P. Duncan, Superintendent Water/Waste Treatment Plants City of Albemarle PO Box 190 Albemarle, NC 28002-0190 Dear Mr. Duncan: George T. Everett, Ph. D. Director February 27, 1992 Subject: NPDES Permit No. NC0024244 City of Albemarle WWTP Stanly County The Division of Environmental Management (DEM) has reviewed your letter of January 16, 1992, and subsequent adjudication dated January 21, 1992. The three items of concentration in the letter and adjudication are addressed in this letter in the same sequence as listed in you letter. The DEM has evaluated the additional influent and effluent data submitted in your letter and has determined that no additional changes can be made to the percent removal in the permit issued December 20, 1991. Three conditions must be met to receive a lower percent removal limit. These conditions are: (1) the facility must be meeting its effluent limits; (2) to meet the percent removal requirements, the treatment works would have to achieve significantly more stringent limitations than would otherwise be required by the concentrations -based standards; and (3) the less concentrated influent wastewater is not the result of excessive I/1 (inflow/infiltration). For the percent removals of 62 percent and greater, it appears that these three conditions may have been met. For percent removals less than 62 percent, it is obvious that there was excessive I/1. After reviewing all circumstances associated with the instream monitoring, the DEM agrees to relax the instream monitoring at the end of NCSR 1960 to only monthly monitoring during the months of June, July , August and September. Information submitted to this office by Mooresville Regional Office staff indicate that the stream can be accessed by following the power line right-of-way. Due to the need for this data, it is felt that someone can be properly equipped to obtain this data on a once -per -month basis. Pollution Prevention Pays P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer 1 Mr. Duncan Page Two The DEM has been working with Albemarle since 1989 to resolve the toxicity problems at the wastewater treatment plant. As stated in the letter of December 20, 1991, the DEM intended to give Albemarle one year of monitoring only, but it took two years to resolve the percent removal, the instream, and toxicity issues. Consequently, the limit must be included in the permit and it must become effective immediately. The division can reduce the limit from 94% to 90% and change the limit to a Phase II requirement based on new DEM protocol. The DEM has included a copy of a DRAFT NPDES Permit with the changes highlighted in this letter. If you concur with these changes, please notify the DEM and staff will issue the permit. Additionally, please complete the attached Notice of Withdrawal of Petition and forward the original to the Office of Administrative Hearings and a copy to our office. If you do not concur, please notify the DEM and the staff will proceed with the adjudication process. A response must be submitted to the division by March 31, 1992. If you have any questions, please contact Mr. Dale Overcash or me at (919) 733-5083. cc: Ms. Brenda Smith Ar:Da1e -Overcash Sincerely, teve W. Tedder, Chief Water Quality Section D AT- /ll Pl Arrn)/ -.Tire c 1 9/ 02 A. iiAaa 44d „ °An azi 94 NHS c / (ior sT Cam,,, l�clLi ORD-�LS I3 92 s Re5o„ ,-/4J P s 1#4,-9g ___7:23 taiyyt R07, sg,---/ v___ -1 ,sc���„/),, Or Ie 1� R c id (4, 3 AIR 9Q g /1,091 Ree-id /Voice or Ai-ick.t.i...e STATE OF NORTH CAROLINA COUNTY OF STANLY CITY OF ALBEMARLE Petitioner, v. DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES ) DIVISION OF ENVIRONMENTAL MANAGEMENT Respondent. ) IN THE OFFICE OF ADMINISTRATIVE HEARINGS FILE NO. 92 EHR 0069 NOTICE OF WITHDRAWAL OF PETITION Petitioner hereby withdraws its petition for a contested case hearing. No further proceedings are needed or required to resolve the contested case captioned above. This the 2nd day of March , 19 9 i Petitioner/Authority for Petitioner CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the attached NOTICE OF WITHDRAWAL on by having same placed in the United States Mail bearing sufficient postage for delivery by first class mail and addressed as follows: Attorney General's Office Environmental Protection Section PO Box 629 Raleigh, NC 27602-0629 March 2, 1992 (Date) Petitioner/Attorney for Petition ECEIVED MAR 41992 N. C. ATTORNEY GENERAL Environment3I Protection Section DIVISION OF ENVIRONMENTAL MANAGEMENT Memorandum To: Don Safrit From: Carla Sanderson Through: Ruth Swanek CL Subject: Albemarle, City NPDES Permit No. Stanly County Adjudication of February 11, 1992 of NC0024244 downstream sampling point at SR 1960 Tel,/ : o/n4c, bIIY Gobw„„J,I In response to Mr. Duncan's adjudication of the NPDES Permit for the City of Albemarle's first downstream monitoring location, I offer the following: In July, 1990 DEM collected instream data to verify the need for year-round instream monitoring at the requested first downstream location at SR 1960. Since this location proved critical, DEM requested regional staff to accompany Mr. Duncan to the site to verify its accessibility. On December 4th, 1991, I received a telephone call from Tony Parker (Mooresville Regional Office) who verified the site accessible. He said that he visited the site with Mr. Duncan and through discussions with him it was noted that the site could be accessed. Tony Parker then followed up with a compliance evaluation inspection in which he explains the site visit with Mr. Duncan (see attached). Per 15A NCAC 2B.0505, sampling points may be established instream for at least one upstream location and not more than three downstream locations to measure impacts of the discharge to the receiving stream. Technical Support has used the option of requiring more than one downstream location when the permitted wasteflow is greater than 1 MGD and a modeling analysis shows continued affects on the stream for several miles below the outfall location. Since the City of Albemarle is permitted at 16 MGD (current actual discharge is averaging -8 MGD) and the instream dissolved oxygen values reflect levels below the standard, at the first downstream location, it is necessary for both downstream locations to remain a requirement of the City of Albemarle's permit. Attachment cc: Tony Parker • f4-r-tFri State of North Carolina Department of Environment, Health, and Natural Resources Mooresville Regional Office James G. Martin, Governor Albert F. Hilton, Regional Manager William W. Cobey, Jr., Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT December 9, 1991 Mr. Don Duncan City of Albemarle Post Office Box 190 Albemarle, North Carolina 28002 Subject: Compliance Evaluation Inspection City of Albemarle NPDES Permit No. NC 0024244 Stanly County, NC Dear Mr. Duncan: Please find enclosed a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on December 3, 1991, by Mr. Tony R. Parker of this Office. The Report should be self-explanatory. If you have any questions concerning this Report, please do not hesitate to contact Mr. Parker or me. Enclosufe cc: TRP:se Sincerely, D. Rex Gleason, P. E. ^� Water Quality Regional Supervisor Roger 0. Pfaff, EPA tanly County Health Department s. Carla Sanderson, DEM/Raleigh 919 North Main Street, Mooresville, N.C. 28115 • Telephone 704-663-1699 • FAX 704-663-6040 An Equal Opportunity Affirmative Action Employer United States Environmental Protection Agency Washington, D.C. 20460 NPDES Compliance Inspection Report Section A: National Data System Coding Transaction U Inspection Type C 18 361 I Reserved 671 1 1 169 1 Code NPDES 2 u 3 1N1C)01012141214141 11 Inspector Fac. Type ISI 19u 20 u 21 11 1 Remarks yr/mo/day 121911111210131 17 Remarks 1 I I I I 1 I I 1 1 1 1 I 1 1 1 1 1 1 I 1 I I 1 I I 1 1 1 1 I 1 Facility Eval. Rating u 70 BI N 71 QA N 72 Reserved 135 166 731-1--174 751 1 I 1 1180 I Section B: Facility Data Name and Location of Facility Inspected City of Albemarle NCSR 1900 Stanly County, North Carolina Entry Time 0930 NAM UPM Exit-Time/Date 1135 911203 Name(s) of On -Site Representative(s) Mr. Don Duncan Title(s) ORC/Superintendent of Public Works Phone No.(s) 704/982-0131 Name, Address of Responsible Official Mr. Don Duncan Post Office Box 190 Albemarle, North Carolina 28002 Title Phone No. FlContacted Yes Noil Permit Effective Date 840501 Permit Expiration Date 890430* Section C: Areas Evaluated During Inspection (S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Evaluated) N S S S Permit* Records/Reports Facility Site Review Operations & Maintenance S S S N Flow Measurement Laboratory Ef f /Rec . Waters Sludge Disposal N S Pretreatment Compliance Schedules Self -Monitoring Program Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) *PERMIT New Permit (issued January 8, 1990) is currently being contested. Compliance status, is therefore, based on old Permit. RECORDS/REPORTS Records, reports and calibration logs are maintained in accordance with Permit requirements. FACILITY SITE REVIEW 1. All major mechanical equipment appeared to be operational and functioning properly. 2. One of the primary clarifiers had developed a leak in the retaining wall. Repairs have been scheduled. OPERATIONS AND MAINTENANCE The facility appeared to be adequately operated and maintained. There appears to be adequate staffing and personnel to perform the necessary tasks associated with running the facility. FLOW MEASUREMENT Flow is measured in accordance with Permit requirements. LABORATORY The on -site lab appeared to be well equipped for the required analyses. Good record keeping was noted. Name(s) and Signature(s) of Inspector(s) 1Tony R. Parker Agency/Office/Telephone DEM/MRO/(704) 663-1699 Date 911204 I 1 Signa re of Reviewer Agency/Office Date Regulatory Office Use Only Action Taken Date Compliance Status f:=1 Noncompliance Compliance Name: City of Albemarle Permit Number: NC0024244 Summary of Findings/Comments (Continued) EFFLUENT/RECEIVING WATERS The effluent was light pink in color with a moderate amount of foam noted. The source of the foam should be determined and corrected. SLUDGE DISPOSAL Sludge is currently land applied. Land Application Permit No. WQ0002616 was issued (renewed) on February 28, 1990 and expires January 31, 1995. SELF -MONITORING PROGRAM 1. Self -monitoring data was reviewed for the period 11/90 through 9/91. 2. Toxicity failures were reported in April, June and August, 1991. 3. Elevated copper and zinc levels were reported for the entire review period. Stream action levels may have been compromised during this period. PROPOSED DOWNSTREAM MONITORING LOCATION The City of Albemarle has contested one of the downstream monitoring locations (at the end of S. R. 1960). During this inspection the inspector and Mr. Duncan visited the proposed site. A previous site visit was made by DEM staff (Joe Crabb and Keith Haynes) in 1990 and they had noted that the site appeared to be accessible. Mr. Duncan had previously noted that the site had no trespass signs at the entrance. During this visit trespass signs were noted; however, the signs were on adjacent property. Access was by driving to the end of S. R. 1960 and then down a dirt drive to a pig enclosure. There were no trespass signs around the enclosure (one strand of electric fence). From this point access to the creek is by walking along a low voltage power line for approximately 200-300 yards. Mr. Duncan previously stated that rattle snakes frequent the area in summer months. This is probably true, however, a person equipped with snake chaps, boots and a radio should have no problem. The area could also be cleaned ' by mowing. Mr. Duncan stated that Union Electric maintains the power lines. This inspector advised Mr. Duncan that it appeared that the site was accessible and that his concerns were valid; however, with some caution and site preparation there should be no problem collecting samples at this location provided permission is granted by Union Electric and/or other land owners. DIVISION OF ENVIRONMENTAL MANAGEMENT February 11, 1992 MEMO TO: Don Safrit FROM: Rex Gleason PREPARED BY: Michael Parke0/19 SUBJECT: City of Albemarle NPDES Permit No. NC0024244 Stanly County vet fltrd ;to This Office has conducted a review of the petition filed with the Office of Administrative Hearings concerning the subject Draft Permit and offers the following comments. 1. Suspended Solids removal efficiency of 62%. Data supplied by the City indicates that with a few exceptions, compliance with the proposed removal efficiency has been achieved. Low influent SS concentrations do not appear to be the result of Infiltration/Inflow, but rather industrial wastewater from various textile dyeing operations. The Director, however, may substitute a lower removal efficiency or a mass loading limit provided the City can meet the requirements of 40 CFR 133.103(d). 2. Downstream Sampling Point at SR 1960. At the request of Technical Support, site visit by MRO personnel revealed that access is attainable at the proposed downstream sampling location at the end of SR 1960. Due to the importance of the data in determining downstream WQ impacts, it is recommended that the downstream monitoring location remain in the Permit. 3. Chronic Toxicity. Comments concerning this matter should be obtained from the Aquatic Toxicology Group. If you have any questions, please advise. MLP err' DIVISION OF ENVIRONMENTAL MANAGEMENT January 29, 1992 MEMORANDUM TO: Don Safrit THROUGH: Ken Eagleson FROM: Larry Ausley SUBJECT: Comments on City of Albemarle WWTP petition NC0024244 Stanly County I have reviewed the referenced petition and have the following comments on the City's objections to permit chronic toxicity limitations. • • 1) In the petition, the city objects to the use of the chronic toxicity test on the' contention that one absolute value for reproduction of the test organisms exposed to the effluent which results in "Fail" is greater than other absolute values of reproduction of exposures which result in "Pass". The City makes the comparison of an absolute value that is "sufficient enough for control water" which I am assuming to be our quality assurance standard of 15. This argument does not take into account the basic scientific assumption which is the basis for the analysis. That basis is that each and every test is performed as a controlled experiment with effects of the effluent on test organisms compared directly to effects on control organisms, all of which represent one homogenous and otherwise random population. Since it is expected that any biological population will have normal cycles of reproduction, growth, feeding, etc., it would not be valid to make absolute comparisons to any given standard. This is why the statistical analysis comparing control vs. treatment is made for each individual test. This analysis determines, to a given level of statistical certainty (99% in this case) whether reproduction is suppressed by exposure to the effluent. The minimum absolute value of 15 young per female that is placed on control populations is simply a limit made to insure that the analysis is performed and completed in a manner that provides at least a minimally acceptable environment. Of the tests reported by the facility (see attached)which failed since 7/89 (total of 15 failures) only five had effluent treatment reproduction greater than 15 (33% of the tests rather than 50% as claimed by the facility). These results indicated percent reduction of effluent treatment reproduction vs. concurrent control populations ranging from 17% to 33%. Failures where effluent treatment reproduction was less than 15 showed percent reductions from 34% to 96% of concurrent controls. North Carolina Water Quality Standards, 15 NCAC 2B.0202, define chronic toxicity as any harmful effect to populations and do not specify any acceptable percentage of harmful effect. In summary therefore, the test methodology proposed presents us with a defined statistical certainty whether an effect has occurred and the objection raised has no merit in science or regulation. 2) The City additionally references a March 15, 1989 letter which objects to this same test on the basis that "there is no economically feasible way to consistently meet this limit with both the large percentage of industrial waste in the WWTP effluent and low 7Q10 in Long Creek". Twelve monthly chronic toxicity tests were reported by the facility in 1991. Eight of these analyses passed, four failed. No two consecutive failures were reported for the year. Thus, for 1991, the facility was in compliance with chronic toxicity limitations. This type of compliance history cannot support this objection. 3) The March 15, 1989 letter requests that fathead minnows be utilized in lieu of Ceriodaphnia dubia as the required test species. The N.C. Water Quality Program has to date not written any permits which require the EPA seven day fathead minnow survival and growth chronic test, nor are programs in place that can adequately perform compliance testing using this analysis. The following request by the city also indicates that acute rather than chronic limitations are being requested by the city. 4) The City states that it would accept acute toxicity testing as an alternative to chronic testing using the assumption that "results from acute testing are more reproducible and reliable than chronic results". Simply stated, acute toxicity testing cannot provide results sensitive enough to protect the receiving stream from chronic impact, as required by regulation. The Albemarle WWTP discharge, as currently sized and located must receive chronic toxicity limitations by current permitting policy established from 15 NCAC 2B.0200 regulations. If I can provide you with further information, please advise. cc:Rex Gleason Central Files • Albemarle Test Results Jul-89 CONTROL TREATMEN 1 16 L 2 7 L 3 25 L 4 29 L 5 25 L 6 24 L 7 20 L 8 23 L 9 21 L 10 14 11 10 L 12 23 L AVG REP %MORT P/F 19.75 I 8.3 T Aug-89 CONTROL TREATMEN 1 2 3 4 5 6 7 8 9 10 11 12 13 1 0 1 15 7 15 5 14 5 18 16 13 14 17 17 L L L L L L L L L L L L 1 24 2 14 3 25 4 28 5 20 6 26 7 27 8 18 9 15 10 27 11 24 12 27 L L L L L L L L L L L FI AVG REP %MORT P/F FI 22.9 I 0 T Sep-89 CONTROL 1 15 2 19 3 17 4 15 5 18 6 16 7 23 8 17 9 19 10 18 11 23 12 19 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 '10 11 12 18.3 I 0 1 AVG REP %MORT PIF 37 38 L L 32 L 36 L 31 L 38 L 41 L 38 L 44 L 31 L 35 L 36 L 36.4 I 0 FI TREATMENT Oct-89 CONTROL 1 2 3 4 5 6 7 8 9 10 11 12 27.8 I 0 30 30 24 21 30 34 31 33 25 30 21 25 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 1 AVG REP %MORT P/F 37 L 36 L 29 L 32 L 32 L 27 L 39 L 34 L 38 L 32 L 31 L 33 L 33.3 I 0 TREATMENT Nov-89 CONTROL TREATMEN 1 8 2 12 3 11 4 11 5 9 6 12 7 18 8 8 9 13 10 12 11 18 12 11 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 11.9 1 o 1 F1 AVG REP %MORT P/F 22 25 23 22 28 20 24 25 24 23 22 26 23.7 I 0 L L L L L L L L L L L T Dec-89 CONTROL TREATMEN 1 2 3 4 5 6 7 8 9 10 11 12 19.7 I 0 21 26 21 20 19 18 22 17 21 19 14 18 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 1 F1 AVG REP %MORT P/F 25 25 26 30 27 31 26 26 22 29 23 24 26.2 I 0 L L L L L L L L L L L L T Jan-90 CONTROL TREATMEN Feb-90 CONTROL TREATMEN CONTROL TREATMEN 1 7 2 5 3 6 4 8 5 7 6 6 7 1 8 10 9 6 10 3 11 10 12 9 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 6.5 I 0 1 FI AVG REP %MORT P/F 10 21 11 21 22 12 26 18 18 18 16 27 L L L L L L L L 2 3 4 5 6 7 8 9 10 11 12 7.58 1 0 8 8 9 5 3 10 8 7 5 10 11 7 L L L L L L L L L 26 2 14 3 15 4 11 5 14 6 24 7 19 8 14 9 15 10 20 11 14 12 6 AVG REP %MORT P/F L L L L L L L L L L 2 3 4 5 6 7 8 9 10 11 12 11 10 13 8 13 10 9 12 18 9 9 L L L L L L 2 3 4 5 6 7 8 9 10 11 12 AVG REP %MORT PIF 11 15 21 21 11 15 12 24 21 21 15 L L L L L L L L 2 3 4 5 6 7 8 9 10 11 12 5 9 10 6 6 15 9 5 13 4 11 8 L L L L L L L Albemarle Test Results Apr-90 CONTROL TREATMEN Jun-90 CONTROL TREATMEN JuI-90 CONTROL TREATMEN Aug-90 CONTROL TREATMEN Sep-90 CONTROL TREATMEN Oct-90 CONTROL 1 21 2 22 3 25 4 25 5 24 6 27 7 25 8 27 9 27 10 22 11 25 12 24 AVG REP %MORT P/F 24.5 I 0 L L L L L L L L L L L L 1 11 2 18 3 5 4 13 5 13 6 12 7 15 8 5 9 5 10 8 11 9 12 16 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 10.83 I 0 FI AVG REP %MORT P/F 18 11 25 23 12 16 12 27 12 11 14 14 16.25 I 0 L L L L L L L L L L L L 2 3 4 5 6 7 8 9 10 11 12 20 1 0 11 23 19 18 19 29 22 18 24 21 18 18 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 PI AVG REP %MORT P/F 34 27 29 37 29 36 39 20 32 29 38 32 31.83 l 0 L L L L L L L L L L L L 1 23 2 15 3 24 4 24 5 27 6 29 7 28 8 30 9 28 10 24 11 31 12 27 L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 FI 25.83 ( 25 AVG REP %MORT P/F 12 14 19 26 20 23 29 23 18 15 19 21 19.92 I 0 L L L L L L L L L L L L P 1 14 2 15 3 19 4 23 5 18 6 15 7 14 8 15 9 14 10 18 11 18 12 16 L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 16.58 I 8.33 AVG REP %MORT P/F 25 17 30 14 22 19 21 25 14 17 22 27 21.08 1 0 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 15.83 I 16.67 1 26 17 21 22 17 24 12 0 20 18 0 13 L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 AVG REP %MORT P/F 20 22 14 28 15 17 32 19 18 22 22 17 L L L L L L L L L L L L TREATMENT Jan-91 CONTROL TREATMEN Feb-91 CONTROL TREATMEN CONTROL TREATMEN 1 2 3 4 5 6 7 8 9 10 11 12 10 5 6 8 7 8 10 9 8 12 10 7 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 AVG REP %MORT P/F 11 13 16 39 34 24 25 15 39 18 23 30 L L L L L L L L L 2 3 4 5 6 7 8 9 10 11 12 14 15 19 18 12 19 14 16 29 13 12 24 13 26 21 15 21 19 15 21 19 23 5 AVG REP %MORT P/F 2 3 4 5 6 7 8 9 10 11 12 45 24 38 40 45 40 44 39 39 36 40 8 1 2 3 4 5 6 7 8 10 11 12 AVG REP %MORT P/F 19 19 6 12 19 18 19 24 19 32 16 14 2 3 4 5 6 7 8 9 10 11 12 15 22 17 15 16 19 21 11 24 19 25 25 Albemarle Test Results Apr-91 CONTROL TREATMEN 1 16 2 18 3 19 4 9 5 15 6 16 7 19 8 26 9 17 10 16 11 17 12 16 AVG REP %MORT P/F 17 I 0 L L L L L L L L L L L L T May-91 CONTROL TREATMEN 1 2 3 4 5 6 7 8 9 10 11 12 7.5 I 0 5 0 8 18 0 0 15 0 13 16 10 5 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 1 FI AVG REP %MORT P/F 15 26 21 24 19 15 15 25 6 16 21 16 1825 I 0 L L L L L L L L L L L L T Jun•91 CONTROL TREATMEN 1 2 3 4 5 6 7 8 9 10 11 12 21.17 I 0 24 20 37 25 9 16 26 18 15 17 27 20 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 1 PI AVG REP %MORT P/F 17 L 15 L 15 L 14 L 15 L 15 L 15 L 15 L 16 L 16 L 16 L 17 L 15.5 I 0 FI T JuI-91 CONTROL TREATMEN Aug-91 CONTROL TREATMEN Sep-91 CONTROL TREATMEN 1 0 2 0 3 0 4 0 5 0 6 4 7 0 8 0 9 3 10 0 11 0 12 0 D D D D 0 D D 0 D 0 D 1 2 3 4 5 6 7 8 9 10 11 12 0.58 I 100 I AVG REP %MORT P/F 20 26 9 16 14 5 19 16 17 20 19 23 17 I 15.17 L L L L L L L L L L L L 1 2 3 4 5 6 7 19 L 17 L 12 L 16 L 15 L 15 L 14 L 8 13- L 9 10 11 12 15.17 I 0 1 18 L 9 L 17 L 17 L 1 2 3 4 5 6 7 8 9 10 11 12 PI AVG REP %MORT P/F 24 L 25 L 27 L 27 L 22 L 31 L 24 L 27 L 24 L 21 L 26 L 19 L 1 2 3 4 5 6 7 8 9 10 11 12 13 12 19 14 14 16 11 20 15 20 22 22 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 AVG REP %MORT P/F 18 16 10 15 16 16 14 17 15 24 19 18 L L L L L L L L L L L L T Oct-91 CONTROL TREATMEN Nov-91 CONTROL 1 2 3 4 5 6 7 8 9 10 11 12 17 19 17 19 5 16 16 16 12 14 18 17 L L L L L L L L L L L L 1 2 3 4 5 6 7 8 9 10 11 12 14 18 21 21 6 20 13 23 11 17 17 15 LLLLLLLLLLLL AVG REP %MORT P/F 1 15 2 20 3 23 4 16 5 16 6 7 7 17 8 17 9 20 10 23 11 13 12 22 L L L L L L 16 2 25 3 14 4 23 5 20 6 21 7 8 8 18 9 17 10 20 11 16 12 26 AVG REP %MORT P/F L L L TREATMENT 2 3 4 5 6 7 8 9 10 11 12 14 20 20 23 23 26 23 20 26 21 21 23 L L L L L STATE OF NORTII CAROLINA COUNTY OF(I) Stanly IN THE OFFICE OIL ADMINISTRATIVE HEARINGS (2) City of Albemarle ) Petitioner, ) (Your Name) ) ) PETITION VERSUS ) FOR A ) CONTESTED CASE HEARING (3) Di vis i on of Environmental Respondent. M a n a gem6 n t (The State Agency or Board about which ) you are complaining) ) I hereby ask for a contested case hearing as provided by G.S. 150-B-23 because the (4) Permit Limits has (briefly state facts showing how you believe you have (name of agency) been harmed by the state agency or board) SPP attached (if more space is needed, use additional sheets and attach) (5) (Check all that apply): Because of these facts, the agency has: deprived me of property; ordered me to pay a finc or civil penalty; or has otherwise substantially prejudiced my rights; and based on these facts the agency has exceeded its authority or jurisdiction; acted erroneously; failed to use proper procedure; acted arbitrarily or capriciously; or failed to act as required by law or rulc. VERIFICATION I, the undersigned, first being duly sworn, say that this petition is true to my own knowledge, except as to matters stated on information and belief, and as to those, I believe them to be true. SWORN TO AND SUI3SCRIIBED BEFORE ME (11) 2Z _ap,-) g2 (6) January 21, 1992 Date (12) `/,kk , rr Signature (13) GT dtt 1 ?u ISLAC- Mk of person authorized to administer oaths (7) h C Your Signature (8) City of Albemarle (14)MyCommission Expires: iO-3-e (p (9)P 0 Box 190, Albemarle, NC 28002-0190 Your Address (15) (Scnl) (10) ArcaCoLle004 ) 98'2-01 31 17 . 7S_l) Your l depilorte Number Mail the original to the Office of Administrative Hearings, I'.O. Drawer 27447, Raleigh. N.C. 27611.7447 and mail a copy to the State agency involved. tk - (revised 03-01-90) CERTIFICATE OF SERVICE I certify that this Petition has been served on the State agency named below by depositing a copy of it with the United States Postal Service with sufficient postage or by delivering it to the named agency. Served on: (16) George T. Everett, Director (name) (17) Division of Environmental Management (agency) 512 North Salisbury St., (18) P 0 Box 276.$7 (address) Ra 1 e i gh , NC 976.31 (19) This the 21st day of January (20) City of Albemarle Petitioner , 19 92 by Don Duncan tk - (revised 08-01-90) 11-06 Office of Treatment Plants (704) 9 2.0I it City of A ibemncrrle North Carolina January 16, 1992 George T. Everett, Director Division of Environmental Management Dept. of Environment, Health and Natural Resources P 0 Box 27687 Raleigh, NC 27611-7687 Subject: Modification to NPDES Permit No. NC0024244 City of Albemarle Stanly County Dear Dr. Everett: 11,O1,n-I,!i/le%% .`xun' • l vn The City of Albemarle received the a!love sul , act permit dated December 20, 1991. The permit, has three lini.s_ is which need to be modified or deleted. We would like to co.ne to Raleigh to meet with you and your staff to discuss the following: 1. Suspended solid removal limits of 62%. 2. Downstream sampling point at SR 't 1960 . 3. Chronic toxicity limits. If a meeting cannot be arranged with you and your staff we feel that we must ask for an adjudicatory hearing. I called Dale Overcash and asked that he forward to me t!: proper forms to request the hearing. The City of Albemarle staff has always !•:ors,7:d with the staff of the Division of Environment Management will strive to meet all the new permit requirements, but w'. feel that some of the requirements need to be modified. Enclosed is a copy of correspondence and ov_: responses to the permit limits we hope to discuss with you your staff. 1. Suspended Solids Removal - The 6 2'., .-emova_l requirement is lower than the original proposed 8 Even with a 62 ; removal limitation, the wastewater trr_'.;..ment plant would have violated this condition for five ;::')nths during the time period of January 1988 thru Dccc .:' :r 1991. During the five months (Jan. 1988, March 19. Oct. 1989, Jan. 1990 and Jan. 1991) , the 30 mg/L, ::cl for. suspcndcd Page 2 George T. Everett January 16, 1992 solids discharge was met. The City of 1'..lbemarle requests a lower percent removal limit in the NPI'ES Permit as is allowed by 40 CFR Part 133.103 (d) regumtions . Enclosed you will find data for a three year period (Jan. 1988 thru Dec. 1991). 2. Downstream Sampling Point (SR ##1960) - we received a letter from the Division of Environmental Management that is dated October 11, 1990 from J. Trevor Clements, Asst. Chief Water Quality Section in reference to SR #1960. See the enclosed copy of the letter. In a 2otter addressed to Mr. Arthur Mouberry dated March 15, 1989 (item '.) we asked that the proposed sampling location be deleted from the NPDES Permit. See enclosed copy of the letter to Mr. Mouberry. 3. Chronic Toxicity Requirements - Enclosed is data that was conducted by Pace Labs that indicate the pass/fail for the City of Albemarle WWTP effluent (94 %) for the months of July, August, and September 1991. The date indicates the samples from July and September hacl lower effluent reproduction than the August sample, and these samples were considered compliant. The sample from August was considered a failure even though the reproduction was sufficient enough for control water. Since 1939, nearly 50% of these failures were attributed to the same situation This seems to be a major fallacy in judging compliance. See enclosed copy of letter dated March 15, 1939 addressed to Mr. Arthur Mouberry (item '! 4) . Your earliest response to the above mentioneel items would be very much appreciated. S .nc,rely opy- Don P. Duncan, Superintendent Water/Waste Treatment Plants DPD : sw h Enclosures (MG/L) FLOW(MGD) TSS EFF TSS INF PERCENT MONTH AVG AVG AVG REMOVAL Jan-88 12.14 21 33 36.4 Feb-88 9.68 18 95 81.1 Mar-88 10.33 20 79 74.7 Apr-88 9.12 13 74 82.4 May-88 8.23 12 84 85.7 Jun-88 8.61 18 98 81.6 Jul-88 7.82 11 77 85.7 Aug-88 8.92 12 69 82.6 Sep-88 10.00 10 48 79.2 Oct-88 8.30 18 66 72.7 Nov-88 9.43 22 58 62.1 Dec-88 7.22 21 68 69.1 Jan-89 9.77 17 64 73.4 Feb-89 8.52 23 104 77.9 Mar-89 13.92 26 57 54.4 Apr-89 12.21 20 79 74.7 May-89 11.11 19 137 86.1 Jun-89 9.88 14 85 83.5 Ju1-89 8.03 21 263 92.0 Aug-89 9.65 15 64 76.6 Sep-89 10.78 20 68 70.6 Oct-89 11.84 18 45 60.0 Nov-89 9.63 19 53 64.2 Dec-89 10.13 30 82 63.4 Jan-90 12.36 23 57 59.6 Feb-90 13.11 27 168 83.9 Mar-90 11.50 21 139 84.9 Apr-90 10.00 21 95 77.9 May-90 11.60 20 122 83.6 Jun-90 8.61 24 177 86.4 Ju1-90 7.03 19 351 94.6 Aug-90 7.56 18 105 82.9 Sep-90 7.04 14 339 95.9 Oct-90 11.61 21 106 80.2 Nov-90 8.41 20 57 64.9 Dec-90 9.16 24 167 85.6 Jan-91 12.23 29 52 44.2 Feb-91 8.46 18 60 70.0 Mar-91 12.14 16 54 70.4 Apr-91 9.30 13 66 80.3 May-91 8.66 15 75 80.0 Jun-91 9.22 12 81 85.2 Ju1-91 7.78 16 102 84.3 Aug-91 8.81 14 100 }6.0 Sep-91 6.79 13 99 36.9 Oct-91 6.45 11 77 85.7 Nov-91 6. 4 2 14 98 55.7 Dec-91 5 . 94 19 72 7; . 6 AVERAGE 9.49 18.33 99.35 76.7 State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management 512 North Salisbury Street . Raleigh, North Carolina 27611 James G. Martin, Governor George T. Everett, Ph.D. William W. Cobey, Jr., Secretary Director Mr. Don Duncan City of Albemarle PO Box 190 Albemarle, NC 28002-0190 Dear Mr. Duncan: December 20, 1991 Subject: Modification to NPDES Permit No. NC0024244 City of Albemarle Stanly County In accordance with your request for Permit modification received January 25, 1990, we are forwarding herewith modifications to the subject permit. These modifications are to: (1) allowing the instream monitoring to remain at the existing downstream sampling location, but with an additional downstream monitoring location at the end of NCSR 1960; and (2) require a removal efficiency of 62% for total suspended residue. The 62% removal efficiency must remain in your permit. As explained in a letter to you on February 8, 1990, the DEM reviewed 19 months of data and found that Albemarle could consistently meet its limitation in 17 of the months. The other two months had removal efficiencies of 54 and 36 percent, respectively, which is inconsistent with the data for the seventeen months. Also, this limitation is well below the mean annual removal efficiency. This determination is consistent with the federal guidelines. Attached is a revised permit which reflects the changes. The division originally intended to allow one year of toxicity monitoring before the limits became effective. However, it has taken nearly two years to resolve the downstream monitoring locations. As a result, the division feels that monitoring in lieu of a limit is not warranted. These modifications are 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 December 6, 1983. • Pollution Prevention Pays P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer Mr. Duncan Page Two If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 11666,Raleigh, North Carolina 27604. Unless such demand is made, this decision shall be final and binding. If you have any questions concerning this permit, please contact Mr. Dale Overcash at telephone number 919/733-5083. Sincerely, Original Signed By Donald Safrit for George T. Everett cc: Mr. Jim Patrick, EPA Mooresville Regional Supervisor Compliance Central Files Permit No. NC0024244 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM vosol In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, City of Albemarle is hereby authorized to discharge wastewater from a facility located at Long Creek WW'TP NCSR 1900 Southwest of Albemarle Stanly County to receiving waters designated as Long Creek in the Yadkin -Pee Dee River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof. This permit shall become effective February 1, 1992 This permit and the authorization to discharge shall expire at midnight on May 31, 1994 Signed this day December 20, 1991 Original Signed By Donald Safrit for George T. Everett, Director Division of Environmental Management By Authority of the Environmental Management Commission Permit No. NC0024244 SUPPLEMENT TO PERMIT COVER SHEET City of Albemarle is hereby authorized to: 1. Continue to operate and maintain the existing wastewater treatment facilities consisting of mechanical bar screens, dual gravity grit chambers, influent lift station, parshall flume with instrumental flow measurement, preaeration basins, primary clarifiers, trickling filters, mechanical aeration basins, secondary clarifiers, gravity tertiary filters, chlorine contact basin, instrumental effluent flow measurement, twelve in -plant screw lift pumps, aerobic digestors, dissolved aeration floatation units and sludge holding tanks located at Long Creek WWTP, NCSR 1900, Southwest of Albemarle, Stanly County (See Part III of this Permit), and 2. Discharge from said treatment works at the location specified on the attached map into Long Creek which is classified Class C waters in the Yadkin -Pee Dee River Basin. A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (Aril 1 - October ober 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is a outfall(s) serial number 001. Such discharges shall be limited uthorized to discharge from Effluent Characteristics Flow BOD, 5 day, 20°C** Total Suspended Residue** NH3 as N Dissolved Oxygen"' Fecal Coliform (geometric mean) Total Residual Chlorine Temperature Total Nitrogen (NO2 + NO3 + TKN) Total Phosphorus Chronic Toxicity** g and monitored by the permittee as specified below: Discharge Limitations Monitoring Measurement Frequency Continuous Daily Daily Daily Daily Daily Daily Daily Monthly Monthly Quarterly *Sample locations: E - Effluent, I - Influent, U - Upstream above discharge point, D - Downstream 1 at miles below discharge at NCSR 1967 () the Upstream and downstream samples shall be grab samples. Stream samples shall be collected once month May) and once per week during the summer (June through September). pero th i Monthly Avg, 16.0MG0 10.0 mg/I 30.0 mg/I 2.0 mg/I 200.0 /100 ml Weekly Avg, 15.0 mg/I 45.0 mg/I 3.0 mg/I 400.0 /100 ml Daily Max Requirements Sample Type Recording Composite Composite Composite Grab Grab Grab Grab Composite Composite Composite 'Sample Location I or E E, I E, I E E, U, D E, U, D E E,U,D E E E end of NCSR 1960 and (2) 3.9 n the winter (October through **See Part III, Condition F; Chronic Toxicity (Ceriodaphnia) P/F at 94%; March, June, September, and Dece mber. � ***See Part III, Condition G. ****The monthly average effluent BOD5 concentrations shall not exceed 15% of the respective influent values (85% effluent Total Suspended Residue concentrations shall not exceed 38% of the respective influent values62removal). The monthly ( % o removal). *****The daily average dissolved oxygen effluent concentration shall not be less than 5.0 m The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. l A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. (Continued) g Effluent Characteristics Discharge limitations Monitoring Requirements Units (specify) Measurement Sample 'Sample Monthly Avg, Weekly Avg, Daily Max Frequency J_ Location Pollutant Analysis"" Annually E Conductivity • Grab U, D Cad mium 2.0 ug/I Weekly Composite E Chromium po 52.0 ug/I Weekly Composite E Nickel 53.0 ug/I Weekly Composite E Lead po 26.0 ug/I Weekly Composite E Copper Monthly Composite E Zinc Monthly Composite E l A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0024244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below: g Effluent Characteristics Discharge Limitations Flow BOD, 5 Day, 20 °C"" Total Suspended Residue"" NH3 as N Dissolved Oxygen"' Fecal Coliform (geometric mean) Total Residual Chlorine Temperature Total Nitrogen (NO2 + NO3 + TKN) Total Phosphorus Chronic Toxicity" Monitoring Measurement Frequency Continuous Daily Daily Daily Daily Daily Daily Daily Monthly Monthly Quarterly *Sample locations: E - Effluent, I - Influent, U - Upstream above discharge point, D - Downstream (1) at the end of NCSR 1960 and(2)- miles below discharge at NCSR 1967 3.9 Upstream and downstream samples shall be grab samples. Stream samples shall be collected once per month in th winter (October throw h May) and once per week during the summer (June through September). g **See Part III, Condition F; Chronic Toxicity (Ceriodaphnia) P/F at 94%; March, June, September, and December. ***See Part III, Condition G. ****The monthly average effluent BOD5 concentrations shall not exceed 15% of the respective influent values (85% removal). The monthl average effluent Total Suspended Residue concentrations shall not exceed 38% of the respective influent values (62% removal). Y *****The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent bygrab sample. p There shall be no discharge of floating solids or visible foam in other than trace amounts. Monthly Avg, Weekly Avg, Daily Max 16.0 MGD 20.0 mg/I 30.0 mg/I 4.0 mg/I 30.0 mg/I 45.0 mg/I 6.0 mg/I 200.0 /100 ml 400.0 /100 ml Requirements Sample Tvge Recording Composite Composite Composite Grab Grab Grab Grab Composite Composite Composite 'Sample Locatior1 I or E E, I E, I E E, U, D E, U, D E E,U,D E E E A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0024 244 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. (Continued) g Effluent Characteristics Discharge Limitations Monitoring Requirements Units (specify) q Measurement Sample 'Sa mn Ie Monthly Avg, Weekly Avg, Daily Max Frequency Type Location Pollutant Analysis***Annually E Conductivity • Grab U, D Cadmium 2.0 u g / I Weekly Composite E Chromium 52.0 ug/I Weekly Composite E Nickel 53.0 ug/I Weekly ! Composite E Lead 26.0 ug/I Weekly g Composite E Copper Zinc Monthly Composite E Monthly Composite E Part III Permit No. NC0024244 F. Chronic Toxicity Limit This condition shall be in effect from the effective date of the permit until permit expiration. The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity tests, using test procedures outlined in: 1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay Procedure - Revised *September 1989) ortubsequent versions. The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is 94% (defined as treatment two in the North Carolina procedure document). The permit holder shall perform quarterly monitoring using this procedure to establish compliance with the permit condition. The first test will be performed after thirty days from issuance of this permit during the months of March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. 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 TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Environmental Sciences Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 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 any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Environmental Management indicate potential impacts to the receiving stream, this permit may be reopened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit suitable test results will constitute noncompliance with monitoring requirements. G. POLLUTANT ANALYSIS MONITORING CONDITION The permittee shall conduct a test for pollutants annually at the effluent from the treatment plant. The discharge shall be evaluated as follows: 1) A pollutant analysis of the effluent must be completed annually using EPA approved methods for the following analytic fractions: (a) purgeables (i.e., volatile organic compounds); (b) acid extractables; (c) base/neutral extractables; (d) organochlorine pesticides and PCBs (e) herbicides; and (f) metals and other inorganics. The M1 l'w'q • Annual Pollutant Analyses Monitoring (APAM) Requirement Reporting Form A and accompanying memo, to be provided to all discharges affected by this monitoring requirement, describes the sampling and analysis requirements and lists chemicals to be included in the pollutant analysis. This monitoring requirement is to be referred to as the "Annual Pollutant Analysis Monitoring Requirement" (APAM). 2) Other significant levels of synthetic organic chemicals must be identified and approximately quantified. For the purpose of implementing this requirement, the largest 10 GC/MS peaks in the purgeable, base/neutral extractable, and acid extractable fractions (or fewer than 10, if less than 10 unidentified peaks occur) for chemicals other than those specified on the APA Requirement Reporting Form A should be identified and approximately quantified as stated in the APAM Reporting Form A instructions. This part (item 2) of the APAM requirement is to be referred to as the "10 significant peaks rule". State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Govemor George T. Everett, Ph.D. William W. Cobey, Jr., Secretary Director October 11, 1996 Mr. Don P. Duncan Superintendent, Water/Waste Treatment Plants City of Albemarle P.O. Box 190 Albemarle, N.C. 28002-0190 Subject: City of Albemarle WWTP NPDES Permit No. NC0024244 Stanly County Dear Mr. Duncan, The Division of Environmental (DEM) has received the data for the Long Creek stream profile collected July 19, 1990. DEM appreciates the City's efforts to obtain this data for review of the stream conditions. The temperature, dis- solved oxygen (DO), and conductivity values were very informative and indicate a DO sag location. The DO values ranged from 5.3 mg/1 to 6.8 mg/1 below the wastewater treatment plant, a change of more than 1 mg/1. The lowest DO values were located at approximately 1.8 to 2.0 miles downstream. This indicates a critical location for the stream and therefore, supports the need for a monitor- ing location approximately 2.0 miles downstream, near SR 1960. As indicated in your letter, the stream flow at the time samples were collected was 2.88 MGD (4.5 cfs) , which is above 7Q10 (1.6 cfs) . DEM uses the 70.10 to develop wasteload allocations for the analysis to be considered under critical conditions. Therefore, under the higher flow conditions, the DO is likely to be higher. A review of the City of Albemarle's most current (August) Daily Monitoring Reports indicated the stream's DO values below the standard of 5 mg/1 at SR 1967 (approximately 4 miles downstream). Since the data collected during the profile reflected the lowest DO values at milepoint 2.0, this station would be critical for data to be collected. In light of the above mentioned, DEM will require monitoring at the SR 1960, or approximately 2.0 miles downstream from the discharge as well as the existing monitoring location at SR 1967. Since the location at 2.0 miles downstream, (near SR 1960) is difficult to access, monitoring will be required during the Pollution Prevention Pays P n Pcnx 77687. Raleigh. North Carolina 27611-7687 Telephone 919-733-7^:5 a summer months only (April -October). Monitoring requirements :or the site at SR 1967 will remain during the winter as well as the summer. D:'; intends to modify the City of Albemarle's NPDES permit in 30 days to require the monitoring site 2.0 miles downstream as well as the existing monitoring site at SR 1967. Please contact Carla Sanderson at (919) 733-5083 if you have any further ques- tions or comments regarding this matter. cc: Rex Gleason Don Safrit WLA File Sincerely, l- T evor Clements, Asst. Chief Water Quality Section City of A lbeinarle .North Carolina Office (,t Treatment Plants (O4) 9R2-01:I March 15. 1989 Mr. Arthur Mouberr' Permits and Engineering Unit Division of Environmental Management Department of Natural Resources and Community Development P O Box 27687 Raleigh NC 27611-7687 RE: Draft NPDES Permit No. NC 0024244 Dear Mr. Mouberrv: I'. O. Box 190 • 1 /hc',,,a:Ie. \ . c' The City of Albemarle has received the draft of the proposed NPDES Permit No. NC 0024244 for the Wastewater Treatment Plant. After review of this document, there are several concerns about how certain discharge limitations and conditions in this permit will affect the City of Albemarle. Under the present circumstances, it is felt that unless several of these requirements are modified, it will not be economically feasible for the WWTP to be in total compliance with the new NPDES Permit. For this reason, the City of Albemarle opposes several items in this permit. The following is a summary of objections and comments on the discharge limitations in the proposed permit. Item 1. Sampling Point at NCSR 1960 In the draft permit, it is stated that there are to be two sampling locations downstream of the WWTP discharge on Long Creek. In the past the City has been using the sampling point on NCSR 1967 for downstream samples. The newly proposed sample location at the end of NCSR 1960 has been inspected by the City staff and found to be inaccessible. To get to Long Creek and collect samples, one would have to cross 1/4 mile of posted private property, fight through heavy vegetation, and encounter an embankment that is too steep for some four wheel drive vehicles. In order to make this area suitable for monitoring, the City would have to negotiate a right-of-way from NCSR 1960 to Long Creek and perform a considerable amount of landscaping. For these reasons, the City requests that the proposed sampling location at NCSR 1960 be deleted from the NPDES Permit. Item 2. Percent Removal of Total Suspended Residue The total suspended residue effluent limitations in the draft permit are identical to those in our present NPDES Permit. However, in the proposed permit there is the additional requirement that there be a minimum of 85% removal of total suspended residue basted on respective Mr. Arthur Mouberry 03-1 5-89 influent values. Due to the low concentration of suspended residue in the WWTP influent, there is no way an 85% removal can be achieved. The reason for the low solids concentration is not excessive I/I, but that the influent flow is 62% industrial (textile dvehouses). It should be noted that in the past the WI:TP has consistently met its suspended solids concentration discharge limitations. Based on the average influent solids loading, the suspended residue concentration that would have to be achieved if the 85 removal provision is involved, would only be 1/3 of the allowed concentration in the proposed permit. It is stated that if all conditions in 40 CFR 133.103 (d) are met, a lower percent removal may be substituted in the NPDES Permit. As has been shown above, all of the criteria in this regulation is being met. Therefore, the City requests that the percent removal provision for total suspended residue be deleted entirely. Item 3. 7Q 10 Flow Due to the low 7Q 10 Flow in Long Creek, the City of Albemarle requests a variance in which all effluent limitation would be based on the actual daily flow in Long Creek. The City of Albemarle plans to install a flow metering station directly upstream from the WWTP discharge into Long Creek for this purpose. Also, the City of Albemarle plans to utilize City Lake to regulate the flow in Long Creek by releasing water from the lake into the stream during low flow conditions. This would give the City of Albemarle WWTP discharge limits which are more tolerable than . are currently proposed. Item 4. Chronic Toxicity Limits The proposed limit that will have the most impact on the City of Albemarle is the chronic toxicity requirement. The effluent toxicity analysis has been conducted on the WWTP discharge since August 1988, on a monthly basis. During this time, the effluent has consistently failed to achieve satisfactory results. The City staff has met with local industry on several occasions during the last 15 months to discuss ways to reduce the toxicity in the WWTP effluent. In April 1989, these industries will conduct toxicity bioassays on their discharges to determine the probable causes of this problem. In December 1988, the City began utilizing lime stabilization for primary sludge. This process should facilitate additional removal of heavy metals from the WWTP effluent, which could reduce the toxicity. Also, the City has the capability to dechlorinate the effluent, and plans to do so during low flow conditions in Long Creek to reduce toxicity. A. The City cf Albemarle requests that there be no chronic toxicity limitations in the NPDES Permit. The reason being that there is no economically feasible way- to consistently meet this limit with both the large percentage of industrial waste in the t%TP influent and low 7Q 10 flew in Long Creeh. In Mr. Arthur Mouberry 03-15-89 3 order for the City of Albemarle 1 TP to meet the proposed chronic toxicity limit, local industry would not be competitive and would be forced to relocate or cease operations entirely. B. The City of Albemarle requests that the fathead minnow be utilized as a test species rather than the ceriodaphnia in the bioassays. In Section .0202 (30) of the NC Water Quality Standards, is a list of sensitive species for aquatic toxicity testing which may be utilized in accepted procedures. Included in this list (Item (d)) is the genus for fathead minnows. C. The City of Albemarle would accept acute toxicity testing as an alternative to chronic testing limits. The main reason for this request is that results from acute testing are more reproducible and reliable than chronic results. The City of Albemarle requests that all of these modifications be implemented in our NPDES Permit. If the NC Division of Environmental Management disapproves of these changes, the City requests that there be an adjudicatory hearing before the proper authorities. The reason for the hearing request is that the City of Albemarle cannot accept the NPDES Permit as it now exists. The amount of funds that would be required to achieve compliance with all of these proposed requirements would be disastrous to the economy of the City and its constituents. The City believes that all of the parties involved in this process would want to avoid creating a situation of that nature. All considerations and cooperation in this matter will be greatly appreciated. If you have any questions, call myself or Gary Smith at the above number. Sincerely, Don P. Duncan, Superintendent Treatment Plants DPD/ljl cc:file Mayor and City Councilmembers Ray Allen, City Manager Calvin Chandler, Director W/S Dept 0 EFFLUENT AVG. CONTROL AVG. MONTH REPRODUCTION REPORDUCTION PASS/FAIL July 1991115.17 17.00 Pass August 1991 16.50 24.75 Fail September 1991 15.50 1G.50 Pass