NC0083925_Staff Comments_20041020

Re: NCO083925
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Subject: Re: NCO083925
From: Susan Wilson <susan.a.wilson®ncmafl.neb
Date: Wed, 20 Oct 2004 16:24:13 -0400
To: Steve Mauney <Steve.Mauney®ncmail.net>
Yes - halhal you did comment on this one.
1) Well, there has been some argument about this by various people, but our current and past policy has been if the dilution is very
high (greater than 331:1) then we would not give a fecal coliform limit, but would require monitorin o (unless it's in Class B waters,
or the region specifically requested that we limit, or in areas of fecal impairment - in whi case we won give a limit). However - it
looks like fecal monitoring was never included in this permit - so someone may have inadvertently left it out. I think we would have to
reopen the permit at this stage to include it. I will make sure it gets noted in the file for next time. (but if you guys think there is a
potential public health problem, etc. we'll look into reopening it). In some cases, permittees have requested elimination of the fecal
monitoring and we'll look at the data and instream data to determine if it can be eliminated (don't think that was the case for this
permit).
t7
2) what's an "emergency engine generator"? It may be tricky ground since we left it out of the description of the permit, but If the ATC
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was approved with a generator - they should have a generator (your wording doesn't indicate that the generator was approved as
portable) - and that should be the legal driving force (OK - easier said than done, I know). Approvals after May 1993 require standby
generators (not portable) or dual feed (from 2 separate substations - hard to come by). The exception is for Class C - if they can
demonstrate electrical reliability (and I can tell you based on the ice storms and hurricanes - no one is asking for exceptions based on
5 „
reliability - they're just installing generators). Duality and standby generators were required after Tedder sent out the reliability memo
May 1993.
V
I'll copy this entire e-mail for the permit file.
Steve Mauney wrote:
SUSAN-This permit was just reissued on 4-15-04 and 2 questions have now come up.
1-Dven though this facility discharges to the Yadkin River and has significant dillution, shouldn t they have fecal coliform monitoring
and limits?
2-1his facility had an ATC issued on 12-30-96 which includes among other things, "an emergency engine generator". While I do not
know what equipment was listed in the original NPDES permit, the permits issued on 5-24-99 and 4-15-04 do not mention the
generator. Hasn't It been standard procedure on any discharges to WS waters to have the generator with emergency switch -over
required ?
Obviously the WSRO has had an opportunity to comment on all of the draft permits and in fact I "reviewed" the draft in 2004 and did
not mention any of these issues. (Ordering new reading glasses soon 11). We can get by with the portable generators that this facility
houses at this location for the new future, but if we modify this permit prior to 2009 we can address these issues.
Please clarify DWQ policy on items 1 & 2.-Steve
Steve Mauney
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone] ext 282
FAX: [phone]
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