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HomeMy WebLinkAboutNC0021873_HWA Approval_20220915DocuSign Envelope ID: E678AB22-9CCO-4869-A014-FCFE86AC4EB8 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality 9/15/2022 Town of Mayodan Attn: Melessa Hopper, Town Manager P.O. Box 1279 Mayodan, NC 27012 Transmitted via email to mhopper@mayodannc.org Subject: Dear Permittee: Review of Headworks Analysis Program: Town of Mayodan NPDES Permit No: NC0021873- Mayodan WWTP Rockingham County The Municipal Unit of the Division of Water Resources has reviewed the Headworks Analysis (HWA) and Allocation Table (AT) for the Town of Mayodan's wastewater treatment plant (WWTP) working under the NPDES Permit No NC0021873 (effective on August 1, 2018). The revised HWA was submitted on July 8, 2022, in response to the DWR's September 3, 2021, HWA Review Letter. The Division concurs with the HWA calculations for all pollutants of concern, with the updates, corrections, and observations discussed below. These approved Maximum Allowable Headworks Loadings (MAHLs), Maximum Allowable Industrial Loadings (MAILs), and the basis for these values are found in the enclosed HWA AT spreadsheet, which has the updates and corrections highlighted. Please replace or update POTW's HWA AT spreadsheets and supporting documents with these approved ones. 1. HWA Updates and Corrections a. Water Quality Stream Standards: The HWA was updated to use the site -specific water quality standards (WQS) for cadmium, copper, lead, and zinc according to the WQS for human health used in the reasonable potential analysis (RPA) Input table (See `WQS RPA Input' Tab in the HWA AT Sheet). b. Mercury Removal Rate was changed from 0.01% to 18.35% based on the additional mercury sampling provided by the Town. c. AT: All Industrial User Permits (IUPs) were renewed in January 2022. The AT has been updated to reflect those changes. d. The use of Headworks Addendum for Sludge Loadings (HASL) is deemed necessary for nickel and selenium and has been delisted for cadmium since there is no overallocation based on sludge ceiling for cadmium. 2. Next HWA Due date: The HWA approved today is based on DMR/LTMP data for the period of March 2016 through June 2020. Including mercury data collected in 2021 and 2022. Unless conditions at the POTW change significantly and thus warrant an earlier submittal (see Comprehensive Guide, Section B), the POTW must submit an updated site -specific HWA by October 1, 2025, as set by the DWR's September 3, 2021, Letter. Regardless of this approval action today, within 180 days of the effective date of any reissued/modified NPDES permit, the Permittee would be required to submit to the Division a written technical evaluation of the need to revise local limits (i.e., an updated HWA or documentation of why one is not needed) INPDES Permit Section D, 4.1. This action may include revising, updating, or adding to the list of Significant Industrial Users (SIUs) and/or modifying SIU Industrial User Pretreatment Permit (IUP) limits. In addition, any executed Special Order of Consent (SOC) conditions or requirements related to pretreatment or pretreatment program updates must be complied with separately from this approval action. DocuSign Envelope ID: E678AB22-9CCO-4869-A014-FCFE86AC4EB8 Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW. It is the POTW's responsibility to ensure that these objectives are consistently met. Thank you for your continued support of the Pretreatment Program. If you have any questions or comments, please contact the Pretreatment Coordinator Keyes [keyes.mcgee@ncdenr.gov], or the Unit Supervisor, Michael at[michael.montebello@ncdenr.gov]. Sincerely, EDocuSigned by: L higUta kiNAl t g C464531431644FE... for Richard E. Rogers Jr., Director Division of Water Resources dy/Mayodanhwa 2022 Attachments: 2022 Approved HWA-AT cc with attachments: Nadine Blackwell, Pretreatment Coordinator Jim Gonsiewski, Winston-Salem Regional Office Municipal Unit File and Central Files (Laserfiche)