NC0024112_Staff Comments_20050208

[Fwd: Re: 309 letters]
Subject: [Fwd: Re: 309 letters]
From: Steve Tedder <[e-mail]>
Date: Tue, 08 Feb 2005 11:06:01 -0500
To: Charles Weaver <[e-mail]>
fYi
Original Message
Subject:Re: 309 letters
Date:Tue, 08 Feb 2005 11:05:25 -0500
From:Steve Tedder <[e-mail]>
Reply-To:[e-mail]
Organization:NC DENR - Winston-Salem Regional Office
To:Coleen Sullins <[e-mail]>
CC:Dave Goodrich <dave.goodrich(ancmail.net>, Tom Belnick
<[e-mail]>, Rick Shiver <[e-mail]>,
"[e-mail]" <[e-mail]>, Paul Rawls
<[e-mail]>, [e-mail],
[e-mail], [e-mail],
[e-mail], Abner.Braddynancmail.net
References :<[e-mail]>
<[e-mail]>
The 309 letters have been sent by EPA and nothing I can do about that. The facilities
will just have to do their homework, jump through a lot of hoops and create a
mountain of paper to take up space in Atlanta. Here are some quick facts on Eden,
Randleman and Thomasville.
Eden: NC0025071
Eden got a 309 letter but it basically just said they are looking at them and did not
require anything to be submitted. Its interesting that they even received a 309 letter in
that EPA mentioned only 13 violations over a FOUR year period and four of those are
not listed as violations in our records. So thats 9 tss violations in four years.
Remember this is a 30/30 facility into a big river. City has obtained A to C to
construct solids settler to handle water plan alum sludge. They are the first town we
have under soc for. SSO problems.
There is not a problem here folks.
Randleman: NC0025445
1 of 3 2/10/2005 6:09 AM

[Fwd: Re: 309 letters]
Randleman also received the standard 309 letter and they are being requested to send
EPA everything but the kitchen sink. The EPA letter mentioned 47 listed violations
over a four year period. Actually, 26 of those listed were NOT violations according to
our records. So thats 21 violations over four years. Since 2001 we have assessed
them 15 times for violations for $15,912. There may be some O& M concerns we
have at Randleman and our Training and Certification TA folks have evaluated the
plant as well as the Town paying for three consultant studies that make
recommendations as to how to improve O&M. Bottom line is the Town needs to put
the recommendations of our TA folks and their consultants into action not more
studies. Maybe the 309 copying efforts will get their attention.
Thomasville: NC0024112
The EPA 309 letter listed 56 violations over the four year period of 2001-2004.
Twenty nine of those violations were for cyanide. Because of the efforts of our staff
(George Smith) we found that the contract lab was incorrectly preserving the cyanide
samples. Once they started doing the samples correctly the violations ceased. Six
other violations listed were actually not violations according to BIMS and our files. So
we are really talking 21 violations over the four year window. This is an aging plant
that needs work. Town is moving ahead with the Construction Grants staff to upgrade
and expand the facility. SOC in in the works that will need to address their new limits
for P and Chlorine. We are waiting on the Town for flow information to finalize the
SOC. Ball is in their court. There have been Ni violations historically that EPA did
not mention. Last permit increased the Ni limits and the violations have ceased. We
have assessed them 35 times in the four year period for $89,660. I think this as well
as the other two is an over -reaction by EPA and they (the Towns) will do a lot of
copying and spend a lot of time that should be devoted to the SOC, pretreatment and
getting the upgrades completed.
Tedder's Two Cents.
On 2/4/2005 11:10 AM, Coleen Sullins wrote:
Steve - I am not aware of any communication. I think Dave said that Tom was
handling these for us. As you say, we usually have conversations with EPA before
the letters go out so that we know in advance.
Tom - are you the person handling these? Can you comment? We should probably
call EPA and ask if they have changed the process and why. Thanks Coleen
Steve Tedder wrote:
2 of 3 2/10/2005 6:09 AM

Re: FW:4Fwd: Watch List Follow-up]
Subject: Re: FW: [Fwd: Watch List Follow-up]
From: Steve Tedder <[e-mail]>
Date: Thu, 20 Jan 2005 08:02:05 -0500
To: [e-mail]
CC: [e-mail]
As for Thomasville, see Steve Mauney's comments below. Bottom line is that we are
waiting on the City. Any future violations will be met with elevated penalty amounts.
Steve
After looking at Thomasville's new permit, their biggest compliance issues will be
total phosphorus which became effective 4-1-04 and total residual chlorine which is
effective 1-1-06. The phosphorus limit is a seasonal limit and the first season
concluded October 31, 2004 with their total phosphorus at 10726 Ws (limit is 3570 #
for summer). Thomasville was assessed for violating BOD in July 2004 but has been
OK since then. Apparently BIMS is not programmed to catch this seasonal violation.
Thomasville's SOC application got to Raleigh on 9-27-04. I spoke to Kelly Craver in
October about the need for the particular interim limits that they wanted and the
amount of sewer taps that were needed. He indicated that the engineer was handling
that. Keith West, Pease Associates sent an updated schedule to us on 12-10-04. I sent a
bare -bones SOC to Kelly on 12-17-04 and to Keith West on 1-7-05. I met with Kelly
on 1-11-05 and discussed the information that we still needed to finalize the SOC. He
will be preparing the flow request in the near future. I looked back in the files and in
our CEI of 1-29-04 we told Thomasville that an SOC may be necessary and advised
them that technical assistance was available through Sonja. When we met with Kelly
Craver and Morgan Huffman, ORC on 2-11-04 we gave them the SOC application.
Steve Mauney
On 1/14/2005 12:03 PM, [e-mail] wrote:
Steve - have been out all week due to respiratory virus. Am working
from
home today. Any info you have on this [item 1 in Lisa Uhl's message]
would
be welcome.
Thanks,
CHW
1 of 4 1/20/2005 1:08 PM

Re: FW: [Fwd: Watch List Fol-up]
-- Original Message --
Date: Fri, 14 Jan 2005 11:03:58 -0500
From: Tom Belnick <[e-mail]>
To: Bob Sledge <[e-mail]>,
Charles Weaver <[e-mail]>,
Karen Rust <[e-mail]>,
Jeanne Phillips <[e-mail]>
Subject: [Fwd: Watch List Follow-up]
Hello folks- just passing along a request from EPA Reg 4 Compliance
for
Watch List. Based on ROCs, it looks like Charles has Item 1, Bob
has
items 2 and 3, and Karen has item 4. I would suggest emailing Lisa
Uhl
directly with your responses for this one. I told her that we'll
try to
respond by early next week. Bob/Jeanne- I'm not sure who takes lead
on
the Data Action List?
Original Message
Subject: Watch List Follow-up
Date:
From:
To:
CC:
Thu, 13 Jan 2005 13:37:54 -0500
[e-mail]
[e-mail], [e-mail]
[e-mail]
Dave & Tom,
I sent Dave G. & Bob S an email on 12/10/04 regarding some
followup
questions I had to the October watch list as well as the data
action
list for Jeanne & others of data corrections. I didn't hear
anything
back on the action list or the questions. Please let me know who I
can
2
of 4 1/20/2005 1:08 PM

FWv[Fwd: Watch List Follow-up]
followup with to address the questions below. Also, please have
Jeanne
or someone let me know if they were able to address all the issues
on
the data action list. All of the corrections on the data action
list
needed to be made by 1/15/05 in order to get facilities off the
watch
list for the Jan 2005 list.
Please let me know something or let me know if I need to speak with
the
ROs directly. I'll be out of the office tomorrow & it's a holiday
for
us on Monday, back in office on Tuesday.
1. Thomasville - NC0024112 & Eden - NC0025071 - What is the
timeline
for issuing the SOC? What stage are the negotiations? When can
EPA see
a draft SOC? Will the action have an upfront penalty? If the SOC
is
not drafted, I'd like to review the SOC application.
2. Tuckaseigee - NC0039578 - What is the status? This is the one
that
was on the original list of questions I sent on 11/23, but I didn't
see
anything from Bob on this facility.
3. Lenior
who to
contact in
email, but
upgraded?
- What's the update here on both plants or let me know
the RO, I can call them myself. This was also on 11/23
I didn't see a response yet. Was Gunpowder recently
Does Lower Creek have upgrade plans?
4. Williamston - Did you follow up with RO on their
recommendations/impressions yet as stated? If not, I can.
Attached is the data action list again, please take a look at this
give me some feedback on these things, too.
Thanks, Lisa
(See attached file: action list for Bob Oct 2004 WL.doc)
Lisa J. Uhl
Environmental Engineer
EPA Region 4
[phone]
[phone] fax
http://www.epa.gov/region4/wpeb/
3 of4
1/20/2005 1:08 PM

Re: FW: [Fwd: Watch List Follow-up]
[e-mail]
N.C. DENR/DWQ/NPDES
919-733-5083,ext. 543
Attachment: action list for Bob Oct 2004 WL.doc
Steve Tedder <Steve.Tedder(aNCmail.net>
NC DENR
WSRO
4 of 4 1/20/2005 1:08 PM