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HomeMy WebLinkAboutNC0000311_Permit (Modification)_20040415 ' * WA7- ) Michael F.Easley,Governor 44Q State of North Carolina CGWilliam G.Ross,Jr.,Secretary Department of Environment and Natural Resources 0 Alan W.Klimek,P.E.,Director Division of Water Quality April 15,2004 Mr. Edwin M.Morrow M-B Industries,Inc. P.O. Box 1118 Rosman,North Carolina 28772 Subject: NPDES Permit Modification Permit Number NC0000311 M-B Industries Transylvania County Dear Mr.Morrow: The Division issued NPDES permit number NC0000311 to M-B Industries for its Rosman facility on April 2, 2001. The Division has reviewed your request for permit modification at the subject facility. Enclosed please find the modified permit page (condition A.(1.)), which becomes effective immediately. This page should be inserted into your permit and the old one discarded. This permit modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.Environmental Protection Agency dated May 9,1994 (or as subsequently amended). This letter authorizes the following permit modifications: ➢ Monitoring frequencies for TSS and oil and grease have been reduced from weekly to 2/Month. ➢ Monitoring frequencies for chromium and zinc have been reduced from 2/Month to monthly. ➢ Monitoring frequencies for phenols, copper, and cyanide have been reduced from monthly to quarterly. In response to your specific requests: • Monitoring frequencies for parameters of concerns (as defined in 40 CRF 433.13) cannot be reduced below quarterly,even though values in your effluent might be low. There are a minimum number of data points that must be collected in order for your effluent to be properly characterized during permit renewal. • Quarterly WET testing is a requirement of the NPDES program for complicated waste streams. The requirement cannot be removed,nor can monitoring be reduced. Also note that your facility failed a WET test in June,2003. • We are unable to alter monitoring frequencies at Outfall 003 due to insufficient data. DWQ only has 5 months of certified (signed) discharge monitoring reports on record for this outfall. This is not enough data to sufficiently characterize this effluent. M-B Industries has requested (and received) changes in monitoring frequency twice within the past 12 months, in addition to a previous request during this permit cycle. Further review of these requirements will be postponed until the permit comes up for renewal in August, 2005. At that time there should be sufficient data to characterize the effluent at all discharge points and re-evaluate monitoring requirements. Please note that a reduction in certain monitoring frequencies at this time does not preclude DWQ from making the permit more stringent should the need arise during renewal. This permit is not transferable. Part II,E.4.addresses the requirements to be followed in case of change in ownership or control of this discharge. This permit does not affect the legal requirement to obtain other permits 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617-TELEPHONE 919-733-5083/FAX 919-733-0719 VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES 4 • which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local government permit that may be required. If you have any questions concerning this permit,please contact Toya Fields at(919)733-083 ext 551. Sincerely C/041 .1(11'")9 Alan W.Klimek,P.E. Cc: Central Files NPDES Permit File Asheville Regional Office Robert Farmer,Point Source Compliance and Enforcement Unit • Permit NC0000311 April 15,2004 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL During the period beginning on the date of this modification and lasting until permit expiration, the Permittee is authorized to discharge from outfall 001 -METAL FINISHING. Such discharges shall be limited and monitored by the Permittee as specified below: 'EF'LtJENT LIMITS MONITO1ING RECIUIREMATTS CHARACTERISTICS Monthly Average Daily Maximum Measurement Sample Type Sample Location Frequency Flow 0.030 MGD Weekly Instantaneous Influent or Effluent pH Between 6 and 9 S.U. Weekly Grab Effluent Total Suspended Solids 31.0 mg/L 60.0 mg/L 2/Month Grab Effluent Oil and Grease 26.0 mg/L 52.0 mg/L 21Month Grab Effluent Phenols Quarterly Grab Effluent Effluent, Temperature("C)' Weekly Grab Upstream, Downstream Total Toxic Organics(TTO)2 2.13 mg/L Monthly Grab Effluent Acute Toxicity3 Quarterly Composite Effluent Cadmium 0.240 mg/L Quarterly Grab Effluent Chromium 1.71 mg/L 2.77 mg/L Monthly Grab Effluent Nickel 2.38 mg/L 3.98 mg/L Quarterly Grab Effluent Copper 2.07 mg/L 3.38 mg/L Quarterly Grab Effluent Cyanide 0.65 mg/L 1.20 mg/L Quarterly Grab Effluent Lead 0.43 mg/L 0.69 mg/L Quarterly Grab Effluent Silver 0.24 mg/L 0.43 mg/L Quarterly Grab Effluent Zinc 1.48 mg/L 2.61 mg/L Monthly Grab Effluent Footnotes: 1. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 0.500 and in no case cause the ambient water temperature to exceed 20°C. 2. In lieu of monitoring for'ITO, the permittee may submit the following certification statement: Based on my inquiry of the person or persons directly responsible for managing compliance with the permit limitation for total toxic organics, I certify that, to the best of my knowledge and belief, no dumping of concentrated toxic organics into the wastewater has occurred since the filing of the last discharge monitoring report. 3. Whole Effluent Toxicity will be assessed using the Acute Toxicity (Fathead Minnow) Pass/Fail at 90% test. See part A.(4.). There shall be no discharge of floating solids or foam visible in other than trace amounts. 01/15/04 THU 09:32 FAX 8288624297 MB INDUSTRIES (J001 r-PiM - B INDUSTRIES, INC. SERVING INDUSTRY SINCE 1894 HWY.64 WEST,P.O. BOX 1118, ROSMAN, NC 28772 PHONE (828) 882-4201. FAX (828) 862-4297 January 13, 2004 Ms.Valerie Stephens NC DENR Water Quality Section 1617 Mail Service Center Raleigh NC 27699-1617 Subject: M-B Industries,Inc. NPDES Permit No. NC000031 I Request for Modification to Water Quality Monitoring Program Dear Ms. Stephens: Altamont Environmental. Inc. (Altamont)is working on behalf of M-B Indusuies, Inc. to modify our water quality monitoring program. The monitoring requirements are described in the above-referenced permit. Mr. Jim McEldutf is the engineer coordinating their efforts. Please accept this letter as notification that they are working on our behalf. If you have any questions, please feel free to contact me at(828) 862-4201. Sincerely, M-B Industries.Inc. 14 /Gvc n..) Edwin Morrow cc: Ms. Kerry Becker, DENR-ARO (828)251-6452 MITCHELL-BISSELL CO. DIVISION SUNBELT SPRING &STAMPING CORP. DIVISION FLAME SPRAY ENGINEERING DIVISION (928) 882-4201 (828) 882-4263 (828) 882-3304 •p ENGINEERING & H Y D R O G E O L O G Y 781/2 PATTON AVE.,ASHEVILLE, NC 28801 TEL.828.281.3350 EAG. 828.281.3351 November 26,2003 www.altamontenvironmental.com Mr.David A. Goodrich NC DENR Water Quality Section 1617 Mail Service Center Raleigh NC 27699-1617 Subject: M-B Industries,Inc. NPDES Permit No.NC0000311 Request for Modification to Water Quality Monitoring Program Dear Mr. Goodrich: Altamont Environmental,Inc. (Altamont)has conducted a review of historic water quality data associated with the M-B Industries,Inc. (M-B). As a result of that review,Altamont is requesting a modification to the water quality monitoring program specified in the above-referenced permit. The M-B facility is located in Rosman,North Carolina. This letter summarizes the data that we have reviewed and concludes with a recommendation for a reduction in the scope of the water quality monitoring program. On October 23,2003,Altamont submitted information pertaining to M-B to Ms.Kerry Becker in the North Carolina Department of Environment and Natural Resources(DENR)Asheville Regional Office. Altamont met to discuss that information with Ms.Becker on November 17,2003. During that meeting, two additional items were discussed:the anticipation of reduced flow through Outfall 001 and the absence of certain monitored inorganic parameters in the M-B processes. Those two additional items are addressed in this letter. Ms.Becker requested that DENR staff in Raleigh contact her during review of the enclosed information. Similarly,if Altamont staff may be of assistance,please do not hesitate to contact our office as well. BACKGROUND M-B currently discharges wastewater at two locations to the West Fork of the French Broad River under NPDES Permit No.NC00003311. Discharge locations include Outfall No. 001 (metal finishing)and Outfall No.003 (groundwater treatment). FINDINGS The monitoring requirements for the NPDES permit were most recently updated by the DENR Division of Water Quality(DWQ)in a letter dated August 21,2003. Water quality data collected since September 17,2001 have been tabulated by Altamont for each of the two outfalls. p:\mitchell-bissellUtr-goodrich.doc//ZP/11-03 Mr.David A. Goodrich November 26,2003 Page 2 of 4 Data for each of these units are presented in the attached tables. Review of the data indicates that only one exceedance of the permit requirements has been detected. A general description of the data follows: Outfall No. 001: • Flow: Changes in process operations are expected to reduce flow during the coming year. • Acute Toxicity:No failures in 7 tests. • Cadmium: No detections in 22 measurements. Cadmium is not used in any processes at the plant;nor is it expected to be used in any future applications. • Chromium:No permit exceedances in 36 measurements. • Copper:No permit exceedances in 21 measurements. • Cyanide:No permit exceedances in 36 measurements. Cyanide is not used in any processes at the plant. Pace Analytical stated in an email to Altamont that their laboratory in Asheville previously had two separate issues that contributed to detections of cyanide. Either could have been the source of the cyanide detections. First,Pace found that if a sample was pulled for cyanide digestion from the metal sample container,and if the sample was high in nitrate, it caused a positive interference for cyanide. This was due to the difference in sample preservative of the two analyses. The Asheville lab no longer does this. Sample volume for cyanide analysis is now pulled from a completely different sample container. Secondly,the Asheville laboratory discovered that glassware contamination caused false positives for cyanide. This issue has also been rectified. As shown in the attached table,there have been no detections of cyanide since January 2003. • Lead: Two detections and no permit exceedances in 36 measurements. • Nickel: Two detections of nickel occurred in 21 measurements. One detection,which occurred on May 5,2003,exceeded the permit limit. • Oil and Grease:No permit exceedances in 67 measurements. • Phenols:No permit exceedances in 36 measurements. • Silver: No detections in 21 measurements. • Total Suspended Solids(TSS): Eleven detections and no permit exceedances in 70 measurements. • Zinc:No permit exceedances in 35 measurements. Outfall No. 003: • Arsenic: No detections in 3 measurements. • Cadmium: One detection in 42 measurements. This concentration did not exceed the permit limit. • Chromium:No permit exceedances in 41 measurements. • Chronic Toxicity:No failures in 6 tests. • Cis-1,2 Dichloroethene:No detections in 4 measurements. p:lmitchell-bissellUtr-goodrich.doc//ZP/11-03 Mr.David A. Goodrich November 26, 2003 Page 3 of 4 • Cyanide: See description for cyanide in section describing"Outfall No.001". • Lead: One detection and no permit exceedances in 34 measurements. • Selenium: No detections in 6 measurements. • Silver. No detections in 3 measurements. • Tetrachloroethene:No detections in 38 measurements. • Trichloroethene:No detections in 38 measurements. • Zinc: Thirteen detections in 41 measurements. • VOCs: There were no detections of VOCs in 2 measurements. CONCLUSIONS Outfall No. 001 Fifteen parameters are measured at Outfall No.001 in frequencies ranging between weekly and quarterly. As shown in the preceding section,some parameters have been measured as many as 70 times. Excluding flow,analytical tests have been conducted 408 times. There has been one exceedance. Two of the monitored parameters,cadmium and cyanide,are not used in processes at the facility. Outfall No. 003 Fourteen parameters are measured at Outfall No. 003 in frequencies ranging between 2/month to quarterly. As shown in the preceding section,some parameters have been measured as many as 42 times. Excluding flow,analytical tests have been conducted 258 times. There have been no exceedances. General Cyanide detections were caused by internal Quality Assurance/Quality Control problems at Pace Analytical laboratory in Asheville. Those issues have been resolved and their have been no detections since January 2003. RECOMMENDATIONS Outfall No. 001 • Weekly: flow,temperature. • Monthly: total toxic organics,zinc • Quarterly: acute toxicity,oil and grease,TSS • Annually: cadmium,chromium,copper,lead,nickel,phenols,silver • Eliminate: cyanide Outfall No. 003 • Continuous: flow • Semi-Annual: cadmium,chromium,zinc,arsenic,lead, selenium, silver,cis-1,2- p:\mitchell-bissell\ltr-goodrich.doc//ZP/11-03 Mr.David A.Goodrich November 26,2003 Page 4 of 4 dichloroethene,tetrachloroethene,trichloroethene • Eliminate: chloride,chronic toxicity,cyanide Mr.Goodrick,thank you for your assistance with this project. I look forward to discussing our request during the next few weeks. Please contact me if you have questions or need additional information. Sincerely, James S.McElduff,P.E. enclosures: Attachment A: Outfall No. 001 data tables Attachment B: Outfall No. 003 data tables cc: Mr.Edwin Morrow,M-B Industries,Inc. Ms.Kerry Becker,DENR-ARO p: ltr-goodrich.doc//ZP/1 1-03