HomeMy WebLinkAboutNC0072699_Technical Correction_20071220Mr. John Young
Public Works Director
412 Hedrick Street
Beaufort, North Carolina
Dear Mr. Young.
28516
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
December 20, 2007
Subject: Correction for NPDES Permit NCO072699
Pine Street W'IP
Correction fro NPDES Permit NCO072702
Glenda Drive WTP
Carteret County
In regards to your November 5, 2007 request to modify Pine Street WFP 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 NC0072702 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 Associites.
The protocol is for the permittee 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 WTP Pemut
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 (Mysidopsis 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 Brands Telephone (919) 733-7015
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 FAX (919) 733-0719�{�;�lina
512 N. Salisbury Sleet, Raleigh, North Carolina 27604 On the Internet at ht4m11h2o.enrsrate.n :vs1 Ovu�urldI,�
An Equal OpponunWAffinnalive 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 WIT 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 permittee. 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.berry@ncmafl.net.
Sceerr�
Pnelyy,
o
�
berry
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 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 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
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum.
Measurement
Frequency
Sample,Type
Sample Location,
Flow
Weekly
Estimate
Effluent
Tem erature, ° C
Monthly
Grab
Effluent, Downstream 1
Salinity
Monthly
Grab
Effluent, Downstream 1
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 rn /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 Toxicit 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.
PHONE LOG: Pine Street WTP NC0072699 Correction pb: Ron Berry
Date: 11 /09/2007
Called John Young, contact for Beaufort WTPs, left voice message asking for return
call to discuss 11/5/07 letter.
Date: 11/13/2007
Received voice message from Greg Churchill, consultant River & Associates, requesting
return call in regards to 11 /9/2007 call to John Young.
Called back and discussed Acute Toxicity Monitoring intent for WTP. Acknowledged
existing permit Toxicity language for Pine Street WTP should be a Monitoring format.
Both the Pine Street WTP and the Glenda Drive WTP toxicity language, excluding the
test months, should be the same. Noted the Glenda Drive WTP test organism was
already set at the default. Reviewed test organism selection process, future selection
options, and requested the consultant contact Beaufort and obtain a test organism or we
would revert to default for Pine Street WTP. Upon establishment of the test organism we
would issue a cover letter with the corrected permit pages including more details were
applicable.
Date: 11/20/2007
Received email from Craig Churchill designating Mysid Shrimp as test organism for Pine
Street WTP. See file copy email.
Pine Street WTP - Beaufort, NC - NPDES Permit Clarification
Subject: Pine Street WTP - Beaufort, NC - NPDES Permit Clarification
From: "Greg Churchill"<ghurchill@riversandassociates.com>
Date: Tue, 20 Nov 2007 13:31:26 -0500
To: <ron.berry@ncmail.net>
CC: <bflpubwk@beaufortnc.org>, <bftwater@beaufortnc.org>
Ron -
The Town has selected the Mysid shrimp as
Whole Effluent Toxicity monitoring. Thank
matter.
Greg
Please visit our website:
http://www.riverBandaBsociates.com
NC po �-no cl`i
N e o D q-2-4�-O 2-
the species for conducting
you for your help with this
PrNF�- s l2rr—r
C,UFNb A -D P,IQrr
1 of 1 11 /21 /2007 8:08 AM
1 * \ (Th C) I, rL 0
Permit NC0072699
A. (2.)ACUTE TOXICITY PASS/F ERMIT LIMI QUARTERLY)
A ti IY�WI%�,elN�
The permittee shall conduct acute t city tests on aguarlerlu basis using protocols defined in the
North Carolina Procedure Docum t entitled "Pass/Fail Methodology For Determining Acute Toxicity
In A Single Effluent Conc ntrati n" (Revised -July. 1992 or subsequent versions). The monitoring
shall be performed as a(a ea Minnow (Pimephales promelas), or ysid Shrimp (Mysidopsis Bahia),
rside Minnow (Memdta ery tna errm nour static test. Once a test
organism a en-selecte,-all-su�mustuse-the same test organism. The permittee
must noti the NPDES r f the selected test organism during the draft permit review period.
The effluent concentration t which there may be at no time significant acute mortality is 90% 1/
(defined as treatmdrrttwo if th'"rocedure document -Effluent same for se -m�lo Ylnrisg-guzpes6s
must be obtained during representative effluent dis ge below all waste treatment. The tests will be
performed durin th be .
All toxicity testing results required as part of thi 1 I �-G di '
Discharge Monitoring Form (MR-1) for the in which-it-wa<.
code E6C-(Fathead Mirinow), pr TGE3 ysid Shrimp) or TIE
Additi orm Nor-2 (original) is to a sen o e
Attention: th Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center /
Raleigh, North Carolina 27699-1621 Ql
entered on the Effluent
Minn�o\\_
" �vda
,Oa kA4A4- Iu'�'
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no 01
later than 30 days after the end of the reporting period for which the report is made. (j
. Ja
Test data shall be complete and accurate and include all supporting chemical/physical 0t\
measurements performed in association with the toxicity tests, as well as all dose/response data. D
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine i�
employed for disinfection.
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. l A
W(5uid 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. _
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 sina est i Z
passe Upo assin
this monthly test requirement will revert to quarterly in the mon sp red a ovQ.
LV
Should any test data from either these monitoring requirements or tests performed)rfby 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.
4t�rM:55 �^^
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 S�
following the month of the initial monitoring.
sc_ ��
Permit NC0072699
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
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample Location
Flow
Weekly
Estimate
Effluent
Temperature, o C
Monthly
Grab
Effluent, Downstream 1
Salinity
Monthly
Grab
Effluent, Downstream 1
Conductivity
Monthly
Grab
Effluent, Downstream
PH 2
2/ Month
Grab
Effluent, Downstream
Dissolved Oxygen
Monthly
Grab
Effluent, Downstream
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 ToACIty 4
Quarterly
Grab
Effluent
Notes: `
1. Downstream sample at least 100 feet downstream of the discharge point. Y
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 8 m_ Win___
er t e permrt a ec roe a e monitoring shall begin immediately.
Acute Toxici ass/Fail Monitoring shall be conducted quarterly at 90% int at
March, June, September, and December. Permittee has designated Mysid Shrimp as his f�
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.)).
4.
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 EAUIE®]E T
412 Hedrick Street
Beaufort, N.C. 28516
(252) 728-7166, (252) 728-7931 fax
www.beauforurc.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
L5 jj�1
!ta Nov 7 2007
_j
,.K 1iER QUALITY �
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 of Public Works
Johnny O'Sball, Public Works Supervisor Frank Sansone, Water/ORC
Elbert Godelle, Construction R Maintenance Supervisor Dennis Metcalf, W WTP/ORC
Sallie Pace, Administrative Support Specialist.
• 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
re� pied 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,
John You
Public Wor irecto
cc: Jim 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.