NC0055221_Permit Modification_20100215

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NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Steven W. Miller, ORC
City of Marion WTP
194 North Main Street
Marion, North Carolina 28752
Dear Mr. Miller:
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
February 15, 2010
Subject: Permit Modification for
NPDES NCO055221
Marion WTP
Marion County
Pursuant to your January 23, 2010 letter, Division personnel have reviewed your request to change the "Whole Effluent
Chronic Toxicity Monitoring (Quarterly)" requirement to "Acute Toxicity Monitoring (Quarterly)" requirement in your NPDES permit,
which was issued December 23, 2009. Your permit modification request has been approved. We are forwarding you this new
Attachment A. (2) "Acute Toxicity Monitoring (Quarterly)". You should replace your existing Attachment A. (2) with this new
Attachment A. (2).
This permit correction 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 October 15, 2007 (or as
subsequently amended). If any parts, measurement frequencies or sampling requirements contained in this permit modification
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following
receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150E of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
Please note that your NPDES permit is not transferable except after noiice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other
permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the
Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any
questions concerning this permit, please contact Bob Guerra at telephone number [phone] or email at
(bob.guerra ncdenr.gov).
Si erely,U..0
le -en H. Sullins
Enclosure: Attachment A. (2) A ute Toxicity Monitoring (Quarterly)
cc: Asheville Regional Office / Roger Edwards Surface Water Protection
Aquatic Toxicology Unit, Susan Meadows (E Copy)
NPDES Unit
Central Files
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

A. (2). ACUTE TOXICITY MONITORING (QUARTERLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North
Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single
Effluent Concentration" (Revised -July, 1992 or subsequent versions). The monitoring shall be performed as
a Fathead Minnow (Pimephales promelas) 24 hour static test. The effluent concentration at which there may
be at no time significant acute mortality is 90% (defined as treatment two in the procedure document).
Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge
below all waste treatment. The tests will be performed during the months of January, April, July and
October.
The parameter code for Pimephales promelas is TGE6C. All toxicity testing results required as part of this
permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-2 (original) is to be sent to
the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of
the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the
waste stream.
Should, there be no discharge of flow from the facility during any month, the permittee will complete the
information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Environmental Sciences Section at the
address cited above.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened
and modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
{ monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Form submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month following the month of
the initial monitoring.
MAMFathead/Mysid 48 version 9104

CITY OF MARION
WATER FILTRATION PLANT
P. O. Drawer 700 SUPERINTENDENT
Marion, North Carolina 28752
januarv.. 7010
Mr. Bob Guerra
Environmental Specialist - 2
NPDES - West
ARO Regional Contact
512 North Salisbury St.
Raleigh, NC 27600
Re: Request for a 24 hour acute toxicity test
Dear Mr. Guerra:
The City of Marion Water 1,iltration Plant aiscnarges fro , the sludge iagooi} t!1iisodicall}
--3%er-% ther wi=+ k. Div- to the infrequence of ot,r discharge,'- regular tw.icity tect would
nt �t he representative of the discharge. The requirem;xt of a reS: _ sher samnie after the
regular toxicity test would be an added expense.
The best representative sample of our dis6arg, vould be a 21. hour acute toxicity test.
We would >;ke to request that our NPDES permit, NC0055221. be amended to allow us
to perform a 24 liour acute toxicity test. Please feel free to contact me at any time to
di -,cuss this request at 828.652.2428 or smillerCacmarionne.crg.
Sinncereiy,
:'t�) at
Steven W. Mi,'jer
Water Filter Plain Superintendent
City of "v:ai ian Water Filter Plant
Cc. Bob Boyette, Pity Manager, City of kla►ion

Guerra, Bob
From:
Moore, Cindy
Sent:
Tuesday, February 02, 2010 12:31 PM
To:
Guerra, Bob
Cc:
Menzel, Jeff
Subject:
RE: Chronic testing question
Yes, I am in agreement! I think we can give them a choice in organism,either Fathead or Cerio
From: Guerra, Bob
Sent: Tuesday, February 02, 2010 10:27 AM
To: Menzel, Jeff
Cc: Moore, Cindy
Subject: RE: Chronic testing question
I am in receipt of a request from City of Marion WTP NCO055221 to change the toxicity from Chronic to 24
Acute. It appears that everyone is in agreement that this facility should be doing a 24 hour acute toxicity test. If
that is the case can you, Cindy, reply in the affirmative to this email so when Tom B asks me who,.
authorized/suggested this change would be appropriate from the new WTP strategy I have the reasoning.
Does the target organism change? Thanks in advance
From: Menzel, Jeff
Sent: Friday, January 15, 2010 10:54 AM
To: Guerra, Bob
Subject: FW: Chronic testing question
Jeff Menzel - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
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: Moore, Cindy [mailto:[e-mail]]
Sent: Friday, January 15, 2010 10:31 AM
To: Ventaloro, Christopher
Cc: [e-mail]
Subject: RE: Chronic testing question
We really don't want them to change their operations. We really want to monitor what is actually happening at the
plant.

From: Ventaloro, Christopher
Sent: Friday, January 15, 2010 10:29 AM
To: Moore, Cindy; Hollenkamp, Carol
Subject: FW: Chronic testing question
Some further information on the facility.
From: Menzel, Jeff
Sent: Friday, January 15, 2010 10:28 AM
To: Ventaloro, Christopher
Cc: Edwards, Roger
Subject: RE: Chronic testing question
NC0055221 Marion WTP
The operator may be able to change operations to accommodate the test. I guess the question is, do we want to change
the historical nature of the discharge (A one day discharge with two weeks retention time before discharge) to
something that could potentially be filter backwash water with little to no retention time before entering the creek.
Reviewing the DMRs the maximum flow that I've seen in the last 12 months is 0.28 MGD
Jeff Menzel - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
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: Ventaloro, Christopher
Sent: Friday, January 15, 2010 9:57 AM
To: Menzel, Jeff
Subject: RE: Chronic testing question
Jeff, can you tell me what facility this is? We are trying to come up with some options and it would be helpful to have
more information on them.
Thanks
From: Menzel, Jeff
Sent: Friday, January 15, 2010 8:40 AM
To: Ventaloro, Christopher
Subject: Chronic testing question
Chris,
We have a water plant whose new permit will require a chronic tox test for their filter backwash discharge. The facility
typically has a 2 week period for retention in their lagoon before discharge. This allows for solids to settle and chlorine
to dissipate. The operator is concerned that trying to separate this discharge for Tuesday/Friday grab samples may not

be representative. He is also concerned that any filter backwash that occurred between Tuesday and Friday would have
the potential to negatively impact Friday's sample because they would not have the retention time (that is typically
there).
So the question has come up ... can the facility just conduct a one day sampling event? Or, can the facility collect on two
consecutive days Monday/Tuesday ?
Thanks,
Jeff
Jeff Menzel - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Surface Water Protection Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
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.