NC0047597_Correspondence_19890124

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CITY OF MEDICINE
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CITY OF DURHAM S 6 ry"
NORTH CAROLINA
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RECEIVFD
JA N 31 1989
TECHNICAL SERVICES SI71
NCh
Mr. R. Paul Wilms, Director
Division of Environmental Management
Post Office Box 27687
Raleigh, North Carolina, 27611-7687
Dear Mr. Wilms:
January 24, 1989
The following comments are offered in response to the
Public Notice on reopening NPDES Permit No. NC0047597 issued
to the City of DuiEham for the Farrington Road Wastewater
Treatment Plant (WWTP). The draft permit proposes limits for
Cadmium, Chromium, Cyanide, Lead and Nickel. There has been
con-'silerab eI previous correspondence between the City of Durham
and DEM relative to this permit. Listed below is a
chronological summary of the relative correspondence:
December 1985 - DEM issued a Notification of Intent to
Issue a State NPDES Permit. This draft permit contained a
Mercury limit of 0.2 ug/1 and a Cyanide limit of 5.0 ug/1.
December 6, 1985 - The City of Durham submitted comments
on the renewal of the Farrington Road WWTP permit. We
specifically requested deletion of the Cyanide limit and the
Mercury limit.
January 21, 1986 - DEM issued an NPDES permit with the
aforementioned limits for Cyanide and Mercury.
February 21, 1986 - the City requested modification of the
permit to delete the Cyanide and Mercury limits, issuance of an
SOC to cover those parameters or an adjudicatory hearing to
resolve areas of disagreement.
September 5, 1986 - The City again requested that the
Cyanide limit be deleted. Current analytical data was
submitted revealing no detectable levels of Cyanide. A
reduction of the Mercury monitoring frequency was also
requested.
101 CITY HALL PLAZA. DURHAM, NORTH CAROLINA 27701
[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER

Depart/ uent•of Water Resources
Mr. R. Paul Wilms
January 24, 1989
Page 2
January 19, 1987 - DEM issued a Modification to NPDES
Permit No. NC0047597. This modification deleted the Cyanide
limitation and monitoring requirement. It also reduced the
monitoring frequency for Mercury.
July 1987 - DEM issued a notice of intent to issue a new
permit for the Farrington Road WWTP
August 13, 1987 - the City filed comments relative to the
issuance of a new permit. We requested the deletion of the
monitoring requirements for Cadmium, Nickel, Lead and Chromium.
We also requested deletion of the monitoring requirement and
permit limitation for Mercury.
September 10, 1987 - DEM issued a new permit for the
Farrington Road WWTP containing monitoring requirements for
Nickel, Cadmium and Lead as well as the 0.2ug/1 limit for
Mercury.
October 5, 1987 - the City of Durham requested waiver or
modifications of the September 10, 1987 permit. The parameters
disputed were Chromium, Nickel, Cadmium, Lead, Toxicity,
B.O.D., and Mercury. We requested an adjudicatory hearing if
necessary.
October 26, 1988 - DEM sent a response to the City of
Durham's letter of the prior year. This response denied all
requests made by the City for modification of the permit.
December 9, 1988 - the City of Durham filed for an
adjudicatory hearing for resolution of the above referenced
disagreements.
The City of Durham has supplied considerable amounts of
data to DEM on the metals for which limits are proposed.
Previously submitted correspondence summarizes that over
several years of monitoring that few if any detectable levels
of these parameters have been detected in the discharge of the
Farrington Road WWTP nor in the effluent of it's predecessor
facilities. Cyanide has previously been protested and removed
from the permit. Cadmium, Chromium, Nickel and Lead have been
similarly protested using similar logic and data. This draft
permit would reimpose Cyanide as a limit as well as imposing
permit limits for the four metals.

Department of Water Resource,
Mr. R. Paul Wilms
January 24, 1989
Page 3
By this letter the City of Durham is requesting that the
permit limitation for Cyanide not be included in any new
permit. Monitoring for these parameters would impose on the
City a significant analytical load, particularly at the levels
proposed. The proposed permit limits for Mercury, Cadmium,
Chromium, Lead and Nickel are also the analytical
limits of the tests. That level of accuracy and precision is
the best which can be achieved under ideal laboratory
conditions. The multitude of interferences and problems which
could be foreseen in a wastewater matrix makes detection at or
below analytical detection limits extremely difficult if not
impossible. We feel that these factors unnecessarily expose
the City to permit violations, fines and moratoriums on sewer
extensions. Therefore, we would like to request that limits on
these be set at a more reasonable level. We would suggest a
level of 1.5 times the detection limit as a possible permit
limit until a more stringent level can be justified.
Sincerely,
DEPARTMENT OF WATER RESOURCES
A. T. ROLAN
Director

Departimteitt of Water ResourceA
Mr. R. Paul Wilms
January 24, 1989
Page 4
cc: Mr. John T. Marlar, Chief, Facilities Performance Branch,
Water Management Division, United States Environmental
Protection Agency, Region IV, 345 Courtland Street,
Atlanta, Georgia 30365
/Mr. Charles Wakild, Chief, Water Quality Section, Division
of Environmental Management, Post Office Box 27687,
Raleigh, North Carolina 27611
Mr. William A. Kreutzberger, Supervisor, Regional Water
Quality, Division of Environmental Management, North
Carolina Department of Natural Resources and Community
Development, Post Office Box 27687, Raleigh, North
Carolina 27611
Ms. Karen Sindelar, Assistant City Attorney, City of
Durham, 101 City Hall Plaza, Durham, North Carolina
27701
Mr. Orville W. Powell, City Manager, City of Durham, 101
City Hall Plaza, Durham, North Carolina 27701
Mr. Cecil A. Brown, Senior Assistant City Manager,
City of Durham, 101 City Hall Plaza, Durham,
North Carolina 27701
Mr. William W. Telford, Jr., Superintendent of Treatment
Plants, Department of Water Resources, 101 City Hall
Plaza, Durham, North Carolina 27701