NC0023906_Pretreatment_LTMP_Letter & Pretreatment_HWA_Letter_20240403

DocuSign Envelope ID:OEEF2183-189B-439B-BF6D-BCBBCB6198FF
ROY COOPER cd
5 _
Governor d C
ELIZABETH S.BISER ;e
Secretary •E .
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
Via Electronic Mail Qpruitt(a-)wilsonnc.com) 4/3/2024
Laura Pruitt
Water Reclamation Compliance Coordinator
City of Wilson
P.O. Box 10
Wilson,NC 27893
Subject: Pretreatment Review of Long Term Monitoring Plan and Head Works Analysis
Program: City of Wilson
Wastewater Treatment Plant: Hominy Creek Water Reclamation Facility
NPDES#: NC0023906,Wilson County
Dear Laura Pruitt:
The Municipal Unit of the Division of Water Resources has reviewed the updated Long Term Monitoring Plan
(LTMP), the Headworks Analysis (HWA), and the Allocation Table (AT) for the City of Wilson (NC0023906).
The submission was received by the Division on 3/17/2023 (HWA and AT) and 5/27/2023 (LTMP).
The Division finds the LTMP sufficient for implementation. The Division concurs with the HWA calculations.
Proper implementation of an LTMP is also required by the City of Wilson's NPDES permit. Modifications to the
LTMP must be approved by the Division. Please ensure to use the latest LTMP, HWA, and AT reviewed by the
State.
The Division recognizes concern by the City for the calculated overallocation of Silver in the HWA/AT while
consistently maintaining an effluent non-detection for this parameter and also passing all toxicity tests.The Division
requests the City maintain status quo for the Silver sample regiment. The Division also requests the City to notify
the Division of any additional industrial discharge of Silver containing effluent.
The Division appreciates the reference to the Cyanide Limits and Metals Monitoring Memo from December 21,
1998, in regard to the Cyanide PQL and will be working with the lab to update the information with 2024 data in
light of changes to 40 CFR 136 requirements.
Regardless of approval action today, within 180 days of the effective date of any reissued or modified NPDES
permit the permittee would be required to submit to the Division a written technical evaluation of the need to revise
local limits (i.e., an updated IWS, or documentation of why one is not needed). This action may include revising,
updating,or adding to the list of Significant Industrial Users(SLUs).Pursuant to 15A NCAC 2H.0907(b)either the
Division or the permittee may initiate pretreatment program revisions.
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW. It is the
POTW's responsibility to ensure that these objectives are consistently met.
Thank you for your continued cooperation with the Pretreatment Program. If you have any questions or comments,
please contact Natalie Gorensek[email:natalie.gorensekkdeq.nc.gov] at(919)707-3660 or Keyes McGee at(919)
707-3626 [email: keyes.mcgee(kdeq.nc.gov].
Sincerely,
nhg/wil hominy_ltmphwa_2024_2 DocuSigned by:
Ec: Municipal Unit File khkhbtVh
Cheng Zhang,RRO C464531431644FE...
Central Files(Laserfiche) Michael J. Montebello,NPDES Branch Chief
Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh,North Carolina 27699-1611
919.707.9000