NC0074268_201 Facilities Plan_19880718

South Carolina Department of Health
and Environmental Control
�-4
2600 gull Street
Columbia, S.C. 29201
Commissioner
Michael D. Jarrett
July 12, 1988
Mr. Samuel L. Wilkins, P.E.
Director of Public Works and Utilities
City of Gastonia
P. 0. Box 1748
Gastonia, NC 28053-1748
RE: Gaston County 201 Facilities
Plan Amendment
Dear Mr. Wilkins:
B d
Nloscs H. Clarkson. Jr.. Chairman .i
Oren I.. Brady. Jr.. Vice -Chairman
Euta M. Colvin. M.D., Secretary
m HarM. Hallman. Jr.
Henry S. Jordan. M.D.
Toney Graham, Jr. M.D.
-134
oar
RECEIVED
! L' L 1 3 1988
WA -Er O''t T' -r ;; K ..
t11 •
This is written to be read and ,entered into the record at the public hearing on
the above -referenced 201 Facilities'Plan amendment.
The South Carolina Department of Health and Environmental Control under Title
48, Chapter 1 of the 1976 S. C. Code of Laws is the Agency of state government
having jurisdiction over the quality of the air and waters of the State of
South Carolina, and has jurisdiction over those matters involving real or
potential threats to the health of the people of our State. Due to the fact
that this proposed discharge may be within close proximity to our border, our
Department feels compelled to enter into the record our concerns relative to
the proposed facility permit as follows:
1. The proposed new facility, as with most projects funded under
PL92-500, would provide for consolidation and better treatment of
existing discharges in the subject area. Unfortunately, the
discharge, no matter where, ultimately flows into South Carolina, and
our citizens have a right to expect that their concerns be heard.
Therefore, the location of the facility should be carefully
considered in light of appropriate concerns voiced.
That there be acceptable biological and physical limits placed in the
NPDES permit, to include phosphorus limits. Crowder Creek has been
ranked fourth worst eutrophic stream in our State, and it enters
Lake Wylie. We therefore expect that Phosphorus will be properly
reduced. Also Chlorine must be removed to the appropriate extent.
That appropriate toxicity monitoring language be placed in the NPDES
permit to preclude against acute and chronic toxicity. The use of a
diffuser to minimize the mixing zone should be considered.

4. That a pretreatment program be developed and approved for the
industrial dischargers that would protect against pass through,
interference, and sludge contamination. This pretreatment program
must be in place prior to the operation of the plant. This means
that we expect that all applicable industries will have proper
pretreatment permits and be meeting those permit limits prior to the
initial operation of the subject plant.
5. That the plant be manned with appropriately graded operators 24 hours
a day.
6. That consideration be given to duplication of unit processes since
(1) the City of Rock Hill and Catawba Nuclear Station have drinking
water intakes on Lake__Wylie, and (2) there is a Girl Scout Camp on
Crowder Creek which uses the waters for recreational purposes.
In these regards, the South Carolina Department of Health and Environmental
Control would respectfully request to be provided a copy of any draft NPDES
permit and any FNSI for an opportunity to comment. By copy of this letter we
are advising NCDEM officials of our request. In that our State is inevitably
effected by this proposed discharge, we feel that it is not only our right but
our duty to do such.
I might add that our preliminary discussions with our counterparts at the North
Carolina Department of Environmental Management lead us to believe that they
share the same concerns as we do. So it is with a spirit of cooperation that
we approach this issue.
Thank :you for the opportunity to speak and allow your neighbors to the South to
be heard.
Sin, -
1.t
Geor
Dome
Bure
GMC/fpw
Caughman, P.E., Director
astewater Division
Water Pollution Control
cc: R. Lewis Shaw
Jim Joy
Coy Batten, NCDEM
✓Dennis Ramsey, NCDEM
Alan Wahab, NCDEM
AI Williams, Catawba District
Harold Hopkins, EPA, Region IV