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HomeMy WebLinkAboutNC0026051_Historical information_20021231January 7, 2002 Re: cc: Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Durham County Triangle Wastewater Treatment Plant NPDES Permit NC0026051; Case No. LV 01-473 COUNTY OF DURHAM ENGINEERING DEPARTMENT Enclosure Glen E. Whisler, P.E., County Engineer Chuck Kitchen, County Attorney Ken Schuster, Raleigh Regional Office Scott Lewis, Project Manager - Woodard & Curran CH/jld Dear Sir: As per a letter received December 7, 2001 from Ken Schuster in the Raleigh Regional Office regardins a notice of Violation and Assessment of a Civil Penalty. I am providing this response. A check in the amount of $45.27 is enclosed to cover the enforcement costs of the Civil Penalty. The Durham County Attorney’s Office advised my office to submit the remainder of the Civil Penalty to Durham County, to be forwarded to the local school system, as per a recent court decision. We have submitted the application for this check to be written. The Durham County Industrial Pretreatment Program (IPP) has had some success in determining the source(s) of Mercury discharges into our collection system. We are evaluating this information to determine if additional IPP efforts may be necessary to further reduce the discharges of Mercury and other regulated substances. If you have any questions or need further information, please call me at 560-7992. Sincerely, Chuck Hill P.E Utility Division Manager 120 E Parrish Sired. Law Bldg.. 1st Floor. Durham. N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirmattve Action Employer JV LABEL GENERAL JOURNAL ENTRY of 1(Page 1 J V NUMBER IY CREDIT AMT.DEBIT AMT.BS PROJECT tlACTIVITYDRGAGENCYFUND 2,000.00|III LV01-4731 I TII /2 2, OOP.00|II| ioio|I I3 I1 2514|I 2,000.00I I /4 DESCRIPTION:/V/PBANK7 DATE:4,000.004,000.00PREPARED BY:(NAME)TOTAL DATE: (NAME) APPROVED BY: 02 BANK VENDOR CODE VENDOR CODE SUB ORG PROVIDE! NAM! ACCOUNTING PERIODTRANSACTION CODE REVERSAL DATE V AGENCY|?/Y 02 D VENDOR CODE ADJUSTMENT (M) SUB OBJ/ SUB REV I/G REFERENCE FUND AGENCY 01 BANK 01 BANK TYPE JV Y 22 BANK 660 V/P 101 V/P 101 V/P 660 V/P County WWTP civil penalty Caseil | ioio| VENDOR CODE J_L M I | 1613 [ (DESCRIPTION: Payment of Durham 1/10/02 / //o/g? I I , I PROVIDER[DESCRIPTION : NAME________________L II -1 PROVIDER[DESCRIPTION: NAME______________________L [MM Y Y BUDGET Y Y | 0[ 7| 0| 2| F/Y | 0| 2| BUDGET OVERIDE INDICATORICOMA/ENTS: PIyES (Y) r~lNQ (N)I REPI ACCT. CODE | 4 1 3 M D D I___L_ 710 (6011 | VENDOR / PROVIDER CODE NAME | M M Y Y D D I Oj if 1| 0|0| 2| J V DATE ACTION ~ ORIGINAL ENTRY (E]_ i obj/ r [REV SRC |ACCT. TYPE II, I PROVIDER[DESCRIPTION: NAME Due to Public Schools - Civil Penalties BANK5 V/PBANK6 VENDOR / CODE PROVIDER[DESCRIPTION: NAME________L VENDOR ”7 PROVIDER[DESCRIPTION: CODE_______NAME__________ I January 11,2002 Re: Dear Sir: Sincerely, Enclosure cc: CH/vej Chuck Hill, P.E. Utility Division Manager Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Glen E. Whisler, P.E., County Engineer Chuck Kitchen, County Attorney Ken Schuster, Raleigh Regional Office Scott Lewis, Project Manager - Woodard & Curran Durham County Triangle Wastewater Treatment Plant NPDES Permit NC0026051; Case No. LV 01-473 Additional Information COUNTY OF DURHAM ENGINEERING DEPARTMENT 120 E. Parrish Street, Law Bldg., 1st Floor, Durham, N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirmative Action Employer I am writing to provide follow-up information to my January 7, 2002 letter regarding Case LV 01-473 (a copy of my letter is attached). The attached document titled “JV LABEL” is a copy of a journal entry completed to transfer $2,000.00 into an account (2514) designated for civil penalty amounts that will be transferred to the local public schools. This confirms that we did transfer the civil penalty amount of $2,000.00 per the direction of the Durham County Attorney’s office in response to Case LV 01-473. If you have any questions or need further information, please call me at 560-7992. Pl January 7, 2002 Re: cc: 120 E. Parrish Street, Law Bldg., 1st Floor, Durham, N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirmative Action Employer .•J-.Y‘ - ! .1 S' . Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Durham County Triangle Wastewater Treatment Plant NPDES Permit NC0026051; Case No. LV 01-473 COUNTY OF DURHAM ENGINEERING DEPARTMENT Enclosure Glen E. Whisler, P.E., County Engineer Chuck Kitchen, County Attorney Ken Schuster, Raleigh Regional Office Scott Lewis, Project Manager - Woodard & Curran CH/jld ..... Dear Sir: As per a letter received December 7, 2001 from Ken Schuster in the Raleigh Regional Office regarding a notice of Violation and Assessment of a Civil Penalty. I am providing this response. A check in the amount of $45.27 is enclosed to cover the enforcement costs of the Civil Penalty. The Durham County Attorney’s Office advised my office to submit the remainder of the Civil Penalty to Durham County, to be forwarded to the local school system, as per a recent court decision. We have submitted the application for this check to be written. The Durham County Industrial Pretreatment Program (IPP) has had some success in determining the source(s) of Mercury discharges into our collection system. We are evaluating this information to determine if additional IPP efforts may be necessary to further reduce the discharges of Mercury and other regulated substances. If you have any questions or need further information, please call me at 560-7992. Sincerely, CjLdgD Chuck Hill P.E Utility Division Manager -7 2002 I" I c=DuCTfOt;sACCOUNT NUMBER 45.27LV01-473ENFORCEMENT DWQ $45 Lurditi.s A? This check void if not cashed within 90 days. 664022561386284 -X r 2 Eli* ILD'AT:IMARK.*F1CAIIF CHECK HAS:IEBAIWH1TEPAPEI COH’POL NO. >5 f r ■•q- i c'/o'-' PAY YO=3=aOF □ io x ?&□ &"■ 200 EAST MAIN STREET, DURHAM, N.C. 2/701 AMOUNT OF IN', laL'/Aiii! £7-7407 532 Comtfg of Jurljam DESCRIPTION 01/07/2002|$_____45,2 This disbursement has seen approved as required by the Lccai Government Budget and Fiscal Control Act. 0066402? AMOUNT Or C- = Ck WBW •' CENTRAL CAROLINA BANK - DUR-iAM NC J (in cooperation with American Federal Bank) POINT SOURCE COMPLIANCE ENFORCEMENT UNIT DIV OF WATER QUALITY 1617 MAIL SERVICE CTR n'Odht UO E E"1 CO 5 3 E?liO?U': uuRnZEC.'iiL: iLZiilu dfnmtfg nf ^url]am 200 EAST MAIN STREET DURHAM, NC 27701 February 18, 2002 Re: Dear Sir: 120 E. Parrish Street, Law Bldg., 1st Floor, Durham, N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirmative Action Employer Durham County Triangle Wastewater Treatment Plant NPDES Permit NC0026051; Case No. LV 01-558 Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 - w vrn o'jality Fund SC-.^CE BXA.’iCH COUNTY OF DURH A ENGINEERING DEPARTMENT n ® i o e n A check in the amount of $45.27 is enclosed to cover the enforcement costs associated with the Civil Penalty. The Durham County Attorney’s Office advised my office to submit the payment of the Civil Penalty to Durham County, to be forwarded to the local school system, as per a recent court decision. The attached document titled “JV Label” is a copy of a journal entry that confirms the money has been transfened to the proper account. As per a letter received January 18, 2002 from Ken Schuster in the Raleigh Regional Office regarding a notice of Violation and Assessment of a Civil Penalty, I am providing this response. The Durham County Industrial Pretreatment Program (IPP) has had some success in determining the source(s) of Mercury discharges into our collection system and have issued Notices of Violation for several August violations. We are continuing to evaluate this information to determine if additional IPP efforts may be necessary to further reduce the discharges of Mercury and other regulated substances. Rr----A[ FEB 1 8 2002 If you have any questions or need further information, please call me at 560-7992. Enclosure cc: CH/jld Glen E. Whisler, P.E., County Engineer Chuck Kitchen, County Attorney Ken Schuster, P.E., Regional Supervisor - Raleigh Regional Office Scott Lewis, Project Manager - Woodard & Curran NPDES Permit NC0026051 Case No. LV 01-558 Page 2 Sincerely, Chuck Hill, P.E. Utility Division Manager STREET, DURHAM, N.C. 27701200 EAST W DEDUCTIONSAMOUNT OF INVOICEACCOUNT NUMBER G2022QL.Vui-558 45. 4 = r3 This check void if not cashed within 90 days. 021420022668613561386284 £ o io eq i ?&□&"•||■O□E>E3BEJ IHh* i:O53 2?UO?ii«: :E SACK OFCHECKHA3 A^TiHCAL WATSRMARK. HOLD AT AN ANGEETOD WITH A GREEN BACKGROUND ON WHITE PAPER ■ C?; ? VENDOR NO. ? ?asBa CONTROL NO. an WHEN DETACHED AND PAID. CHECK BECOMES A RECEIPT IN FULL PAYMENT OF ABOVE ACCOUNT. IF NOT CORRECT, RETURN WITHOUT ALTERATION. DETACH BEFORE DEPOSITING This disbursement has been approved as required by the Local Government Budget and Fiscal Control Act. ______amount of CHEC- (Jloutttg nf ^urljam DESCRIPTION 67-7407 532nf 200 EAST MAINSTREET DURHAM, NC 27701 CENTRAL CAROLINA BANK DURHAM, NC (in cooperation with American Federal Bank) 3 3 ■3 § i I 1 * PAY * TO THE ‘ORDER OF i [ForNT SOURCE COMPLIANCE/ ENFCRCEriENT UNIT/DIV OF WATER IT J AL J. TY/ 1617 HAIL SERVICE CT r? ALE IGH NC 2769?- 1617 SHECKNO/ ;- i^'hCHECKPATE:-r?| z7 - JV LABEL GENERAL JOURNAL ENTRY (Page1 of 1 ACCOUNTINGJ VTYPEJ V NUMBERTRANSACTION °| 2|PERIODDATEJVCODE ACTIONYYDDREVERSAL ADJUSTMENT (M)ORIGINAL ENTRY (E)DATE DEBIT AMT. PROJECT #ACTIVITYAGENCYORGTYPEFUNDACCT. 8 2,250.00660161371022 v/p PROVIDERVENDORBANK LV 01-558Case No.NAMECODE 2,250.001010660 |DESCRIPTION:I2 NAMECODE 1010 2,250.00101 /V/P PROVIDERVENDOR3 NAMECODE 2,250.002514101 [DESCRIPTION:/V/P PROVIDERVENDOR4 CODE NAME [DESCRIPTION:IV/P PROVIDERVENDOR5 CODE NAME [DESCRIPTION:/V/P PROVIDERVENDOR NAMECODE /BANK V/P PROVIDERVENDOR7 NAMECODE 02/18/2002DATE :PREPARED BY:(NAME) 4,500.004,500.00TOTAL cQ -[DATE:(NAME) APPROVED BY: Page 1 I I PROVIDER 02 BANK 03 BANK VENDOR J J M J SUB ORG OBJ/ REV SRC SUB OBJ/ SUB REV BS ACCT. CODE 6011 / B 01 BANK 02 01 BANK 02 01 BANK [~|yes (y) REP'll Ono (n) I/G REFERENCE FUND AGENCY '[DESCRIPTION: V AGENCY F/Y | 4 1 3 M M M Y Y BUDGET Y Y 0|8] 0| 2| F/Y BUDGET OVERIDE INDICATOR|COMMENTS: [payment of Civil Penalty CREDIT AMT. D I M M Y Y D D °|2| °|2|1|8| [DESCRIPTION: 8000____________ [DESCRIPTION: [Payment of Civil Penalty: JUL 2 6 2002 Subject: Dear Mr. Hill: cc: State of North Carolina^^ Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P. E., Director Raleigh Region WQ Supervisor Enforcement Files LV 01-473 and LV 01-558 DURHAM COUNTY ENGINEERING DEPARTMENT Chuck Hill Triangle WWTP 120 East Parrish St Durham, NC 27701 Telephone 919-733-5083 Fax 919-733-9612 50% recycled/10% post-consumer paper 1617 Mail Service Center, Raleigh, N. C. 27699-1617 An Equal Opportunity Affirmative Action Employer NCDENR North Carolina Department of Natural Resources Sincerely, E. Shannon Langley, Supervisor PSC/EU Final Notice of Civil Penalty Assessment Triangle WWTP NPDES Permit Number NC0026051 File Numbers LV 01-473 and LV 01-558 Durham County i g e mrint Tpy 2b, 2U0z III The Division of Water Quality assessed civil penalties in the amount of $2,045.27 and $2,295.27 against Triangle WWTP in violations of G.S. 143-215.1(a)(6) and the subject permit, by discharging waste into the waters of the State in violation of permit conditions. The assessments were sent via certified mail to Triangle WWTP and were accompanied by a list of available options that included: payment of the penalty, request for remission of the penalty, or request for an administrative hearing. If thirty (30) days pass after the receipt of a civil penalty assessment and there has been no action to exercise one of the three options cited above, then North Carolina General Statute 143-215.6A(g) allows the Secretary of the Department of Environment and Natural Resources to request the Attorney General to institute a civil action in Superior Court to recover the amount of the assessment. Records from our Division reveal that the assessment documents were delivered on December 7, 2001 and January 18,2002 respectively. To date, no response on behalf of the subject facility for the above enforcement cases have been received. This letter serves final notice that the Division will proceed to refer your cases to the North Carolina Attorney General’s Office for collection through the courts unless payment in the amounts of $2,045.27 and $2,295.27 is received by August 23, 2002. Should you have any questions, please contact Vanessa Manuel at 919/733-5083, extension 532. CERTIFIED MAIL RETURN RECEIPT REQUESTED 7000 1530 0002 2100 3189 l t 20C2 This check void if not cashed within 90 days, 566000372 685793 T fr 4. ....... 4 Permit Number:Annual Fee Period:7/1/2002 to 6/30/2003 Invoice Date:August 22, 2002 Due Date:September 21, 2002 Annual Fee:$2865.00 xjaia. Check Number:] IF CHECK HAS O VIEW. AMOUNT:heck date ‘ I I . It covers the-admmis&afive’ddsti'SNG j s &B 5 ? q 311" VENDOR NO. | CHECK NO. ' ^Cl NC0026051 Triangle WWTP ; L'JLIi ] I*JJ| W r | CONTROL NO. INVOICE Annual Permit Fee ANNUAL PERMIT INVOICE (Return This Portion With Check) v J 1 i Io. NcOPl CAROLINA DEPARTMEt^^F ENVIRONMENT AND NATURAL RESOtJRC nF~~’ I 4 I VJC11CI ar-ouuuixr j i z.. Non-Payment of this fee by the payment due date will initiate the permit revocation process. CHARLES N. HILL, JR. DURHAM COUNTY 120 EAST PARRISH STREET SUITE 100 DURHAM NC 27701 091 12002te****2; 865. OO This disbursement has been approved as required by the Local Government Budget and Fiscal.Control Act. 2. r ~ 3. Remit payment to: NCDENR -Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Should you have any questions regarding this invoice, please contact the Annual Administering and Compliance Fee Coordinator at 919-733-5083 extension 210. CENTRAL CAROLINA BANK ' DURHAM. NC ; (in cooperation with American Federal Bank) »:o5 3 2?uo?ui; io eq j PAY [ncdenr/div of water quality TO THE ORDER OF 1619 MAIL SERVICE CTR RALEIGH nc 27699-1606 | This annual fee is required by the North Carolina Administrative Code pm°1' “*«»"■*«« » ffiounfj of flurlpm ™ 200 EAST MAINSTREET DURHAM, NC 27701 * 6 L CJ This annual fee is required by the North Carolina Administrative Code. It covers the administrative 'ddsts'^G ; Annual Fee Period:7/1/2002 to 6/30/2003Permit Number: Invoice Date:August 22, 2002 Due Date: Annual Fee: Annual Fee Period:7/1/2002 to 6/30/2003 Invoice Date:August 22, 2002 Due Date:September 21, 2002 Annual Fee:$2865.00 Check Number: associated with your permit. It is required of any person holding a permit for any time during the annual fee period, regardless of the facility’s operating status. Failure to pay the fee by the due date will subject the permit to revocation. Operating without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and you later decide a permit is needed, you must reapply, with the understanding the permit request may be denied due to changes in environmental, regulatory, or modeling conditions. CHARLES N. HILL, JR. DURHAM COUNTY 120 EAST PARRISH STREET SUITE 100 DURHAM NC 27701 Permit Number: NC0026051 Triangle WWTP CHARLES N. HILL, JR. DURHAM COUNTY 120 EAST PARRISH STREET SUITE 100 DURHAM NC 27701 September 21, 2002 $2865.00 NC0026051 Triangle WWTP INVOICE Annual Permit Fee NNUAL PERMIT INVOIC (Return This Portion With Check) NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOO^'fil Notes: 1. A $25.00 processing fee will be charged for returned checks in accordance with the North Carolina General Statute 25-3-512. 2. Non-Payment of this fee by the payment due date will initiate the permit revocation process. 3. Remit payment to: NCDENR -Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 4. Should you have any questions regarding this invoice, please contact the Annual Administering and • Compliance Fee Coordinator at 919-733-5083 extension 210. ■Cgsg; n n V E J 1 'i Date: May 2, 2002 To: PART I - GENERAL INFORMATION 1. 2.Report Prepared by: Ken Schuster Discharge Point(s), list for all discharge points:5. Longitude: 78° 53’ 50”Latitude: 35° 52’ 50” Attach a USGS map extract and indicate treatment facility site and discharge point on map. U.S.G.S. Quad Name: Southwest Durham, NCU.S.G.S. Quad No.: D23NW Treatment plant classification (attach completed rating sheet): IV6. 3. 4. STAFF REPORT AND RECOMMENDATIONS FOR AUTHORIZATION TO CONSTRUCT AN UPGRADE 12.0 MGD PLANT WITH BNR, CHEMICAL PHOSPHOROUS PRECIPITATION, TERTIARY SAND FILTRATION AND UV DISINFECTION Non-Discharge Staff Report Page 1 NPDES Unit Attention: Mike Myers County: Durham Permit No.: NC0026051 ATC Permit No.: 026051A01 Date of most recent NPDES Staff Report (attach copy): November 29, 1995 report Changes since previous action on NPDES Permit: The revised draft NPDES permit revision is presently being reviewed by EPA. Facility and Address: Triangle WWTP NC Highway 55 and NCSR 2028 West ofRTP Durham County SOC PRIORITY PROJECT: Yes No X If Yes, SOC No.: 4 Date of Investigation:7. 8.Persons Contacted and Telephone Number: Directions to Site:9. 10. 11.Topography (relationship to flood plain included): Location of nearest dwelling:12. Receiving stream or affected surface waters:13.Northeast Creek PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS Volume of Wastewater to be permitted: Upgrade from 6.0 to 12.0 MGD1.a. b. c. d. e. f. PROVIDE ADDITIONAL INFORMATION FOR PARTS I, II, AND III ONLY IF IT IS NOT PROVIDED IN ATTACHED STAFF REPORT Site size and expansion area consistent with application? Yes: No: If No, explain: Please provide a description of proposed wastewater treatment facilities: Phase II: Upgrade to 12.0MGD and installation of five stage biological nutrient removal Classification: WS-IV NSW River Basin and Subbasin No.: Cape Fear, subasin 30605 Describe receiving stream features and pertinent downstream uses: Non-Discharge Staff Report Page 2 What is the current permitted capacity of the Waste Water Treatment facility? 6.0 MGD a. b. c. Actual treatment capacity of the current facility (current design capacity)? 6.0 MGD Date(s) and construction activities allowed by previous Authorization to Construct issued in the previous two years: New headworks and UV disinfection (ATC no. 026051ACF dated 3/23/01) and post-aeration(ATC no. 026051ACE dated 12/10/99) Please provide a description of existing or substantially constructed wastewater treatment facilities: The phase I construction started March 2002 Possible toxic impacts to surface waters:g- h. X 2.Residuals handling and utilization/disposal scheme: a. b.Residuals stabilization:PFRP: Landfill:c. d.Other disposal/utilization scheme (Specify): SIC Code(s):3. 4. Main Treatment Unit Code:5. PART III - OTHER PERTINENT INFORMATION 1. Special monitoring or limitations (including toxicity) requests:2. 3. Is this facility being constructed with Construction Grant Funds or are any public monies involved, (municipals only)? No Important SOC, JOC or Compliance Schedule dates: (Please indicate) Date Residual Contractor: Telephone No.: Pretreatment Program (POTWs only): in development: approved: should be required: not needed: system (BNR) with chemical phosphorous precipitation and tertiary sand filtration Non-Discharge Staff Report Page 3 PSRP: Other: Wastewater Code(s) of actual wastewater, not particular facilities i.e.., non-contact cooling water discharge from a metal plating company would be 14, not 56. Include more than one code if applicable: If residuals are being land applied, please specify DWQ permit no.: WQ0007989 reissued 11/8/99, expires 10/31/04 4. 5. PART IV - EVALUATION AND RECOMMENDATIONS Submission of Plans and Specifications Begin Construction Complete Construction Non-Discharge Staff Report Page 4 Alternative Analysis Evaluation: Has the facility evaluated all of the non-discharge options available? Please provide regional perspective for each option evaluated. Spray Irrigation: Connection to Regional Sewer System: Subsurface: Other disposal options: Other Special Items: Our staff has reviewed our files of the above referenced site, as well as the plans and specifications submitted, in order to make the following comments and recommendations for the request. The construction of the new phase I headworks and UV disinfection has started as allowed by ATC no. 026051 ACT dated 3/23/01. The treatment train top of wall elevations are shown above the 100 year elevation of 251.7 (251.75 was shown on one detail), as well as the chemical containment walls. I did not see elevations for the electrical equipment panels, etc. These need to be well above the 100 year flood elevation also. With three BNR treatment trains, 4 clarifiers, and 5 tertiary sand filter cells reliability as per 2H.0124 is met. There are 3 each RAS/WAS pumps. The chemical feed systems have multiple pumps for the various trains and meet reliability requirements. Three emergency generators for 100% are included. A 500KW generator for headworks, administration building, and analytical laboratory. A 1400KW generator for BNR process, clarifiers, and the RAS/WAS pumping system. A 500KW The Raleigh Regional Office has reviewed the current submittal package requesting Authorization to Construct (ATC) for the Phase II expansion. This expansion will include: 1. Five stage biological treatment Kruger A2O process utilizing an anaerobic “selector”, primary anoxic tank, aerobic reactor (oxidation ditch), secondary anoxic reactor, and re­ aeration tank to remove organics and nutrients. 2. Alum (or sodium aluminate) is added to the mixed liquor prior to distribution chamber to four 110' dia. x 16' SWD center-feed clarifiers. These clarifiers will maintain a minimum 15" blanket at all times to create anoxic conditions and improved colloidal solids capture, prior to recycling sludge back to the first BNR tank. 3. Replace the existing tertiary filtration with new five-celled traveling bridge type tertiary sand filtration. A traveling backwash hood will be used for cleaning. The hood is indexed to stop on each cell, lowered for a seal, and a backwash pump draws filter effluent from the underlying effluent plenum. Backwash cycles will be able to be initiated either manually, by timer , or via liquid level sensors. BatWater Quality Regional Supervisor Non-Discharge Staff Report Page 5 generator for tertiary filtration, UV disinfection, post aeration, maintenance building, and chemical feed systems. The DWQ issued speculative limits on July 7, 2000 and they are shown on Table VI-2 in the calculation manual. The entry in the table for the design year TN show “8371 Ibs/d”. The related footnote does show it correctly: At 12 MGD 8,371 lb TN/month corresponds to an average concentration of 2.75 mg/1. The plant chemical feed capabilities will be; methanol introduced to the 2nd and 4th BNR stages, potassium hydroxide feed in the oxidation ditches to maintain alkalinity, sodium aluminate for phosphorous removal with capability to feed to the clarifier distribution box or the filters, polymer for settling added to the clarifiers, and sodium hypochlorite to control biological growth in the filters. The SCADA is defined in volume 2 of the technical specifications. An inspection of the present treatment plant was made on April 1, 2002 by Kirk Stafford of this office. During the inspection it was noted that no staff gauge was present in either of the sludge lagoons. Mr Cozart, the ORC stated that the staff gages were knocked down during sludge removal in 2000 by the contractor and that the contractor was supposed to reinstall the gages. The West lagoon had approximately 12 inches of freeboard and the East lagoon had approximately 18 inches of freeboard. The RRO would like to ensure that those gages are replaced as soon as possible. The RRO is concerned that phase II will not include residuals handling and that the phase III residuals management construction is not planned to start until March of 2005. The ORC has stated that during Phase I of the plant upgrade, the West lagoon sludge is scheduled to be land applied. It is not clear what will be done with the sludge in the East Lagoon. The regions previous comments from the EAA review include: The RRO is concerned that the solids handling process is not adequately addressed in the EAA. Although there is some mention to digesters and thickeners, there do not appear to be any shown on the map of the final recommended alternative. The final recommended alternative shows one sludge lagoon is to remain operational at least until start-up of new facility, however, there do not appear to be any other sludge storage facilities identified. The RRO recommends that both sludge storage lagoons be taken out of service once the new facility is on-line, and that appropriate new storage tanks, digesters, and any other necessary solids handling equipment he included with Phase II of construction. (This may already be the case, but it did not appear clear in the EAA.) The City should address whether the lagoons are storage lagoons or treatment lagoons and how they are complying with the 503 requirements Based on the above, the RRO recommends that the subject project be awarded an ATC as requested, pending P&E satisfaction of all requirements. The RRO would also appreciate correspondence back pertaining to any request for additional information. Signature of report preparer y / £>ate WORKS DESCRIPART II (Ultimate to 1. capacity facilitycurrentthe Date(s) e. wastewater f. waters:Chlorine,surfacetoimpacts g- h. scheme: 2. a. b. Landfill:c . scheme (Specify):Otherd. 3. 4 . plant classification - no change description of proposed none Residuals stabilization: PFRP 59, 051-3 PSRP X Other If residuals are permit no. [_ .I OF DISCHARGE AND TREAjj|| be permitted: Treatment sheet):IV disposal/utilization (attach completed rating ■' l activities Construct issued — treatment facilities: the influent pump clarifier, ’--- , 3 allowed by previous in the previous two years: (POTWs only): approved X not needed f. Please provide a treatment facilities: Possible toxic metals, organics Pretreatment Program in development should be required c. Actual treatment (current design d. Date(s) and construction Authorization to <-- none current permitted facility? 6.0 MGD a description of existing or constructed wastewater r grit extended tertiary filters a. volume of Wastewater Design Capacity) b. What is the Water Treatment ---p station dual chlorination and of the Waste Residuals handling and utilization/disposal -< being land applied, please specify DEM WQ0007989 S«C : 4code( s) Of actual wastewater, not particular facilities i e -, non-contact cooling water discharge from a metal plating company would be 14, not 56. Primary 01 Secondary 59, 57, 79, Main Treatment Unit Code. capacity of capacity)? 6.0 MGD Please provide substantially bar screen, train ’--- removal at aeration. 6.0 MGD 55 3976 ”75 55 ”74 3973000m 689 690 •688 55’ 1 MILE or 7000 FEET I KILOMETER ■ ■ ... Unimproved road = Primary highway, hard surface Secondary highway, hard surface Light duty road, hard improved surface = 78’52'30” II • INTERIOR—GEOLOGICAL SURVEY. HESTON. VIRGINIA—198? •L 9 Ml TO U S 64 tgiOOOm [ ROAD CLASSIFICATION .0 ®i 55,3977 'JOO- llpi // CVX o (V £ col/ 01-j 9» / •< yj sfez IgSewage^, Jo Disposal f^Ap: ^ZS/171^ /nA^Xov / / ° 1 T 1/ ’ _Tj > / 2 \ir i^- Soo-Jy J.fsY if Zz O *°/ =4 "300 -35O<// J —TscVrtO /at5 1 WsfsllFx 0 jl iW . A-q.^a . I St???/ 'V •Q.NAME OF FACILITY: MAILING ADDRESS: COUNTY: CONTACT PERSON: TELEPHONE: (.) A/S6O 6Zo(55>7PERMIT NO:Check One: NC2L_ WQ HEALTH DP ORC: TELEPHONE: (.1 PERMITTED FLOW: MGD BNR? YES NO . CHECK CLASSIFICATION: WASTEWATER:1 2 3 4 COLLECTION:1 2 3 4 SPRAY IRRIGATION SUBSURFACE LAND APPLICATION PHYSICAL/CHEMICAL GRADE I GRADE II REGION: RATED BY:DATE: ) 5^/ REGIONAL OFFICE TELEPHONE NUMBER: £ CLASSIFICATION RATING SHEET FOR WATER POLLUTION CONTROL SYSTEMS WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION FACILITY INFORMATION: a RATING INFORMATION: (Before completing this section, please refer to pages 2-4) Lead Review Agency: Municipal Contact:Engineering Consultant: Prepared by: DURHAM COUNTY TRIANGLE WASTEWATER TREATMENT FACILITY INTERIM BIOSOLIDS MANAGEMENT DURHAM COUNTY, NORTH CAROLINA Original Submittal: June 2002 Mr. Kevin C. Eberle, P.E. McKim & Creed, P.A. 5625 Dillard Drive, Suite 117 Cary, N.C. 27511 (919) 233-8091 McKim & Creed, P.A. 5625 Dillard Drive, Suite 117 Cary, NC 27511 (919) 233-8091 Mr. Chuck Hill, P.E. Durham County Engineering Dept. 120 Parrish St. Law Building Durham, N.C. 27701 (919) 560-7992 Mr. Dave Goodrich NC-DENR Water Quality Section, Point Source Branch, NPDES Unit 161 7 Mail Service Center Raleigh, N.C. 27699-1617 (919) 733-5083 ext.517 SEAL > - = /■ INTRODUCTION Phase I: Phase II: Phase III: 2 McKlMcVCREED Influent pumping station, screening, grit removal, influent flow measurement, UV disinfection, post aeration, effluent flow measurement, and SCADA systems. Five stage biological nutrient removal process, tertiary filtration, waste activated and recycled activated sludge pumping systems, chemical feed systems. Laboratory, Administrative Offices and Maintenance Building Construction, and SCADA integration. Waste activated sludge storage, sludge thickening, thickened sludge storage, belt filter press dewatering. Class A lime pasteurization process, truck loading, and emergency Class A residuals storage. A detailed Engineering Alternative Analysis and Basis for Final Design Report was completed for the Durham County Triangle Wastewater Treatment Facility in July 2000. Based on recommendations from that Study and the subsequent Environmental Assessment, Durham County has elected to upgrade the Triangle Wastewater Treatment Facility Upgrade to a state-of-the-art, 12.0 MGD, five stage biological nutrient removal system (BNR) with chemical phosphorus precipitation, tertiary sand filtration and UV disinfection. The proposed improvements will allow Durham County to reduce total nitrogen mass discharges to Northeast Creek by 69% from currently permitted levels and to reduce phosphorus mass discharges by 50% from currently permitted levels. In order to insure that the Triangle WWTF continues to produce an effluent in full compliance with existing and future NPDES permit limits, construction of the proposed improvements must be completed in Phases. This will allow existing treatment processes to remain in full operation until completion of the five-stage BNR process. The proposed improvements will be constructed in three phases via three separate construction contracts. Key treatment process components included in each phase are as follows: The schedule for construction is os follows: BACKGROUND 3 ^MQOd&CREED Treated effluent from the facility is discharged to Northeast Creek, a tributary to Jordan Lake in the Cape Fear Drainage Basin. The existing surface water discharge is permitted under Phase I Construction Starts Phase I Construction Substantially Complete Phase II Start-up, Stabilization and Operational Testing NPDES Permit Issuance (Phase II) Authorization to Construct (Phase II) Phase II Advertisement for Bids Phase II Open Bids Phase II Award Contracts Phase II Start Construction Phase II Substantial Completion Phase II Construction Phase II Final Completion Phase II Start-up, Stabilization and Operational Testing Phase II NPDES Compliance Date Phase III Advertisement for Bids Phase III Open Bids Phase III Award Contracts Phase III Start Construction Phase III Substantial Completion Phase III Construction Phase III Final Completion Phase III Start-up, Stabilization and Operational Testing March 2002 November 2002 November 1 - December 31,2002 May 1,2002 May 1,2002 July, 2002 August 20, 2002 September 16, 2002 November 4, 2002 August 31, 2004 October 31,2004 November 1 - December 31,2004 January 1,2005 September, 2004 October 20, 2004 December 16, 2004 January 15, 2005 January 15, 2006 March 15, 2006 March 15, 2006-June 1,2006 The Phase III improvements (Biosolids Management Processes) cannot be initiated until after the new five-stage BNR process is completed. This is because the new biosolids improvements will be constructed in the footprint of the existing aeration basins and, therefore, cannot be taken off-line until after BNR startup. As such, this Interim Biosolids Management Plan has been developed to insure the Triangle WWTF will continue to adequately store, treat and dispose of all residuals produced while the facility is under the various phases of construction. The Triangle Wastewater Treatment Facility (WWTF) is located at the intersection of NC 55 and Alexander Drive in the southeast corner of Durham County, North Carolina. The municipal wastewater treatment facility is owned by Durham County and is currently operated under contract with Woodard & Curran Inc. ❖1973 1986❖ 1990's❖Upgrade to incorporate chemical phosphorus removal using alum. 4 d»>MCKIM<9CREED In 1993 the County completed a biosolids treatment and disposal plan and received State Certification for periodic Class B land application onto 452 acres of agricultural lands in Granville County. The County entered into two, 1-year contracts with EWR, Inc. and BioGrow, Inc. for biosolids removal and disposal in 1993 and 1994. In 1995, AMSCO, Inc., now known as Synagro Southeast, Inc., was retained by the County under a 3-year contract to remove and land-apply accumulated biosolids. Upgrade to construct a new activated sludge secondary treatment system with design capacity of 3 MGD. Upgrade to expand existing activated sludge process to 6 MGD and to construct two new tertiary sand filters to enhance BOD and TSS removals. In March 1998, Woodard and Curran, Inc. (W&C) was retained as the Contract Operator for the Triangle WWTF and has been responsible for biosolids handling and disposal since that time. W&C’s current contract with the County expires in 2003. The Wastewater Treatment Facility (WWTF) was originally constructed in the earlyl960’s to abate surface water pollution. The original facility consisted of a two-celled facultative lagoon designed to reduce organic and suspended solids loading to Northeast Creek. Since that time, three significant Wastewater Treatment Facility upgrades have been completed including: the National Pollution Discharge Elimination System (NPDES) subject to effluent conditions described in Permit # NC0026051 which became effective on April 1, 1996. The County converted the original, facultative lagoons into facultative sludge stabilization/storage basins as part of the 1973 and 1990 upgrades. The use of these 8 MG (16 MG total capacity) facultative, sludge storage lagoons has continued since that time. 5 ^MCKEWCREED Under W&C's management, biosolids are typically removed from the lagoons and land­ spread only once per year during a 30 - 60 day period coinciding with the farmer's hay cropping schedule. In the past, W&C has retained the services of specialty firms to vacuum dredge the lagoons and either land apply liquid biosolids or dewater the biosolids on-site and dispose of dewatered cake on certified land-application sites located in Granville County. Liquid biosolids removed from the lagoons typically have an average solids content of 6 to 8 percent solids and have been as high as 14 percent solids. In June 1999, the County retained McKim & Creed to assist them in completing the required Engineering Alternative Analysis and Basis of Design Report prior to proceeding with During the three year period from 1999-2001, Woodard & Curran has documented biosolids production to be 2,587 dry tons. During this same period, they have either physically removed, or documented volatile solids reduction in the lagoons amounting to a total of 4,649 dry tons. A Facility Evaluation and Preliminary Engineering Study completed in 1997 identified a number of recommended improvements and the need to expand the hydraulic and organic capacity of the Triangle WWTF. The Evaluation also identified the need to replace the existing biosolids facultative lagoons with more modern biosolids handling facilities to insure the County can consistently satisfy biosolids disposal regulatory requirements. According to Annual Operating Reports submitted to the County by W&C, the 1999 average daily flow to the Triangle WWTF was 4.141 MGD. Waste activated sludge (WAS) production during this same period was 1,112 dry tons. Then in 2000, biosolids production dropped to 753 dry tons and futher dropped to 722 DT in 2001. W&C attributes the significant difference in WAS production in the second and third year to supplemental residuals management by the biotechnology firm Ennix Bio-Service. According to W&C, the cultured biomass additive has been successful in reducing soluble BODs concentrations in the lagoon supernatant, which is regularly returned to the treatment process. This reduction in BODs loading to the main treatment process has significantly decreased biosolids production and, as a result, reduced the volume of biosolids wasted to the lagoons. BIOSOLIDS PRODUCTION ESTIMATES 6 ^MCKIM<9CREED mandatory facility improvements and expanding the hydraulic and organic capacity of the Triangle WWTF to accommodate projected sewage flows through the year 2023. Estimates of biosolids production have been made on an annual basis for the period between May 2002 and December 2006. This period fully includes all phases of construction. Biosolids production estimates were developed using current Average Daily Flow and actual biosolids production information provided by the Contract Operator Woodard and Curran. Future year wastewater flows were previously projected as reported in the Engineering Alternative Analysis and Basis for Design Report dated July 2000, last updated October 2000. Assuming organic and suspended solids concentrations remain consistent, biosolids production will be proportional to influent flow to the plant. As such, residuals production on a dry weight basis are expected to increase as summarized in Table 1. This Interim Biosolids Management Plan is intended to provide overall guidance for managing residuals produced during the four-year phased construction period prior to the start-up of the new Biosolids Management Improvements. Based on the final recommendations from the Engineering Alternative Analysis and Basis of Design Report, the County has proceeded with permitting and design of a new, state-of-the- art, 5-stage biological nutrient removal process at the existing Triangle WWTF site. In order to expedite the environmental review and permitting process, the Engineering Alternative Analysis concentrated on the main process train and did not evaluate biosolids management alternatives in connection with the new facility. Amendment #1 to the original Engineering Alternative Analysis has been completed in draft form and specifically addresses permanent Biosolids Management at the upgraded Triangle WWTF. It also provides recommendations and a basis for final design for the proposed new biosolids storage, thickening, dewatering and stabilization processes. YEAR INTERIM BIOSOLIDS MANAGEMENT INFRASTRUCTURE PHASE YEAR DESCRIPTION OF BIOSOLIDS INFRASTRUCTURE TABLE 2 PROJECTED BIOSOLIDS PRODUCTION BETWEEN MAY 2002 AND DECEMBER 2006 TRIANGLE WASTEWATER TREATMENT FACILITY AVERAGE DAILY INFLUENT SEWAGE FLOW (MGD) As indicated in Table 2, biosolids production is projected to increase, yet biosolids storage capacity will be temporarily reduced by 50% of current capacity during construction. Construction of the new five-stage Biological Nutrient Removal process will necessarily require permanent conversion of existing facultative lagoon cell #1 (western lagoon). Thus, the County will be forced to operate with only one of the two 8 MG facultative sludge storage/stabilization lagoons during the interim four-year construction period. The interim period during construction of the proposed wastewater system improvements will be one of near continuous change. As such, the facilities available for biosolids storage and stabilization are summarized in Table 2 by Phase and year. TABLE 1 PROJECTED BIOSOLIDS PRODUCTION BETWEEN MAY 2002 AND DECEMBER 2006 TRIANGLE WASTEWATER TREATMENT FACILITY 2002 2003 2004 2005 2006 2002 2003 2004 2005 2006 PROJECTED BIOSOLIDS PRODUCTION (TONS/YEAR DRY WEIGHT) _____________________810 _____________________924 ____________________1020 ____________________1112 _________________ 1206 BIOSOLIDS STORAGE CAPACITY (TONS - DRY WT) D ______________4,010 ______________2,046 ______________2,046 ______________2,046 ______________2,046 l/ll l/ll II ll/lll III 5.0 5.7 6.3 6.87 7.45 Facultative Sludge Storage Lagoon Cells #1 and #2 Facultative Sludge Storage Lagoon Cell #2_______ Facultative Sludge Storage Lagoon Cell #2_______ Facultative Sludge Storage Lagoon Cell #2_______ Facultative Sludge Storage Lagoon Cell #2______________________________ 1) Refer to Attachment # 1 for computations of Safe Sludge Storage Volume of each facultative sludge storage lagoon cell. 2,145 DT/7.66 DT/ac = 280 acres 8 ^MCKD\4&CREED Durham County currently has a total of 452.8 acres of permitted agricultural land available for disposal of biosolids. Therefore, the County does not anticipate the need to locate supplemental disposal sites. However, the County is prepared to use supplemental disposal sites as necessary. Per the latest NCDENR Non-Discharge Permit (#WQ 0007989), the 5-year adjusted land application rate for Durham residuals (on agricultural land via surface application) is 7.66 Dry Tons/acre. Durham will therefore need 280 acres of land for disposal of the entire 2,145 Dry Tons as calculated below: Years 2003 - 2004 Biosolids produced in years 2003 - 2004 in the existing extended aeration process and in years 2005-2006 in the new five-stage BNR process will be discharged to Lagoon Cell #2 INTERIM BIOSOLIDS MANAGEMENT PLAN Year 2002 In 2002, Durham County is arranging to retain a contract-dewatering firm to completely remove, dewater and dispose of all existing biosolids in both facultative sludge storage lagoons. The County has programmed sufficient funds to allow them to dispose of up to 3,500 dry tons of Class B residuals from the two lagoons in 2002. The stored biosolids have already been tested to confirm that the material meets Class B requirements for pathogen reduction (i.e. fecal coliform concentration <2,000,000 MPN per one gram sample) and vector attraction (i.e. volatile solids reduction of >38%). It is estimated that there are a total of 1872 dry tons of sludge in inventory (390 dry tons in Lagoon Cell # 1 and an additional 1482 dry tons in Lagoon Cell #2). Between now and the date that contract dewatering is scheduled for completion, an additional 270 dry tons of waste biosolids will be generated and discharged to Lagoon Cell #2. Current estimates indicate that there will be an estimated total of 2,145 dry tons to be removed in 2002. This is well within the County's established budget. YEAR 9 ^MCKIM&CREED In 2006, the County will have the option of either contract dewatering Lagoon Cell #2, as planned for prioryears, or pumping the residuals into the new Class A biosolids stabilization process. In either case, the County will have adequate resources to accommodate storage and disposal of residuals for the entire interim period. Per Table 2, Durham County will maintain biosolids stabilization/storage capacity for up to 2,046 DT of biosolids at an average solids concentration of 7%. This is equivalent to 2.5 years storage capacity (based on 2002 production volumes) or 1.7 years storage capacity (at anticipated 2006 biosolids production volumes). Therefore, even though the County plans to remove biosolids annually at the same rate of production, they have the ability to store biosolids on-site for up to 20- 24 months if necessary. The projected biosolids production and the associated annual removal requirements during these years are summarized in Table 3. TABLE 3 PROJECTED BIOSOLIDS PRODUCTION & ANNUAL DISPOSAL REQUIREMENTS BETWEEN MAY 2002 AND DECEMBER 2006 TRIANGLE WASTEWATER TREATMENT FACILITY 2002 2003 2004 2005 2006 PROJECTED BIOSOLIDS PRODUCTION (TONS/YEAR DRY WEIGHT) ___ ___________810 _______________924 _____ _________1020 ______________1112 ____________ 1206 (eastern lagoon). The Contract Operators will continue to gravity thicken and decant liquid on a semi-continuous basis to thicken residuals to an average solids concentration of 7.0%. The County is committed to continue their annual sludge removal and land application program during this interim period to prevent accumulation of biosolids in the lagoon. ANTICIPATED BIOSOLIDS DISPOSAL VIA LAND APPLICATION (D (TONS/YEAR DRY WEIGHT) __________________________810 __________________________924 __________________________1020 __________________________1112 _____________________ 1206 r 4 June 3, 2002 M&C 1471-0003(10) RE: Dear Mr. Myers, S:\1471 \0002\10-Comm\06-03-02MyerslnterimBiosolidsCoverletter.doc We have prepared the attached Interim Biosolids Management Plan for your review in connection with the previously submitted request for “Authorization to Construct" for the proposed new 5-stage BNR process at the Triangle Wastewater Treatment Facility. We trust that this document adequately addresses provisions for interim biosolids management at the facility and will allow you to issue the Authorization to Construct for the Phase II improvements. On behalf of Durham County, we appreciate your assistance in expediting the ATC review so that construction can proceed in accordance with the Construction Schedule approved in the NPDES permit. Authorization To Construct: Submittal of Interim Biosolids Management Plan Triangle Wastewater Treatment Facility Expansion Durham County, NC Mr. Mike Myers NPDES Unit NCDENR Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 As we have discussed previously, Durham County will need to take one of the two existing 8 MG facultative sludge storage lagoons off-line in early 2003 to accommodate construction of the new facilities. Since the permanent, new biosolids management processes will not be completed until 2006, we have prepared this interim plan to provide detailed guidance as to how the Triangle WWTF will manage biosolids residuals produced during the phased construction period. 5625 Dillard dr., Suite 117, Cary, North Carolina 2751 1 Tel 919.233.8091 Fax 919.233.8031 www.mckimcreed.com AA0002667 "fi I e Please feel free to call me if you have any questions or need additional information. Sincerely, Attachment cc: S:\1471\0002\10-Comm\06-03-02MyerslnterimBiosolidsCoverletter, doc ^MCKIM&CREED Chuck Hill, P.E., Durham County Glen Whisler, P.E., Durham County Bryan Blake, P.E., McKim & Creed Tim Baldwin, P.E., McKim & Creed Mr. Mike Myers 6/3/02 Page 2 McKIM & CREED, P.A. Kevin C. Eberle, P.E. Senior Process Engineer CC falfijhftej June 20, 2002 M&C 01471-0001 (40/60) RE: Dear Mr. Belnick: If you have any questions, please give me a call. Sincerely, 6 /der Chuck Hill, PEcc: £00Z NAP £ L] ri 8 J Brydn^Blake, PE Senior Project Manager Triangle Wastewater Treatment Plant Phase I Expansion ATC No. 026051 ACF Mr. Tom Belnick NCDENR Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 & The Phase I Expansion project is nearing completion. The County has placed into service the various components as listed in the ATC for start-ups, adjustments, and training. As the County's Engineer of Record, we are not yet ready to certify completion until the County is in a position to accept all equipment. However, we wanted to notify you that plant flow has been diverted into these new facilities. We will provide the required certification as soon as practical. ^VFKIM&CR^ED 5i ..J Ma /<, Wma /i 200 MACKENAN COURT, SUITE 200, CARY, NORTH CAROLINA 2751 1 S:\1471\0001\40-Permit\06203Belnick.^ 919 233 8()91 FAX 919 233.8031 www.mckimcreed.com AA0002667 7,Signanire: _DZO , Date: Facilj^: Permit Number: County: ! SCB.Vni A SEPARATE FORM FOR EACH TYPE OF SYSTEM ’ Mark (XlTvpe ofFacjlity CtoU-4j CiMs Operator in Responsible Chx'-^e. ■nificaje H; v Mail or Fax to: Revised 10/2000 Wasr-waier Plant Physical/Chcrnica! Collection System Water Pollution Control System Designation Form WPCSOCC NCAC15A:08G .0201 Spray Irrigation Land Application Subsurface Afl >rv Operator in Responsible Charge: Print Name:, I (| Security # : 3~ 7 7 Certificate Type and Grade:tr:. % 3 7 Work Te lephoat;J Q (A f WCSOCC 1618 MaU Service Center Raleigh, N.C, 276994618 Fax: 9]9/733-133S Facility Information: T~y ,Vi U/’ /6/ 7" Z3 General Information; Permittee Owner/Offfc$r Name; C,, Z jX, C ./C- /////y Mailing Address: /i. o s Z f // ; r A ■£ / -e /" 0 Back-Up Operator in Responsible Charge: Name: ^.J^Sccial Security # : 2 3^- - 7 Certificate Type and Grade: Certificate J 3 S' 2 Work Telephone: (7/7^ Signature-C / FSX NO. : 9198350146 1. 15 2002 11:25AM 83 City;------------12 State: Zip. _A 7^z Telephone Number, f _£// ) - 7 Z7 did fi£ July 15, 2002 Re: Sincerely, Attachments; ORC Change Form Cc:C^Hiil -iC Stafford S. Bullard Change in Back-up Land Application ORC Dear Ms. Wallers; Thank you for your attention to tins regarding this change please call mo Ms. Hope Walters DENR, Division of Water Quality 1618 Mail Service Center Raleigh, NC 27699-1618 C0Te°wT • okf,ces- Wd‘nG' Mas^sett.., ew Hampshire, Connecticut. Illinois. Fionda Ooeraf/ona! offices throughout the U S Durham County DE.R'R- Raleigh Regional Office Woodard & Curran WOODARD&CURRAN •-f.eermy • Science • Operations Triangle Wastewater Treatment Facility . 91.Q.FZ4.Q9OO . n< a - . FAX NO. : 9106350146 T,T^e wa“ Ketteman, certificate 4 23897 PleaseP ^pphcation ORC is Ronald back-up Laud Application ORcSXw ’ # " The Collection and Wastewater ORC and back-up listings will renram as currently listed request. Tf you have any questions or comments at the Triangle facility at (919) 544-8280. 5926 Highway 55 East i Durham Mnrth QEP Plant Manager Jul. 15 2002 11:24AM P2 July 25, 2002 Subject: p Dear Mr. Hill: Should you have any questions, please contact Vanessa Manuel at 919/733-5083, extension 532. cc: State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P. E., Director This letter serves final notice that the Division will proceed to refer your cases to the North Carolina Attorney General’s Office for collection through the courts unless payment in the amounts of $2,045.27 and $2,295.27 is received by August 23, 2002. 1617 Mail Service Center, Raleigh, N. C. 27699-1617 An Equal Opportunity Affirmative Action Employer Raleigh Region WQ Supervisor Enforcement Files LV 01-473 andLV 01-558 ’G5 . le Chuck Hill Triangle WWTP 120 East Parrish St Durham, NC 27701 The Division of Water Quality assessed civil penalties in the amount of $2,045.27 and $2,295.27 against Triangle WWTP in violations of G.S. 143-215.1(a)(6) and the subject permit, by discharging waste into the waters of the State in violation of permit conditions. The assessments were sent via certified mail to Triangle WWTP and were accompanied by a list of available options that included: payment of the penalty, request for remission of the penalty, or request for an administrative hearing. If thirty (30) days pass after the receipt of a civil penalty assessment and there has been no action to exercise one of the three options cited above, then North Carolina General Statute 143-215.6A(g) allows the Secretary of the Department of Environment and Natural Resources to request the Attorney General to institute a civil action in Superior Court to recover the amount of the assessment. Records from our Division reveal that the assessment documents were delivered on December 7, 2001 and January 18, 2002 respectively. To date, no response on behalf of the subject facility for the above enforcement cases have been received. Telephone 919-733-5083 Fax 919-733-9612 50% recycled/10% post-consumer paper Final Notice of Civil Penalty Assessment Triangle WWTP NPDES Permit Number NC0026051 File Numbers LV 01473 and LV 01-558 Durham County Sincerely, / E. Shannon Langley, Supervisor PSC/EU NCDENR North Carolina Department of Environment and Natural Resources CERTIFIED MAIL RETURN RECEIPT REQUESTED 7000 1530 0002 2100 3189 F^OM :Pl WOODARD &CURRAN Engineering . Science • Operations To: nTv/ - V 7/$ Date: Yes No / r/ entity named above and may contain information that is aie not the intended recipient or the ? us immediately by this stationery. Any dissemmahon recipient is stnctly prohibited. Thank’ Note: ------- --------------- --------------— Ihis message is. intended only for the use of the individual or ’XXoIxt m rcab,e w k youtelephone and return the original to vs bv E mtended recipient, please notify ul. 15 2002 11:24AMrAX NO. : 9196350146 Comments Za/- c Durham County Wastewater Treatment Facility 5926 NC Ilwy 55 East • Durham, NC 27713 (919.: 544-8280 • rax. (919) 544-8590 CORPORATE Ol'FICES Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughoul the 1/ S FAX Transmittal Sheet -fa!ftp FAX#. SentJer: . /: No. of Pages (including coversheet) Hard Copy to Follow in Mail: / e> s' .♦q August 9, 2002 Re: Dear Ms. Garrett: This letter is to notify your office that the # 1 Automatic Barscreen in the south channel at the Influent Pump Station for Durham County’s Triangle WWTP Permit # NC0026051has been removed from service. The motor has failed and the gearbox is worn out. The # 2 barscreen in the north channel is operable and currently in service. This pump station is scheduled to be removed from service within nine months upon completion of the new influent station currently under construction. We are planning to install a manually cleaned barscreen to allow the temporary use of the south channel in the event the # 2 barscreen in the north channel experiences operational problems. There is also a by-pass channel that allows sewage into the pump well in the event the barscreens are plugged. This high level bypass prevents overflows. Please note this matter in your files. We will inform you when the manual barscreen is installed. If you have any questions, contact me at (919) 544-8280. cc: Chuck Hill, P.E., Durham County Steve Bullard, W&C Mike Cherniak, W&C Triangle Wastewater Treatment Facility i 5926 Highway 55 East i Durham, North Carolina 27713 919-544-8280 i 919-544-8590 (Fax) i www.woodardcurran.com Ms. Judy Garrett, Environmental Chemist II NCDENR Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 WOODARD &CURRAN Engineering • Science • Operations Permit # NC0026051- Durham County Triangle WWTP Barscreen # 1 removed from service Sincerely, jerry F. Rimmer, QEP Plant Manager C^PORATE OFFICES: Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughout the U.S. a1 FROM :08 2002 08:11PM Pl 37/- y?/?Fax:Pages: ^70 aPhone:Date: □ Urgent X For Review □ Please Comment □ Please Reply □ Please Recycle Note: 9- WOODARD & CURRAN ■ i Durham County Wastewater Treatment Facility 5926 NO HWY 55 East Durham. North Carolina 919 544 8280 Fax 919 544 8590 Rg' (- - Cj/Zp c/z To; THs ...essage is '"tended only for the use of the individual or entity named above and may contain information that is privileged, confidential and exempt from disclosure under the applicable law. If you are not the intended recipient fesP°nsib!e for ddivenng the message to the intended recipient please notify us cnt!y and retUm the On9inal t0 US by postai' at fhe address "otedP on this stationery Any pSSi Thank^u °r C0Py,n9 fay other than the intended recipient is ^ly X/fx A A From: '(f <> A /n A?) /< FAX NO. : 8188350146 General Liformation: 4 Ciry &/l/oDa:e;Signature: County: I SUB^ni A SEPARATE FORM FOR EACH TYPE OF SYSTEM ! Mark (K) Tvoe of.Facilirv Chlid -4)Cl&s Cenificare #: S:g^.aFJ^e.■' 55^-7^-/9 77 Mail or Fax to: Revised 10/2000 Permittee Owner/Ofncer Name: Vr’astewa^r Plant PhysicaVChemica! ___ Collection System Water Pollution Control System Designation I orm WPCSOCC NCAC 15A:08G .0201 Spray Irrigation Land Applicotion Subsurface VVPCSOCC 1618 Mall Service Center Raleigh, h’.C. 27659’1618 Fax: 919,TO.133S Mailing Address: _/ \O la-L. /if Permit Number: Qoc^ P3 UZ Facility Information; Facility; _ Certificate tr. 2^51 / Signature^ J '7 -"/T'-"— Operator in Responsible Chi-ge: Print Name: Social Security # : 7 7 Certificate Type and Grade: C^Lf^ric^ Work Telephone: ) 7^7^ Bicic-Lp Operator in Responsible Charge: Print Name: /sQp_C _Aeo^e»^ /ieFhj.M Scc-al Security # : Certificate Type and Grade: C(>/(<c7'iOfVS I' Work TeLephcne: {,77^..) ~ 8.^8Q State: Zip: ,'2- 7 7 (j ! - Telephone Number. ( jfh ) eLd^ FAX NO. : 9198350146 ig. 08 2002 08:12AM August 22, 2002 NPDES Permit # NC0026051 - NCDENR Files LV 01-473 and LV 01-558Re: Dear Mr. Langley: Please contact me if you need additional information or have any questions. Enclosures cc: CH/jld This letter is written to respond to your July 25, 2002 letter regarding a Final Notice of Civil Penalty Assessment for the above referenced cases. Glen E. Whisler, P.E., County Engineer Chuck Kitchen, County Attorney Curtis Massey, Deputy County Attorney Kenneth Schuster, P.E., Water Quality Regional Supervisor 120 E. Parrish Street, Law Bldg., 1st Floor, Durham, N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirrnative Action Employer E. Shannon Langley, Supervisor Point Source Compliance/Enforcement Unit NCDENR/Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Sincerely, Chuck Hill, P.E. Utility Division Manager Your letter indicates that no response has bee received from Durham County regarding these two cases. However, your office received a response and a check for the enforcement costs of each of these cases, and we sent a follow up letter regarding LV 01- 473 dated January 11, 2002. The Durham County Attorney’s Office also discussed these cases with the Attorney General’s Office. A copy of a letter from our Assistant County Attorney to the Special Deputy Attorney General dated July 30, 2002 is attached for your use, which includes copies of the correspondence related to these two cases. paMi a?4, COUNTY OF DURHAM ENGINEERING DEPARTMENT n © if o w li JUL 3 0 2002 DURHAM COUNH ENGINEERING July 30, 2002 35 Dear Dale: THOMAS W. JORDAN. JR. LOWELL L. SILER DEPUTY A TTORNEYS S.C. KITCHEN COUNTY A TTORNEY Please find enclosed a copy of a letter sent to County Engineering on July 25, 2002, regarding the subject penalties. It assets that Durham County has not responded to previous correspondence and threatens legal action if payment is not received by August 23, 2002. A SSISTA NT CO UNTY A TTORNE YS CATHY L. MOORE CURTIS MASSEY LUCY CHAVIS CAROL S. WOLFF Re: NPDES Permit Number NC0026051 NCDENR Files LV 01-473 and LV 01-558 P.O. Box 3508 Courthouse, 200 E. Main Street Durham, NC 27702 (919) 560-0715 (919) 560-0719 (FAX) 1 8 W. Dale Talbert Special Deputy Attorney General North Carolina Department of Justice P.O. Box 629 Raleigh, NC 27602-0629 As you no doubt recall, in those matters Durham County had remitted to DENR the administrative portion of the penalty assessed and then paid the rest directly to the school board. Durham County believed, and still believes that this was correct in accordance with the provisions of our State’s Constitution, Article IX, Section 7, and the decision of the Court in North Carolina School Boards Association, et al. v. Richard H. Moore, et. al., 98 CVS 14158. Durham County informed DENR of that action by correspondence hand delivered to DENR on January 7, 2002, and February 18, 2002, (copies enclosed) which both included checks for the remitted administrative costs and showed the budget action paying the balance to the school board. Subsequently you contacted our office on behalf of DENR, conveying their disagreement with the County’s legal position. After reviewing the matter, including the cun-ent posture of the NC School Boards case, a case in which our school board is a plaintiff, I, on behalf of Durham County, agreed to your proposal that, pending the issuance of a final appellate decision, Durham County would pay any ftiture assessed penalties which it did not contest to DENR, not the school board. It was also my understanding that part of your proposal was that no action would be initiated by the State to collect that portion of the penalties already been paid to the school board. ■••■Sv COUNTY OF DURHAM OFFICE OF THE COUNTY ATTORNEY 2 Sincerely, Encl: Re: NPDES Permit Number NC0026051 NCDENR Files LV 01-473 and LV 01-558 Copy to: (w/out encl) Glen Whisler Chuck Hill Please advise me if I failed to understand the terms of our agreement, or if there is, as I believe, some administrative error on behalf of DENR, in pursuing this matter. Certainly their CupHs Assistant County Attorney assertion in the correspondence of July 25, 2002, that Durham County never responded to the subject enforcement cases is inaccurate. I can be reached at the letterhead address, or by telephone at 919-560-0722. August 29, 2002 I (- Re: Completion of repair to Aerator unit at Triangle Wastewater Treatment Plant Mr. Stafford: If you have any questions, please feel free to contact me at (919) 544-8280. C/ This is to inform your office that the # 5 aerator unit in the south basin at the Triangle Wastewater Treatment Plant has been repaired. The unit was placed back into operation on August 24, 2002. We have been monitoring the unit closely to ensure proper operations. Triangle Wastewater Treatment Facility i 5926 Highway 55 East i Durham, North Carolina 27713 919-544-8280 i 919-544-8590 (Fax) i www.woodardcurran.com C. Hill. Durham County Jerry Rimmer, Woodard & Curran Victor Cozart, Woodard & Curran io i Q_ LU GO cxj CD Mr. Kirk Stafford, Environmental Chemist NCDENR Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 WOODARD &CURRAN Engineering • Science • Operations ^-^Smcerely, y Ronald G. Ketteman /Operations Manager CORPORATE OFFICES: Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughout the U.S. SqDtarfcer 16, 2002 Dear Mr. Hill: CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Chuck Hill County of Durham 120 East Parrish St., Law Building, Suite 100 Durham, NC 27701 Based upon the above facts, I conclude as a matter of law that Durham Triangle WWTP violated the terms, conditions or requirements of NPDES Permit NC0026051 and N.C.G.S. 143- 215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty may be assessed in accordance with the maximums established by N.C.G.S. 143-215.6A(a)(2). The cover letter attached to the January 2002 DMR states that Cyanide violations are due to Nitrite/Nitrate interference. Mr. Link Thrower, Lab Supervisor for Chemical & Environmental Technology, Durham’s contract laboratory which conducted the Cyanide tests stated that his company did not send a statement attributing Nitrite/Nitrate interference as the cause of the violations. Mr. Thrower further stated that as a Standard Operating Procedure, the lab utilizes Sulfamic Acid to eliminate the interference as per Standard Methods 18th Edition. 1628 Mail Service Center, Raleigh, NC 27699-1628 An Equal Opportunity Affirmative Action Employer This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $1,295.27 ($ 1,250.00 civil penalty + $45.27 enforcement costs) against the Durham Triangle WWTP. This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report (DMR) submitted by the Durham Triangle WWTP for the month of January 2002 for the Durham Triangle WWTP. This review has shown the subject facility to be in violation of the discharge limitations and/or monitoring requirements found in NPDES Permit NC0026051. The violations which occurred in January 2002 are summarized in Attachment A to this letter. SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations ofN.C. General Statute 143-215.1(a)(6) and NPDES Permit NC0026051 Durham Triangle WWTP Case No. LV 02-347 Durham County Telephone (919)571-4700 FAX (919)571-4718 50% recycled/10% post-consumer paper NCDENR North Carolina Department of Environment and Natural Resources ana natural KesourcesRaleigh Regnal Office Michael F. Easley, Governor William G. Ross, Secretary 5^4 45.27 Enforcement costs. $.TOTAL AMOUNT DUE TOTAL CIVIL PENALTY authorized by G.S. 143- 215.6A. tafcngs of fact and conclusions of law, aq^|^ accordance with authority .^^Rf the Department of Environment an< iSRtural Resources and theBased upon the above provided by the Secret; Director of the Division of Water Quality, I, Kenneth Schuster P.E., Division of Water Quality Regional Supervisor for the Raleigh Region, hereby make the following civil penalty assessment against Durham Triangle WWTP: For of the 2 violations of G.S. 143- 215.1(a)(6) and NPDES Permit No. NC0026051, by discharging waste into the waters of the State in violation of permit weekly average effluent limit for Cyanide. For of the 2 violations of G.S. 143- 215.1(a)(6) and NPDES Permit No. NC0026051, by discharging waste into the waters of the State in violation of permit daily maximum effluent limit for Cyanide. For / of the 1 violation of G.S. 143- 215.1(a)(6) and NPDES Permit No. NC0026051, by discharging waste into the waters of the State in violation of permit daily maximum effluent limit for Bromodichloromethane. (1) (8) Within thirty days of receipt of this notice, you must do one of the following: 1. OR 2. (a) (b) (2) (3) (4) (5) (6) (7) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; The duration and gravity of the violation; The effect on ground or surface water quantity or quality or on air quality; The cost of rectifying the damage; The amount of money saved by noncompliance; Whether the violation was committed willfully or intentionally; The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and The cost to the State of the enforcement procedures. Submit payment of the penalty: Payment should be made directly to the order of the Department of Environment and Natural Resources {do not include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 © (d) one or more of the civil penalty assessment factors in G.S. 143B- 282.1(b) were wrongfully applied to the detriment of the petitioner; the violator promptly abated continuing environmental damage resulting from the violation; the violation was inadvertent or a result of an accident; the violator had been assessed civil penalties for any previous violations; Submit a written request for remission or mitigation including a detailed justification for such request: A request for remission or mitigation is limited to consideration of the reasonableness of the amount of the penalty and is not the proper procedure for contesting the accuracy of any of the statements contained in the assessment letter. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation that there are no factual or legal issues in dispute. You must execute and return to this office the attached waiver and stipulation form and a detailed statement which you believe establishes whether: Pursuant to G.S. 1^2-215.6A(c), in determining the amount of the penalty I have taken into account the Findingd^Bfact and Conclusions of Law and the^Bors set forth at G.S. 143B- 282.1(b), which are: Please submit this information to the attention of: OR 3.Submit a written request for an administrative hearing: File your original petition with the and Mail or hand-deliver a copy of the petition to Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not a postmark) indicating when we received your response, will result in this matter Ms. Coleen Sullins Water Quality Section Chief Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Office of Administrative Hearings 6714 Mail Service Center Raleigh, North Carolina 27699-6714 Mr. Dan Oakley, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, North Carolina 27699-1601 Please note that all information presented in support of a request for remission must be submitted in writing. The Director of the Division of Water Quality will review the information during a bimonthly enforcement conference and inform you of his decision in the matter of the remission request. His response will provide details regarding case status, directions for payment and provision for further appeal of the penalty to the Environmental Management Commission’s Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider information that was not part of the original remission request considered by the Director and therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. If you wish to contest any statement in this assessment letter, you must request an administrative hearing. This request must be in the form of a written petition to the Office of Administrative Hearings and must conform to Chapter 150B of the North Carolina General Statutes. You must payment of the civil penalty vJjhprevent payment for the remaining necessary remedial actions. ATTACHMENTS being referred to the Atto^ collect the penalty. I cc: Regional Supervisor w/ attachments Compliance/Enforcement File w/ attachments Central Files w/ attachments Kenneth S^liust^RE. Water Quality Regional Supervisor Raleigh Region Division of Water Quality Please be advised that any continuing violation(s) may be the subject of a new enforcement action, including an additional penalty. If you have any questions about this civil penalty assessment, please contact the Water Quality Section staff of the Regional Office at 919-571-4700. D^^y General’s Office with a request to ii^^te a civil action to AND NATURAL RESOURCES COUNTY OF DURH PERMIT NO. NC0026051 FILE NO. LV 02-347 This the day of ., 20. BY ADDRESS PHONE ) ) WAIVER OF RIGHT TO AN ADMINISTRATIVE HEARING AND STIPULATION OF FACTS Having been assessed civil penalties totaling for violation(s) as set forth in the assessment document of the Water Quality Regional Supervisor dated , the undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after 30 days from the receipt of the notice of assessment. IN THE MATTER OF ASSESSMENT OF CIVIL PENALTIES AGAINST DURHAM COUNTY TRIANGLE WWTP ) ) ) ) I January 2002 Weekly Average Limit Violation Daily Maximum Limit Violations 1/30/02 1.5*0.85 ug/1 Attachment A Durham Triangle WWTP Units ug/1 ug/1 Units ug/1 ug/1 Reported Value 6.3* 7.0* Reported Value 26.0* 18.0* Parameter Cyanide Cyanide Date 1/9/02 1/16/02 Week of 1/7/02 1/14/02 Limit 5.0 5.0 Limit 15.0 15.0 Parameter Cyanide Cyanide Bromo dichloromethane * = Limit violations that were assessed a civil penalty. CERTIFIED MAIL- RETURN RECEIPT REQUESTED October 7, 2002 Dear Mr. Schuster: 5. This letter is to propose a procedure for closing the west sludge lagoon at the Durham County - Triangle Wastewater Treatment Facility. We are unaware of any regulatory requirements for non-hazardous sludge lagoon closures and are providing this proposal per your request to Durham County. This lagoon is scheduled for closure by the end of 2002 to allow construction of Phase 2 for the new treatment system in the current location of the west sludge lagoon. Removal of 3500 dry tons of sludge from the facility began in September. This portion of the project is scheduled for completion within ninety days of the start date of sludge removal. The dried sludge removed will be disposed at landfills in Rougemont, NC and Lawrenceville, VA. The final closure of this lagoon must be completed as soon as possible to allow construction of the Phase 2 treatment modifications to begin by January 2003. Woodard & Curran Inc. as facility operations contractor will assist Durham County Utilities in oversight of the sludge removal and closure. No hazardous wastes have been disposed into this sludge lagoon. It only received sludge from the wastewater treatment facility. The contents have been analyzed for TCLP and no contamination of concern was detected. The previous groundwater monitoring wells analyses collected during the 1990’s have also been reviewed and no contamination was detected. The groundwater monitoring was discontinued in 2000 because no contamination from the lagoon had been indicated. Triangle Wastewater Treatment Facility i 5926 Highway 55 East i Durham, North Carolina 27713 919-544-8280 I 919-544-8590 (Fax) i www.woodardcurran.com 1. 2. 3. 4. Mr. Ken Schuster NC DENR- Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 . WOODARD &CURRAN Engineering • Science • Operations ^^^PORATE OFFICES: Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughout the U.S. The proposed closure plan includes: Remove all sludge from the west lagoon. Pump remaining water into the east lagoon or to the plant head waters as allowable by influent parameters. Apply limestone to the surface. Sample the surface at six inch depth for TCLP and total nitrogen parameters. The sample to be analyzed shall be a composite of samples collected in a grid pattern of eight distinct locations across the surface of the lagoon bottom. After the analyses confirm that there is no threat of environmental contamination from the west lagoon, the closure will be complete. Re: West Sludge Lagoon Closure @ Durham County- Triangle Wastewater Treatment Facility Sincerely, Je Plant Manager cc: Chuck Hill Glen Whisler Steve Bullard Mike Cherniak Please contact me if you have any further questions or additional suggestions regarding this closure. If more detail is needed, Woodard and Curran with the help of Durham County Utilities Department will prepare the information you need to finalize approval of this plan. Your timely review of this proposed closure plan is appreciated. I look forward to discussing this closure with you and your staff. Durham County is interested in completing this closure as rapidly as possible to insure a timely initiation of construction of their Phase 2 construction. October 18, 2002 Notice of Violation and Assessment of Civil Penalty/Case No. LV02-347Re: Dear Sir: Sincerely, cc: CH/jld Payment of Case No. LV02-347 is enclosed. While our investigation of this matter did not identify the specific source of this problem, we have noted that there have been no exceedences since we replaced the sand filter media in March (this year). Durham County is committed to NPDES permit compliance and a healthy environment. Please contact me if you have any questions or need additional information. Glen E. Whisler, P.E., County Engineer Jerry Rimmer, Plant Manager - Woodard & Curran Kenneth Schuster, P.E., Water Quality Regional Supervisor Central Files Chuck Hill, P.E. Utility Division Manager 120 E. Parrish Street, Law Bldg., 1st Floor, Durham, N.C. 27701 (919) 560-0735 Fax (919) 560-0740 Equal Employment/Affirmative Action Employer Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 COUNTY OF DURHAM ENGINEERING DEPARTMENT < : . ;■ > : Z I 130561Inc. BALANCEDEDUCTIONDESCRIPTIONDATE 1295.27.001295.27DURHAM FINE10-11-02 101102CR k WOODARD aCURRAN 1295.27.001295.27130561 130561 . ay: 2002October 11, Checks over S2500 require two signatures & ?B U ?"■i:o i noouit si:n- L 30 Lii" CHECK DATE 41 Hutchins Drive - Portia id, Maine 04102 207-774-2112 • 1-80 3-426-4262 FLEET BANK PORTLAND, MAINE and 27 cents AMOUNT 51-44 119 PAY TO THE ORDER OF WOODARD &CURRAN Engineering • Science • Operations POINT SOURCE COMPLIANCE INVOICE AMOUNT V-coda rd & Curran, INVOICE NO. ***************One thousand two hundrg.^ ninety fiars 130561 $******1,295.27 rPOINT SOURCE COMPLIANCE ENFORCEMENT UNIT DIV OF WATER QUA 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 CHECK \ NUMBER / \10-ll-02 7'1686 ____ I TOTALS \ PLEASE DETACH THIS PORTION AND RETAIN FOR YOUR RECORDS. MEMORANDUM Jay Zimmerman, RRO Groundwater SupervisorTo: Kirk Stafford, RRO Water Quality Randy Jones, RRO Water QualityFrom: Subject: If you wish to discuss this matter, please contact me at 571-4700, ext. 255. Attachment Attached is a letter from Jerry Rimmer regarding a lagoon closure request at the Durham County Triangle WWTF. Please recall that the draft Groundwater policy includes guidance on the sampling that should be performed and the limitations that must be met. If Groundwater finds that it is ok to leave any sludge in place, Water Quality will agree if the lagoon is going to be back filled and graded to shed water. If the lagoon is to remain open. Water Quality requires that the sludge be removed regardless of the analytical results. Kirk, please coordinate the appropriate response(s) and pass back through me. DIVISION OF WATER QUALITY RALEIGH REGIONAL OFFICE October 10, 2002 Lagoon Closure Request--------- Durham County Triangle WWTF Durham County POTASSIUM HYDROXIDE SODIUM ALUMINATE POLYMER S (1.5 Q MAXIMUM)-l^1’R IAS/WA? F5 CLARIFIER CLARIFIERin5 mg/STATIC F4 30 mg/30 mg/l iwmpy Jzr“L__™*UCOB-rc WAS F3 8,371 ib«/month 11.0 mg/10 mg/l (2)F2CLARIFIERCLARIFIER Fl >T1NC 4 ON TH (2) EXISTING SLUDGE LAGOON •AR PLANT SCHEMATIC NOT TO SCALE 310 300 290 280 HWL 27* 26 EL. 274,00 WEIR •267.2S EL 270 HVL 260.69 S ■HAL 260. 9 r-HW. 254.02L. 257.25 ;l 260.091TiBn-e.- : 60.25 ---------------126025325HWL 256 'EL. 253.!FL.EL.254.75 M50? EL 251.0 4-1-250239.00 .50 I I 1£SO" DIP I E. 239.1 240 «.92^uv HWL. El 232.25 CLABFIEA DeTHBOnON a. :l-229.5-INR_UENT_H_OW CLAfire®ALTERSMS.EL. 229.5 230 EL. 219.5 220 <0 K 54" DIP-/ I.E. 242.00 •WEIR HWL : si ANOXIC 30" DIP LE.-342J*- 271J0L RAS CKSTHBUnCW BOX £ 5STA0E BNR PROCESS TRANS 1 INCH - 10 icuncAi erm A'^TYSE*® lustt EXBT»*J 2.75 8.371 Ibi 30" DIP I.E_2«. 42" DIP 2 SB 83 ANAEROBIC SELECTOR 12.0 MOD 36.0 MC.0 ELEVATIONS RAS 'METER TERTIARY SAND FILT- 100 YR ' EL. EXERNQ Qwrc«A*eeit pwbhallfluJe EL 248.00 E L. EL 240.50 EL. 2- 7.0~ 2^7 EXISTING UV DISINFECTION SYSTEM EXBT1NO DBNFECTCN SYSTEM EXBTWaPOST AfiRA-nON NORTHEAST CREEK FLOOD !51 75 WEIR EL.-3 264.00 T ID £ 2ad IC AERATION 1 w <4 t -HW. 270,35 ! GRIT TO LANDFILL ♦ SCREENINGS TO LANDFILL WAS | 242.2C)SA r; %.5<Z/ o METHANOL FEED 5 STAGE 9I0L0GICAL NUTP'ENT REMOVAL INTERNAL RECYCLE (4 Q MAX) ■R HW. ^^263 79 =BHI ’31 AEROBIC ______________| ANOXIC -Y LOADING OF 8.371 LB' ......................— OF Z75 MCA ' DURING SUMMER A 1 8 MCA It ITRAT10N LIMITS). ------ I ANNUAL BLOWERS _?65&i ilSt '■' 364 18 uBS/M! . AT 12 MGO. IN WINTER EL. 10.204 LBS/YE. AT 12 MOD. HYDRAULIC PROFILE VERTICAL SCALE. 1" - 10' HORIZONTAL SCALE: NONE P0S1 AERATION 160“ DIP [I.E. 241 CO 0 I ~ SUPERNATE ___ EXISTING I SCREENINGS I WASHER | r H i WL 277.10 'l FLlvt 2 ZA.SO (1) PERMIT UMIT IS BASED ON MAXIMUM MONTHLI WHICH CORRESPONDS TO A CONCENTRATON C AMMONIA LIMIT IS 1.0 MG/L--------------“ (AVERAGE MONTHLY CONCENT..- (3) PERMIT LIMIT IS BASED ON MAXIMUM ANNUAL .OAOINC OF WHICH CORRESPONDS TO A CONCENTRATION OF 0.28 MGA 10.204 Ibs/yr 6.0 mg/ (minimum) 253.02 /-WEIR EL. 2S2.25 -HWL 252 05 NR-UENT AND EFFLUEf/T CRITERIA LOADHQfl _ INFLLTM PARAMETERS LVERACE DAILY -EAK DAILY ri-f DIP ' I.E. 244.00 EXIS ING 54" OUTFALL I.E 1 40.00 — DESIGN tAR 12020) 12.0 MGO 5 mg/l mg/l >s/month BACKWASH TO EXISTING INFLUENT PUMP STATION X ^54’ DIP I.E. 240. I -4 ! I feF< I • EXISTING Qh^RS EXISTING 14“ DIP- Q 242.5C . ... 200 colonies/ 100 ml 9 f1 .‘.g idcrd iJr ti LL _j 240.25 DESIGN YEAR 12020) 12 0 MGO 24 0 MGO 36 0 MGO 250 mg/ 25,020 Ibs/d 180 mg/ 18.020 Ibs/d 40 mg/l 4.010 Ibs/d 25 mg/l 2.502 lbs/ 5 mg/ 500.4 Ibs/d J p ^'54" OIF I E. 244.00 EXISTING INFLUENT PUMP ’ RON AND SCREENING 0.28 mg/ (3) 10.204 lbs/>» .0 mg/l (minimum) T.O.W, EL. 253.75 IN ~1AL FEAR (7000) 4.5 MGO 9 0 MGO 20.0 MGO 250 mg/ 9.385 Ibs/d 180 mg/ 6.755 ibs/d 40 mg/ 1,500 Ibs/d 25 mg/l 938 Ibs/d 4 mg/ 150 Ibs/d EXjBTna NF4.UENT PUMP STATION ? 241 50 I® I I POTASSIUM HYDROXIDE FEED 2^1® SODIUM ALUMINATE FEED [® ®| ) POLYMER FEED I® — S~^ —I® SODIUM HYPOCHLORITE FEED mill 1' ''< t 11 /i''EgsiTNG dEchar^ ' •— -- I 21 I I 1 'Si i i "fit IHII t1 1 I. i ' ' 11 200 colon(ea/ ipg m| ml/3 (0 * RAS) EACH influent flow and / RAS DlSTR-BunON BOX-I I EXISTING GRIT I I REMOVAL AND FLOW | J___ AKDCT ATTO »TDfcS DeCKAftX LATTATONB EFFLUENT PARAMETERS FLOW. AVERAGE DAILY 3005. CONCENTRATION 3005, MASS TSS. CONCENTRATION TSS. MASS TN, CONCENTRATION TN, MASS (MONTHLY MASS LIMIT) NHJ-N. CONCENTRATION NH3-N. MASS TP. CONCENTRATION TP. MASS DO. CONCENTRATION 00. MASS FECAL CONLIFORM (30 doy geometric) pH LL 2 40TE: AVERA E DAILY FLO PEAK lOW HWL INDICATES PEAh * ; l_5^p£r^aJe__i t EXIST GRIT CLASSIFIER *"L J------------- ---------» EXISTING EFFLUENT FLOW METER IN.TIAL •’EAR (2000) FLOW. AT FLOW. ^6 FLOW. PEAK HOURLY BODS. CONCENTRATION 9005. MASS TSS. CONCENTRATION TSS, MASS TKN. CONCENTRATION TKN. MASS NH3-N, CONCENTRATION NHJ-N. MASS TP. CONCENTRATION TP. MASS c<3 iiol Subject: Dear Mr. Allison: On October 25, 2002, Mr. Kirk Stafford of the Raleigh Regional Office of the Division of Water Quality (DWQ) conducted a Compliance Evaluation Inspection (CEI) of the Bible Baptist Church WWTP accompanied by Mr. Gary MacConnell of MacConnell & Associates who was contracted by the church for design of the subject facility. Mr. MacConnell’s assistance and cooperation was helpful and appreciated. As a result of the inspection, the following items were noted. 1628 Mail Service Center, Raleigh, NC 27699-1628 An Equal Opportunity Affirmative Action Employer Michael F. Easley, Governor William G. Ross, Jr., Secretary 2) The facility was last issued NPDES Permit NC0058785 effective September 1, 1994. Due to the nature of the facility’s wastewater discharge, there was a permit change to General Permit NCG551111 which became effective June 15, 2001. This permit was reissued and became effective August 1, 2002 and will expire July 31, 2007. Please read and make yourself aware of all the permit conditions including annual effluent monitoring requirement and retain those records for five years and have those records readily available for inspection. 3) Bible Baptist Church applied for coverage under SOC 99-007 on February 15, 1999 due to permit violations dating from May 1998. The church decided to construct a wastewater forcemain to the City of Durham’s collection system but was rejected for road easement access State of North Department of DIVISION OF WATER QUALITY October 30, 2002 Telephone (919)571-4700 FAX (919)571-4718 50% recycled/10% post-consumer paper Qyolina STvironment and Natural Resources Raleigh Regional Office Mr. Greg Allison, Pastor Bible Baptist Church 2125 East Geer St. Durham, NC 27704 Compliance Evaluation Inspection Bible Baptist Church WWTP NPDES General Permit NCG551111 Durham County 1) The subject facility was constructed under an Authorization to Construct (ATC) issued by the Division on June 15, 2001. The wastewater treatment plant (WWTP) consists of a 2,000 gallon septic tank, a 3,000 gallon dosing/flow equalization tank (recirculation pump tank), above ground 14 feet X 16 feet recirculating sandfilter with eight lateral dosing lines, tablet chlorinator, chlorine contact tank, and cascade aeration with discharge to an unnamed tributary to Ellerbe Creek. NCDENR North Carolina Department of Environment and Natural Resources w 0^ If you have any questions concerning this correspondence, please contact me at 571- 4700. Sincerely, cc:Maurice Horsey- EPA 7) Proper maintenance of the subject wastewater treatment plant is crucial to the operation and longevity of the components of the system. Please note the items on the effluent limitations and monitoring requirements page referring to maintenance and the documentation requirements. 5) The system was not discharging at the time of inspection but clear effluent was noted in the chlorine contact chamber. Bible Baptist Church CEI Page Two Kenneth Schuster, P.E. Regional Supervisor by the North Carolina Dept. Of Transportation (DOT). The church then requested that Durham County obtain right-of-way easement from the DOT which would then make Durham County responsible for the sewer line should the church not act responsibly. Durham County refused to take responsibility for the sewer line as per a letter from the church dated March 8, 2000. At this point the Director of DWQ contacted the DOT and was not successful obtaining the easement for the church. In May 2001 the church decided to construct a new recirculating sandfilter system with disinfection. It is noted that permit violations ceased after issuance of Permit NCG551111 on June 15, 2001 and therefore no SOC could be entered into. The sandfilter systenTs Final Engineer’s Certification of Completion was stamped August 23, 2002. Please send a written response to this office within 10 working days of receipt of this correspondence stating specifically why the sandfilter system took over one year to install after the ATC was issued on June 15,2001. 6) Chlorine tablets were present in the chlorinator. Please ensure that sufficient chlorine is maintained in the chlorinator at all times to prevent violation of the fecal Coliform Monthly Average and Daily Maximum limits specified in the subject permit. 4) Bible Baptist Church was assessed eleven times for NPDES Permit NC0058785 violations from Augustus, 1998 through November 22, 2000 totaling $12,689.55 which included dines and costs. These assessments were to be addressed in the SOC through an up-front penalty and the church was made aware of this. Since an SOC could not be entered into, these assessments were outstanding but closed by the Division’s Point Source Compliance/Enforcement Unit on December 10, 2001. i 1807473 Permit Effective Date Permit Expiration Date Section C: Areas Permit LX and checklists as necessary)(Attach additional sheets of narrativeSection D: Summary of Findings/Comments Date 13 DateAgency/Office/Phone and Fax Numbers Signature of Management Q A Reviewer 0^! H EPA Form 3560-3 (Rev 9-94) Previous editions r(s)Name(s) end Signature(s) of Cid ^Operations & Maintenance Sludge Handling/Disposal Pretreatment Storm Water areas evaluated)__________ CSO/SSO (Sewer Overflow) Pollution Prevention Multimedia Other: Records/Reports Facility Site Review ^Effluent/Receiving Waters Self-Monitoring Program Compliance Schedules Laboratory inspector 19|CJ 21 I | | | I I Inspection Work Days 671 1 I I69 Phone and Fax Number(s) / Facility Self-Monitoring Evaluation Rating 701 I Fac Type 20 LI | | | | | | |6< ______________Reserved----- 75| | |_1 QA 72 u Evaluated During Inspection fChecfr only those Flow Measurement are obsolete. Bl 71 u Section B: Facility Data users discharging to POTW, also 10MB No. 2040-0057 Approval expires 8-31-98PzEPA A^5’^dJic^,^l)and Fax Numbers NPDES »M(?|g-|5|S|llllllLln hiamefs) ot On-Sit. R.pr.«nt.tiv.(S)/TO.W/Phon. .nd F.x Numb.rW Transaction Code 1 LI 2U Entry Time/Date /a/ag(o Exit Time/Date fO Other Facility Data Name and Location of Facility Inspected (For industrial include POTWname and NPDES permit number> unriwu ***—••• - -------------------- Waehmgton. D.C. 20480 Water CorOfrance Inspection Report Section A: National Data System Coding (i.e., PCS) yr/mo/day Inspection Type i2iA^rk>i3J^17 l0i<3 Remarks I | | » ■! Subject: Dear Mr. Hill: 1) Sample the sludge in the lagoon in three locations (3 sludge samples per lagoon). b) Ignitability SW-846 EP A Method 1010/1020 c) Reactivity EPA OSW d) Corrosivity EPA Method 9045 1628 Mail Service Center, Raleigh, NC 27699-1628 An Equal Opportunity Affirmative Action Employer CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Chuck Hill Division Manager County of Durham 120 East Parrish St. Durham, N.C. 27701 The Division received the correspondence dated October 7, 2002 from Jerry Rimmer of Woodard & Curran detailing closure procedures of the subject lagoon. The following is the cunent draft policy detailing the required Groundwater Section (Section) procedures for lagoon closure: 2) The following analytical procedures should be run on the sludge samples: a) Toxicity Characteristic Leaching Procedure (TCLP) SW-846 EPA Method 1211 for volitiles, semi-volitiles, and metals. 3) If the lagoon does not have a liner, then the underlying material should be sampled in three locations also and analyzed for the TCLP procedures in (2)(a). If the lagoon has a natural Michael F. Easley, Governor William G. (Bill) Ross, Secretary Alan W. Klimek, P.E., Director NOVEMBER 12, 2002 West lagoon closure Triangle Wastewater Treatment Plant NPDES Permit No. NC0026051 Durham County NCDENR North Carolina Department of Environment ano Natural Resources Telephone (919) 571-4700 FAX (919)571-4700 50% recycled/10% post-consumer paper State of North Carolina Department of Environment and Natural Resources Raleigh Regional Office •J As you have noted, the Groundwater Section requires an initial in-place sampling of the sludge at three locations within the lagoon. The Rimmer letter implies that the sludge has already been analyzed by TCLP methods, with “no contamination of concern” detected. The section requires a written, sealed (by P.E. or P.G.) sampling report presenting and summarizing this data, with an appropriately sealed map showing the locations and pertinent lagoon and facility features. Please submit the report before transportation of the sludge to a landfill so that the Section may evaluate the suggested non-hazardous waste characterization. The proposed substrate sampling plan differs from the Section requirements in both the number and sampling locations, three and eight respectively, and the practice of compositing the sample. The Section views compositing as not effective in locating specific contaminant 7) The final approval of the above procedure and analysis is granted by the Raleigh Regional Office groundwater Supervisor Mr. Jay Zimmerman. 4) If the sludge/clay/soil liner underlying soil material has TCLP concentrations that are above the TCLP regulatory limits, then the material is considered hazardous, and the Division of Waste Management/Hazardous Waste Section should be contacted, and the material does need to be excavated. Durham Triangle Page Two b) Perform predictive calculations that demonstrate that the verticle leaching of the contaminant in question in the material will not cause an accedence of Groundwater 2L Standards in the underlying surficial groundwater saturation zone. This calculation would probably require the need of site characterization of the subsurface hydrogeologic parameters of concern. The predictive calculation would need to consider vertical leaching and subsequent mixing of the groundwater saturation zone. 6) If the sludge/clay/soil liner underlying soil material has TCLP concentrations that are below the TCLP regulatory limits AND above Groundwater 2L Standards, then there are two options: a) Excavate the material that is above Groundwater 2L Standards, then proceed with lagoon closure. 5) If the sludge/clay/soil liner underlying soil material has TCLP concentrations that are below the TCLP regulatory limits AND below Groundwater 2L Standards, then the sludge may be left in place and the lagoon closed without excavating the sludge. compacted clay liner, then the clay liner should be sampled in three locations and analyzed for TCLP procedures in (2)(a). If the lagoon has a synthetic liner, then the soil material should be sampled in three locations and analyzed for TCLP procedures in (2)(a). From a field sampling point of view, the sludge and underlying clay or underlying soil material can be collected using a core barrel sampler for shallow soils, where the core barrel is driven into the sludge/clay/soil matrix and later extracted. I Sincerely, cc: Jay Zimmerman If you have any questions concerning this correspondence please contact me at 919-571- 4700 and if you have any questions concerning groundwater regulatory matters contact Mr. Jay Zimmerman at the same phone number. concentrations within the former lagoon area. Hence, the Section is reluctant to alter it’s draft policy without convincing scientific arguments that characterization and remediation would be aided. Please adhere to Section policy unless otherwise noted. Durham Triangle Page Three Kenneth Schuster, P.E. Regional Supervisor CERTIFIED MAIL- RETURN RECEIPT REQUESTED November 15, 2002 c. Re: Dear Mr. Shuster: cc: Iz Chuck Hill Jay Zimmerman Triangle Wastewater Treatment Facility i 5926 Highway 55 East i Durham, North Carolina 27713 919-544-8280 i 919-544-8590 (Fax) I www.woodardcurran.com H « WOODARD sSlJRRAN Engineering - Science ■ Operations Sincerely, Je^fyF^Rimr^MJEP Plant Manager CuHPORATE OFFICES: Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughout the U.S. Mr. Kenneth Shuster, P.E. Regional Supervisor Raleigh Regional Office NC -DENR 1628 Mail Service Center Raleigh, NC 27699-1628 West Lagoon Closure @ Triangle Wastewater Treatment Plant NPDES Permit No. NC 0026051-Durham County This letter is to acknowledge receipt of approval for the closure of the West Lagoon at the T"angle Wastewater Treatment Facility in your letter to Chuck Hill dated November 12, 2002. Thank y for your response to the County’s request on this issue. I would like to make one clarification I have talked to Jay Zimmerman about the actual sludge testing and the submittal of these tests to him. Mr. Zimmerman confirmed that since the sludge will be removed prior to the lagoon closure, the testing related to the sludge itself is not required for the lagoon closure. Therefore, please note that we will close the lagoon per the procedure outlined in your responsei to Chuck Hill dated November 12, 2002, except for the testing of the sludge, which will already be removed. The certified test results for the clay liner will be transmitted to Mr. Zimmerman for fina approval of the closure. Please contact me at 919-544-8280 if you have any further questions or comments. December 9, 2002 Dear Mr. Stafford: Please contact me at (919) 544-8280 if you have questions or require more information. This is to notify NCDENR that the effluent pump and disinfection portion of Phase 1 Modification Project is complete for Durham County - Triangle Wastewater Treatment Facility. Woodard & Curran as operator of the facility will utilize the effluent pumping station, UV Disinfection and Post Aeration Systems beginning immediately. Contractors continue to troubleshoot and make necessary adjustments to the systems to insure proper operation of all systems to insure continued compliance with permit parameters. We are using UV disinfection at this time and not utilizing chlorine. cc: Chuck Hill, Durham County Utilities Manager Mike Cherniak, W&C Triangle Wastewater Treatment Facility i 5926 Highway 55 East i Durham, North Carolina 27713 919-544-8280 i 919-544-8590 (Fax) i www.woodardcurran.com Re: Triangle WWTP Permit #NC002051 Start-up of Phase 1 Effluent System p £ co Mr. Kirk Stafford, Environmental Chemist^7 NCDENR Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 woodard Curran Engineering • Science • Operations i^^’ORATE OFFICES: Maine, Massachusetts, New Hampshire, Connecticut, Illinois, Florida Operational offices throughout the U.S. The discharge will be over a weir installed above the 100 year flood level to eliminate contamination from creek water flooding into the system as before. The sampling location will be at the discharge weir after treatment, clarification, filtration, disinfection and post aeration. The fecal coliform and other grab samples location is planned for the same location as the effluent is discharged from the final treatment portion of the facility. Sincerely, Jeiry F. Rimmer, QEP Plant Manger