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HomeMy WebLinkAboutNC0045993_Staff Comments_19820902NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0045993 Teledyne ALLVAC WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Staff Comments Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: September 2, 1982 This document is pri ited on reuse paper. - ignore sorry contest on the reverse side y14-1 G3-c)7-ri MEMORANDUM DIVISION OF ENVIRONMENTAL W NA September 2, 1982 D. Rex Gleason Mooresville Regional Office FROM: Forrest westall, Head Original Signed By Operations Branch FORREST R. WESTALL SUBJECT: Request for Confirmation of Effluent Limitations Teledyne - Allvac Monroe Plant iNPDLS Permit No. N. C. 0045993 Union County, N. C. In your memo of June 23, 1982, you requested that we re-evaluate the wasteload allocation for Teledyne A11vac in light of copper and zinc bioassay studies done by the Biological Monitoring Group. These bioassay studies were performed; however, they indicated that site -specific factors such as receiving water hardness significantly affect the toxicity level of copper and zinc. Because of this, the results of these studies may not be readily transferrable to the Teledyne-A11vac situation. To establish effluent limitations for copper and zinc for this discharger (or others), a bioassay specific to their discharge site would need to be performed. I have copied Steve Tedder on this memo and you should contact him to discuss the possibility of a study. If bioassay -based limitations for copper and zinc are not established at the time the discharge permit comes up for renewal, then a permit condition requiring a biomonitoring program may be in order. The purpose of this program would be to assess the impact of the toxic components of their waste on the receiving stream. If you have any further questions, please co not hesitate to call. FW:cs cc: Steve Tedder Jennifer Buzun MEMORANDUM T0: FROM: SUBJECT: DIVISION OF ENVIRONMENTAL MANAGEMENT June 23, 1982 Forrest Westall D. Rex Gleason Request for Confirmation of Effluent Limitations Teledyne Allvac-Monroe Plant NPDES Permit No. NC 0045993 Union County, North Carolina Jut ' 2 4 1982 WATER QUALITY OPERATIONS BRANCH Attached is a letter from Mr. Don Bailey, Teledyne Allvac, requesting that the Division of Environmental Management reconsider the effluent limitations in the subject Permit (copy attached). Teledyne Allvac produces nickel and titanium alloys. The Company has a history of non-compliance with the fluoride and copper limitations and has in the past had difficulty with nickel and zinc. A memo from you to Mr. Dave Adkins and Mr. Walt Evans (Mooresville Regional Office) dated January 25, 1980 (copy attached), concerning the derivation of the effluent limitations, stated that the Biological Monitoring Group of Technical Services was planning bioassay tests to determine the 96-hour LC50 for copper and zinc. Considering that there may now be more information available on the toxicity of copper and zinc, it may be that these limitations should be modified. It is suggested that the Technical Services Branch re-evaluate the waste load allocation for this discharge. In making this analysis, it is suggested that all parameters listed in the Permit, and on the attached waste load allocation request, be re-evaluated. To our knowledge, there are no BPT limitations applicable to this industry. When Technical Services has developed a revised waste load allocation, the Mooresville Regional Office staff will further investigate the situation at Teledyne Allvac, giving consideration to Mr. Bailey's comments, to determine if the effluent limitations should be revised. If you have any questions regarding this matter of if we can offer any assistance, please advise Mr. Thurman Horne or me. Attachment WTELEDYNE ALLVAC fir. C. DEPT. orATAI-rni .COSIM L. \; iI'I + Mr. D. Rex Gleason, P.E. Water Quality Regional Engineer Division of Environmental Management 919 N. Main Street Mooresville,N.C. 28110-0950 P.O. BOX 759 MONROE. NORTH CAROLINA 28110 (704) 289-4511 June 14, 1982 Subject: Notice of Non -Compliance (5/19/82) Monroe Plant - NPDES Permit # N.C. 0045993 Dear Mr. Gleason; This letter is written in response to your letter to me of May 19, 1982 and a follow-up of my letter to Mr. Van M. Jones of June 2, 1982. Over the past couple of weeks, I have had analytical analyses ran on influent streams into Teledyne All - vac's lower cooling pond. These analyses have been performed by both our internal chemistry lab as well as a state certified lab. The main influent sources into the lower cooling pond consists of storm water run off from the surrounding neigh- borhood, in particular a 24" RCP storm water drain line and city water that is used in our steam boiler that is eventually discharged to the upper pond for cooling. This water is also discharged to the lower pond via the same ditch as the major- ity of storm water influent. Please find attached the analytical results of our sampling over several days. In examining these results, it becomes evi- dent that Teledyne Allvac's violation of its N.P.D.E.S. permit limits for copper and fluoride can be partially or completely attributed to the influent sources into the lower pond that far exceeds the pond's permit limits. An example is the re- sults from samples taken on June 4, 1982 and tested by Chem- Bac laboratory. The fluoride found in city water was 15.0 mg/L and copper entering from the storm drain was at 0.15 mg/L. Both the city water make-up and the storm water influent for the lowerpond constitutes a large percentage of its continuous volume and therefore, would strongly influence it's effluent quality. page 2 Since Teledyne Allvac has no control on storm water entering onto it's property or the chemical make-up of the city's water supply, I petition the State, through your office to ease Teledyne Allvac's N.P.D.E.S. permit #N.C. 0045993 into Rich- ardson Creek to within reasonable attainable limits and still be environmentally acceptable. Please notify me of any additional data that you may need for action on this petition or any questions you may have in this regard. Sincerely, )r7 Don M. Ba eyy P Plant Engineer DB/va Enclosures: c Mr. Johnnie H. Rollins, Jr. (City of Monroe) Mr. Gary L. Mills, P.E. attachment TELEDYNE ALLVAC LABORATORY ANALYTICAL REPORT Results Are Reported as MG/L Date 5/24/82 Lower Pond Storm Drain To Pond City Water Supply F TSS 0.04 Cu. Pb 0.2 N1 0.06 CR 0.0 Date 6/2/82 F 30.1 3.7 TSS 64.0 59.0 54.0 -- Cu .04 0.04 0.0 0.0 Pb 0.0 0.0 0.06 N1 0.12 0.12 CR 0.0 0.06 0.0 Date 6/4/82 F 6.4 5.8 6.5 12.0 TSS 11.0 13.0 Cu 0.08 0.04 0.04 Pb 0.20 0.20 0.20 0.06 N1 0.06 0.06 CR 0.08 0.16 0.08 TELEDYNE ALLVAC LABORATORY ANALYTICAL REPORT Results Are Reported as MG/L Date 6/7/82 Lower Pond Storm Drain To Pond City Water Supply r - 5.7 3.8 4.6 TSS 7.0 7.0 6.0 Cu. 0.04 0.04 0.04 Pb 0.20 0.20 0.20 N1 0.14 0.06 0.0 CR 0.24 0.24 0.40 Date 6/4/82 Chem-Bac Laboratory F- 1.75 1.75 15.0 TSS 6.1 9.6 <1.0 Cu 0.05 0.15 <0.03 Pb < 0.05 <0.05 <0.05 N1 0.14 0.08 < 0.05 CR < 0.05 0.05 <0.05 Date 6/7/82 F- 4.5 1.75 2.8 TSS 12.2 9.6 < 1.0 Cu 0.03 0.15 <0.03 Pb <0.05 <0.05 <0.05 N1 <0.05 0.08 ( 0.05 CR <0.05 0.05 0.05 Mayor Fred C. Long Council Members James S. Barnett P. E. Bazemore Thomas L. Gordon Lynn A. Keziah H. Duke Parker I. B. Shive City Manager J. E. Hinkel r,. Od gm/ e dl/ozd`�a�taeh w June 18, 1982 Mr. Don M. Bailey Teledyne Allvac P. 0. Box 759 Monroe, N. C.28110 Re: NPDES Permit NC 0045993 Dear Mr. Bailey: 410 S N 21 AIR QU!.'. SECT 1 By letter dated June 14, 1982, you presented information to Mr. Rex Gleason which we feel is incorrect. The water supply for Monroe is tested daily by the Filtration Plant Laboratory (which is state certified) for requirements issued by the Division of Health Services and these analysis are reported monthly. The Filtration Plant supplies water to the distribution system with maximum fluoride content 1.1 mg/1. There are no requirements for TSS, but turbidity is less than 1.0 mg/1. Chem-Bac Laboratory analysis appears to contain a typing error for fluoride which should be 1.5 mg/1, not 15.0 mg/l. The other results seem to be compatible. I trust by checking your laboratory results, you will confirm my comments. If I can offer assistance, please contact me. Sincerely, P. Wilson Crook Director of Utilities PWC/jm cc: J. E. Hinkel D. Rex Gleason J. L. Montgomery Johnnie Rollins P. O. Box 69 - 300 W. Crowell St. Monroe, N. C. 28110 704/289-8557