NC0026051_Technical Correction_20100723

415Fr
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
July 23, 2010
Mr. Glen E. Whisler, County Engineer
Durham County
120 E Parrish Street, 1st Floor
Durham, North Carolina 27701
Subject: Technical Corrections
Permit NC0026051
Durham County Triangle WWTP
Durham County
Dear Mr. Whisler:
In response to comments received July 21 from Joe Pearce, Utility Division Manager, please find
enclosed the following corrected pages for the County's NPDES permit, issued July 9, 2010:
• Supplement to Permit Cover Sheet. The facility description is revised to reflect a single 'Sludge
lagoon' rather than multiple 'Sludge lagoons,' and the three references to projected service dates
now specify '2011' instead of '2010.'
• Standard Conditions, Part IV, Section C, Municipal Control of Pollutants from Industrial -Users.
Two grammatical/ typographical errors have been corrected:
• Subparagraph 2.b.5. - 'Heat in amount which will may inhibit' becomes 'Heat in amount
which will inhibit'
• Paragraph 4. -'Industrial User discharging sending to the POTW' becomes 'Industrial User
discharging to the POTW'
Please insert the new pages and discard or strike out the corresponding pages of the permit you
recently received.
These corrections do not alter the issuance or effective dates of the permit, which remain at July 9 and
. August 1, 2010, respectively. Mr. Pearce indicated that the county received the permit on July 12. If the
permit, including these corrections, is not acceptable to the County, its 30-day window to file a petition
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
,Naturally

Mr. Glen E. Whisler, County Engineer
Technical Corrections
July 23, 2010
with the OAH ends on August 11, 2010. Please refer to the July 9 permit cover letter
information and other details.
If you have any questions concerning this permit, please contact Mike Templeton at
[e-mail].
Sincerely,
-�loleen H. Sullins
(
Enclosure: Technical corrections, NC0026051 (3 pages)
Copies: Joseph R. Pearce, Utility Division Manager
Chief, NPDES and Biosolids Permits Section, Region IV, EPA
Raleigh Regional Office, Surface Water Protection
PERCS Unit
NPDES Files
Central Files
for OAH contact
[phone] or at

Permit No. NC0026051
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of
this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements,
terms, and provisions included herein.
Durham County
is hereby authorized to:
1. Continue to operate an existing 12.0 MGD wastewater treatment facility located south of Durham
at the Durham County Triangle WWTP off NC Highway 55 in Durham County. The facility
includes the following treatment components:
• Mechanical fine screens
• Mechanical grit removal
• Parshall flume
• Influent pump station
• Three 5-stage BNR trains
• Four secondary clarifiers
• Five tertiary sand filters
• Ultraviolet disinfection
• Post aeration
• Sludge lagoon
• Waste and return activated sludge pumping system
• Methanol, potassium hydroxide, and sodium hypochlorite storage and feed systems
• Liquid waste activated sludge storage (projected service date is the end of 2011)
• Dewatering facility (projected service date is the end of 2011)
• Truck loading for contract composting operation (projected service date is the end of 2011)
2. Discharge from said treatment works (via Outfall 001) into Northeast Creek, a Class WS-IV NSW
water in the Cape Fear River Basin, at the location specified on the attached map.

NPDES Permit Standard Conditions
Page 15 of 18
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact that may result from the change of the
quantity or quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from industries
using the municipal system may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water
quality standards.
2. Prohibited Discharges
a. Under no circumstances shall the Permittee allow introduction of pollutants or discharges into the waste
treatment system or waste collection system which cause or contribute to Pass Through or Interference as
defined in 15A NCAC 2H.0900 and 40 CFR 403. [40 CFR 403.5 (a) (1)]
b. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment or waste collection system [40 CFR 403.5 (b)]:
• 1. .Pollutants which ,create • a .fire or explosion hazard in the PO'rW, including,. but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
2. Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH
lower than 5.0, unless the works is specifically designed to accommodate such discharges;
3. Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
4. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW;
5. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
6. Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will
cause Interference or Pass Through;
7. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity
that may cause acute worker health and safety problems;
8. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the permittee's Pretreatment Program
and/or the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional
Office. Any information shall be provided orally within 24 hours from the time the Permittee became
aware of the circumstances. A written submission shall also be provided within 5 days of the time the
Permittee becomes aware of the circumstances. The written submission shall contain a description of the
discharge, the investigation into possible sources; the period of the discharge, including exact dates and
times; and if the discharge has not ceased, the anticipated time it is expected to continue; and steps taken
or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance,
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance
Version 7/1/2010

Templeton, Mike
To: [e-mail]
Cc: [e-mail]; [e-mail]; Poupart, Jeff
Subject: FW: Intent to Modify NPDES Permit NC0026051
Joe -
Thanks for your detailed comments on the final permit. I have copied the comments below and inserted responses to
each one. And I have additional remarks after that, including a significant request for clarification.
From: [e-mail][mailto:[e-mail]]
Sent: Thursday, July 22, 2010 12:00 PM
To: Templeton, Mike
Subject: RE: Administrative Errors in NC0026051 Permit
Cover Letter
• The cover letter has a Memorandum of Agreement (MOA) date of October 15, 2007. We recently
went into a new MOA approved by DWQ on May 1, 2010.
[MET] No correction is necessary. The cover letter refers to the NPDES program MOA between DWQ and Region 4 of
the USEPA, which was most recently revised on 10.15.2007.
Supplement to Permit Cover Sheet
• #1 — sludge lagoons should be lagoon (not plural)
• #1 — Projected service date for the liquid waste activated sludge storage, dewatering facility and
truck loading for contract composting operation should be 2011 not 2010. Note the plans are at
CG&I under review; hopefully we will have our approval soon.
[MET] Corrections noted. Also noted that the County did not mention these errors during the extended public
comment period.
Effluent Limitations & Monitoring Requirements
• The daily maximum for total residual chlorine should be modified to 50 ug/1 based on the attached
letter issued by DWQ on May 1, 2008. Durham County does not use chlorine for disinfection but
we are required annually to analyze chlorine as part of the Priority Pollutant Analysis (PPA).
[MET] No correction is necessary. The 17 ug/L limit is based on the surface water standard for chlorine and the plant's
instream waste concentration and is correctly applied. The 5.1.2008 memo explains that, due to difficulties with the
TRC analytical method, DWQ is now treating any reported value <50 ug/L as zero for compliance purposes. As
analytical methods improve in the future, we will lower that 'compliance level' accordingly.
Part IV Special Conditions
Section C, Municipal Control of Pollutants from IU
[MET] Thanks for catching these errors.
• #2.b.5 — grammatical issue, Heat in amount which will may inhibit
[MET] "will" is the correct choice; this language is taken directly from 40 CFR 403.5(b)(5), cited.
• #4 — grammatical issue, Industrial User discharging sending to the POTW.....
[METJ "discharging" is the word of choice, though the error does not significantly alter the meaning of the passage.
1

Lastly, the Total Nitrogen Allocation was not assigned by rule to be effective at this time. Can you
explain why it is being applied to this facility at this time, instead of later like all of the other dischargers
in the Upper New Hope Arm?
[MET] l applied the increased TN limit at this time in response to your request on behalf of the County to do so. Here is
your original request and the ensuing e-mail thread:
PREVIOUS MESSAGE & THREAD:
From: [e-mail][mailto:[e-mail]]
Sent: Thursday, October 08, 2009 9:25 AM
To: Templeton, Mike
Cc: [e-mail]
Subject: Intent to Modify NPDES Permit NC0026051
Mike,
We have received the October 1, 2009 letter. The letter was based upon the generic letter sent to other large dischargers to
which the Jordan Lake rules apply. As you probably know, the Durham County Triangle Wastewater Treatment Plant was
upgraded in 2005 to a 5-stage Enhanced Biological Nutrient Removal facility. It is not appropriate for our NPDES permit to be
modified with the TN process optimization requirement. It is appropriate that NC0026051 be modified to a TN load limit of
111,207 pounds per year and a TP limit of 8,432 pounds per year with the permit modifications (to be completed by the end of
2009). This modification was publicly discussed and agreed upon with both Coleen Sullins and Dave Goodrich over a year ago
during a stakeholders meeting. Let me know if this is going to be a problem at your earliest convenience.
Thanks,
Joe
Joseph Pearce PE
Utility Division Manager
Durham County Engineering Department
[phone]
fax: [phone]
From: Templeton, Mike [mailto:[e-mail]]
Sent: Thursday, October 08, 2009 9:46 AM
To: Pearce, Joseph R.
Subject: RE: Intent to Modify NPDES Permit NC0026051
Joe - Points well taken, and I don't see a problem with modifying the TN limit now. Just so I have my facts straight when I
talk to Coleen, can you be more specific about which meeting you had with her and Dave? I don't recall this being discussed in
the Jordan Lake stakeholder meetings, but then I might have missed it. Also, Dave left the NPDES program in Jan 2006 so it was
well over a year ago that you met. — Mike T
From: [e-mail] [mailto:[e-mail]]
Sent: Thursday, October 08, 2009 11:45 AM
To: Templeton, Mike
Subject: RE: Intent to Modify NPDES Permit NC0026051
Mike,
believe the discussion was at the August 10, 2005 stakeholder meeting at TJCOG. Dave was talking about how this
proposed rule would actually benefit one facility, the Triangle WWTP.
Joe
Your final question today leaves the County's position in some doubt. Please verify at your earliest position whether the
County is now asking DWQ to restore the previous TN limit of 100,452 Ib/yr until 2016.
2

Depending on your response, here are my next steps:
• If you choose to keep the current TN limit, I can complete the minor corrections to the Supplement to Permit
Cover Sheet and to Part IV of the Standard Conditions and forward the affected pages to you next week.
• If you choose to revert to the previous TN limit, we more -or -less start over, and the permit must go out for
another round of public review. In that case, I will include all of the corrections in a new draft permit.
• In either case I will forward the Standard Conditions corrections you noted to be included in that boilerplate
language.
I expect to be out of the office Friday morning, returning for the afternoon. Feel free to call if you have any other
questions or comments regarding the permit.
- Mike T
Michael E. Templeton, P.E.
Point Source Branch/ NPDES
Surface Water Protection Section
NCDENR • DWQ Raleigh, NC
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
3

Templeton, Mike
From:
Sent:
To:
Subject:
Attachments:
Cover Letter
jpearce©co.durham.nc.us
Thursday, July 22, 2010 12:00 PM
Templeton, Mike
RE: Administrative Errors in NC0026051 Permit
TRC Compliance Letter.pdf
P si a r-4 6
cv► .: t-• ' is e4 µ- . lLt I•t11�S'
\1,. di,; d per"
• The cover letter has a Memoz dum of Agreement (MOA) date of October 15, 2007. We recently
went into a new MOA appred by DWQ on May 1, 2010.
C . 4-1.,,NIQA- be v t�v l9:', t . v. ,,J. to • / S .01,
Supplement to Permit Cover Sheet
• #1 — sludge lagoons should be lagoon (not plural)
• #1 — Projected service date for the liquid waste activated sludge storage, dewatering facility and
truck loading for contract composting operation should be 2011 not 2010. Note the plans are at
CG&I. under review; hopefully we will have our approval soon. 00" eAlu.
Effluent Limitations & Monitoring Requirements
• The daily maximum for total residual chlorine should be modified to 50 ug/1 based on the attached
letter issued by DWQ on May 1, 2008. Durham County does not use chlorine for disinfection but
we are required annually to analyze chlorine as part of the Priority Pollutant Analysis (PPA).
` rto rt k 1 L. 'ts T(-L s-+-444-el l 11 C
Part IV Special Conditions is Ly '1,.,_ 5.1.%
Section C, Municipal Control of Pollutants from IU
• #2.b.5 — grammatical issue, Heat in amount which wi i sit 4, SO
• #4 -fratical issue In us,trial,User discharging sendingto the POTW....
�., Is �"'' aei.565� `J g g
1'� �t i
Lastly, tI o agen Ato lion was not assigned by rule to be effective at this time
explain why it is being applied to this facility at this time, instead of later like all of the other dischargers
in the Upper New Hope Arm?
Joe
From: Templeton, Mike [mailto:[e-mail]]
Sent: Thursday, July 22, 2010 11:30 AM
To: Pearce, Joseph R.
Cc: Brixey, Stephanie; Whisler, Glen; Poupart, Jeff
Subject: RE: Administrative Errors in NC0026051 Permit
Hi, Joe - Hope you're doing well.
"Is DWQ amenable to correcting or would you prefer we just file an appeal?"
So what's *that* all about?! You know we're always ready to correct simple errors in our permits and that, except where
those result in substantive errors as well, we can simply send a fresh copy of the permit with the necessary corrections.
That Durham County is prepared to adjudicate its permit suggests that some of the errors you found could be more
substantive. If that is the case, we might have to re -notice the permit to make those changes.
1

Please send me a list of the errors you've identified or fax me a markup of the affected pages. I will review them and let
you know in short order how we propose to address each point. Then the County can decide whether it is satisfied with
that response and, if not, how it wishes to proceed.
I look forward to your response.
- Mike T
Michael E. Templeton, P.E.
Point Source Branch/ NPDES
Surface Water Protection Section
NCDENR • DWQ Raleigh, NC
Tel: [phone]
Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, July 21, 2010 5:02 PM
To: Templeton, Mike
Cc: [e-mail]
Subject: Administrative Errors in NC0026051 Permit
Mike,
There are some typo's and admin errors in the permit which we received. Is DWQ amenable to correcting or would you
prefer we just file an appeal?
Joe
Joseph Pearce PE
Utility Division Manager
Durham County Engineering Department
[phone]
fax: [phone]
"This message is being sent on a public e-mail system and may be subject to disclosure under the North Carolina Public
Records Act."
"This message is being sent on a public e-mail system and may be subject to disclosure under the North Carolina Public
Records Act."
2

Templeton, Mike
• From: [e-mail]
Sent: Friday, July 23, 2010 10:03 AM
To: Templeton, Mike
Cc: [e-mail]; [e-mail]; Poupart, Jeff
Subject: RE: Intent to Modify NPDES Permit NC0026051
Mike,
You were able to find my old email, and we could choose to stand behind it and not appeal. However, we could also
choose to change our minds similar to what DWQ is doing with the reuse water blowoff approval. You probably have
not dealt with that issue, but Matt Matthews definitely did and Jeff Poupart may be aware of the issue. Probably the
best thing at this point is for DWQ to reissue the permit with the corrections, and we will consider whether we wish to
appeal the permit limit.
We received the permit on July 12, 2010, and we understand that our appeal must be made by August 11, 2010. Will we
receive the modified permit prior to August 11, 2010?
Joe
Joseph Pearce PE
Utility Division Manager
Durham County Engineering Department
[phone]
fax: [phone]
From: Templeton, Mike [mailto:[e-mail]]
Sent: Friday, July 23, 2010 9:38 AM
To: Pearce, Joseph R.
Cc: Brixey, Stephanie; Whisler, Glen; Poupart, Jeff
Subject: FW: Intent to Modify NPDES Permit NC0026051
Joe -
Thanks for your detailed comments on the final permit. I have copied the comments below and inserted responses to
each one. And I have additional remarks after that, including a significant request for clarification.
From: [e-mail][mailto:[e-mail]]
Sent: Thursday, July 22, 2010 12:00 PM
To: Templeton, Mike
Subject: RE: Administrative Errors in NC0026051 Permit
Cover Letter
• The cover letter has a Memorandum of Agreement (MOA) date of October 15, 2007. We recently
went into a new MOA approved by DWQ on May 1, 2010.
[MET] No correction is necessary. The cover letter refers to the NPDES program MOA between DWQ and Region 4 of
the USEPA, which was most recently revised on 10.15.2007.
1