NC0026441_Historical information_20041231

oton of loiter QEitp
SILER CITY, NORTH CAROLINA 27344-0769
(9
to
>i
January 6, 2004
Dear Mr. Mize:
If you have questions or concerns, please give me a call at 919-742-4732.
Sincerely,
TOWN OF SILER CITY
TG:ka
cc: Files
P. 0. BOX 769
311 N. SECOND AVE.
Wilson Mize, Environmental Technician
Division of Water Quality
Raleigh Regional Office
Water Quality Section
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
Terry Green
Director of Public Works & Utilities
'e
1^731
This letter is in response to the letter written on December 9, 2003, requesting a summary of activity performed
in 2003 to eliminate and reduce inflow and infiltration in our collection system and what we have planned for
2004.
I
CD
3
m;
hi October of 2003, bids were received to replace approximately 3500' of sewer line on East Fourth Street and
North Dogwood Avenue which we had targeted as an inflow and infiltration problem. The work for this
project began in December, 2003 and will continue to completion in 2004. In our 2004 budget, we will again
appropriate approximately $100,000 to continue with our I & I projects. We have two (2) projects earmarked
for 2004 that we will bid after the 2004/2005 budget is approved. As always the Town of Siler City is doing
everything possible to take as much inflow and infiltration out of our collection system.
PHON^
/ s/ // /
/f/
/ ° /
I « )3
Raleigh, North Carolina 276093800 Barrett Drive
May 21,2004
SUBJECT:
Dear Mr. Brower:
1.
2.
3.
4.
Mr. Joel D. Brower
Town of Siler City
311N. Second Avenue
Siler City, North Carolina 27344
This is to inform you that a review of your toxicity self-monitoring report form for the month of
March 2004 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition, this correspondence contains important information on the Division’s Copper and
Zinc Action Level Policy which is triggered by two or more toxicity limit violations that occur during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division’s Toxicity Reduction
Guidance have been included with this Notice of Violation.
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0026441
Town of Siler City WWTP
Chatham County
Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and the data indicate that the levels
of copper/zinc in your effluent have the potential to cause an exceedance of the NC water quality action
level for this (these) parameter(s) in your receiving stream during low stream flow conditions. The
policy states that whenever a facility experiences two or more toxicity limit violations during a toxicity
testing calendar quarter, the NPDES Permit will be modified to include numeric limits for copper and/or
zinc UNLESS the permittee provides one or more of the following:
3
ATTACHMENTS
cc:
Ken Schuster, P.E.
Regional Water Quality Supervisor
Raleigh Regional Office (no attachments)
Susan Wilson-NPDES Unit (no attachments)
Pretreatment Unit (no attachments)
Madolyn Dominy-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA
30303 (no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)
If the effluent is toxic, then we expect work to commence immediately with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper anchor zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You may consider entering into a Special Order by Consent (SOC) with DWQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division’s copper and/or zinc action level policy can be
found at the following web site - http://www.esb.enr.state.nc.us . Click on the “Aquatic
Toxicology” Unit and go to the prompt “DOWNLOADS” located at the bottom of the page. This web
site also contains EPA’s “Toxicity Reduction Evaluation Guidance for Municipal Wastewater Treatment
Plants.” Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
3800 Barrett Drive Raleigh, North Carolina 27609
July 23,2004
SUBJECT:
Dear Mr. Brower:
OR
Mr. Joel J. Brower
Town of Siler City
P.O. Box 769
Siler City, North Carolina 27344
This is to inform you that a review of your toxicity self-monitoring report form for the month of
May 2004 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or
zinc as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc are not the cause of toxicity
NOTICE OF VIOLATION
Effluent Toxicity Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0026441
Town of Siler City WWTP
Chatham County
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Previous correspondence was sent to you concerning implementation of the Division’s Copper
and Zinc Action Level Policy. The correspondence included prospective permit limits for copper and
zinc and stated that the trigger for implementing the policy would be two or more WET limit violations
which occur during a toxicity testing calendar quarter. Please note that the second WET limit violation
has occurred and you must provide:
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by
August 22, 2004. DWQ approval of options 1-3 below is not necessary as the Division
expects work to rule out copper and/or zinc as causative effluent toxicants to begin
immediately upon the second WET permit limit violation that occurred during May 2004.
a) Written notification indicating acceptance of the prospective copper and/or
zinc permit limit. Notification is due by August 22, 2004.
2
Written notification (a or b above) shall be sent to:
Three copies of the final report shall be submitted to:
cc:
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final
report should be comprehensive and include all data used to support your conclusion. The report
is due by April 23, 2005.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Additional information regarding the Division’s Copper and Zinc Action Level Policy can be
found at the following web site - http://www.esb.enr.state.nc.us/. Click on the Aquatic Toxicology
Unit and go to the prompt “AT Downloadable Files” located at the bottom of the page.
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Sincerely,
Ken Schuster
jT Water Quality Regional Supervisor
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Raleigh Regional Office
Susan Wilson-NPDES Unit
DWQ Pretreatment Unit
Kim Pierce-Water Management Division, USEPA Region IV, 61 Forsyth St., SW, Atlanta, GA 30303
Central Files
Aquatic Toxicology Unit Files
If the effluent is toxic, then we expect work to commence immediately with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.
Client:
Dare Sample Rcvd:6/9/04
Meritcch Work Order #06090439 Sample: Influent Composite 6/2-3/04
Parameters Result Analysis Reporting Limit Method
Meritech Work Order #06090440 Sample: Effluent Composite 6/2-3/04
Parameters Result Analysis Reporting Limit Method
Meritech Work Order #06090441 Sample: Influent Composite 6/3-4/04
Parameters Result Analysis Reporting Limit Method
Meritech Work Order #06090442 Sample: Effluent Composite 6/3-4/04
Parameters Result Analysis Reporting Limit Method
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
6/11/04
6/16/04
Arsenic, total
Copper, total
/line, total
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]
0.010 mg/1
0.015 mg/1
0.028 mg/1
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
0.010 mg/1
0.002 mg/1
0.010 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
6/10/04
6/10/04
6/10/04
Ms. Ann Clark
Town of Siler City
P.O. Box 769
Siler City, NC 27344
< 0.010 mg/1
0.036 mg/1
0.105 mg/1
< 0.010 mg/1
0.074 mg/1
0.209 rng/1
< 0.010 mg/1
0.014 mg/1
0.025 mg/1
Page 1 of 3
Report Date:
Revision Date
~ o6 Meritech, Inc."
’ Environmental Laboratory
Laboratory Certification No. 165
6/11/04
Client:
Date Sample Rcvd:6/9/04
Mentech Work Order #06090443 Sample: Influent Composite 6/4-5/04
Result AnalysisParameters Reporting Limit Method
Mentech Work Order #06090444 Sample: Effluent Composite 6/4-5/04
Result AnalysisParameters Reporting Limit Method
Sample: Influent Composite 6/5-6/04Meritech Work Order #06090445
Result Analysis Reporting Limit MethodParameters
Meritech Work Order #06090446 Sample: Effluent Composite 6/5-6/04
Result Analysis MethodParametersReporting Limit
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
Ms. Ann Clark
Town of Siler City
P.O. Box 769
Siler City, NC 27344
0.010 mg/1
0.035 mg/1
0.123 mg/1
0.010 mg/1
0.015 mg/1
0.027 mg/1
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
0.010 mg/1
0.002 mg/1
0.010 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
642 Tamco Road, Reidsville, North Carolina 27320
tel.(336)342^748 fax.[phone]
< 0.010 mg/1
0.015 mg/1
0.026 mg/1
0.010 mg/1
0.002 mg/1
0.010 mg/1
EPA 200.7
EPA 200.7
EPA 200.7
< 0.010 mg/1
0.045 mg/1
0.111 mg/1
Page 2 of 3
Report Date:
6/11/04
Client:
Date Sample Rcvd:6/9/04
Sample: Influent Composite 6/6-7/0406090447Meritech Work Order #
Result Analysis MethodReporting LimitParameters
6/6-7/0406090448Sample: Effluent CompositeMeritech Work Order #
Result Analysis MethodReporting LimitParameters
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
Arsenic, total
Copper, total
Zinc, total
Arsenic, total
Copper, total
Zinc, total
Ms. Ann Clark
Town of Siler City
P.O. Box 769
Slier City, NC 27344
0.010 mg/1
0.040 mg/1
0.114 mg/1
0.010 mg/1
0.015 mg/1
0.031 mg/1
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
6/10/04
0.010 mg/1
0.002 mg/1
0.010 mg/1
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
EPA 200.7
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
0.010 mg/1
0.002 mg/1
0.010 mg/1
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]
Page 3 of3
Report Date:
'Qlnftm of JBiler OXif-g
CD
August 9, 2004
/
Dear Mr. Matthews:
We will
If you have questions or need additional information, please advise.
Sincerely,
TOWN OF SILER CITY
Town Manager
JJB:ka
Attachment: Monitoring Reports for June, 2004
WILLIAM C. MORGAN, JR.
TOWN ATTORNEY
JOEL J. BROWER
TOWN MANAGER
Mr. Matt Matthews
NC Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Attached are monitoring reports for June, 2004 for the parameters arsenic, copper and zinc,
continue this monitoring process and forward our report by April 23, 2005.
Failed
Passed 94.9%
Failed 82.2%
Passed> 100%
Passed
PHONE: [phone]
FAX: [phone]
Total Copper 12 UG/L Total Zinc 21 UG/L
Total Copper 16 UG/L Total Zinc 'll UG/L
Total Copper 14 UG/L Total Zinc 24 UG/L
COMMISSIONERS
SAM ADAMS
HELEN M. BUCKNER
LARRY CHEEK
PATRICIA PERRY
TONY SILER
GUY D. SMITH
JOHN GRIMES
PROTEM
CHARLES L. TURNER
MAYOR
This is to inform you that the Town of Siler City NPDES Permit No. NC0026441 wishes to choose option
#3 Toxicity Identification Evaluation (TIE). We have initiated sampling with the following results.
• Effluent Toxicity Testing:
March, 2004
April, 2004
May 5, 2004
May 19, 2004
June 8, 2004
POST OFFICE BOX 769
31 1 NORTH SECOND AVENUE
SILER CITY, NORTH CAROLINA 27344-0769
o/ WHi < H
\QX^ MAHCH 7. IHK7
cc.^udy Garrett
Terry Green, Director of Public Works & Utilities
Curtis Brown, WWTP Superintendent
September 23, 2004
Subject:
Dear Mr. Brower:
A review of Siler City WWTP's monitoring report for July 2004 showed the following violations:
Parameter Limit ValueDate Reported Value Limit Type
Phosphorus, Total (as P)07/31/04 0.5 mg/1 0.55 mg/1
Sincerely,
xc:WQ Central Files
Also, please note that you reported the system to be "compliant" on the DMR. Remedial actions should be
taken to correct this problem. To prevent further action by the State, carefully review the causes of these
violations to avoid future occurrences.
Raleigh Regional Office
Surface Water Protection
Kenneth Schuster, P.E.
Raleigh Regional Water Quality Supervisor
phone[phone]
facsimile [phone]
Monthly
Average
Exceeded
NOTICE OF VIOLATION
Permit No. NC0026441
Siler City WWTP
Case No. NOV-2004-LV-0479
Chatham County
Joel J Brower
Town of Siler City
PO Box 769
Siler City NC 27344
1628 Mail Service Center
Raleigh, NC 27699-1628
Customer Service
1-877-623-6748
One NorthCarolina
Naturally
4^
nCdenr
0^2^
I If. > J LzUJn-Q V
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Departmen^f Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
1.
2.
3.
4.
5.
L
SECTION
DATE
NAME
REPRESENTING
1.
2.
3.
4.
5.
Signature / Date
Please attach a business card if possible
Please call for an appointment with Charlene Esposito, extension 241.
Appointments will be scheduled between 9:00 a.m. and 3:00 p.m., Tuesday
through Thursday. Viewing time ends at 4:00 p.m.
You must specify files you want to review by facility name, address or incident
number. The number of files that you may review at one time will be limited to
five.
hi accordance with General Statute 25-3-506, a $25.00 processing fee will be
charged and collected for checks on which payment has been refused.
FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may
not be taken from the office. To remove, alter, deface, mutilate, or destroy
material in one of these files is a misdemeanor for which you can be fined up to
$500.00.
11
You may make copies of a file when the copier is not in use by the staff and if
time permits. Cost per copy is 10 cents for ALL copies if you make more than 25
copies-there is no charge for less than 25 copies; payment may be made by check,
money order, or cash at the reception desk. Your company can also be invoiced.
—Incident number
OF NORTH CA^fcl^A
Department of Environment and Natural Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, North Carolina 27609
919-571-4700
//
Time In / Time Out
Guidelines for Access: The staff of the Raleigh Regional Office is dedicated to making
public records in our custody readily available to the public for review and copying. We
also have the responsibility to the public to safeguard these records and to carry out our
day-to-day program obligations. Please read carefully the following guidelines before
signing the form:
Facility Name
File Access Record
7
r
September 30, 2004
Subject:
Dear Mr. Brower:
Sincerely,
Xc:
Raleigh Regional Office
Water Quality Section
Kenneth Schuster, P.E.
Raleigh Regional Water Quality Supervisor
phone[phone]
facsimile [phone]
Michael F. Easley, Governor
William G. Ross Jr., Secretary
invironment and Natural Resources
Alan W. Klimek, P.E. Director
Colleen H. Sullins, Deputy Director
Division of Water Quality
Rescission of Notice of Violation
Permit No. NC0026441
Siler City WWTP
Case No. NOV-2004-LV-0479
Chatham County
Joel J Brower
Town of Siler City
PO Box 769
Siler City, NC 27344
1628 Mail Service Center
Raleigh, NC 27699-1628
Customer Service
I-877-623-6748
A review of Siler City's permit requirements shows that the Notice of Violation
[NOV-2004-LV-0479] issued to Siler City for exceeding phosphate discharge
monthly average was issued in error. The phosphate limit should be calculated
for quarterly average and not monthly. The Division regrets any inconvenience or
problem this may have caused. This correspondence hereby rescinds NOV-2004-
LV-0479 and the Division will remove the record from the tracking database.
North Carolina
WQ Central Files
Vanessa Manual- NPDES Compliance Unit
Curtis Brown- ORC, Siler City WWTP
If you have any questions concerning this correspondence please contact me at
919-571-4700.
-/!■ I ■«
N^DENR
One NorthCarolina Naturally
tic
FILE No.677 10/18 ’0 1/ 6:$ILER CITY WWTP PAGE
Fax Transmittal Form
Fr«»
Wastewater Tr&sment Plant
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Message:
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Your Address Um 2
Phone.9l».M2~4£8|
Fax 9J9-742-MW
Email:
OO
P O-Box 769
311 North Satxxtd Avenue
SterCity, N.C 27344
It
Review
□ Please rnmwut
□ Please Reply
Bate S(nt:
Time sent:
Nuri>er of pages including cover
Phone: [phone]S81
Fax: [phone]
Email:
Norn:
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CC:
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Fax number:
To 7^77
-------
: 919^5499
FILE No.677 10/18 ’O-

42
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FILE No.677 10/18 ’0 :$ILER CITY WWTP 3/ 6=919 499 PAGE
2710MODEL
DISPLAYSTEP NO.
23.None23.
None
♦Exeople - Eby be other value.
Ofprogramming
2.2.5.2
2-35
21
Flow pulse
definition
INDICATOR
LIGHT ON
23-
Operation in
composite time
mode
Freed PROGRAM/
STEP PROGRAM key.
This rfturns the sam­
pler to the standby
stata .
Shows four dashes
and if the »ao-
plinfc progr&o previously
completes( rotates with
'■PULL".
at a known,
into a
section 2.1.8,
inputs of a certain specific nature from an
These electronic flow input signals
the sampler at fixed increments of total flow,
That is, each time 10,000 gallons of
the flow meter, a signal is sent to
The
Model 2710 Sampler can be programmed to totalize any number
of flow pulses from 1 to 9999 before a sampling cycle is ini­
tiated. For example, if the sampler were programmed to totalize
5 flow pulses and each flow pulse represented 10,000 gallons
of total flow, a sample would be collected each time 50,000
gallons (5 flow pulses of 10,000 gallons each) had flowed
past the flow meter.
the Model 2710 Sampler in
Following the example, after the
from the moment the 25 minute
24. Rotates between the
time Interval in oinutaa
until tha firat/nexc sampi*
is collected (”00ll"») and
the total nunber of cob-
poalte s&nples which have
boon collected (’* 0.
24. Press tne START
PROGRAM key. This
places the sampler
In the ruo state.
meter .
to
every 10,000 gallons. That is, each time
liquid has flowed past the flow meter, a
the sampler, which registers it as a single flow pulse.
be programmed to
Composite Flow - The object of composite flow sampling using the Model
2710 is to collect a series of discrete, equal volume samples
regular flow interval, and to place these samples
single composite sample container. As discussed in
the Model 2710 will accept flow proportional
certain specific nature from an external flow
are transmitted
for example
This completes the
the composite time mode*
initial delay of 25 minutes
delay was entered in step 9, the sampler will place the first
individual 80 ml sample in the composite container at
The display will continue to rotate between
12:00
noon. The display will continue to rotate between the time
in minutes remaining until the next sample is collected (for
example, "0011") and the total number of individual samples
which have been placed in the composite container (for example,
“ 36“)• After the first sample has been collected, the time
interval to the next sample will be reset to the programmed
value of 15 and will continue decrementing. When it decrements
to zero, a sample will be collected, the display will be reset
to the programmed value of 15, and the decrementing process
will be started again. The process of placing individual
80 ml samples into the composite container will continue until
the 96th and last sample is placed in the container (after
a 2U hour period), at which time the sampler will shut-off
and the display will rotate between the text "FULL" and the
total number of samples collected 96").
FILE No.677 10/18 ’04 21 4/ 6:919 499 PAGE
MODEL 2710
2-36
Programming
calculations
Calculation of
flow increment
between samples
Average time
interval known
Thus, the desired flow Increment between samples is approximately
35,000 gallons.
Thus, the desired flow increment between samples is approximately
52,000 gallons.
Total number
of samples
known
^:SILER CITY WWTP
1 day
24 hours
= 1736.11 gallons
minute
1736.11 gallons X 30 minutes
minute sample
= 52,083 gallons
sample
To calculate the flow increment between samples, the average
flow rate of the flow stream and either the desired average
tiae interval between individual samples or the total desired
number of individual samples to be collected over the sampling
period must be known. If the desired average time interval
between individual samples is known, the flow increment between
samples can be determined by calculating how much flow (based
on the average flow rate) occurs during that time interval.
For example, assume that the average flow is 2.5 MGD and it
is desired to oollect a sample every 30 minutes, based on
chia flow. The flow Increment between samples is calculated;
Alternatively, if the total number of samples to be collected
over the total sampling period is known, the flow increment
between samples can be determined by calculating how much
total flow will occur during the sampling period, and dividing
this by the total number of samples to be collected. For
example, assume that the average flow is 1.75 MGD, that the
composite sampling period la 2 days, and that it is deaired
to collect WO individual samples. The flow increment between
samples is calculated;
2.5 MOD = 2,500,000 gallons/day
2,500,000 gallons X 1 day X 1 hour
day 24 hours 60 minutes
1.75 MGD = 1,750,000 gallons
day
1,750,000 gallons X 2 days
day
= 3,500,000 gallons
3,500,000 gallons V 100 samples
= 35,000 galiana
sample
When programming the sampler in a composite flow mode, three
quantities must be calculated to allow the sampler to be
programmed in a rational manner; the flow volume increment
between samples (number of flow pulses), the total number of
samples to be collected, and the volume of each individual
sample.
FILE No.677 10/18 ’04 22 PAGE 5/6
MODEL 2710
52,000 gallons 10,000
5.2 flow pulses
Thia
= 2,500,000 gallons
50 sampless
flow of 2.5 MOD,50 samples willan average
2-37
Calculation of
sample volume
gallons of flow,
into the sampler is
number of samples
be known;
to
a
2,500,000 gallons 7 50,000 gallons
sample
2,500,000 gallons X 1 day
day
gallons
flow pulse
2.5 MOD = 2,500,000 gallons
day
^:SILER CITY WWTP
Calculation of
number of
flow pulses
The total number of samples to be collected in this 24 hour
period is then calculated!
Calculation of
total number
of samples
Thus, based on
be collected.
Once the deaired flow increment between samples is known,
the number of flow pulses to be programmed into the sampler
may be calculated, assuming that the volume of the flow pulses
The number of flow pulses is
flow increment between samples
Using the first example
as
10,000
Rounding this to an even number results in 5 flow pulses
be programmed into the sampler. Thia in turn results in
flow increment between samples of 50,000 gallons (5 flow pulses
X 10,000 gallons/flow pulses).
:919^p499
To calculate the volume of each individual sample, the volume
of the composite sample container being used and the total
number of samples to be collected (calculated above) must
be known. Isco provides three different size composite sample
containers for use with the Model 27W;
To calculate the total number of samples to
three quantities roust be known: the average
flow increment between samples (calculated above),
total time over which the composite sample is to be collected.
The total number of samples to be collected is determined
by first calculating the total flow volume over the sampling
period, and then dividing this by the flow increment between
samples. For example, assume that the average flow is 2.5
MOD, the flow increment between samples is 50,000 gallons,
and the composite sample is to be collected over a 24 hour
period. The total flow volume over a 24 hour period is:
from the flow meter is known.
calculated by dividing the
by the volume of each flow pulse.
above, the flow increment between samples was calculated
52,000 gallons} assume that each flow pulse represents
The number of flow pulses to be programmed
calculated:
be collected,
flow rate, the
and the
FILE No.677 10/18 ’04 SILER CITY WWTP PAGE
MODEL 2710
15,000 nil v 50 aaoplea
« 3oo mi
250 inl/sample X 50 samples
= 12,500 b1
2-38
2
Composite flow
example
Calculation of
total saaple
volume
Sample volume
considerations
Thus, a sample volume of 290 ml (the next smaller volume which
may be programmed on the Model 2710) will result in the desired
composite sample, Because of the basic uncertainty of the
delivered sample volume exactly matching the programmed nominal
sample volume and the -10 ml sample repeatability, it is good
practice to select a nominal sample volume which is slightly
smaller than the calculated aample volume, this is to prevent
overfilling of the sample container. In the example, an
individual nominal sample volume.of 250 ml might ba a prudent
choice, For critical applications, it may be useful to use the
calibrate sample volume mode, as described in section 2.2.6.1.
A shut-off float prevents the composite sample container from
overflowing, but may terminate the sampling program
prematurely, degrading the quality of the sample. Thus, it is
important to select an Individual sample volume which will not
result in an overfilled sample container under worst-case
conditions,
The individual sample volume is calculated by simply dividing
the volume of the oomposite sample container being used by the
total number of samples to be collected. For example, assume
that a b gallon plastic container is being used, and that a
total of 50 samples are to be collected in it. The individual
sample volume is then calculated:
The nominal volume of the composite sample may be calculated
by multiplying the programmed nominal sample volume by the
total number of samples to be collected. In the example:
It should be kept in mind, though, that this calculated nominal
total volume may vary from the actual total volume because of
variations in the actual volume of each individual sample from
the programmed nominal sample volume, and the total time to
collect the 50 individual samples may vary from the desired 24
hour period because of variations in the average flow rate from
the 2.5 MGD figure used for calculations.
p 919^499
After the flow volume increment between samples (number of
flow pulses), the total number of samples to be collected,
and the volume of each individual sample have been determined,
the sampler may be programmed for automatic operation in a
composite flow mode by the use of the following set of step-
by-step instructions. These instructions assume that the
sampler is off and that a composite sample container has been
installed, as described in section 2.1.2.
2-1/2 gallon s 9,462 ml
4 gallon = 15,000 ml
6/ 6
North Carolina Departmen'
October 21, 2004
Subject:
Dear Mr. Brower:
2.
3. Flow meters were calibrated September 2004.
4.The influent and effluent composite samplers
5.The effluent was clear and free of excess solids.
6.
7.
8.
9.A cursory review of July 2004 laboratory and DMR data showed consistent reporting of results.
£
/
Sludge is disposed of by Synagro. 503 regulations
method.
phone [phone]
facsimile [phone]
Michael F. Easley, Governor
William G. Ross Jr., Secretary
nvironment and Natural Resources
Alan W. Klimek, P.E. Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
Mr. Joel Brower
Town Manager
Town of Siler City
P.O. Box 769
Siler City, NC 27344-0769
Compliance Evaluation Inspection
Siler City WWTP
NPDES Permit No. NC0026441
Chatham County
1628 Mail Service Center
Raleigh, NC 27699-1628
Customer Service
1-877-623-6748
performed October 15, 2004 by myself. The cooperation of Curtis Brown (Grade 4
, was appreciated. Findings during the inspection were
are programmed to collect samples flow proportionally.
are complied with by the Town using the SOUR
The subject inspection was ]
ORC), Ann Clark (Grade 3, backup ORC), and David Hicks,
as follows:
Raleigh Regional Office
Surface Water Protection
10. There continues to be an accumulation of grease/foam on the filters. Previous inspection reports have
noted grease/foam on the filter surface. Although this did not appear to detrimentally affect the effluent
quality at the time of the inspection, continued accumulations may at some point jeopardize effluent
quality, or cause filters to be taken out of service for maintenance or repair.
jUJGqe
A review of laboratory records showed satisfactory documentation and calibration of equipment.
Equipment temperatures were within acceptable ranges.
l/r> [ L
nCdCFw
NorthCarolinaNaturally
Mr. Brown stated the Town has 4 pump stations. All stations have autodialers, except for the Harmony
Hills station, which will have an autodialer soon. Mr. Brown stated the Blood Run station has a generator,
and the other stations share a portable generator. The Town is encouraged to ensure sufficient generators
are available to prevent overflows during power outages.
An emergency generator is onsite, but is only capable of operating the influent pump station. The Town
should consider adding generator capacity to power the entire plant to prevent partially treated waste to be
discharged during power outages, and avoid liability associated with such incidents.
1. The treatment units at this 4.0 mgd design WWTP consist of the following: auto and manual bar screens,
influent pump station with ultrasonic flow meter, grit removal, grease removal unit (not in operation, not
functional), 5 equalization basins, 2 oxidation ditches with jet aeration, alum and lime addition as needed, 2
circular clarifiers, 4 tertiary filters, gas chlorination, contact chamber, gas dechlorination, cascade aeration,
effluent ultrasonic flow meter, 2 aerobic digesters (near empty), DAF unit, thickened sludge holding basin’
(near empty). All units were operating satisfactorily except as noted.
18.
19.
20.
21.
22.Weirs of both clarifier needed to be cleaned of excessive algae.
Sampler temperatures were within specified ranges.23.
24.
13. A review of DMR data from September 2003-August 2004 showed compliance with monitoring and limit
requirements, except for a Notice of Violation for toxicity for May 2004.
14. The WWTP is staffed 24 hours/day, 7 days/week. The Division requires a facility to be staffed around the
clock only when the design flow is 5.0 mgd or greater. We commend the Town on the attention level given
to the plant.
15. Mr. Brown stated the significant industrial users include Townsends (chicken processing), Goldkist
(chicken processing), Mastercraft (textiles), Acme-McCrary (textiles, formerly Phantom Glendale), and
Brookwood Farms (ham processing).
16. As discussed during the inspection, place an asterisk on the front of the DMR beside data that needs to be
qualified, in addition to an explanation of the qualification.
Vegetation was growing in the sludge holding basin and digester. This must be removed as soon as
possible.
The WWTP staff is responsible for checking and maintaining the Town’s pump stations. It may be
beneficial to the Town to require the WWTP staff to be certified collection system operators.
We recommend the Town designate additional backup ORC’s to ensure the visitation requirements are
complied with at all times.
Please submit a summary of activity performed in 2004 to eliminate/reduce inflow and infiltration in the
collection system, and what is planned for 2005. Please submit this information by November 12, 2004.
There was a 1 ton cylinder of chlorine that was not properly secured. Please keep all cylinders secured.
The Town is encouraged to investigate using sodium hypochlorite or UV disinfection to replace the hazards
associated with chlorine gas.
Mr. Brower
Page 2
11. We recommend the food processing industries be inspected to ensure the fats, grease, and oils are being
removed from their respective waste streams.
12. It is our understanding that educational material is distributed to community residents as needed. You are
reminded of the requirement to notify this office by telephone anytime the filters are bypassed or taken
offline for any reason.
17. The influent BOD and TSS values are consistently significantly lower on Tuesdays and Wednesdays of
nearly every week. Mr. Brown stated he doesn’t know why this occurs, but it appears to have no affect on
the WWTP. It is recommended this trend be investigated as needed in conjunction with pretreatment
inspections, and interviews with industrial sources.
Mr. Brower
Page 3
Please submit your respond to item 18 as indicated. Please contact me at 919.571.4700 ext. 271 if you have
questions regarding this report.
I
>
Sincerely, ‘
7^/
Ted Cashion
Environmental Chemist
!
t
NC0026441Permit:
10/15/04Inspection Date:
Is the facility as described in the permit?
Are there any special conditions for the permit?
Comment:
Yes No NA NEOperations & Maintenance
NA NE
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
NA NFGrit Removal
Type of grit removal
a.Manual
b.Mechanical
Is disposal of grit in compliance?
Comment:
NA NF
Is the basin free of bypass lines or structures to the natural environment?
Is the general housekeeping acceptable?
Are all pumps operable?
Are float controls operable?
Comment:
Secondary Clarifier Yes NANo NE
■ Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Owner - Facility: Town of Siler City - Siler City WWTP
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Comment: There was some vegetation in the digester and sludge holding basin.
Bar Screens
Are audible and visual alarms operable?
Is basin size/volume adequate?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Type of bar screen
a.Manual
Is the basin free of excessive grease?
Are all pumps present?
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells?
Is the plant generally clean with acceptable housekeeping?
Is the site free of excessive organic content in the grit chamber?
Is the site free of excessive odor?
Equalization Bnsins
Is aeration adequate?
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
Yes No
Yes No NA NE
Yes No
Yes No
V
NC0026441Permit:
Inspection Date:10/15/04
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the sludge blanket level acceptable?
Is the return rate acceptable (low turbulence)?
Comment: There was some solids going over the weirs. Algae blocking some weirs.
NEYesNoNAAeration Basins
Ext. Air
Jet
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Does the foam cover less than 25% of the basin' s surface?
Is the DO level acceptable?
NEYesNoNA
Are the aerators operational?
Does the foam cover less than 25% of the basin’ s surface?
Is the DO level acceptable?
Are settleometer results acceptable (> 30 minutes)?
Comment:
NA NEFiltration (High Rate Tertiary)
Type of operation:
Is the filter free of growth?
Is the air scour operational?
Does backwashing frequency appear adequate?
Comment: There continues to be an accumulation of grease/foam on the filters.
NEYesNoNADisinfection
GasType of system ?
■ Are cylinders secured adequately?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the overflow clear of excessive solids/pin floc?
Is the surface free of bulking ?
Mode of operation
Type of aeration system
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Are the aerators free of excessive solids build up?
Is the foam the proper color for the treatment process?
Is the filter media present?
Is the filter surface free of clogging?
Is the scouring acceptable?
Is the clear well free of excessive solids and filter media?
Owner - Facility: Town of Siler City - Siler City WWTP
Inspection Type: Compliance Evaluation
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
Secondary Clarifier
Is the site free of weir blockage?
Are settleometer results acceptable?
Comment: Foam does not appear to affect treatment at this time.
Oxidation Ditches
■
■
■
■
■
■
Down flow
■
■
■
■
■
■
■
Yes No NA f ~
Yes No
NC0026441Permit:
10/15/04Inspection Date:
Disinfection
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Yes No NA NE
Is ventilation operational?
Comment:
Are the tablets the proper size and type?
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Yes No NA NE
Yes No
Is there adequate detention time
Is the contact chamber free of growth, or sludge buildup?
Comment: One 1 ton cylinder was not secured.
Lime and alum containment areas appeared satisfactory.
De-chlorination
Standby Power
Is automatically activated standby power available?
Is generator tested weekly by interrupting primary power source?
Is generator tested under load at least quarterly?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Does generator have adequate fuel?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Comment: Town should consider adding additional generator capacity.
Sand Filters (Low rate)
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is ventilation equipment operational?
Is ventilation equipment properly located?
Is SCBA equipment available on site?
Is SCBA equipment operational?
Is staff trained is operating SCBA equipment?
Is staff trained in emergency procedures?
Is an evacuation plan in place?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
Is de-chlorination substance stored away from chlorine containers?
(If pumps are used) Is an audible and visible alarm Present and operational?
Is the distribution box level and watertight?
Is sand filter free of ponding?
Owner - Facility: Town of Siler City - Siler City WWTP
Inspection Type: Compliance Evaluation
■
■
■
■
■
■
■
Simplex, Single
■
■
■
■
■
■
■
■
■
■
■
■
■
■
NA NEYes No
■
■
■
■
■
■
■
■
■
■
■
NA NE
NC0026441Permit:
Inspection Date:10/15/04
Sand Filters (Low rate)
Is the sand filter effluent re-circulated at a valid ratio?
Is the sand filter surface free of algae or excessive vegetation?
Comment:
Yes
Are all other parameters(excluding field parameters) performed by a certified lab?
Is the facility using a contract lab?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius*/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
Comment:
NA NFFlow Measurement - Influent
Is flow meter used for reporting?
Is flow meter calibrated annually?
Comment:
YesFlow Measurement - Effluent
Is flow meter operating properly?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
Yes No NA NFRecord Keeping
Are sampling and analysis data adequate and include:
Dates, times and location of sampling
Dates of analysis
Name of person performing analyses
O&M Manual
As built Engineering drawings
Has the facility submitted its annual compliance report to users?
Schedules and dates of equipment maintenance and repairs
Are DMRs complete: do they include all permit parameters?
Name of individual performing the sampling
Results of analysis and calibration
|. aboratory
Are field parameters performed by certified personnel or laboratory?
Are analytical results consistent with data reported on DMRs?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is flow meter operating properly?
(If units are separated) Does the chart recorder match the flow meter?
Is flow meter used for reporting?
Is flow meter calibrated annually?
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Transported COCs
Plant records are adequate, available and include
Owner ■ Facility: Town of Siler City - Siler City WWTP
Inspection Type: Compliance Evaluation
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
No NA NE
■
■
■
■
■
■
■
■
■
■
Yes No
No NA NE
Yes No NA NF
I
NC0026441Permit:
10/15/04Inspection Date:
■
NEYesNoNA
Is sampling performed according to the permit?
NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
NA NE
■
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
Record Keeping
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Is the facility description verified as contained in the NPDES permit?
Does the facility analyze process control parameters, for example: MLSS, MORT, Settleable Solids, DO, Sludge
Judge, pH, and others that are applicable?
Facility has copy of previous year’s Annual Report on file for review?
Comment: Facility is staffed around the clock; no regulatory requirement.
Influent Sampling
Is composite sampling flow proportional?
Comment:
Effluent Sampling
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is proper volume collected?
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is the odor acceptable?
Comment: Sludge holding basin near empty. Vegetation in basin and digester needs to be removed.
Owner - Facility: Town of Siler City - Siler City WWTP
Inspection Type: Compliance Evaluation
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
Comment: Stream sampling performed by Association.
Aerobic Digester
Is the capacity adequate?
■
■
■
■
■
■
Comment:
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)?
Yes No NA NE
Yes No
Yes No
Yes No NA NE
EPA
NPDES
3L 12|NC0026441
21| I I I I I I I I I I I I I I I I I I 1 Illi66
Entry Time/Date Permit Effective Date
03/03/0101:00 PM 04/10/15
Siler City WWTP
Exit Time/Date Permit Expiration DateNCSR 1363 US Hwy 64
Siler City NC 27344 06/10/3103:30 PM 04/10/15
Other Facility Data
///
Name, Address of Responsible Official/Title/Phone and Fax Number
Joel J Brower,311 N Second Ave Siler City NC 27344//919-742-2323/
Permit Flow Measurement
Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
PRO WQ//91957147000235/919-571-4718■Rebin L Caldwe-1-1-
Agency/Office/Phone and Fax NumbersSignature of Management Q A Reviewer
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Curtis R. Brown/ORC/919 742-4581/
Self-Monitoring Program | Sludge Handling Disposal
Laboratory
United States Environmental Protection Agency
Washington, D C. 20460
Contacted
No
yr/mo/day
04/10/15
QA
72 LJ
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Facility Self-Monitoring Evaluation Rating
70
Inspection Type
18[CJ
Date
Oy- /c 2./
7
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
J 11
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)_______
Operations & Maintenance H Records/Reports
Facility Site Review
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Fac Type
20 uJ17
Inspector
19|£j
Remarks
I I I I I I I I I I I I I I I I I I I I I I I
Bl71 u 73l I I74
Inspection Work Days
671 139
--------Reserved-------------------------
75l I I I Illi80
Transaction Code
1 [nJ 2 LsJ
Water Compliance Inspection Report
Section A: National Data System Coding (i.e., PCS)
1NPDES
NC0026441
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
yr/mo/day
04/10/15 J17J113l12 I
Inspection Type
18 lc]
November 8, 2004
Dear Mr. Cashion:
Sincerely,
TOWN OF SILER CITY
TG:ka
cc: Files
P. O. BOX 769
31 1 N. SECOND AVE.
Ted Cashion, Environmental Chemist
Raleigh Regional Office
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
Terry Green
Director of Public Works & Utilities
'c
“uunt uf g’tlrr Citir
SILER CITY, NORTH CAROLINA 27344-0769
I
—i
I
o
This letter is in response to #18 of the letter received by the Town of Siler City on November 1, 2004,
from your inspection of the Waste Treatment Plant on October 15, 2004. As you are aware, the Town
of Siler City has been attempting to eliminate inflow and infiltration in our collection system since
1987. The fiscal year of 2003/2004 was no exception. During this time the Town replaced 1500 ft. of
sewer line between East Ninth Street and North Dogwood Avenue, 900 ft. on East Fourth Street and
450 ft. on North Greensboro Avenue spending approximately $150,000. In the upcoming fiscal year
of 2004/2005, the Town has a project to replace approximately 2,000 ft. of gravity sewer on West
Second Street and two other projects to replace approximately 980 ft. of gravity sewer on Siler Street
and Alston Avenue and 1385 ft. of gravity sewer on Elk Street and Finch Street depending on the
availability of the money.
The Town of Siler City will continue its efforts to reduce and eliminate inflow and infiltration to the
best of its ability. Should you have questions, please do not hesitate to give me a call at 919-742-4732.
EHQME: [phone]
FAX: [phone]
II
c
i
p Li
North Carolina Departmei
November 10, 2004
Subject:
Dear Mr. Green:
2.
Raleigh Regional Office
Surface Water Protection
phone[phone]
facsimile (919) 571-47IS
Michael F. Easley, Governor
| William G. Ross Jr.. Secretary
Environment and Natural Resources
Alan W. Klimek, P.E. Director
Coleen H. Sullins. Deputy Director
Division of Water Quality
Pretreatment Compliance Evaluation Inspection
Town of Siler City WWTP
NPDES Permit No. NC0026441
Chatham County
1628 Mail Service Center
Raleigh, NC 27699-1628
Customer Service
1-877-623-6748
5. A pretreatment inspection was performed at Joan Fabrics as part of this PCI. The format
followed and performance was excellent.
On November 10, 2004 Deborah Gore of DWQ PERCS Unit and Jerry Rimmer of the Raleigh
Regional Office conducted an inspection of the Town of Siler City pretreatment program. A
copy of the inspection form is attached. The assistance given by Curtis Brown and you during
this inspection was greatly appreciated. Findings were as follows:
1. The program has five SIU’s. There are no categorical SIU's.. None were in Significant
Non Compliance (SNC) during the past year. NOV's were issued to Brookwood Farms
and Townsend for all violations noted per your ERP.
A review of the program elements records indicated that all necessary records are being
maintained. Records of DWQ PERCS staff approval of all pretreatment program
components are maintained appropriately. The HWA was approved in 2002 and are due
for revision 9/1/2005. Your SUO will need revision to include language allowing up to
$25,000 fines. The information regarding this revision is available on the DWQ/PERCS
website. You had no problem locating requested documentation.
3. The pretreatment inspection file review included Townsends, Inc., Mastercraft and
Brookwood Farms. The files needed for review were readily available, up to date and
well organized. Letters of NOV are written as soon as any violations are discovered.
Your pretreatment program has performed appropriate tracking. Annual site inspections
of each facility have been performed.
4. We discussed the need to include all LTMP data on the monthly DMR's submitted to
DWQ. The October 2004 DMR is to include all data for the effluent taken as part of the
LTMP. The DMR's for January through September 2004 should be amended as we
discussed to include the additional data. These amended DMR's should be signed and
submitted to DWQ by December 31, 2004.
Mr. Terry Green, Public Works Director
Town of Siler City
P O Box 769
Siler City, NC 27334
I?dukM
nCDenr
One NorthCarolina Naturally
Sincerely,
/Enclosure: 2004 Siler City PCI Inspection Form
cc:
Page 2
Siler City PCI
November 10, 2004
The pretreatment program is well organized, well documented and is being managed in a timely
manner. Much improvement is obvious in the management of this program and the associated
files. If you have any questions or comments, please call me at [phone].
Jerry/f7. Rimmer
Environmental Specialist
Deborah Gore, PERCS Central Office
Central Files
LE
9/1/20052/27/2001 & 6/10/2002(ior NH3)Headworks Analysis (HWA)
Submitted revision July 2002 No3/2/1998Industrial Waste Survey (IWS)
Sewer Use Ordinance (SUO)
(add $25,00 tine max revision.)
7/9/1991Enforcement Response Plan (ERP)
8/23/1996Long Term Monitoring Plan (LTMP)
NoKI Yes
3. Brookwood Farms2. Mastercraft1. Townsends, Inc.
35.
a.EYesDNoON/Aa-OYesaNoEN/A
Page 2
approval yet.
Revisions due 12/2006
24.
25.
Filename: Siler City PC1'O4
Revised: 6/30/98
SUO on file as approved and adopted-
6/6/95 -Approval letter not found.
a. ElYesBNonN/A
b. OYesDNoElN/A
a.nYesENoQN/A
bnYesONoEN/A
K Yes
No
No
Is the Table Adequate?
a.DYcsElNoEIN A
b nYesaNoglN/A
j^j^TS REVIEW- Please review PO
Date of Last Approval
YesENoDN/A
YesONolSN/A
ElYesaNoDN/A
K Yes No
INDUSTRIAL USER PERMIT (IUP) FILE RE VIE W( 3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
26. User Name
a. ^Yes dNo
bBYesDNoaN/A
KI Yes No
K Yes No
ElYesDNoDN/A
K Yes No
a. [3Yes DNo
b. DYes DNo
YesDNoEN/A
b-DYesUNoDN/A
YesQNoEIN/A
Yes K N?
YesDNo^N/A
Yes|%NolZ|N/A
YesQNoEIN/A
KYes No
a. SYes EINo
b. DYes DNo
YesDNoSN A
ElYesDNoDN'A
K) Yes No
K Yes |~ZI No
a. SYes DNo
b. DYes DNo
YesCNoElN/A
^YesDNogN/A
KI Yes No
NH3 & BOD
a.0YesDNoDN/A
a. ®Yes UNo
b-BYesDNoDN/A
K) Yes No
Yes KI No
SYesONogN/A
a. 13Yes □No
b aYcsDNoDN/A
K Yes No
b.B YesDNoQN.'A
□YesgNogN/A
Yes K n7
S YesgNogN-A
Yes K No
YesgNogN/A
gYes3Nol3N/A
gYesgNoEINA
005
K Yes No
12 /31 / 2005
NA
K) Yes No
006
KI Yes No
12 /31 / 2005
NA
K Yes No
PRETREATMENT PROGRA^^
Program Element
b.!3YesDNoDN/A
YesgNogN/A
Yes No
□YesgNogN/A
NOV-NH3&Color
r^^cjniplete the following:
Date Next Due, If Applicable
LTMP FILE REVIEW:
22.
23.
Is the LTMP Monitoring Being Conducted at Appropriate Locations and Frequencies? K Yes No
Should any Pollutants of Concern be Eliminated from or Added to the LTMP? O Yes K No
If yes, which ones? Eliminated: Added:
Are Correct Detection Levels being used for all LTMP Monitoring?
Is the LTMP Data Maintained in a Table or Equivalent? K Yes
27. IUP Number____________________________________________________________
28. Does File Contain Current Permit?______________________________________
29. Permit Expiration Date__________________________________________________
30. Categorical Standard Applied (LE. 40 CFR, Etc.) Or N/A
31. Does File Contain Permit Application Completed Within One Year Prior
to Permit Issue Date?____________
32. Does File Contain an Inspection Completed Within Last Calendar Year?
33. a. Does the File Contain a Slug Control Plan?
b. If No, is One Needed? (See Inspection Form from POTW)
34. For 40 CFR 413 and 433 TTO Certifiers, Does File Contain a Toxic
Organic Management Plan (TOMP)? _________________________________
a. Does File Contain Original Permit Review Letter from the Division?
b. All Issues Resolved?_______________________________
36. During the Most Recent Semi-Annual Period, Did the POTW Complete
its Sampling as Required by IUP?_______________________________________
37. Does File Contain POTW Sampling Chain-Of-Custodies?
38. During the Most Recent Semi-Annual Period, Did the SIU Complete its
Sampling as Required by IUP?__________________________________________
39. Does Sampling Indicate Flow or Production? Flow
40. During the Most Recent Semi-Annual Period, Did the POTW Identify
All Non-Compliance from Both POTW and SIU Sampling?
41. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self­
Monitoring Violations?
b. Did Industry Resample Within 30 Days?______________________________
42. Was the SIU Promptly Notified of Any Violations (Per ERP)?
43. During the Most Recent Semi-Annual Period, Was the SIU in SNC?
44. During the Most Recent Semi-Annual Period, Was Enforcement Taken
_____as Specified in the POTWs ERP?____________________________
45. Does the File Contain Penalty Assessment Notices?
46. Does The File Contain Proof Of Penalty Collection?____________________
47. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
003
K Yes No
12/31/2005
NA
K Yes No
Yes Ei
Unsatisfactory OMarginal O
Date: 11/10/2004PCI COMPLETED BY: Jerry Rimmer & Deborah Gore
INDUSTRY INSPECTION PCS CODING:
InspectorInspec.TypeTrans.Code
(INSP)(TYPI)
TJ No Reviewed observations and thanked facility for the tour and cooperation.
Page 3
1. Industry Inspected: Joan Fabrics
2. Industry Address: 1311 East 11th Street, Siler City, NC
3. Type of Industry/Product: Furniture & wall Covering Fabrics Weaving
4. Industry Contact: Tommy Johnson Title: Plant Engineer
Elmer Jones Maintenance Supervisor
Filename: Siler City PCI’04
Revised: 6/30/98
KI No
K No
Main Program Permit Number
iNlcInlolllbUUll I
Fac. Type
FACT)
ifficult^pbtaining Any of This
NOD: Yes K No
NOV: Yes
QNCR: Yes
POTW Rating:
Satisfactory K
MM/DD/YY
I 11 I K) I 04 I
(DTIA)
FILE REVIEW COMMENTS:
-Brookwood Farms # 44- BOD & TSS violations due to DAF breakdown and plant shutdown during sampling event (No NOV
Issued). Additional sampling after DAF repaired showed compliance. Noncompliance data not used for compliance judgment.
Town and SIU in communication during this time. Re-sampled 6/2/2004.
-Brookwood Farms # 44-TSS violation 06/03/2004 -NOV Issued 6/10/2004.
-Townsend. Inc. violations for BOD in July 2003. They modified DAF and operation of pretreatment unit to correct problem.
PCT SUMMARY AND COMMENTS:
PCI Comments: No IWS submitted as stated in 2003 PCI report. 9/29/2002 last IWS. Will fax copy olTWS Approval letter (3/2/98).
ERP approval letter (7/9/1991) and LTMP approval letter (8/23/96) to regional office to complete our files.
Requirements:
Recommendations: SUO guidance is on the PERCS website. This details requirements to modify SUO to include ability to fine up to
S25.000 and other updating issues. Prepare these changes and submit for approval.
Yes^^No~^|^] Yes KI No
use.
KI No Pretreatment not required except grease trap at cafeteria which is cleaned
monthly.
D. Sampling Review KI Yes No Reviewed sampling data and calibration records since last inspection.
E. Exit Interview KI Yes
Industrial Inspection Comments:
Demonstrated good knowledge of facility and good rapport with personnel.
SIU Inspection conducted by Terry Green and Curtis Brown.
5. Does the POTW Use the Division Model Inspection Form or Equivalent? K Yes KI No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview KI Yes No Discussed production rates and potential new products
B. Plant Tour KI Yes No Discussed chemicals used and process procedures. Observed chemical storage and
C. Pretreatment Tour I I Yes
48. Did the POTW Representative Have^ff
Requested Information For You?
EPA
Water C
NPDES
12LNC0026441
Illi66I I I I I I I I I | I I |
80
Section B: Facility Data
Permit Effective DateEntry Time/Date
09:30 ZiM 04/1:
Siler City WWTP
Permit Expiration DateExit Time/DateNCSR 1363 US Hwy 64
Siler City NC 27344 04/11/1001:55 PM
Other Facility DataName(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Name, Address of Responsible Official/Title/Phone and Fax Number
Joel J Erower,311 N Second Ave Siler City NC 27344//919-742-2323/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Agency/Office/Phone and Fax NumbersName(s) and Signature(s) of Inspector(s)Date
RRO WQ//91957147000235/919-571-4718R imme rJerry
Agency/Office/Phone and Fax NumbersSignature of lagei
Rev 9-94) Previous editions are obsolete.EPA Form 3560-:
Mill
3L
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
United States Environmental Protection Agency
Washington, D C 20460
yr/mo/day
04/11/10
QA
72 LU
Form Approved
OMB No. 2040-0057
Approval expires 8-31-98
Inspector
19^
Inspection Work Days
67 I I 69
Contacted
No
Fac Type
20 u
2ii i i i i i i i i i i i i i i i i i i i i i TTT i i i i i
Date
Facility Self-Monitoring Evaluation Rating
70 LI
J11
Inspection Type
18LJJ 17
pliance Inspection Report
Section A: National Data System Coding (i.e., PCS)
Transaction Code
1 LI 2 LJ
Bl71 u 73l I I 74
—Reserved--------------------
75| I I I I I I I
mt Ri
1
NPDES
3l NC0026441
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
See attached PCI Checksheet Report.
yr/mo/day
04/11/1012 I J17J”
Inspection Type
18 [P]
Michael F. Easley, Governor
November 29, 2004
DEC 0 1 2004
SUBJECT:
Dear Permittee:
1.
>
2.
(fax) 919 733-0719
Joel J. Brower
Town of Siler City
Post Office Box 769
Siler City, NC 27344
Your NPDES permit for a municipally owned/operated WWTP expires on October 31, 2006. This notice is being sent to
explain the requirements for your permit renewal application.
You are receiving this advance notice because your facility has a permitted flow at or above 1 MGD, or the subject
facility receives industrial [pretreatment] wastewater. If either of these criteria no longer applies, contact the NPDES
Unit before submitting a renewal application.
Federal (40 CFR 122) and state (15A NCAC 2H.0105(e)) regulations require that permit renewal applications be filed at
least 180 days prior to expiration of the current permit. Your renewal application is due to the Division no later than
May 4, 2006. Failure to apply for renewal by the appropriate deadline may result in a civil penalty assessment or other
enforcement activity at the discretion of the Director.
These additional analyses must accompany your permit renewal application, or any request for a major permit
modification. The Division cannot draft your permit without the additional data. Any data submitted cannot be over 4
¥2 years old, and must account for seasonal variation (samples cannot be collected during the same season each year
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Visit us on the internet @ http://h2o.enr.state.nc.us/NPDES
>
>
>
>
919 733-5083, extension 511
Charles, weaver® ncmail.net
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
The U.S. EPA revised and expanded the application requirements for municipal permits, effective August 1, 2001. EPA
form 2A is attached to this Notice, and must be used for your permit renewal application. The new application
requirements mandate additional effluent testing:
Conduct three Priority Pollutant Analyses (PPAs) and submit results with your renewal application. Collect
samples for the PPAs in conjunction with sampling for your current quarterly toxicity test. The new PPA
requirements differ from previous versions. Each PPA must include:
Analyses for all total recoverable metals listed in Part D of form 2A. This includes metals that are not
normally monitored through your NPDES permit.
Analyses for total phenolic compounds and hardness.
Analyses for all of the volatile organic compounds listed in Part D.
Analyses for all of the acid-extractable compounds listed in Part D.
Analyses for all base-neutral compounds listed in Part D.
Analyses for Total Mercury must be performed using EPA Method 1631.
Conduct four toxicity tests for an organism other than Ceriodaphnia and submit results with your renewal
application. The tests should be conducted quarterly, with samples collected on the same day as your
current toxicity test. Call the Aquatic Toxicology Unit at [phone] for guidance in conducting the
additional tests.
’’•5) 'Z U/JTP
Advance Notice of Renewal Application Requirements
Permit NC0026441
Siler City WWTP
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
ene'
Sincerely,
The following items are REQUIRED for all renewal packages:
□
□
□
□
if collected over multiple years). If your permit already contains a requirement for an annual effluent pollutant scan,
additional scans are not required [provided you have conducted at least 3 scans prior to submitting your application].
If any wastewater discharge will occur after the current permit expires, this NPDES permit must be renewed.
Discharge of wastewater without a valid permit would violate Federal and North Carolina law. Unpermitted discharges
of wastewater could result in assessment of civil penalties of up to $25,000 per day.
The completed ERA Form 2A application (copy attached), signed by the permittee or an Authorized Representative.
Submit one signed original and two copies.
If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares the renewal
package, written documentation must be provided showing the authority delegated to the Authorized
Representative (see Part II.B.ll.b of the existing NPDES permit).
cc: Central Files
Raleigh Regional Office, Water Quality Section
NPDES File
Send the completed renewal package to:
Charles H. Weaver, Jr.
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Charles H. Weaver, Jr.
NPDES Unit
j^^otice for Permit NC0026441
Chatham County
Page 2
Use the checklist below to complete your renewal package. The checklist identifies the items you must submit
with the permit renewal application. If all wastewater discharge has ceased at this facility and you wish to rescind this
permit, please contact me. My telephone number, fax number and e-mail address are listed at the bottom of the
previous page.
A cover letter requesting renewal of the permit and documenting any changes at the facility since issuance of the
last permit. Submit one signed original and two copies.
A narrative description of the sludge management plan for the facility. Describe how sludge (or other solids)
generated during wastewater treatment are handled and disposed. If your facility has no such plan (or the
permitted facility does not generate any solids), explain this in writing. Submit one signed original and two copies.
This information can be included in the cover letter.
T
Michael F. Easley, Governor
&
December 30, 2004
Dear Mr. Loeffler:
Sincerely,
cc:
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Kenneth Schuster, P. E.
Regional Water Quality Supervisor
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
If any parts, requirements, or limitations contained in this approval are unacceptable, please provide a
written response within thirty days after receipt of this approval, describing your concerns. This cover
letter shall be considered a part of this approval and is therefore incorporated therein by reference.
Mr. Guy E. Loeffler, Managing Member
Horizon Cellars LLC
466 Vineyard Ridge
Siler City, NC 27344
Subject: Approval for Pump and Haul
Horizon Cellars LLC
Chatham County
Chatham County Health Department
Joel Brower, Town Manager, Town of Siler City
Terry Green, Director of Public Works, Town of Siler City
Raleigh Regional Office
1628 Mail Service Center
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Phone [phone]
FAX [phone]
Alan W. Klimek, P.E., Director
Division of Water Quality
If you need additional information concerning this matter, please contact Barry Herzberg at
[phone] extension 238.
Surface Water Protection
Raleigh, NC 27699-1628
OneNorthCarolina____ Naturally
Customer Service
1-877-623-6748
-Il- it
In response to your request, the Division has modified your Pump and Haul approval. Pumping and
hauling shall be performed in accordance with the description, terms, and conditions specified in the
attached document. Pumped wastewater will be hauled and disposed of at the Town of Siler City’s
wastewater treatment plant as approved by the Town of Siler City. This modified approval changes the
reporting requirements required by Paragraphs 9 and 10 to quarterly rather than monthly.
*7
t
ERMISSION IS HEREBY GRANTE
1.
2.
3.
4.
5.
6.
7.
8.
9.
The facilities for wastewater storage shall be properly operated, maintained and inspected at all
times.
for the operation of a wastewater pump and haul activity which will consist of the pumping and hauling of
up to 6,500 gallons annually of industrial wastewater from a winemaking process to the Town of Town of
Siler City’s wastewater treatment plant for final treatment and disposal, pursuant to the request received
on November 10, 2004.
This approval shall become voidable unless the pump and haul activities are carried out in a manner
and by firms that have been approved by the Division of Water Quality (the Division) to haul industrial
wastewater.
This approval is effective only with respect to the nature and volume of wastes described in your
request of November 10, 2004.
This approval is not transferable. In the event of sale, name change, ownership transfer or similar
activities, a formal request for change must be submitted to the Division.
No type of wastewater other than that generated by the wine making process and removed from the
storage tank for this wastewater shall be included in these pump and haul activities.
This approval shall be voided unless the agreement between Horizon Cellars LLC and the Town of
Siler City for the ultimate disposal of the wastewater is in full force and effect.
Horizon Cellars LLC shall keep an inspection log or summary including, as a minimum, the date and
time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by
Horizon Cellars LLC. affecting any aspect of the pump and haul process including any significant
changes which could affect the type or character of the wastewater.
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, Horizon Cellars LLC shall cease operation of all pump and haul activities and take such
immediate corrective actions as may be required by this Division.
Horizon Cellars LLC is liable for any damages caused by a spill or failure of the pump and haul
operations carried out within their premises.
the date wastewater is removed from the facility,
the name and permit number of the carrier (hauler) of the wastewater,
the name of the facility receiving the wastewater, and
the volume of wastewater removed
Horizon Cellars LLC
Siler City, North Carolina
Chatham County
a)
b)
c)
d)
This approval shall become voidable unless the agreement between Horizon Cellars LLC and the Town
of Siler City for the acceptance and final treatment of the wastewater is in full force and effect, and shall
be subject to the following specified conditions and limitations:
10. An accurate record of the pump and haul activities must be maintained by Horizon Cellars LLC,
indicating:
Noncompliance Notification:
Approval granted this the 30th day of December, 2004.
Kenneth Schuster, P. E.
Regional Water Quality Supervisor
Raleigh Regional Office
13. Failure to abide by the conditions and limitations contained in this approval may subject Horizon
Cellars LLC to appropriate enforcement actions available to the Division.
14. The granting of this approval does not preclude Horizon Cellars LLC from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government agencies
(local, state, and federal) which have jurisdiction.
Persons reporting such occurrences by telephone shall also file a written report in letter form within
fifteen (15) days following first knowledge of the occurrence. This report must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
Horizon Cellars LLC shall report by telephone to the Raleigh Regional Office, telephone no. 919/571-
4700, as soon as possible, but in no case more than twenty-four (24) hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following:
b. Any failure of a pumping station, sewer line, etc., resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or
facility.
Horizon Cellars LLC
Siler City, North Carolina
Chatham County
Page 2
11. Any duly authorized officer, employee, or representative of the Division of Water Quality may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to the
pump and haul collection facilities at any reasonable time for the purpose of determining compliance
with the Division’s approval; may inspect or copy any records that must be maintained under the
terms and conditions of this approval; and may obtain samples.
The records as required in paragraphs 9 and 10 shall be subm^Kd (by the last day of the
following month for quarters ending March 31, June 30, September 30 and December 31) to the
Raleigh Regional Water Quality Supervisor, Department of Environment and Natural Resources,
1628 Mail Service Center, Raleigh, NC 27699-1628.
a. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
of pumps, aerators, compressors, etc.