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HomeMy WebLinkAboutNC0074268_instream assessment_19940811DMSION OF ENVIRONMENTAL MANAGEMENT August 11, 1994 MEMORANDUM TO: Rex Gleason FROM: Jacquelyn M. Nowell/\ THRU: Don S Ruth Swanek 2(.5 Carla Sanderson SUBJECT: Instream Assessments for the City of Gastonia Wastewater Treatment Plants Catawba Creek WWTP - NC0020192 - (SOC # 93-017) Long Creek WWTP - NC0020184 - (SOC # 93-015) Crowders Creek WWTP - NC0074268 - (SOC # 93-016) Gaston County Summary The Technical Support Branch has reviewed the request for instream assessments for the City of Gastonia's WWTPs . The City is requesting Special Orders of Consent (SOCs) for all facilities for whole effluent toxicity problems and noncompliance with limits for metals and other toxics. In addition, each facility is requesting an increase in wasteflow during the life of the SOC, however this flow will be 100% domestic and there will be no increase in allocated BOD. Based on this, the wasteflow at the Gastonia plants may be increased in the following amounts: SOC Flow (MGD) Catawba Creek WWTP 1.973 Long Creek WWTP 0.817 Crowders Creek WWTP 1.371 Existing design flows and instream waste concentrations of the three plants are as follows: Design Qw IWC Catawba Creek WWTP 9 MGD 90% Long Creek WWTP 8 MGD 80.5% Crowders Creek WWTP 6 MGD 42% The Catawba Creek plant has consistently experienced toxicity problems since the implementation of toxicity testing, however the Long Creek and Crowders Creek plants have just recently started to have problems. Increased pollutants from industries tying on to the plants are evidently where the toxicity problems are originating but additional time is needed to correct the situation. MRO staff have indicated that the request for chronic toxicity monitoring - full range testing has already been reviewed and approved by the Environmental Sciences Branch, and Technical Support will concur with their recommendation. Memo to Rex Gleason page 2 Discussion Gastonia has also requested monthly average limits for the metals instead of daily maximum limits that have been assigned in the NPDES permit. The City has also requested SOC limits for several metals however the staff of the Mooresville Regional Office (MRO) does not think that SOC limits for all the requested metals are warranted. The MRO recommended daily maximum limits for the Gastonia WWTPs are as follows: Catawba Creek Cyanide 27 Nickel 205 Cadmium 12 Long Creek 10 210 8 Crowders Creek nr nr 12 The Instream Assessment Unit has reviewed 1994 effluent data from all three facilities and has determined that the following metals limits could be recommended in the SOCs for the Gastonia facilities. The Division can offer Gastonia the option of limits permitted in weekly averages and higher daily maximum limits. The daily maximum limit could be established to provide protection from acute toxic effects. Compliance with the weekly average limit is determined by the average of the daily samples for that week. For the purposes of this calculation, samples listed at less than analytical detection will be assumed to be zero. The penmittee may choose to collect 5 samples for the week and base the number of analyses run on the outcome of the first sample. If the first sample is in compliance with the weekly average limit, then no more analyses need be run for that week. However, if the first sample is above the weekly average, then more samples should be analyzed and the permittee must comply with both the weekly average and daily maximum limits. If this option is implemented, the recommended metals limits for each of the plants would be as follows: Catawba Creek WWTP Long Creek WWTP Cyanide Nickel Cadmium Cyanide Nickel Cadmium Crowders Creek WWTP Cadmium Recommendation Weekly Avg. 5.5 µg/1(WQ) 97 µg/1 (WQ) 2.2 µg/1(WQ) Weekly Avg. 6.2 µg/1(WQ) 109 µg/1(WQ) 2.5 µg/l (WQ) Weekly Avg. 4.8 µg/1 (WQ) Daily Maximum 22 µg/1 388 µg/1 5.5 µgf1 Daily Maximum 251.41 436 µg/1 6.2 µg/l Daily Maximum 12 µg/1 After review of the effluent data for all the facilities and discussion with MRO staff, the Instream Assessment Unit recommends the following monitoring requirements for the SOCs for the Gastonia plants. The exceedance of allowable concentrations for parameters Memo to Rex Gleason page 3 is not normally recommended, in those cases we suggest that effluent monitoring only for that substance is placed in the SOC. Our recommendations for the Gastonia SOCs are as follows: Catawba Creek WWTP Long Creek WWTP SOC requirement Cyanide monitor Nickel monitor C dmium _ monitor SOC requirement Cyanide monitor Nickel monitor Cadmium monitor Crowders Creek WWTP SOC requirement Cadmium monitor If there any questions concerning these recommendations, please contact me. cc: Kent Wiggins Dave Goodrich Central Files WLA File DIVISION OF ENVIRONMENTAL MANAGEMENT June 2, 1994 Memorandum To: Ruth Swanek From: D. Rex Gleason Prepared By: Kim H. Colson-j� Subject: City of Gastonia Crowders Creek WWTP SOC # 93-016 NPDES Permit No. NC0074268 Gaston County, NC This Office request that the Instream Assessment Unit conduct an instream assessment for the subject facility's request for interim effluent limits for Nickel, Cyanide, Cadmium, Chromium, and Lead (request enclosed). The facility has also requested that daily maximum limits for these parameters be changed to a monthly average. This Office does not recommend any interim limits for Nickel, Cyanide, Chromium or Lead. Since the facility has only reported 1 violation for Nickel, 1 violation for Lead, and no violations for Chromium in the past year, interim limitations do not appear to be needed. Cyanide is no longer limited in the recently renewed NPDES Permit. This Office would most likely recommend a maximum interim limit for Cadmium of 12 ug/1 (daily maximum). Please evaluate the facility's proposed interim limits and this Office's suggested interim limits with regard to potential instream affects. Also advise on other possible alternatives to monthly average limits, such as weekly average / daily maximum limits. If you have any questions concerning this matter, please advise. Attachment cc: Jeff Bouchelle, Facility Assessment Unit TOXICANT ANALYSIS Facility Name Gastonia-Crowders Creek NPDES # NC0074268 Qw (MGD) 6 7Q 1Os (cfs) 13.3 Crowders Creek IWC (%) ,.._.._.._.._.._.._.._.._.._.._.._..41.15 Rec'ving Stream Stream Class C FINAL RESULTS Cadmium Max. Pred Cw 41.6 Allowable Cw 4.9 Nickel Max. Pred Cw 930 Allowable Cw 213.8 Cyanide Max. Pred Cw 17.1 Allowable Cw 12.2 Chromiu m Max. Pred Cw 84 Allowable Cw .121.5 Lead Max.. Pred Cw 478.4 Allowable Cw 60.8 0 Max. Pred Cw 0 Allowable Cw 0.0 0 Max. Pred Cw 0 Allowable Cw 0.0 0 Max. Pred Cw 0 Allowable Cw 0.0 0 Max. Pred Cw 0 Allowable Cw, 0.0 0 Max. Pred Cw 0 Allowable Cw 0.0 0 Max. Pred Cw 0 Allowable Cw 0.0 0 Max. Pred Cw 0 Allowable Cw 0.0 6/25/94 PAGE' 2). D414/11c= (714-'7.8) p2- icA V ----- a./ Instream Assessment Request for Gastonia WWTPs - Crowders Creek WWTP- NC0074268 SOC No. 93-016 - Catawba Creek WWTP - NC0020192 SOC No. 93-017 - Long Creek WWTTP - NC0020184 SOC No. 93-015 The City of Gastonia is requesting SOCs for all their treatment plants for toxicity and metals. Telecon w/ Kim Colson All Gastonia plants are failing toxicity. Catawba creek started failing in the late 80's, starting passing and then started consistently failling again. Town submitted THE for Catawba Creek, and are in the process of finalizing TREs for Long Creek and Crowders Creek facilities. All the language for chronic monitoring and test ranges have been reviewed by Aquatic Toxicity. Gastonia wants monthly averages for all the metals. Gastonia knows that the problems are from pollutants coming into the plants from the industries that are tying on. Crowders plant can ease the problem through source reduction. Long Creek plant wants to wait until they expand and relocate to SF Catawba River to start working an toxicity problems. Catawba will be using lime precipitation and new industrial waste surveys and headworks analysis. The City requested SOC limits for several metals and MRO reviewed the requests and made recommendations of their own. The tables below show the limits requested from Gastonia and the MRO, plus data from January to April, 1994 for the treatment plants 1/2 FAV Values Cn Cr Ni Cd Pb Hg 22 984 789 5 33.8 2.4 Crowders Creek WWTP Cn Cr Ni Cd Pb Existing Limits m o n. 120 211 4.8 60 Town Requested -data not included- MRO Recommended 12 Max. value reported 9 35 300 16 104 Max. value predicted 17 8 4 930 4 2 478 # Obs. for analysis 2 7 2 6 26 2 5 2 6 Below Detection 2 3 3 7 10 Catawba Creek WWTP Cn Cr Ni Cd Pb Existing Limits 5.5 55 97 2.2 28 Town Requested 12.4 55 212 5 2 8 MRO Recommended 2 7 - 2 0 5 12 - Max. value reported 7 2 2 5 230 17 113 Max. value predicted 410 57.5 552 42.5 520 # Obs. for analysis 21 21 21 21 21 Below Detection 9 4 - 3 5 Instream Assessment Request for Gastonia WWTPs page 2 Long Creek WWTP Cn Existing Limits 6.2 Town Requested 18 MRO Recommended 10 Max. value reported 40 Max. value predicted 232 # Obs. for analysis 15 Below Detection 9 Cr Ni Cd Pb Hg 62 109 2.5 31 0.02 62 142 8.4 31 0.36 210 8 - - 56 210 14 85 0.3 140 441 67 408 0.51 16 19 16 18 23 2 1 6 7 21 7/5/94 Talked w/ Kim Colson and related recommendations for the SOCs. Said that he'd call back after talking w/ Rex. 7/26/94 Kim Colson called with MRO recommendations: Catawba Creek- can't meet the limitsrecommended by TSB Cyanide Nickel Cadmium Weekly Avg. 5.5 µg/1(WQ) 97 µg/1(WQ) 2.2 µg/1(WQ) Daily Maximum 22 µg/1 388 µg/1 5.5 µg/1 MRO wants to keep daily maximum values. Doesn't want the Town to spend all their efforts sampling effluent to try to meet weekly avg limit. Would rather have Gastonia sample influent and collection systems to track down the source of the cyanide in the discharge. Based on recent samples, Kim doesn't think that Catawba Creek could meet the Cd limits recommended by TSB. MRO recommends following Daily Max. limits for the Catawba Plant: CN 27 nil Ni 205 µg/1 Cd 12 µg/1 The SOC will be effective through Dec. 1995. Gastonia has submitted ATC for addition of lime precipitation at the Catawba plant that will precipitate out a lot of metals. The toxicity problems are probably being caused by concentrations of Ni, Zn, Cu and Cd. Dechlorination has also been added that will help some with the toxicity problem, but chlorine is not the major source of the tox problem. Crowders Creek - MRO recommends that the daily max. limit of 12 ug/1 for Cadmium be given for this facility. TSB had recommended Wk avg of 4.8 µgf1 and Da. Max. limit of 12 µg/1. Long Creek - MRO recommends daily max. limits: Cn 10 µg/1 Cd 8 µg/1 Ni 210 µg/1 Instream Assessment Request for Gastonia WWTPs page 3 Kim thought that since MRO recommended da. max. values for some parameters like Ni were less than TSB recommended limits, that it was okay. However, for Cd, the TSB recommended limits could not be met by the plants during the SOC and that some leeway needed to be given. Told him that I would probably still include the wk avg./da. max limits in the instream assessment letter but that our officewould probably go along with whatever recommendations the MRO wanted to give for the SOC limits. 7/28/94 After review of Carla's comments on the first draft of the instream assessment, I'm recommending effluent monitoring for the parameters where the MRO recommendation exceeds the allowable concentration. In the cases where the MRO recommendation is lower than the calculated daily maximum limit, we will concur with their lower limit for the S OC. aviD,444 /(619 1). ,r4 14 65Vfate • 77. 2 _I"' 1(14/I L.- I /2.y erm 6,0• 79P"' - 3 c /?.7 Cot ( /2, is-- 3) (5) 73 / of / at .44.4 }c-s) - Lf f. 3 f,J O7pli4i 4 - /1 44.r,644 44, 14, Pg-tv 1-, 1,1,mstn- Page 1 Note for Jackie Nowell From: Randy Kepler Date: Mon, Feb 28, 1994 11:31 AM Subject: RE: Gastonia-Crowders Creek J To: Jackie Nowell I don't think it is in the regs but i have done several like this. For chlorine, Charles A. has said that with other facilities, DEM has required the facility to use a new test called the DPD colormetric method (blanks at 50 µg/1, test number 4500-G-Cl). This if done correctly will detect to 1014/1. Charles said Bill Edwards in the lab gave this to him. I had asked to see if you guys have changed policy or anything like that. I'll keep the C12 level the same and tell them what i said above... Thanks. R From: Jackie Nowell on Mon, Feb 28, 1994 11:24 AM Subject: RE: Gastonia Crowders Creek To: Randy Kepler Our response in the past has been that if your limit is lower than detection level, a reading of less than detection, in this case, less than 100 ug/1 will be considered in compliance. Therefore, no need to increase the limit, if they can record less than 100 ug/1. I'm checking the regs to see what the exact statement is. From: Randy Kepler on Mon, Feb 28, 1994 11:10 AM Subject: Gastonia-Crowders Creek To: Jackie Nowell 03-08-37, NC0074268. They have commented on the draft but it is only one concern. They don't like to chlorine limit of 1914/1. They dislike it because of their measurement and control systems are not capable to measure down to that level. Can only go to 10014/1. They request their chlorine level be raised to 100 µg/1 weekly average combined with 100 µg/1 daily maximum. They say these limits " represent the current best technology control loop detection levels for chlorine control. Could you send me back some form of response for this request. A mail message should be sufficient. Thanks, Randy K.