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Home My WebLink AboutNC0004685_Wasteload Allocation_19961115DIVISION OF WATER QUALITY November 15, 1996 MEMORANDUM TO: John Le THRU: Don S Ruth anek 'qq Carla Sanderson FROM: Jacquelyn M. Nowell��\p, SUBJECT: PPG Industries -Shelby Plant SOC Interim Fluoride Recommendation NPDES Permit No. NC0004685 Cleveland County The Instream Assessment Unit (IAU) has reviewed the request for interim limits for fluoride during the proposed SOC for PPG Industries. The existing permit limit of 5.4 mg/1 for fluoride was exceeded in March 1996 according PPG's daily monitoring reports. However, the DMRs show that was the only exceedance to occur in 1995 and thus far in 1996. If the one permit violation is excluded, in the past two years, fluoride values have ranged from 1.1 mg/1 to 5.0 mg/l. IAU reviewed the possibly of giving a weekly average limit in addition to a daily maximum limit but since there is no federal acute criteria for the fluoride parameter, this could not be done. Therefore, it is our recommendation that the SOC contain weekly effluent monitoring only for fluoride and allow the limit of 5.4 mg/1 to be reinstated at the expiration of the SOC. When toxicity is monitored, it should coincide with the weekly monitoring of fluoride. Additionally, we will concur with any recommendation rendered by the Environmental Science Branch concerning the most effective way for PPG Industries to correct and solve their whole effluent toxicity problems. Please contact me if there are questions. cc: Rex Gleason WLA Files DIVISION OF WATER QUALITY October 25, 1996 Memorandum: 11 TO: Carla Sanderson, Rapid Assessment Group FROM: John Lesley, MRO v� Aoy SUBJECT: PPG Shelby SOC interim limits NPDES Permit No. NC0004685 Cleveland County, NC Carla, please provide suggested limits for Fluoride to be included in the subject SOC. PPG discharges into Brushy Creek (BRD04, 7Q10 = 4.0, IWC = 33%, Class C). Fluoride limits are needed because the facility will be conducting tests to determine if conductivity is a causitive agent in their toxicity noncompliance. In order to explore this, the addition of aluminum chloride for fluoride removal may need to be modified which would likely lead to an exceedance of the NPDES Permit limit according to the facility's consultants, Aware Environmental. The facility has a 5.4 mg/1 daily max. limit and has reported values up to 7.6 mg/l in the past 12 month period. Would a "monitoring only" requirement be appropriate for fluoride? Any recommendations you could make would be most appreciated. Thanks JL. PPG INDUSTRIES-SHELBY PLT. JMN BRUSHY CREEK 11/13/96 030804 MRO requesting fluoride limits for pending SOC for facility. PPG manufactures fiberglass for reinforced plastics and other applications. Has been failing toxicity test for approx. 1 1/2 years and is looking into ways to correct the problem. They use aluminum chloride for fluoride removal and in trying to correct the tox problem, will be using less aluminum chloride and they are anticipating F► effluent levels to increase. MRO would like to know if a higher Fl limit during the SOC is appropriate or whether to just recommend Fl monitoring. Existing Fl limit =5.4 mg/l, however since there is no acute value for fluoride, cannot recommend a weekly average/daily max. limit . Will have to recommend effluent monitoring only for the life of the SOC and resume the limit of 5.4 mg/l at the expiration of the SOC. Reasonable potential analysis for fluoride: with 62 obs. from 1995 and 1996, max. value of 7.6 mg/l, analysis indicates that limit is still necessary. Toxicity test results - IWC of 33% - PPG has consistently failed the chronic test since May, 1995. Only Passes in Sep. 1995 and Jan. and June, 1996. Prior to May 1995, PPG only FAILs in Jan. 1993 and Apr. 1994. PPG has been targeted for compliance evaluation for whole effluent toxicity limits by ESB. MRO sent recommendation for enforcement sent to facility on July 22, 1996. PPG responded that they thought that source of toxicity had been eliminated. Telecon w/ Kevin Bowden of ESB- called to talk about recommendation of monthly toxicity monitoring during the SOC. Kevin indicated that ESB was recommending in a letter to MRO that PPG have a quarterly full range testing requirement during the SOC. ESB feels that the multiple concentration full range testing, using the LC50 or chronic value, allows the facility to see the trends in toxicity reduction and allows them to get a better idea of how close or how far they are from meeting the toxicity limit. ESB prefers this test over monthly P/F testing which may not give provide facility with enough information as to how far they are from meeting the tox limit. ESB is recommending that PPG achieve compliance by the Jan. 31, 1998 (SOC expiration date). Will send me ESB's 5/96 comments on PPGs TRE. PPG has been addressing toxicity problems from a treatability standpoint (ie treating at the end of pipe) instead of source reduction and effluent characterization. ESB feels that PPG $ could be better spent by looking at the source reduction. ESB notes that facility has had high effluent Cu in the past, up to 126 µg/l resulting in a predicted instream concentration of 41-42 µg/1. RECOMMENDATION: Monthly effluent monitoring for fluoride during SOC (instead of a higher effluent limitation) and will defer to ESB on recommendation for toxicity testing during the SOC. Faclky Name NPOES a irK000/886 Cw !MGC! _.._.._.._.._.._.._.._.•1.9 ........................ IOS 10IV,C(Y�0 l �_.._.._.._.._.._.._.._.._ IIVC ! ._.._.._.._.._.._..__._ RecYkrg Stream !brushy fork Seven) Clew !a,,,_.._.._.._.._.._.._.._.. Mu. Prod Cw Allowable Cw Mo. Value Mo. Prod Cw Allowable Cw Max, Value Mu. Pled Cw Allow" Cw Max. Value Max. Pled Cw Allowable Cw Max. Value Max. Pred Cw alowaole Cw Max. Value Mo. Pled Cw Allow lob Cw Max. Value 0 Max. P W Cw Allowable Cw Max. Value 0 Max. Prod Cw Allowable Cw Mao. Value 0 Mat. Pred Cw Allowable Cw Mat. Value 0 Max. Pred Cw Allowable Cw Mat. Value 0 Mao. Pred Cw Allowable Cw Max. Value 0 Max. Neel Cw 11/12M eVALUEI eVALUEI aVALUEI aVALUEI RVALUEI Palemwer- 1luorMa s._.._.._.._.._. SlarMad- n BOL-1/PDL Adual Data 1 2910 2910 2 1480 1480 3 4670 4670 4 4650 4050 5 3700 3700 6 4470 4470 7 3800 3800 8 5070 5070 9 4300 4300 10 3560 3560 11 3820 3820 12 4290 4290 13 3790 3790 14 3900 3900 15 4100 4100 16 7600 7600 17 4690 4690 13 5330 5330 19 3680 3050 20 3600 3600 21 4610 4510 22 3600 3600 23 3020 3020 24 3650 3650 25 3900 3900 26 5000 5000 27 3890 3890 28 3290 3290 29 2640 2640 30 3520 3520 31 4140 4140 32 3160 3150 33 3470 3470 34 1580 1580 35 3550 3550 36 2740 2740 37 3920 3920 39 2340 2340 39 4030 4030 40 3760 3760 41 M70 3270 42 3010 3010 43 3600 36M 44 2800 2800 45 2730 2730 46 2550 2550 47 2810 2810 48 3140 3140 49 1520 1620 50 1790 1790 51 1450 1450 52 2460 2450 53 2320 2320 54 2460 2460 55 25M 2520 56 1410 1410 57 1450 1460 59 2540 2540 59 2790 2790 60 1120 1120 61 1310 1310 62 1430 1430 RESULTS Sol Dev. 1184.198593 Mean 3281.] 4194 C.V. 0.360840973 MuB Factor- t.3 Max. Value 7800 yyl Max. Prod Cw 9880 yp4 Allowable Cw 537320 yy4 3/3Ir/1/ WHOLE EFFLUENT TOXICITY TESTING OISELF-MONrr(W.INQ SUMMARY] T11u,Scp19,19% ( REQUIREMENT I'Hn AIC slip IX IV DFC P61111po PI.O.S Co. PERM 2e1111 P/F AC LW', 90% V 92 — — Pete! — — Puat — — P..A — — Peat NCO0016{IA101 BcSia:1/193 Fnq- ..Q P/F 6 Mw Ju Sep Doe No.Caelp:SING1E 0 — — Puat — — Pnel — — PI Cow9y:Cnw ReSwe:WARO SIW--:NEU10 Re— _ P..w — — Pes.I — — ... p — — New PF:010 Sp w M _ _ Pu.I — — P... — — ... I Peu — — — — Nwp.W P.0 7Q10: TWAI_ IWf(%): 100 fxJm R6 — — Pu. — — Pass — Pilot Mw.l.l. WWTP PERM CIIR LIM: ", 5% 0 EAP B RELOC, 3% O RMOC Y 92 61.2 — — 61 NCOD26616U01 BcW.YI/93 PooF :QPM A WAM JW Oa No.Comp.SWliIE 0 el — — 21 21 — NIWA FM Fee 71 — Cow.JY:Srm, Rey". WSRO S-Ab..r: YA00] W n3 — _ 96 _ — 76 — — 159 PP L5 Spew SOC:90/93-7/1/% MONIT Q CIV(75.1.5.3.0.60.1201 JAIO o`o Ise — — NWJ6.% — — 16.6 — — 35 — 7QI00,153 MQ%)9392 O'de " 7.1 — — e6.0 — _ Fol P1..Iepa WWTP IM CIIR TAR: 61% 92 Fees — — M Fal Po. Peso — — p... — _ NC00301]SAYII Iky.: SOINI FaF-ucYQ U.Ap JdW NoaCo 9D P... — — P.n — — Pe.. — coewy:EulYanaoAe Rgws: RRO SWAuie TAR03 w L.W,FM L..LeNI — P... — — P. — — — P... F.e — PF:O.J Spoew 95 Pu. — — Fee FMJ'u. — Pew — — p... 7QI00.3 W(S)W78 0"W 96 P... — — pu. — — Late P.0 Pkntetlo. Pipeline Co. (MI) N. 2e1v lC50.c mwu rykfAJ IV.M 62 WW51161A01 &,,;z WIM FwFwncY A NoaCowP. 0 Co., fiWfW ReSi": WSRO Subb.aie: CPPo6 W — — — alOd — _ _ alOp — -_ — PF'. SI w K _ _ _.1w— _ _ _ — 7QI0.00 IWf(%)NA qJ¢ oe _ _ _ _ aIOD— Pb.J.O.. Plpell.. Co. (W2) Porn 24W lC50 ec nano ryn 6W(V.b) 92 — — — a10p,a1001 elm>1W lim— NLW51161AI02 BcSu: ]/1% Fmprnry: A Nw'.wp 0 _ — — _ Coowoy:Geilfand Rehm: WSRO Subb . CPIO W — — _ a1001 _ — _ >1001 .Iw PK Spalat 06 _ _ _ >1001- — 7Q100.00 IWf/%): NA °'d.: w — _ — aIw — — PP(: Isd.atrW W. cb ban. e9% 92 — Labe M MJ Fed P... — Pau P... M(0001636r001 B.y.: WIA5 Pmyunlry: Q P0' 6 ikb Mq A.l Nov Nwd'." Sw{k 93 — Pu. — _ FW Fw FM FM Po. — Pee. — C.,Dor R-Iiw:WSRO SWAwi.. YADDI 9e — P... — — Fee pne Fry.) p... — FW Few.) PK 0.6 Speckl N FM FW FM Fell Fw Fw FM FW Fee Fee fee Pn. 7QI0. 1.0 IWC(%):.{ 19 Gd'r 96 — Fell Fal Pau Fee P... — PPG.Sbelby -NI WAM CIIR LIM: 13% V 92 P... — — P.w.P.n — — P.0 — — p... — NL00016L%WI Bey.:1111M Fool . Q P/F A J. Ape JW W N..Coanp S-.{k M FM P... — P.0 — — p... — Co.atr:ClevcJwl R.65": MRO SWAwb: BRIM 91 Po. — — Fal P... — Pen — — — p... I.'. — p... PF: 1.3 SprcW " p... — — Fol FM Fol Fr10 F.qp P.aata) FmNa) F.JbI F.R.) 7QIO: eO 1WQ%):33 adee 06 P... FW FW Fw Fail P.0 F"Y" Prl.c.Jn. WWTP PERM CIIR LIM: 7% 92 M M P.aa.P — — Pe.. _ — p... NCw2666LO01 Be'Resnm hoe :QP/F d Mee I. SePOs Neecoo,,swoIP. 0 — — p... — — P.. — — p... -- — Low Cou-Y:JaI"we Rey": RRO Subba.i.: NI:U06 W F".P.e. — P... — — NJW.a — — P... — -_ Poo. PF: 0.275 S"W 95 — — P... — — Pm — — Pau — — pq. 7QI0. 550 IWC(%R7.19 J]'dlc W — -- Pere — — Pm — Peoew We. PERM CIIR LIM: 1.7% 02 — — fd FM Foe Fol P. — paae P.a. N 57010)1 11ryW:8/I/96 Foo c :Q P/F A MwJ"Sep Dec N"C.n, sINC.IE 92 — — I" P... — Pen — — P... — — p... Co...,. Surry RcS1ae:WSRO SWAwi.: YAOW IN — — Fue Pees — Pno — — pun — — fol PF 0065 S"W 95 P... — Pea. — — Pu. — — p... -- — Pen 7QIO /9 IWC(%):17 ( *: N — -- P... — — Pao. — PVA/Mo.... h Ise. Pawahr Ilan 90%(Grd) 02 WW15561/W1 Begs: Vll96 Fex- QPO' 6 Mu lw Scp Ua N..C..np Sw.k 0 C....y. MncklwduS Re,.: MRO SWAsai.: Mu W P12 00216 Spnl.l 95 7Q10. 00 IWC(%): IM 96 R.ef.rd WWTP PIDlMC11RLIM: 9%INc.pw ]/IN61 W Pu. P.n — — Pee. — — p.» N1002651A1011I Bcyoa2/INI Fog :QIll; A 12b May A.S Nor NoeCowp.Sm{le 93 — NWP.0 — — p... — — p.» — -- P.» — Cou-Y:Ibtr Rc ":FRO SulAuset:CPFIS W — p... — -- Pu. — — P.sa _ — _ -- p... P.v. _ _. NO 30 $,,,W 95 — I'u. — — p..e - — Peu — — IW» - 7Q10.e90 IWf(%1'.667 (odor N — NJWna -- -- p... _ ... 0 2me.¢wm fuluan.=ulmNc.w ownompL.wz V P. 1w1 Du. ArwlaWe 1)911'NR ml(M=Venan-RNuoeooee IJff.AdnliwVwiveln-er To,, 1'nyueery=M-almoulanyrcany Q-(Nmnly:M-MwOdy:bM- BlnnidJYSA]enw n"I,A-Annuoly,OWD (Wywl.enJweog{x{.0 lhuwn�ni.eJ nua�n.uw a.IS I'wNw nn L ,Jew unit bore=We-mwlhmwwed 7QI0.Rrcdrw1.ovuo Wwl wcn,enwlcfdl 6= umcdy wonnunn wnuxnlJ N'nrvucnu pw Vn y { nrrtaA y upon ain9le Clue M�+o-lu Nw a.un{ own a'cw n. IAN,AI'It.11ll_(NT N.A'w,p -1'wvm Cw,yJu.e Nwryimn>w a 1'F=Pomu.fI..J IWC%.Ie.W..... a...rW" `Io-lJ—.lcW.ww ua- AC=A.wc CI �('luw-c Iw. Nw.-iw f pulreJ Miwww: • CmadaAane ce -. mr , MYJW Jhnnw: (TV (luwu vd.e. P Alnnalnr W uucJ ocuewre u IJWwu cwrcm�uwiw: w - 1'o L,rneJ br INiM Tan IirJ Grwp, k Doi.. Nrpwuo{N.J->w:=U+w nw JcyuueJ, NN NW rtpumd;l )-OcOrc"n6WQuurw PrdnyAarnY Sww.IInrtiro,NNcwIY l..ucJ(locwuwop:IL Ac-rrc lw-owJ-uhnb'n6,tMure Ja-uvwlabk lm mmulnnyuc.-wn I-uNCu9naua m+kJ j 38 Facilities with >_6 Toxicity Permit Limn Violation Failures From August 1, 1995 July 31, 1996 rmi Region # Violations ENilb PeNO, O1 g Highlands Camp NC0061123 O1 7 Metal industries NC0057819 03 7 Alumax Extrusions NCO048712 03 10 PPG -Shelby NC0004685 Comments Facility initiated pre/post chlorination testing in 2/96. "Fail" test results reported in May, June, and July 1996, No additional information on facility's progress to reduce effluent toxicity. CBI conducted on 5/7/96- 48-h Ceriodaphnia du nc LC50 result measured ,600 Copper ' concentrations measured 2.000 µgA and Ni concentrations measttr'iance. µg/I• No additional information on facility's actions to address toxicity noncomp Notice of Recommendation for Enforcement sent to facility on 7122/96 for toxicity permit limit violations. Notice of Recommendation for Enforcement sent to facility on 7/22/96. Facility responded eliminated. Facility has submitted application for SOC which is being Processed. to Notice with a letter dated 8/1/96 indicating that they felt cause(s) of toxicity ha een This list contains the most recent facility status information which has been presented to this ()free. Should the inl'omiation need updating, please advise' Facilities Targeted for Compliance Evaluation for Whole Effluent Toxicity Limits:July, 1996 September 19, 1996 Reg Facility NPDES Date County it Requirement ARO Buncombe County MSD NCO024911/001 7/23/96 Buncombe 4 Perm chr lim: 12% & 24hr p/f ac lim 90% Ithd ARO Burnsville WWTP NCO020290/001 7/8/96 Yancey 1 PERM CHR LIM: 6% ARO Cranston Print Works NC0000094/001 7/15/96 Henderson 2 Perm chr lim: 1.9% ARO Dupont-Brevard NC0000337/001 7/15196 Transylvania 2 Perm chr lim: 24% ARO Etowah WWTP NCO071323/001 7/22/96 Henderson 2 Perm chr lim: 54%; when relocate to French Broad no tox ARO Highlands Camp & Conf Center NCO061123/001 7/10/96 Macon 9 PERM CHR LIM: 90% (Grab) ARO Metal Industries NCO057819/001 7117/96 McDowell 7 PERM 48HR LC50 AC LIM: 77% (GRAB) ARO Spindale WWTP NCO020664/001 7/22/96 Rutherford 4 PERM CHR LIM: 73%; WHEN RELOC. TO CATHEY'S CRK. FRO Mt. Gilead WWTP NCO021105/001 7/29/96 Montgomery 2 PERM CHR LIM: 69%; IF RELOC TO PEE DEE CHR LIM 3.21 FRO Star WWTP NCO058548/001 7/23/96 Montgomery 1 Perm chr lim: 90% FRO Swift Textiles NC0001406/001 7/23/96 Harnett 1 PERM 48HR LC50 AC LIM: 66% (CERIO OR DAPH) MRO Alumax Extrusions, Inc. NCO048712/001 7/23/96 Catawba 7 Perm 24hr ac p/f lim: 90% fthd MRO Claremont North WWTP NCO032662/001 7/22/96 Catawba 1 Perm chr lim: 13% MRO Oakboro WWTP NCO043532/001 7/22/96 Stanly 1 PERM CHR LIM: 19%, 2.6% ® REL TO ROCKY R. MRO PPG -Shelby -001 NC0004685/001 7/8/96 Cleveland 10 PERM CHR LIM: 33% MRO PPG -Shelby -001 NC0004685/001 7/22/96 Cleveland 10 PERM CHR LIM: 33% MRO Stanley WWTP NCO020036/001 7/8/96 Gaston 4 Perm chr lim: 74%; if PF 1.0 chr lim 79% MRO Textron, Inc. NCO084662/001 7/22/96 Gaston 1 Perm chr lim: 66% RRO Allied Signal Fibers/001 NC0001899/001 7/9/96 Chatham 4 PERM: 48HR LC50 AC LIM 90% CERIO OR DAPH RRO Fuquay-Varina/ Kenneth Br WWTP NCO028118/001 7/8/96 Wake 3 PERM CHR LIM: 90% (New perm 9/1/96) RRO Wand Transformer Co, Inc. NCO045608/001 7/30196 Wake -i 1 PERM CHR LIM: 90% WSRO ABTco, Inc. NC0005266/001 7/9/96 Wilkes 5 PERM: 48HR LC50 AC LIM 68% WSRO LCP Plastics NCO036366/001 7/17/96 Guilford 5 Perm chr lim: 90% (Grab) 1 WSRO Pilot Mountain WWTP NCO026646/001 7/29/96 Surry 1 1 SOC: 9/7/93-7/1/96 MONIT O ChV (.75,1.5,3.0,6112.0) JA # indicates number of targeted events since August 1, 1995 NC DEM lC ENVSCI �oaa»v� Fax:919-733-9959 Nov 13 '96 11:23 DIVISION OF ENVIRONMENTAL MANAGEMENT To: Rex Gleason / Tbm: Carty Ansley, Matt Maultews rnt^ From: Kevin Bowden rV May 29,1996 F. 01iO3 �'ctc. •imp SUBJECT: Toxicity Reduction Evaluation Progress Report -April 1996 PPG Industries -Shelby NPDES Permit No. NCO004685 Cleveland County This office has received and reviewed a copy of the facility's Toxicity Reduction Evaluation Progress Report dated April 1996. The report has been prepared by the facility's toxicity consultant, AWARE Environmental, Incorporated (AEl). This progress report contains an executive summary, a monthly listing of THE activities undertaken from June 1995 through April 1996, and suggested recommendations for ongoing THE activities. Toe report cites two factors which appear to be related to effluent toxicity. The first factor involves an increase in the use of chemicals such as lime and aluminum chloride to control effluent solids and turbidity. The second factor involves the intermittent discharge of a manufacturing plant wastesrream to the treatment system which contains an "acutely toxic material." The facility is proposing a bench scale study to determine if the toxicant(s) can be removed via use of activated carbon. The facility will also employ fractionation testing to "identify the toxic component of the sample" once a sample has been collected which contains the "acutely toxic material" , 71W facility has been unable to consistently comply with its 33% chronic permit limitation since April 1995. In June 1995, the facility contracted with AWARE Environmental to assist with reconunendations concerning "system effluent quality," In August 1995, after experiencing five consecutive toxicity test failures, the facility expanded their efforts to also include activities to reduce and/or eliminate whole effluent toxicity. Section 2 of the: submittal provides a chronology of THE efforts beginning in June 1995 and continuing through April 1996, Our comments addressing THE activities conducted during each month are presented below. Sebtion 2.1 June 1995 - In late June 1995 the facility and AWARE met and discussed a plan of action to improve WWTP performance. On -site jar testing was conducted to determine polymer dosage rates to achieve optimum removal of fluoride and turbidity in the effluent. The facility split toxicity samples from June 1995 through January 1996 in hopes of "evaluating the original labs results." Our previous comments to you contained in correspondence dated February 16, 1996, stated out concerns that split sampling would not determine causative toxicants in the facility's wastestteam. Seption 2.2 - July-1995 - AEI conducted approximately 125 jar tests with lime and alum to determineioptimum pH range and dosage rates. The facility began a program to feed bacterial cultures in an effort to reduce toxicity. Attachment B contains literature concerning this effort which encompasses a treatability approach to toxicity. The attempt to treat toxicity was unsuccessful.. We once again stress the importance of source reduction activities which have proven to be a cost-effective means to reducing/e irninatien toxicity in a facility's effluent. Section 2.3 - August 1995 -The facility conducted a second set of jar tests to rank "binders" which- appeared to be the major cause of toxicity. Binders are a material used during a step in the fiberglass, manufacturing process. The binders were evaluated to determine relative contribution to effluent turbidity some of which were shown to be "untreatable" Technical personnel in the Binder Development Department at PPG determined that some binders were more difficult to treat and that these binders contained the highest percentage of non-ionic surfactants. Operating data from early 1995 to July 1995 was evaluated which showed an apparent correlation between effluent TDS levels and toxicity. The NC DEM li'C EWSCI Fax:919-733-9959 Nov 13 '96 11:24 P.02iO3 Page 2 PPG -Shelby Progress Report -April 1996 May 29,1996 facility evaluated the system's sand filters in an effort to determine what.may be causing slime development on the media and walls of the sand filter. Several polymer manufacturers were consulted to provide insight on polymer toxicity. One polymer manufacturer suggested the facility conduct a bench scale study with bentonite clay. to determine if toxicity could be reduced. The report mentions the facility's intent to seek a "method of removing fret flocculant." Station 2.4 - September 1995 - Bench scale studies conducted to, determine polymer dosage concentrations were inconclusive. Based on information provided by product vendors, the facility conducted a treatability study using bentonite clay. Two grab samples were pulled from the effluent pump suction tank with one sample serving as the control while the other sample was dosed with 500 mg/i of bentonite clay. Both the control and treatment sample failed. The report does not address TDS concentrations and whether TDS concentrations may have affected the test result(s) in this study. Section 2.5 - October 1995 - No additional bench scale work was conducted due to passing test results obtained for September 1995. Section 2.6 - November 1995 - The facility initiated ten (10) bench scale studies which appear in Table 4, All effluent samples treated with physicalibiological methods failed while all influent samples subjected to chemical/biological treatment passed. The report states, "This indicated that the toxicant in this sample was related to conductivity since the lab scale samples had better control of chemical addition." I The facility also conducted a powdered activated carbon study during November which proved ineffective at reducing effluent toxicity. Sc�tion 2.7 - December 1995 - The facility tested the filtrate,from the bcltpress used for sludge dewatering for toxicity. Sample test results did not indicate this wastestrearn to be toxic. The facility considered metals.as a possible toxicant and split an effluent sample into four aliquots. The report mentions that two aliquots were treated with EDTA and two aliquotg were treated with bentonite clay. All treatment test results were reported as fail The submittal does not mention the concentration of EDTA used in this treatability sample. Seddon 2.8 - January 1996 - The facility initiated C-18 treatability study based on "success using the C-18 procedure a the PPG -Lexington facility." Two samples were collected during December, one sample was not manipulated prior to C-18 testing, the other sample was pH adjusted to 5.0 prior to testing. The results of these tests indicated that neither of the SPE samples was significantly less toxic than the effluent. The facility modified its alum feed location and concentration based on apparent relationships between conductivity and toxicity. The facility considered a process to remove non-ionic surfactants, based on conversations with technical representatives and several chemical suppliers. The facility also approved use of a coagulant CYTEC 515C for full scale pilot testing. Two bench scale tests, one with CYTEC 515 C coagulant addition in the primary part of treatment and one without the coagulant were conducted. Test results showed the sample containing CYTEC 515C failed, Further testing, as reported by the faciliq,;suggested that this coagulant was not a "direct cause of effluent toxicity and more recent testing has indicated that it may be a factor in actually reducing effluent toxicity." Section 2.9 February 1996 - This section discusses the "fail" test result for February and mentions that several process changes had been made. The report does not address the modifications or process cberiges which occurred prior to and diming this time. Section 2,10 -March 1996 - As mentioned earlier, the facility believes that one of the process changes may be resporisible for causing acute toxicity observed in a March grab sample. All of the bench scale samples tested in March failed. These treatments are located in Table form in Attachment F. The March bench scale testing showed an increase in treatment reproduction with increased CYTEC 515 C dosage. Section 2.11 - April 1996 - One conclusion drawn from the March bench scale testing was that neither the CYTEC 515C coagulant used in the primary system nor the cationic polymer used in the secondary system appeared to be the cause of acute toxicity noticed in February and Match Based on the March bench scale tests results another round of bench scale studics was conducted during April. The April bench scale testing results appeared to indicate that aeration time did not have an effect on effluent NC MA li0 ENVSCI Fax:919-733-9959 Nov 13 '96 11:25 P.03iO3 i Page 3 , , PPG -Shelby Progress Report -April 1996 May 29, 1996 toxicity. �YTEC 515C dosage was increased to 50 ppm and the corresponding toxicity test result was pass. Section 2.12 - On -going activities - Based on the data from the latest full scale toxicity test results (acutely t xic upon second renewal addition) the facility believes that conductivity is not the cause of observed acute toxicity and the toxicant is organic in nature. The facility proposes additional PAC testing to support these conclusions. The facility also proposes acute toxicity screenings to assess if "the toxicant of concerti;is present in any of the samples collected." The report mentions that once it is determined that the toxicant is present via acute testing, then the facility will develop a series of bench scale tests to "find a treatment for the toxicant" In summary, we do nor.disagree that PPG has spent monies in trying to soIve its toxicity problem We question the manner in which the testing has been proposed and the current approach taken to reduce toxicity. The effluent data submitted for compliance purposes suggests• the facility has made little progress to°date to resolve effluent toxicity. The facility indicates it has conducted almost 39 bench scale tests at a cost of $250.00 each, conducted eight more additional toxicity tests than required by the permit at a cost of$250.00 per sample, and has spent $12,000.00 on a program to feed bacterial cultures. In our opinion some of these expenditures may have been more wisely utilized by the facility if it had initially conducted the full compliment of Phase I toxicity characterization procedures designed to characterize potential toxicants at the onset of the TRE. The current approach has been "hit and miss" and the facility continues to consider a treatability approach to toxicity reduction .versus a. source reduction approacb. Source reduction efforts do not appear to be driving the activities at this point in the THE while treatability options, appear to be the primary concern. We emphasize and reiterate the importance of the following activities which we feel deserve consideration during the TRE: identification and confirmation of toxicant(s); development and implementation of a long-term chemical management plan, chemical substitutiori/optimizadon activities, maintaining accurate WWTP/productlon records during the TRE, full range chronic toxicity testing to track toxicity reduction over time, and participation in a no -cost site evaluation by Office of Waste Reduction personnel. Alt4oughthe facility has conducted a number of bench walc tests, our foremost concern is that the toxicant(&); whether primary, secondary, or contributory have not been sufficiently characterized and identified. , k review of the facility's DMR data for the past twelve months shows a significant amount of ROD variability. Perhaps the variability in ROD concentrations can be attributed to bacterial culture feedings which began during July 1995. We also note that effluent copper concentrations during the pact year have averaged 126 µg/l. The facility may be headed in the right direction;.however the approach PPG has chosen to resolve toxicity noncompliance with its 33% chronic permit limitation has been somewhat indirect. We continue to support appropriate characterization of the effluent and removal of toxicant(s) at the source versus end of pipe treatment. Should you have questions, please contact me at (919) 733-2136, cc: Dennis Ramsey . John Lesley -Mooresville Regional Office Tom Poe -Pretreatment Aquatic Survey and Toxicology Unit Files Central Files I- --- -- - - 12 PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA April 26, 1996 Mr. John Lesley Water Quality Section N.C. DEHNR 919 North Main Street Mooresville, N.C. 28115 Dear Mr. Lesley: Reference: Fluoride data, Monthly Monitoring Reports January, February, March, 1996 PPG Industries has discovered an error in the fluoride data reported for the seven week period starting January 15, 1996. Normal effluent fluoride levels are 4 mg/l, however in mid January unusually low levels were reported at less than 1 mg/l. Initial investigation of the low values gave several possible explanations for the reduction which continued through February. Fluoride analysis is done in house by the PPG laboratory. A brief review of lab procedures did not reveal a problem. Near the end of February, growing suspicions that the low values may be in error lead to sending samples to Pace, Inc. laboratory in Huntersville for verification. In early March, was confirmed that the low levels were in error and that effluent fluorides were still in the typical 3 to 4 mg/l range. Data sheets from the January and February DMR's are attached with the invalid data marked. Based on process control data and chemical usage, fluoride levels for the seven weeks in question are believed to have been in the normal range and in compliance with the 5.4 mg/l limitation. The two weeks data before and after the period showed fluoride levels at 4.3 mg/l before and 4.0 afterwards. Recent analysis of the only keeper sample available from the period showed effluent fluoride to be 3.66 mg/l on 2-22-96. In mid March, efforts were being made to minimize aluminum chloride additions, along with other treatment chemicals, to aid in the resolution of the effluent toxicity problem. Due to the time required to recej7e fluoride analysis back from Pace, Inc. and the reliance on ef'roneous in house data, the aluminum chloride dosage was reduced too much and resulted in a 7.6 mg/l value on March 25 and a -V73 mg/l value on April 2. Immediately upon discovery bf the'problem, aluminum chloride dosage was increased and fluoride levels returned to normal ranges. On April 4, efflu_ent fluorrdej as 4.30 mg/1 and has been runninq from 3.56 to 4.2g mg/l so far this month. -2- A detailed investigation of laboratory procedures showed that a repeated calibration error had been made, apparently involving the slope and efficiency entry, on the Accumet specific ion instrument. The correct two point calibration procedure has been reviewed with lab personnel along the use of a third standard to verify calibration. Other quality assurance procedures have been implemented to insure consistent quality data: the use of a purchased ULTRAcheck blind QA standard for verification of the procedure, the training of additional technicians on the fluoride procedure, and periodic duplicate analysis by each technician. We regret the occurrence of this error and the length of time it took to identify and correct the problem. If additional information is needed, please contact me at 704-434-2261, ex 544. Sincerely, LacG� rd / Staff Engineer cc: C. Whiting - N.C. DEHNR A. Astroth M. LeCroy R. Fletcher B. Blackwell W. Schenck