NC0024945_Correspondence_19890814

NPDES DOCUMENT SCANNING COVER SHEET
NC0024945
Irwin Creek WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Draft Permit
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 14, 1989
This document ies printed on reuase paper - ignore any
content on the reYeree +ecide

CHARLOTTE
August 14, 1989
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Environmental Management
P. 0. Box 950
Mooresville, N. C. 28115-9050
Attention: Mr. Richard Bridgeman
uv 2 9 1989
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Subject: Failure to Meet Chronic
Target Value
CMUD-Irwin Creek, WWTP
_r NPDES Permit No. NC0024945
t y „ ; Mecklenburg County, N. C.
Dear Mr. Gleason:
In respgnse to your request for a progress report on the subject failure to
meet the chronic target value for the Irwin Creek WWTP, we are able to report
the following:
Efforts Completed
1. 59 pretreatment permits have been issued to SIU's discharging into the
Irwin Creek WWTP.
2. The pretreatment staff has attained its full complement of employees.
3. The Aware Environmental, Inc. firm was contracted in May to assist the
plant staff in bringing the plant into permit compliance.
--� 4. Changes were made in June in the discharge procedures of the water plant
wastewaters.
5. A scope of work for Phase 1 Toxicity Reduction Evaluation was received in
June from Aware Environmental, Inc.
6. The Chronic Bioassay samples taken in June achieved a PASS.
7. In July, Charles Petty was temporarily appointed to supervise process
operations at both Irwin Creek and Sugar Creek WWTPs.
Current Plans
1. We are awaiting a reply from the Division of Environmental Management to
our comments on the draft NPDES permit assigned to the McAlpine Creek
WWTP. We have objected to certain aspects of the toxicity testing
requirements of the State of North Carolina. The reply to our comments
will allow us to plan appropriately to address toxicity reduction at the
Irwin Creek WWTP.
Administration Division 5100 Brookshire Boulevard Charlotte, NC 28216 704/399-2221
Charlotte -Mecklenburg Utility Department

Mr. D. Rex Gleason - 2 - August 14, 1989
2. In July, we requested information from the Division of Environmental
Management concerning the legalities of septage management. When we
receive the reply, we will be able to assess our current program and make
changes which may benefit all of the CMUD plants.
Please inform us if this response is unsatisfactory.
Sincerely yours,
Charlotte -Mecklenburg Utility Department
Henry L. orrest
Utility perations ChL.ef
Attachments
cc: Mr. Ken Eagleson
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ENVIRONMENTAL INC.
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June 12, 1989
Mr. Henry L. Forrest
Utility Operations Chief
Charlotte -Mecklenburg Utility Department
5100 Brookshire Boulevard
Charlotte, NC 28216
Re: Scope of Work for Phase I Toxicity Reduction
Evaluation - Irwin Creek Wastewater Treatment Plant
AEI Job No. N131-01
Dear Mr. Forrest:
AWARE Environmental Inc. (AEI) is pleased to present this
proposal to assist the Charlotte -Mecklenburg Utility Department
(CMUD) in conducting the initial phase of a toxicity reduction
evaluation (TRE) program. The proposed THE will be for the Irwin
Creek Wastewater Treatment Plant, and it is our understanding
that the effluent from the treatment plant is currently not in
compliance with the toxicity criteria.
Specifically, a toxicity reduction evaluation is a study to
determine the cause of effluent toxicity and approaches for
complying with the effluent toxicity criteria. We recommend a
step -wise multi -phased approach to•conducting this study. The
following.sections present a proposed scope of work for the
initial phase of the study.
PHASE I - SCOPE OF WORK
The initial phase of the program will be an overview of toxicity
problems at the plant. The results of this phase will be used to
930S MONROE ROAD • DUDE J • CHARLOTTE, N.C.:t22S • TELEPHONE (704) OIS•1497
develop a toxicity reduction approach for the Irwin Creek Planl
The proposed activities will include:
a. A review of the specific toxicity criteria for the
Irwin Creek Plant and the basis for that criteria;
b. A review of the toxicity test data for the Irwin
Creek Plant;
c. A review of the data base on POTW operation and
performance;
d. An evaluation of available industrial pretreatment
and characterization data for discharges into the
Irwin Creek facility:
e. Conduct of preliminary toxicity screening tests to
define the relative magnitude of the toxicity problem
f. Preparation of a Phase I report summarizing the resul
of the evaluations, and defining a specific toxicity
reduction program and additional test criteria.
ADDITIONAL WORK PHASES
The Phase I program is designed to determine the nature of the
toxicity and develop an overall toxicity reduction approach. T
major work effort will be in the additional phases which would ;
conducted at the Irwin Creek Plant and principal industrial
discharges. The work efforts will include, but not be limited
a)
b)
Toxicity Identification Evaluation - A procedure to
characterize and identify the toxic components.
Toxicity Source Evaluation - Tier I - This is the
sampling and toxicity analysis of specific

discharges and sewer lines.
Toxicity Source Evaluation - Tier Its Source
Ranking/Pretreatment Evaluation - This confirms
the suspected sources of toxicity identified
in Tier I.
Toxicity,Control Selection - This defines the selected
control strategy for the Irwin Creek Plant.
pROJECT PERSONNEL,
AEI personnel responsible for the successful completion of
specific tasks in this category will be assigned based upon the
work to be completed. AEI will work closely with personnel from
CMUD. The project team will be composed of Mr. Bob Stein and Mr.
Ned Fiss. Mr. Fiss will be project manager and will be assigned
the responsibility for timely and successful completion of the
work. Mr. Stein will be the technical director and will overview
the project.
MANHOUR AND COST ESTIMATE
We have developed a manhour and cost estimate to perform the
Phase I program. This is presented in Table 1.
We would propose to perform these services on a time and
materials basis, in accordance with our May 10, 1989 agreement.
,We appreciate this:opportunity to submit this proposed Scope of
;Work to CMUD. We would welcome the opportunity to review the
proposed program with you. If you have any questions or need
additional information, please feel free to contact me.
Sincerely,
AWARE Environmental Inc.
Robert M. Stein
President
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