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HomeMy WebLinkAboutNC0072702_Technical Correction_20071220WAr4f� December 20, 2007 Mr. John Young Public Works Director 412 Hedrick Street Beaufort, North Carolina 28516 Michael F. Easley, Governor State of North Carolina William G. Ross, Ir., Secretary Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality Subject Correction for NPDES Permit NCO072699 Pine Street WTP Correction fro NPDES Permit NCO072702 Glenda Drive WTP Carteret County Dear Mr. Young. In regards to your November 5, 2007 request to modify Pine Street WTP NCO072699 Acute Toxicity Testing requirement to be monitoring only and thus be consistent with the Toxicity Testing requirement at the Glenda Drive WTP Permit NCO072702 the division concurs. The Divisions also recognizes NCO072702 Toxicity Testing organism is defined at the default selection, Mysid Shrimp, because no election was made by the permittee. To complete the necessary corrections we outlined the selection protocol with your consultant, River and Assocaites. The protocol is for the pem ittee to designate the test organism from the three available organism (Fathead Minnow, Mysid Shrimp, Silverside Minnow) or if no selection is provided during the draft period Mysid Shrimp is the default test organism. We received an email November 20, 2007 from Greg Churchill, River and Associates, designating your choice as Mysip Shrimp. This same response was also used to validate the test organism selection for the Glenda Drive WTP Permit NC0072702. Therefore, we have made corrections to the necessary text on the two pages of the Pine Street WIT' Permit NCO072699 that are affected including stating the effective date for Total Residual Chlorine compliance. The corrected pages are part of several pages included with this letter. The invalid pages from Permit NCO072699 should be removed from the active permit and replaced with the corrected pages. A summary of the corrections on Permit NCO072699 are as follow: 1) Corrected Title Header reads "A. (2.) ACUTE TOXICITY PASS/FAIL MONITORING (QUARTERLY)" 2) Corrected text reads "The monitoring shall be performed as a Mysid Shrimp (Myeidopsis Bahia) 24 hour static test." 3) Corrected text reads "All toxicity testing results required as part of this permit condition will be entered on the effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE3E." 4) Corrected text for clarity reads "Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine or a chlorine derivative is employed for disinfection of the waste stream." 5) Unnecessary Text removed, not applicable for monitoring "Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above." Page 1 of 2 Division of Water Quality, Point Source Brandt Telephone (919) 733.7015 0� 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 FAX (919) 733-0719 NO�ttCarolina 512 N. Salisbury Street, Raleigh, North Carolina 2J604 On the Internet at FAX �atura/!il An Equal Opportunity/Affirmative Action Employer 6) Corrected text footnote reads: 3 "The limit becomes effective May 1, 2009, monitoring shall begin immediately." 7) Corrected text footnote reads: 4 Acute Toxicity 24-hour Pass/Fail Monitoring shall be conducted quarterly at 90% in March, June, September, and December. Permittee has designated Mysid Shrimp as his test organism. Permittee may choose to use Fathead Minnow, or Mysid Shrimp, or Silverside Minnow as the test organism. However, any change in test organism requires prior written approval by DENR/DWQ so all affected concerns can be addressed including assignment of the correct parameter code (see A. (2.)). To be consistent with the text content in both permits the Glenda Drive WTP NC0072702 permit was also corrected to match NC0072699 were applicable. Consequently, the 2 invalid pages from Permit NC0072702 should be removed from the active permit and replaced with the corrected pages provided. All of the changes are deemed as corrections and take effected upon receipt of this letter by the pertnittee. All other terms and conditions in these permits not affected by these corrections remain in force. These corrected permits are 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 you have any questions concerning these corrected permits, contact Ron Berry at (919) 733-5083, extension 531 or ron.bcnT@ncmail.net. fk Siiinnely, Bert Cc: Wilmington Regional Office/Surface Water Protection Section Central Files NC0072699 (copy cover letter with permit NC0072699 corrected pages) NC0072702 (copy cover letter with permit NC0072702 corrected pages) NPDES Unit NC0072699 (copy cover letter with permit NC0072699 corrected pages) NC0072702 (copy cover letter with permit NC0072702 corrected pages) Page 2 of 2 Permit NCO072699 A. (2. )ACUTE TOXICITY PASS/ FAIL 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 Mysid Shrimp (Mysidopsis Bahia) 24 hour static test. The effluent concentration defined as treatment two in the procedure document will be 90%. 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 March, June, September and December. All toxicity testing results required .as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE3E. 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, North Carolina 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 or a chlorine derivative is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, 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 the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a valid test is submitted. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified 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. 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. Permit NCO072699 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -FINAL During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge filter backwash and softener regeneration backwash from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS i MONITORING REQUIREMENTS Monthly Avera a Daily Maximum Measurement Fre uenc Sample Type Sample Location, Flow Weekly Estimate Effluent Temperature, ° C Monthly Grab Effluent, Downstream Salinity Monthly Grab Effluent, Downstream Conductivity Monthly Grab Effluent, Downstream 1 H 2 2/ Month Grab Effluent, Downstream 1 Dissolved Oxygen Monthly Grab Effluent, Downstream 1 Total Dissolved solids Monthly Grab Effluent Total Suspended Solids 30.0 m /L 45.0 m /L 2/ Month Grab Effluent Total Residual Chlorine 3 13 ug/ L 2/ Month Grab Effluent Total Copper Monthly Grab Effluent Total Chloride Monthly Grab Effluent Total Iron Monthly Grab Effluent Total Manganese Monthly Grab Effluent Total Lead Monthly Grab Effluent Total Zinc Monthly Grab Effluent Ammonia Nitrogen Monthly Grab Effluent Whole Effluent Toxicq 4 Quarterly Grab Effluent Notes: 1. Downstream sample at least 100 feet downstream of the discharge point. 2. The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units. 3. Total Residual Chlorine limit and monitoring are effective only if chlorinated water is used for softener regeneration and backwash. The limit becomes effective May 1, 2009, monitoring shall begin immediately. 4. Acute Toxicity 24-hour Pass/ Fail Monitoring shall be conducted quarterly at 90% in March, June, September, and December. Permittee has designated Mysid Shrimp as his test organism. Permittee may choose to use Fathead Minnow, or Mysid Shrimp, or Silverside Minnow as the test organism. However, any change in test organism requires prior written approval by DENR/DWQ so all affected concerns can be addressed including assignment of the correct parameter code (see A. (2.)). All samples collected should be from a representative discharge event. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NCO072702 A. (2.) ACUTE TOXICITY PASS/FAIL MONITORING (QRTRLY) The permittee shall conduct acute toxicity tests on a quarterlbasis 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 Mysid Shrimp (Mysidopsis bahia) 24-hour static test. The effluent concentration defined as treatment two in the procedure document will be 90%. 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. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE3E. 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 or a chlorine derivative is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, 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 the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a valid test is submitted. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified above. Should any test data from this monitoring requirement 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. 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. Permit NCO072702 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge filter backwash from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS T MONITORING REQUIREMENTS Monthly Average— Daily Maximum Measurement Frequency Sample Typel :Sample Locatlon2 .. Flow Weekly Estimate Effluent Temperature (00010) Monthly Grab Effluent, Upstream, and Downstream Salinity (00480) Monthly Grab Effluent, Upstream, and Downstream Conductivity (00094) Monthly Grab Effluent, Upstream, and Downstream pH3 (00400) 2/Month Grab Effluent, Upstream, and Downstream Dissolved Oxygen (00300) Monthly Grab Effluent, Upstream, and Downstream Total Dissolved Solids 70295 Monthly Grab Effluent Total Suspended Solids 00530 10.0 mg/L 15.0 mg/L 2/Month Grab Effluent Total Residual Chlorine4 50060 13 µg/L 2/Month Grab Effluent Total Copper 01042 Monthly Composite Effluent Total Chloride 00940 Monthly Composite Effluent Total Iron 01045 Monthly Composite Effluent Total Manganese 01055 Monthly Composite Effluent Total Lead 01051 Monthly Composite Effluent Total Zinc 01092 Monthly Composite Effluent Ammonia -Nitrogen 00610 Monthly Composite Effluent Fluoride 00951 Monthly Composite Effluent Total Nitrogen 00600 Monthly Composite Effluent Total Phosphorus 00665 Monthly Composite Effluent Whole Effluent Toxicity Monitoring5 (TGF3E) (,fuse Mysid Shfimp as test organism) Quarterly Composite Effluent Footnotes: 1. An exception to the composite sampling is provided by 15A NCAC 2B.0505 (C), which states that facilities with design flows under 30,000 gallons per day may use grab samples to characterize their effluent. 2. Upstream = at least 100 feet upstream from the outfall; Downstream = at least 100 feet downstream from the outfall. 3. The pH shall not be less than 6.8 standard units nor greater than 8.5 standard units. 4. The limit for total residual chlorine will take March 1, 2009, only if chlorine is used for disinfection. 5. Acute Toxicity 24-hour Pass/Fail Monitoring shall be conducted quarterly at 90% in March, June, September, and December. Permittee has designated Mysid Shrimp as his test organism. Permittee may choose to use Fathead Minnow, or Mysid Shrimp, or Silverside Minnow as the test organism. However, any change in test organism requires prior written approval by DENR/DWQ so all affected concerns can be addressed including assignment of the correct parameter code (see A. (2.)). All samples collected should be from a representative discharge event. There shall be no discharge of floating solids or visible foam in other than trace amounts. TOWN OF B EAUFORT 112 Fredrick Street Betud'ori, N.C. 28516 (252) 728-7166, (252) 728-7981 rm m%-%v.bcaulixlnc.org November 5, 2007 Mr. Gil Vinzani Supervisor, Eastern NPDES Program NCDENR — Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJECT: Request for Modification from Whole Effluent Toxicity Limits to Monitoring Pine Street Water Treatment Plant NPDES #0072699 Town of Beaufort, Carteret County, North Carolina Dear Mr. Vinzani: The Town of Beaufort is currently working to update the Pine Street WTP and Glenda Drive WTP facilities and operations to meet new discharge limits and monitoring requirements imposed by the most recent NPDES permits. It has come to our attention that while the Glenda Drive WTP is subject to a monitoring requirement for Whole Effluent Toxicity (WET), the Pine Street WTP is subject to an Acute Toxicity Pass/Fail Permit Limit. Our Engineer, Rivers and Associates, Inc., has discussed the rationale for the Pass/Fail requirement at the Pine Street WTP with Jim McKay of you office and Linda Willis of the Wilmington Regional Office. The result of those discussions suggested that the Pine Street WTP NPDES permit should have included WET monitoring in lieu of the P/F limit. As such, we have been encouraged to request a modification to that effect. Our request for this modification is based on the following factors: • The NPDES Permitting Strategies for Potable Water Treatment Plants, dated September 2007, indicates "Membrane, ion exchange, and conventional WTPs should be required to conduct quarterly WET tests for monitoring purposes." John Young, Director or Public \Yorks Johnnv O'Shall, Public \Yorks Supenisor Prink S:utsonc, \Vater/ORC Elbe,t Godctte, Construction fi\laiuta•nanee Supen�isor Dennis Dictcalr, \YwTP/ORC Sallie face, Adminis native Support Specialist y 1, - o The Glenda Drive WTP, which is not subject to a WET Permit Limit, discharges to Class SA surface waters. The Pine Street WTP, however, discharges to lower quality Class SC waters. It does not seem reasonable that the WTP that discharges to lower quality waters should have more stringent limits. • It would appear that if the P/F Limit was truly intended for the Pine Street WTP, a compliance time frame would also be provided. The only compliance schedule provided was for the low level total residual chlorine limit. As such, we respectfully request that the Acute Toxicity P/F Limit for the Pine Street WTP be replaced with the WET Monitoring requirement. On behalf of the Town of Beaufort, thank you for your consideration of this request. Should you have any questions, please do not hesitate to call this office at 252-728-7166 or Rivers and Associates, Inc. at 252-752-4135. W' best regards, f �, John You Public Wor irecto cc: Oirn McKay, Eastern NPDES Program Linda Willis, Surface Water Protection, DWQ, Wilmington Regional Office Terri Parker-Eakes, Town of Beaufort Frank Sansone, Water System ORC Greg Churchill, P.E., Rivers & Associates, Inc.