NC0023884_Staff Comments_20071011

that Salisbury thing
,r
Subject: that Salisbury thing
From: Susan Wilson <[e-mail]>
Date: Thu, 11 Oct 2007 14:14:10 -0400
To: Rob Krebs <[e-mail]>, Wes Bell <[e-mail]>, Jackie Nowell
<[e-mail]>, Bob Sledge <[e-mail]>
OK - I'm so sorry Rob - definitely meant to get back with you about this earlier.
Here's what we think: we need to do what we think is right and what will essentially give us the
infoiunation we need to assess compliance. Let's just put the past behind us (we know we may
have created confusion on our end and frustrated you guys and them).
So - we're just fine if they want to do a feasibility study and complete by 1/31/08 (as specified in
their 7/20/2007 letter). In that study, though, they do need to detail why it would not be feasible
for them to sample composite after UV.
If I understand this correctly (having not been to the site) - composite sampling is after all
treatment except UV/cascade aeration (meaning after the biological treamtent system/clarifiers);
grab sampling (for fecal and other?) is after the UV treatment and prior to cascade aeration. D.O.
sampling is at cascade aeration. (and all of this sampling includes the combined treatment
plants).
Seems like this scenario would be a pain in the neck for them - but I don't see how it doesn't
supply us with the information we need to assess compliance, so I'm OK with it. I don't think
every facility out there would want to emulate this - it's too much trouble. They must be running
into a cost issue with having to move a sampling refridgerator or electrical box and that's why
they don't want to do it - either that or Wes made them mad!
But - in order to agree with that - as part of that study I would have them set up a composite
sampler for a week (or at your judgement) downstream of the UV to make sure the UV system
isn't 'creating' some unusual compound that's not being picked up by the composite sampler prior
to UV. The other thing I'd make them specify (if you guys don't know this already) - is exactly
what is being measured by grab post -UV and at the cascade aeration. Always to their advantage
to grab volatiles at the cascade aeration if they have to be measured.
So - that's our 2 cents - hope we're done with this one.
Now Wes I know what you're thinkin' , but let's just take the high road on this! Hope this helps -
give a ring if you have questions.
Susan A. Wilson, P.E.
Supervisor, Western NPDES Program
(919) 733 - 5083, ext. 510
1617 Mail Service Center
Raleigh, NC 27699-1617
1 of 1 10/11/2007 4:30 PM

[Fyd: Sampling Point Relocation Response Letter]
Subject: [Fwd: Sampling Point Relocation Response Letter]
From: Rob Krebs <[e-mail]>
Date: Thu, 16 Aug 2007 07:26:29 -0400
To: Susan Wilson <[e-mail]>
Susan,
Can you help with this? I sent a letter to Salisbury, following an inspection,
regarding the location of the sampling point for the Salisbury WWTP (NC0023884)
effluent. My inspector (Wes) noticed the sampling point was in the wrong place and
has been for at least three years. We did not NOV them. Instead we asked them to
move it back to where it was previously located (prior to cascade). We we told
Salisbury (Sonja Basinger) about the permit condition, she requested that we send
Salisbury a letter to tell them what they needed to do to be in compliance As you
can see from their response they feel that they are in compliance. We, in the MRO,
do not believe they are.
We spoke with the CO staff prior to me sending out the letter and felt comfortable
allowing the sampler to be located after the UV but prior to the cascade. Based on
their permit conditions, I want to make sure that were are all on same page on the
permit requirements. I want to stick to the strict interpretation of the permit. If
it requires the sampling point to be located after the cascade then I am all for it.
Let me know the CO's opinion on this permit condition. If you need any additional
information, please feel free to call me.
Thanks,
Rob
Rob Krebs - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Cell [phone]
Ph: [phone]
Fax: [phone]
Subject: Sampling Point Relocation Response Letter
From: "Matt Bernhardt" <[e-mail]>
Date: Fri, 20 Jul 2007 15:11:49 -0400
To: <[e-mail]>
Mr. Krebs:
Attached please find a response from the City of Salisbury (Salisbury -Rowan Utilities) regarding your letter of June 21,
2007. This letter has been transmitted by Fax, Email, and regular mail service. We apologize for any redundancy this may
created, but wanted to be sure that it reached you. Please contact us if you have any questions, and we look forward to
working with you to address the issues contained in our respective letters.
Matt Bernhardt
Assistant City Manager for Utilities
Salisbury -Rowan Utilities
Sampling Point Relocation Response Letter
Content -Type: message/rfc822
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1 of2
8/20/2007 12:0(

IlVIILE TO i 704) 6;
1B Krebs
_ace Water Protection Section Supervisor
Division of Water Quality.
DENR Mooresville Regional0
Centex Ave, Suite 301.
ooresville
Sal sbury-Rowan.WWTP Permit No NC002388=4 Effluent: Sampling Location :'
etter responds toz-a.,-letter dated June 21, 2007,;in which S411,..10suiy Rowan:,'.
`Utilities` (SRU) is directed to notify the Division of W ater Quality" (DWQ) proposed,
schedule' to relocate the effluent. sampling point :at the. Salisbury Rowan Regional;-
°`W'c TP The Juz e 21, 200'1,� `letter directs SRU to"ypresent a proposed schedule.: for;.
relocation o?= the effluent, san�ipling point abased on the following analysis:_
e ;May 25, 2D07 inspeehon-fevealed] that you have been collecking,reffluent-
cornp*rte. samples prior to. 'the ult .violet (UV) treat rient' location. This
samplings ocation is notan approved, ocaticn.in accordance withyour reyious
or current. pericnits Since thee_ May 20,; 2002, NPDES pe mit r'(enciosed), the
location of the of fluent,isampIing point`has been ideri ified as at<fhe effluent from
the:,' UV .freatinent systern Your current ' PDES: permit :`.(September 7, 20.06)
requires that an°effluent.sample be obtained from the effluent of'te "Combined
effluent �rorn the Grant Creels and Town Creek: treatment :trains, " Ili'
accordance:1with :$4 NCAC 2B 0503(22} the definition of effluent references
"following ''all treatment=;processes" Therefore, to Ise , in compliance, with your
current permit and 2B.0503(12), all effluent, (composite: Band grab) sampling
locat onsn ust be located after the, UV treatment;,,
ermit Provisions and Perms it Ilistory
e?e have conducted an extensive,x review o£ the permit requirements and t
;history and:have d terixa ned;that the.,June 1 letter does not accurately reflect the current
perm t's.conditions or' -the history of those conditions.;, Further, the.June 2;1 letter would:.
;impose,4 def ration o "effluent" that would, in our opinion, ;;render .other provisions
the perrmit unworkable.
1 Wate"r:Str'eet
:-Salisbury, NC 28144-
Salisbury-2owan Utilities:
Telephone (704);638l520
Fax 0O4) 638 E84'7

In particular; we note the,follOwing 'Poi:120Q' s consideration,.
1). There nothing neabbiit any npling lotatiOn thattduld havebeen revealed..
the May 25, 2007 inspeotion. Please ;note that the DWQ comPlior.IPP, iPSPePti.9n.
reports, for 2004, 2005, and 2006 confirm that there is no permit compliance issue
related to sampling location. The current 'locations are as,requir ,edbyPerniii.
No. NC00238$4, a8 discussed below,
2) The Amen letter didmOt enclose:a copy of a pernilt as,Starect but initeattenelb.sed,a
2002,letter _referring:10-4 ;On "permit" The ,':2902 letter does not cl,p§cijbO'cr-di$PuM.
the sampling locations that are identified in the current perinirt, Under which .our
WWTP OPOrateSit fact, the 2002 letter refers to a proposed permit that (1)-never
became effective, did, not -accurately - describe our 'S4.1--09.1Fan 1Z•pgioinaI,
WWTP:„.(3) did not identify the three separate treatment trams that idelitifted, in
the otihtrit permit, and (4) did not include the current perinitTs, 'description, of
sampling looationa, The 2002 proposed perniityras, adjudicated 1:003) and:
its text, (specifically including the text that identifieS, :the :•sampling locations) was
substantially revised before beingisstied,asapeiton Atigki. St
'3). On August 15 2003,.DWQ issued aperinit (reCeived.b Salisbury Sepfein$etai,
2003.)that, subject to correction of typographical errors by DWQ, became Anal,
-Accordingly, the current permit (issued on, August 28„. 2006) identifies Withfn, the,
:'.alislattry7Roli‘iriliVIYTP,'anifong other thiins, the tolici*ins
a. Grant Creek wastewater treatment Itai*
b. Town Creek wastewater treatinetittrait;and
Yadkin River-wgstewaterfreatmeni' tr*.
,4) Enclosed please find 411 annotated aerial .phOtVaPtf that identifies (l). the Otatit-:
Creek treatment tram, (2) the Town Creek treatment train, (?)::the,point ato:vitich the,
Grant Creek treatment train effluent and the Town Creek treatment tram effluent 4..r4'
combmed, and (4) the current sampling;:location. 'aatnple'a:are.crigrentry
collected oni.the'''combinea effluent from 'the GrantCreek:and Town Creek
'treatment trains" required by .Effluent Liotolions:,441;IMOzaptingiequitement.,.
(5:ectiorkA;(1) of.Pertnit NoNC0023884)
5), The current ppqpit sampling location text and the current sampling location were in,
place and in use during the 13WQihspeCtian:S'in 2004, 2005, 04'2006 inSpeOtiOns,;,
confiim that the gampling.location,cornOie&Wiihihdrogniternenta,:oethe
.7-114-4±,
:-1-WatetStredt, 7t:o,1pphone,(16:4)
8a1151:opry,$( 28144'
Salisbury -Rowan Utilities, Fax [phone]

Finally, the June 21 letter refers to a definition of "effluent" ("following all
treatment processes") and seems to imply that "effluent" cannot mean "treatment train
effluent." The permit, however, makes it very clear that in some instances the permit is
referring to treatment train effluent rather than WWTP effluent. For example, the
calculation set out in Section A.(6) uses the following terms: WWTP Effluent, Grants
Creek Treatment Train Effluent, and Town Creek Treatment Train Effluent. If the
definition of "effluent" were to be applied as apparently suggested by the June 21 letter,
the calculation required by the permit would be rendered unworkable.
Conclusion
Permit compliance and overall excellence in the operation of our WWTP are of
the highest priority to SRU. We take very seriously our responsibility to follow all
aspects of our permit. We believe our sampling location is an approved location in
accordance with our permit. However, we understand from the June 21 letter that DWQ
wishes to see the sampling occur at a point "after the UV treatment." We note for clarity
that "after the UV treatment" also includes points upstream of the cascade. SRU proposes
the following schedule for consideration by DWQ:
1) SRU immediately initiates a feasibility study of relocating sampling to a point
that is after the UV treatment.
2) By January 31, 2008, SRU completes a feasibility study report, and subsequently
develops a plan of action to be discussed with NC DENR.
We look forward to your approval, and appreciate the effective working
relationship that we have enjoyed in the past with your office.
Enclosure (Annotated aerial photo).
Since rly,
Matt Bernhardt
Assistant City Manager
for Utilities
Telephone [phone]
Salisbury -Rowan Utilities Fax [phone]
1 Water Street
Salisbury, NC 28144

Current Sampling; Location
"TreatmentTraii
EffluentsCoiittbine
Grant_Creek ,.
•Treatment Train
Tow!),Creek ''
Teatiienti'rart
Pbaso tra r T o infgn?iatimi prosargcd.i i mrs mep;ts:oiily,.
ooprosmta6'and rosuks 4tin the mmpliicn of avadatyol
sane inati TfiexO Qi,'zton¢tsiri font Door!:
.eth ad rd.:acaaocy 71*ia4p10101a1144rfeB:tpran
a1prcpem%,Cttya/Salsbtry and SztsDurya anoutCiteS
rn ood,ontosordetcaorwarrar yNncerntsithoocwra•.y.
OfOieTntarnaSnnpresentao N this map;' map'ilayir
atiY tfzla�leti p'a+s orCroonps of potiitiidiosi 6t intrastiiidara'
foAai, ,Ihe,map is not ripobto mcoid.nod rot.tot rtiin or .
iettartsitea.rSD!obbie&- - .
Current Sampling Lacation'
Saliebury Rawan_"V1LWTP`
2QOO.:
Feet

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
0
June 21, 2007
Soma Basinger
Salisbury — Rowan Utilities
1 Water Street
Salisbury, North Carolina 28144
Subject: Effluent Composite Sampling Point Location
Salisbury - Rowan WWTP
Permit No. NC0023884
Rowan County
Dear Ms. Basinger:
This letter is intended to address your concerns about correct sampling locations following a
compliance inspection visit at the Salisbury — Rowan Waste Water Treatment Plant on May 25, 2007.
Specifically, you wanted additional clarification on the correct effluent composite sampling location.
The May 25, 2007, inspection reveled that you have been collecting of Juent composite samples
prior to the ultraviolet (UV) treatment location. This sampling location is not an approved location in
accordance with your previous or current permits. Since the May 20, 2002, NPDES permit (enclosed),
the location of the effluent sampling point has been identified as at the effluent from the UV treatment
system. Your current NPDES permit (September 7, 2006) requires that an effluent sample be obtained
from the effluent of the "Combined effluent from the Grant Creek and Town Creek treatment trains,
..". In accordance with 15A NCAC 2B .0503(12) the definition of effluent references "following all
treatment processes". Therefore, to be in compliance with your current permit and 2B .0503(12), all
effluent (composite and grab) sampling locations must be located after UV treatment.
We appreciate your request to clarify the effluent composite sampling location and hope the
above clarification is sufficient. Please notify us, within thirty days of this letter, of your proposed
schedule to relocate the effluent composite sampling point.
If you have any additional questions regarding this issue please contact Wes Bell at 704-235-
2193 or me at 704-235 2176.
Sincerely,
/ «
Robert B. Krebs
Surface Water Protection Section Supervisor
Division of Water Quality
Mooresville Regional Office
enclosure
Cc: Central Files
Bob Sledge — Western NPDES Unit
1617 Mail Service Center Raleigh, NC 27699-16117
919-733-7015 (Telephone) Customer Service 800-623-7748