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HomeMy WebLinkAboutNC0026441_Historical information_20051231January 25, 2005 JAN 2 6 2005 Environments! Sciences D' Dear Mr. Matthews: If you have questions or need additional information regarding this situation, please advise. Sincerely, TOWN OF SILER CITY Town Manager JJB:ka Attachment: (3) Copies - Copper and Zinc Evaluation Report WILLIAM C. MORGAN, JR. TOWN ATTORNEY JOEL J. BROWER TOWN MANAGER PHONE: (919) 742-2323 FAX: (919) 663-3874 CHARLES L. TURNER MAYOR COMMISSIONERS SAM ADAMS HELEN M. BUCKNER LARRY CHEEK PATRICIA PERRY TONY SILER GUY D. SMITH JOHN GRIMES PROTEM potnr RECEIVEDMr. Matt Matthews NC Division of Water Quality Environmental Sciences Branch Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, North Carolina 27699-1621 cc: Terry Green, Director of Public Works & Utilities Curtis Brown, Wastewater Treatment Plant Superintendent Bill Lester, Hobbs, Upchurch & Associates Files p( x , F(A zs/\O\. m*wji 7 iw7 'QIafnn nf ^ilcr POST OFFICE BOX 769 311 NORTH SECOND AVENUE SILER CITY, NORTH CAROLINA 27344-0769 This is to inform you that the Town of Siler City has completed the Toxicity Identification Evaluation (TIE). We have concluded that copper and/or zinc were not causative factors in effluent toxicity. As required in a letter from the Division of Water Quality dated July 23, 2004, I am submitting three (3) copies of our study evaluating the effect of copper and zinc on chronic toxicity at the Siler City Wastewater Treatment Plant. In that letter it was indicated that the Division would consider prospective limits for copper at 15 UG/L and 116 UG/L for zinc. Our sampling has indicated that zinc is running well below this proposed limit. Our study indicates that the concentration of copper in our plant effluent has exceeded the proposed limit of 15 UG/L on occasion, but has not affected the chronic toxicity compliance at our plant. In fact, there seems to be no direct correlation between the concentration of copper in plant effluent and the chronic toxicity testing. On May 5, 2004, the concentration of copper was found to be 12 UG/L and the toxicity test failed at 82.2%. In December, the proposed limit was exceeded but the chronic toxicity test passed. At this point, the Town feels that something other than the presence of copper and zinc in the Town’s wastewater effluent is responsible for the failure of the chronic toxicity test. PASSED-94.9%4-7-04 FAILED-82.2%5-5-04 PASSED->100%5-19-04 PASSED6-8-04 6-9-04 6-10-04 6-11-04 PASSED9-13-04 9-14-04 9-16-04 9-17-04 2 C 20G-; Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc Copper Zinc 9 32 12 21 16* 27 15* 23 14 24 14 24 13 24 7 20 8 22 13 24 14 23 DATE 3-17-04 EFFLUENT(UGZL) 14 32 PARAMETER Copper Zinc CT COMPLIANCE FAILED Siler City Wastewater Treatment Plant Evaluation of Effluent Copper and Zinc Analysis For Chronic Toxicity Compliance 12-07-04 12-9-04 12-10-04 *Copper meets or exceeds proposed limit of 15 ug/1. Copper Zinc Copper Zinc Copper Zinc 29* 45 23* 30 26* 30 DATE 12-06-04 EFFLUENT(UGZL) 20* 29 CT COMPLIANCE PASSED PARAMETER Copper Zinc co o February 4, 2005 Subject: Dear Mr. Brower: Please feel free to contact me or Kevin Bowden at (919) 733-2136 if you have any questions. Sincerely, cc: 1621 Mail Service CenterEnvironmental Sciences Branch A review of the facility’s toxicity self-monitoring data from May 18, 2004 to date indicates that no additional effluent toxicity permit limit violations occurred during the review period. This office has received a copy of your letter dated January 25, 2005 documenting the Town’s actions to rule out copper and zinc as causative effluent toxicants. DWQ’s Copper and Zinc Action Level Policy was triggered by the March and May 2004 Whole Effluent Toxicity test failures. An evaluation of reasonable potential to violate instream action levels-rota| for these parameters was conducted by the NPDES Unit and NOVs dated May 21,2004 and July 23, 2004 were sent to the facility. The Town submitted correspondence dated August 9, 2004 to our Unit and chose Option 3 (Toxicity Identification Evaluation) to definitively rule out copper and/or zinc as causes of effluent toxicity. Your submittal indicates no correlation between effluent copper and zinc concentrations and toxicity test results. The submittal suggests copper and zinc are not responsible for Whole Effluent Toxicity test failures occurring in March and May 2004. While ephemeral toxicity may be difficult to characterize utilizing TIE/TRE procedures, the data does not conclusively rule out copper and zinc as causative effluent toxicants. We note a trend of increasing copper and zinc concentrations for December effluent samples (eg, 12/6, 12/7, 12/9 and 12/10, 2004). Based on information contained in your January 25, 2005 submittal, our office will not recommend the NPDES Permit be reopened to include copper and zinc permit limits at this time. Michael F. Easley Governor William G. Ross, Jr., Secretary Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality Raleigh, NC 27699-1621 (919) 733-2136 Mr. Joel Brower, Town Manager Town of Siler City PO Box 769 31 1 North Second Avenue Siler City, North Carolina 27344-0769 DWQ’s Copper and Zinc Action Level Policy Evaluation of Copper and Zinc Town of Siler City WWTP NPDES No. NC0026441 Chatham County Matt Matthews, Supervisor Aquatic Toxicology Unit CERTIFIED MAIL RETURN RECEIPT REQUESTED Please be reminded that the Town of Siler City remains subject to the provisions of DWQ’s Copper and Zinc Action Level Policy should additional effluent toxicity violations occur in the future (ie. two effluent toxicity pennit limit violations occurring within the toxicity testing calendar quarter defined by the NPDES Permit). Ken Schuster-Raleigh Regional Office Ted Cashion-Raleigh Regional Office Dave Goodrich-Point Source Branch Pretreatment Unit Kim Pierce, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta, Georgia 30303 Aquatic Toxicology Unit Files Central Files NCDENR Customer Service 800 623-7748 ,E \o.441 G4/09 '03 0?:^;D:S1LER C.ITV WWTP SL37425499 PAGE i Fax Transmittal Form From Wastewater Treatmert Plant Message: Pdg To MT r To T- 7~(O3 Y, ■■ss Town tof Siler City Phone: 919-742-4581 Fax: 919-742-5499 Emai1; P O Box 769 j I i North Second Avenue $ilei City, N C 27344 Phone 919-742-458. Fax 9 9-742-5499 Errail: I our Addrei> Line 2 Date sent: Time sent: Number of pages including cover page: / Urgent ^Tar Review Pl ease Comment ? Pl ease Repl y Some: Orgam zati on \ame/Dept:1 CCPhone number: «•>: Fax number: 1 1 1 ! a 1I -:W off /W/" no hm to July 7, 2005 Subject: Dear Mr. Green: On July 6, 2005 Mr. Christopher Wu of the Raleigh Regional Office conducted The following observations were made: 2. 4. 5. Mr. Curtis Brown, ORC of the facility. His help process. Phone (919) 571-4700 FAX (919)571-4718 Alan W. Klimek, P.E., Director Division of Water Quality North Carolina Division of Water Quality Internet: h2o.enr.state.nc.us Mr. Terry Green Director of Public Works Town of Siler City 311 North Second Street Siler City, NC 27344 Compliance Evaluation Inspection Town of Siler City WWTP NPDES Permit Number NC0026441 Chatham County fOUQt ... - -------------------------a compliance evaluation inspection of the Town of Siler City wastewater treatment plant with the assistance of » was appreciated as it facilitated the inspection One NofthCarolina------- Naturally Customer Service 1 -877-623-6748 Meritech is the contract lab responsible for testing metals, TN/TP, and chronic toxicity. The rest of the parameters are analyzed on-site in the certified laboratory. Michael F. Easley, Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Synagrow is responsible for pumping and hauling the sludge from the aerobic digesters. The sludge is land applied. Raleigh Regional Office Surface Water Protection 3800 Barrett Drive Raleigh, NC 27699-1628 An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper 1. There is currently not enough standby power to operate the entire facility. The generator can only operate the influent pump station, bar screen and grit removal processes, and in situations of duress, partially treated wastewater might be discharged to Loves Creek. The Town ol Siler City should consider adding generator capacity to the facility to avoid the problems associated with loss of power. There are two functional clarifiers at the facility. One of the clarifiers, however, was drained for general maintenance and will be in operation soon. 3. The sample storage units for both influent and effluent sampling were set at a temperature deemed too cold by state standards. The influent sampler had a temperature of 0.8° C and the effluent sampler had a temperature of 0.5° C. Both were outside of the acceptable temperature range (1.0 - 4.4° C). Mr. Brown was made aware of this and stated that the temperatures would be adjusted. required. Mr. Brown stated that Terry 7. With the exception of the Annual report, Mr. Brown is keeping all of the files and data in a well organized fashioned. Such order eased the file review process. The overall conditions of the Town of Siler City WWTP are compliant with Division standards. Sincerely, Cc: Mr. Curtis Brown, Town of Siler City WWTP Christopher Wu, RRO Central Files Christopher Wu Environmental Specialist Town of Siler City WWTP, NCOOJ 07/07/2005 6. The Annual Report was not on file for review as Green keeps the report in his office at City Hall. If you have any questions regarding the attached report or any of our findings, please contact Christopher Wu at: (919) 571-4700, ext. 266 (or email: chris.wu@ncmail.net). 1 Permit Yrs No NA NF Yes No NA NF b.Mechanical Secondary Clarifier Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? 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? Type of grit removal a.Manual Type of bar screen a.Manual ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ 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: While the bar screen is mechanical it can be operated manually as well. Grit Removal (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? Are there any special conditions for the permit? Is access to the plant site restricted to the general public9 Is the inspector granted access to all areas for inspection9 Comment: There are no special conditions to this permit. Operations & Maintenance Is the grit free of excessive organic matter? Is the grit free of excessive odor? Is disposal of grit in compliance? Comment: ■ ■ NA NF NA NF NA NF NA NF Yrs No Yrs No Yes No Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH. DO. Sludae Judae and other that are applicable? a a ’ Comment: The facility analyzes DO and sludge blanket depth (sludge judge). Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? Comment: Bar Semens Yrs No ■ ■ ■ ■ ■ ■ ■ Yes NF NA NF Yrs No NA NF NA NF ■ Yes No NA NF There is not, however, enough power to operate the entire facility. Standby Power Is automatically activated standby power available9 Is the generator tested by interrupting primary power source? Is the generator tested under load? Is the feed ratio proportional to chlorine appropriate? (Approximately ratio 1:1) Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? ■ ■ ■ ■ ■ ■ o ■ ■ ■ ■ ■ ■ ■ Is the DO level acceptable? Are settleometer results acceptable (> 30 minutes)? Is the DO level acceptable^! .0 to 3.0 mg/l) Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes) Comment: The DO level is approximately 1.5 mg/L. Disinfection-Gas Are cylinders secured adequately9 Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? Is the level of chlorine residual acceptable9 Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de-chlorination? Comment: De-chlorination Secondary Clarifier Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) Comment: There are currently 2 clarifiers at the facility. One, however, was drained for general maintenance. THe return rate is approximately 1,900 gallons/minute. The sludge blanket depth is approximately 2 feet (out of a 20 foot well). Oxidation Ditches 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? Comment: Are the aerators operational? Are the aerators free of excessive solids build up? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin' s surface? ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site9 Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: There is enough standby power to operate the influent pump station, bar screen, and grit removal processes. Yes No No NA Yes No Gas ■ ■ ■ 4 v Sand Filters (Low rate) (If pumps are used) Is an audible and visible alarm Present and operational? Is the sand filter effluent re-circulated at a valid ratio? is the sand filter surface free of algae or excessive vegetation? No NA NFYes NA NF Results of analysis and calibration NA NF Is composite sampling flow proportional9 Laboratory Are field parameters performed by certified personnel or laboratory? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re-circulated at a valid ratio? (Approximately 3 to 1) Comment: Are analytical results consistent with data reported on DMRs? Is the chain-of-custody complete? Is the tubing clean? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Is sampling performed according to the permit? Comment: The temperature was 0.8 degrees Celcius. Is sample collected above side streams? Is proper volume collected? Dates, times and location of sampling Name of individual performing the sampling Dates of analysis Name of person performing analyses Transported COCs ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Are all other parameters(excluding field parameters) performed by a certified lab9 Is the facility using a contract lab? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius*/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? Comment: LAb work for metals, TN/TP, and chronic toxicity are contracted to Meritech. Record Keeping 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 DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MOD 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? Facility has copy of previous year's Annual Report on file for review? Comment: The Annual Report is kept by Terry Green in city hall and was not on-site during the time of the inspection. Although the facility is <5 MGD they still operate 24/7 with a certified operator. Influent Sampling Yes No Yes No Yes No NA NF r.. NA NE ■ ■ ■ ■ ■ ■ ■ ■ ■ o ■ ■ Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? Is the odor acceptable? Is tankage available for properly waste sludge? Comment: Synagrow pumps and hauls sludge for the facility and then land applies it. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? 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 facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: The temperature was 0.5 degrees Celcius. Aerobin. Digester NA NE Yes Nd Yes No 13 = 47 S.ER CITY WUITP 9197425199 P.01 I To Judy Garrett Wastewater Treatment Plant Message; Thanks,Curtis Your Address Line 2 Town of I er ( i tv f4 P.O.Box 769 311 North Second Avenue Siler Chy, N.C 27344 Date sent: 7-2S-OS Time sent: 1:50 pm Number of pages including cover page: 3 Phone 919.742-4581 Fax 919-742-5499 Email: candmbrown5B@eanh»nk. □ Urgent □ For Review □ Please Comment □ Please Reply Phone: 919-742-4581 Fax: 919-742-5499 Email: candmbrown58@earthlink.net ax Transmittal Form Name: DEM Organization Name/Dept: CC: Phone number:919-571-4700 Fax number:919-571-4718 ' JUL-25-2005 Judy, Take a look at this, Carolina Analytical Services Would like to bring this waste to the plant. They are on a septic system and the Chatham County Health department Wants them to stop discharging to the septic system. Will this require a pump and haul, or should they find a alternate disposal plan. I don’t know if I should accept it ? (Ju/) From Curtis Brown 9197425199 P.02 July 25, 2005 If you have any questions please call me at 919-837-2021. This waste if approx. 4-5 gallons a day Attn: Curtis Brown Siler City Wastewater Treatment Plant Fax #742-5499 Regards, ' Jennie Stewart This fax including this page is 2 pages The following page is the maximum daily use. I have spoken with Mike Williford at the Div of Waste Management, Hazardous Waste Section. He suggested I call you and see if you could accept this waste The ph of this waste is between 3 - 10 (this is not treated) I will be glad to explain the chart I am faxing. ^ER CITY WWTP Carolina Analytical Services, LLC Affiliated with Barww-Agee Labs, Inc 17570 NC Hwy ?O2 • Bear Creek. NC 27207 • Phone: 919-837-2021 • Fax; 919-837-2110 JUL-25-2005 13=47 P.039197425199 0<l Jt.r use-: TOTAL P.03 o.a_5^ x7 0.3/3 /J k a-tJ'/h 6-014^ ( ^4^6 /9a/ J u$^ 'TisT 3o Te-jT^/ — Cc>r>cc- [ 2 L: Ci^l C-I de*v5 ^ER CITY LdWTP ■^-S ” ixse; ^Dccl /tcsT^ BoTcsT^/^^y -2. 55 D J ^ulPaA/c. Ci J - ^0 l^yjro'fjjc'' - ^mhzSv/u^ lAt/4-<Z^4 Ms/yl A^(C- /’a/£) Lor-tc- fyc.1 J JUL-25-2005 13=47 pl^.3 /t>7A c/tf-J/^5*06^/xld^J ( /3^/y0-7 2 0 > ^C> Z aod cc o’P/tfJ ^OCc O'PCiu.^c (-t/a e,^ 2^ per- (pOD cc^ or ?«^Uk*s Or ^JA-l?/pAy <0 C/^a./lS - S'o / October 21, 2005 Subject: Dear Mr. Brower: Phone (919) 791-4200 FAX (919)571-4718 Alan W. Klimek. P.E. Director Division of Water Quality Mr. Joel Brower Town Manager Town of Siler City P.O. Box 769 Siler City, NC 27344 Raleigh. NC 27699-1617 Raleigh. NC 27609 An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper 2. While Gold Kist, Inc. has been in SNC for flow violations for at least 3 consecutive semi­ annual monitoring periods, the industry has not been assessed any penalties by the Town of Siler City. NC DWQ/PERCS Unit 1617 Mail Service Center Internet: h2o.enr.state.nc.us/Pretreal/index.html 3800 Barrett Drive Notice of Violation: NOV-2005-PC-0235 Pretreatment Audit Inspection Program: Town of Siler City Chatham County NPDES Number NC0026441 ar NprthCarolin -------------Naturally Customer Service 1-877-623-6748 CERTIFIED MAIL RETURN RECEIPT REQUESTED Michael F. Easley. Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources C On October 19, 2005 Ms. Deborah Gore of the Central Office and Mr. Christopher Wu of the Raleigh Regional Office performed an audit inspection of the Town of Siler City’s pretreatment program with the assistance of Mr. Terry Green, Director of Public Works and Utilities, and Mr. Curtis Brown, ORC of the WWTP. The inspection report is attached. Everyone’s assistance was greatly appreciated as it facilitated the inspection process. The significant findings were as follows: 1. There are currently 5 Significant Industrial Users (SIU) discharging to the POTW, none of which are Categorical. Throughout the last 2 semi-annual monitoring periods, only Gold Kist, Inc. has been in Significant Non-Compliance (SNC) for flow violations. Gold Kist, Inc. has a permitted flow of 0.650 MGD, but due to USDA mandated water requirements per slaughtered bird, the SIU continually violates their limit. Gold Kist, Inc. representatives stated that they were considering the construction of an equalization tank that would enable them to better control their flow. They also stated that they were considering a water reuse program that would allow them to reclaim their water and use it to clean drains. It was suggested by the Division inspectors that the Town of Siler City issue Gold Kist, Inc. a consent order that would temporarily increase their flow limits. This will potentially allow them to be in compliance until construction and implementation of future plans are complete. 6. 8. Mr. Joel Brower Page 2 of3 10/21/2005 The approval letters for both the Sewer Use Ordinance (SUO) and Industrial Waste Survey (IWS) were both missing. The missing SUO letter is excused due to the fact that the Division pretreatment unit, itself, does not have a copy of the letter which is dated February 2, 1995. It is recommended that all approval letters be kept and made available upon request. 3. The Town of Siler City issued a NOV in July 2005 to Acme-McCrary, another SIU. A spill of red dye at the Acme-McCrary facility turned the influent, effluent, and Rocky River (receiving waters) red for approximately 1 week. It is possible that the industry will be in SNC for the second half of 2005. Because of this incident, Acme-McCrary and the Town of Siler City are facing a lawsuit for negligent practices. Acme-McCrary, meanwhile, has been reducing production throughout 2005 and has plans to relocate to Asheboro, NC. 4. Townsends, Inc., another SIU and poultry facility in Siler City, has an operable equalization tank that aids in flow control. Numerous odor complaints have been made, however, as a result of the tank. Townsends, Inc. has since added blowers and increased aeration to control the smell. 9. Part II, 2, b) of the IUP requires that SIUs report self-monitoring violations within 24- hours of becoming aware of the violation. There is no documentation that this requirement is being met. The Division recommends that the POTW distribute the attached fax notification form to each of the SIUs for their use to report self-monitoring violations. Alternatively, a phone call documented in a bound logbook is acceptable. Each IUP contains requirements for daily flow measurement by the SIU. The data is being submitted, but it appears that compliance judgment is not being completed. Review all flow data for the year 2005 for each SIU and send Notices of Violation for any flow violations not previously documented. 7. The industry files were very poorly organized and scattered throughout numerous folders and locations. Such disarray hindered the file review process. Numerous files were missing including: the daily flow monitoring data for Gold Kist, Inc. from 2004 - present, all of the original permit review letters from the Division, and the spill control plan for Acme-McCrary (which was later found in Mr. Green’s office). An improved filing system is highly recommended as it will increase efficiency. The poor organization of the paperwork was problematic during the audit. 5. The Long Term Monitoring Plan (LTMP) requires an update. Currently, the most recent version of the LTMP has several incorrect detection limits for pollutants of concern (POC) and lists 4 SIUs that either no longer exist, no longer discharge to the POTW, or have undergone changes of ownership and name. Please update the LTMP to reflect current conditions and submit it to the Division by December 12, 2005. Refer to Chapter 4 of the Comprehensive Guidance for examples, requirements, and recommendations. Sincerely, Cc: Deborah Gore, DWQ - PERCS Unit Christopher Wu - RRO Mr. Terry Green, Town of Siler City Mr. Curtis Brown, Town of Siler City WWTP Central Files Kenneth Schuster, P.E. Surface Water Quality Regional Supervisor Raleigh Regional Office Mr. Joel Brower Page 3 of 3 10/21/2005 A Notice of Violation is being issued to the Town of Siler City for violation of 15 A NCAC 2H .0917, failing to submit permit modifications for both Acme-McCrary and Townsend, Inc. It is important to adhere to the state’s guidelines for permit changes so that an efficient pretreatment program can be maintained. In addition, the Town of Siler City would greatly benefit from an improved filing system. Files should be kept in an organized fashion so that all paperwork is readily accessible. It is possible that the failure to obtain permit modification approval was simply a result of poor housekeeping. 11. 15 A NCAC 2H .0917 requires each POTW to transmit copies of all issued Significant Industrial User pretreatment permits to the Division for review. The permit modification increasing the flow for Townsends, Inc. (IUP # 005) from 0.625 MGD to 0.650 MOD was not submitted to the Division as required. In fact, the IUP in the Town’s file indicated a flow limit of 0.625 MGD; however, Mr. Green did find a permit modification page that included a notation of the flow increase. Flow compliance for Townsends will be based on the 0.650 MGD limit. Please make sure that the current permit renewal reflects the correct flow limit. 10. 15 A NCAC 2H .0917 requires each POTW to transmit copies of all issued Significant Industrial User pretreatment permits to the Division for review. The permit modification changing ownership of Phantom-Glendale, Inc. (IUP # 0007) to Acme-McCrary was not submitted to the Division as required. Thank you for your continued support of the Pretreatment Program. If you have any questions or comments, please contact Christopher Wu at (919) 791-4260 [or email: chris.wu@ncmail.net ] or Deborah Gore at (919) 733-5083 ext. 593 [or email: deborah.gore@ncmail.net]. 12. An industry inspection of Gold Kist, Inc. was conducted by Mr. Brown and Mr. Green, and a tour of the facility was given by Mr. Fred Thomen, Wastewater Manager of the facility. The inspection was thoroughly completed with the aid of the Division’s inspection form. Company Name: Permit Number: Date: To: FAX: so that I Date Sampled Signature: Date: NoYesTown notified within 24 hours? If there is a problem with this transmission, please call: Parameter in Violation Town of ________ Industrial Pretreatment Program Date Results Received Permit Limit, mg/L Result, mg/L Town of Industrial Pretreatment Program Industrial Self-Monitoring Permit Violation(s) Notification Per SIU permit Part II General Conditions 2, B: If the sampling performed by the permittee indicates a violation, the permittee shall notify the Town of---------within 24 hours ot becoming aware of the violation. The permittee shall also repeat the sampling and analysis and submit the results of the repeat analysis to the Town of---------------within 30 days after becoming aware of the violation, unless notified by the Town of---------------- that such repeat analysis is not required. I am submitting this facsimile notification to Town ot will be in compliance with this requirement. 2. 3. 4. Last Inspection Date: 11/10/2004 Inspection Type: PCI 7. 8. 9. PCS (WENDB)Coding Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type l_N I C I 0 I 0 I 2 i 6 4 I 4 1 IIJLI SIUS CIUS NOIN SNC for Either Reporting or Limits Violations During Either of the Last 2 1 PSNC 0 NOCM 0 MSNC 1 SNC for Both Reporting and Limits Violations During Either of the Last 2 0 0 SNIN Page 1 I—S_| (INSP) LLJ (FACC) 5 0 0 0 0 Pretreatment Audit Report Revised: 10/27/00 L_G_I (TYPI) 10 / 19 / 05 (DTIA) or with an Expired IUP am Info Sheet(s)? YES ..P.uring Either of the 2 Semi-Annual Periods 19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of the Last 2 Semi-Annual Periods 5. Audit Date: 10/19/2005 6. Is POTW under an Order That Includes Pretreatment Conditions? NO Order Type and Number:-------- Are Milestone Dates Being Met? N/A Parameters Covered Under Order: Control Authority (POTW) Name: Town of Siler City Control Authority Representative(s): Terry Green Title(s): Director of Public Works and Utilities Address of POTW: Mailing: Po Box 769 City: Siler City Phone Number (919) 742 - 2323 ext: State: NC Zip Code: 27344-0769 Fax Number (919) 663 - 3874 ext: ~ Inspected or Sampled If Y^s'ExpSn1118 the POTW experienced any NPDES or Sludge Penrat compliance problems? NO ..N^er of ISIUs Not Sampled by POTW in the Last Calendar Year? .1..l-.....Enter the Higher Number of 12 or 13 15. Number of SIUs in U’" ~ ~ ‘ ~ ?.?.^.TA^al.Periods...(Total Number of^^ in SNC) JA.with No iup, .I.Z:.....Murr,I).er of SIUsJP. SNC for Repoiling Dun 2 Semi-Annual Periods 18. Number of SIUs in .1..9.:.....CpEent Number of Significant Industrial Users (SIUS)? .LL.9£rent..Number of.Categorical Industn 12. Has Program Completed All Requirements from the Previous Inspection or Progr; If No, Explain. CAROLINA DIVISION oIWuHUr QUALITY PRETREATMENT AUDIT REPORT Background Information [Complete prior to audit; review Program Info Database Sheet(s)| 1. U.ll.1P9£[..9lSIUs Not..Inspected by POTW in Last Calendar Year? 13. Industrial Waste Survey (IWS)12/03/2004 09/29/2007 Sewer Use Ordinance (SUO)02/15/1995 12/01/2006 Enforcement Response Plan (ERP)07/09/1991 within 3 months of SUO approval Long Term Monitoring Plan (LTMP)08/23/1996 Legal Authority (Sewer Use Ordinance-SUO) 21. 22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? YES / NO A copy, if not already submitted, should be sent to Division. 23. It yes to #21, Have you had any trouble working with these towns or districts? YES / NO If yes, Explain. Enforcement (Enforcement Response Plan-ERP) Page 2 Date of Last Approval 10/18/2005 26. Did you send a copy of the ERP to your industries? YES If no, POTW must send copy within 30 days. Pretreatment Audit Report Revised: 10/27/00 PRETREATMENT PROGRAM ELEAIEIV Program Element Headworks Analysis (HWA) or enforcing any part of the SUO? NO i.e. any adjudications, improper enforcement, etc.)? NO. ^^REVIEW- Please review POTW the following: _______Date of Last Approval Date Next Due, If Applicable 09/01/2010 25. Have you had any problems interpreting If yes, Explain. 24. Date of Last SUO Adoption by Local Council: 06/05/1 995 27. Have you had any problems interpreting or enforcing any part of the ERP (i If yes, Explain. WhiCh y°U n0'iD —xedjurisdiction NO 28. List Industries under a Schedule or Order and Type of Schedule or Order near'uXforflow'"65 3 SChedU'e Or G°ld KiSt lnC- h°Wever' may be put under a consent °rder in the Resources Unsatisfactory Explanation, if Unsatisfactory Satisfactory Satisfactory Satisfactory Satisfactory Reference Materials Satisfactory seminars andSatisfactory Satisfactory Page 3 Computer Equipment (Hardware and Software) Personnel Available for Maintaining POTW's Pretreatment Program Pretreatment Audit Report Revised: 10/27/00 The staff is encouraged to attend offered workshops. 37. Were all industries in SNC published in the last notice? YES Only 1 industry was in SNC for 2004, and it was published. Availability of Funds if Needed for Additional Sampling and/or Analysis Access to POTW Vehicles for Sampling, Inspections, and Emergencies______________ Access to Operable Sampling Equipment Marginal Rating 35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? YES side from the annual inspection the Mr. Green tries to meet with industry representatives at least twice per year. 36. Is the public notified about changes in the SUO or Local Limits? YES The SUO has not changed since 1995. an industry tor certain information to remain confidential? th P°TW rcC°Ver the C°St °f the Pretreatm™t progr^ from their industries? Explain. The POTW recovers costs through surcharges and also uses money from the Town's water and sewer fund. Public Perception/ Participation 33. Has any one from the public ever requested to review pretreatment program files? YES If yes, explain procedure. If no, How would the request be addressed? While there is no formal procedure, the Town has always been fully compliant with requests for information. YES haVe a Proce^ure in P'ace that addresses requests by If yes, explain. All confidential information is kept under lock and key. Annual and Etc.) 3°. Does the POTW have an adequate data management system to run the pretreatment program1? YES. Explain Yes or No. Staff Training (i.e. Regional Workshops, 29. Please Rate the Following: Satisfactory 32' YES^If yesyexpinSUeS a®*'”8 Pretreatment Pro8ram (e g- odor, plant closing, new or proposed plants)? Townsends had some odor problems stemming from its EQ tank, but have since added more blowers and increased the reri^Th lnne' A S0' Acm®‘McCrary had allowed red dye to enter the wastewater system eventually dying the Rocky River Town of Silw Cit°US C°mP stemm|n9 from the color change have resulted in a law suit against Acme McCrary and the (Example, designated point, samples drawn, Page 4 Pretreatment Audit Report Revised: 10/27/00 : were only those pollutants 43. Review copies of current allocation tables for each WWTP. Are there any over allocations? YES If yes, What parameters are over allocated9 ------ BOD, Hg 39‘ Does the POTW receive waste from any groundwater remediations (petroleum, CERCLA) or landfill leachate9 NO If Yes, How many are there? ' ----- Please list each site and how it is permitted, if applicable. 41. If the POTW accepts trucked waste, what controls are placed on this waste? manifests required) Samples are taken and standard laboratory tests are run. 42. How does the POTW allocate its loadings to industries? Historical Industry Need Explain Other: 40. Does the POTW accept waste by Truck or Dedicated Pipe? TRUCK The POTW receives waste from septic tanks and haulers. Permitting (Industrial Waste SurveynVS)^^ 38. How does the POTW determine which industries have the reasonable potential to adversely impact the WWTP and therefore require a permit? (Who is an SIU?) Prior to a potential industry moving in, an IWS is sent to them, and impact is based on their response and a preemptive site visit. Tho nianSft0 ’S tO addreSS the OVer allocations? (short term lUPs, HWA to be revised, pollutant study etc ) The plant is very likely underloaded on BOD. Hg is not really over-allocated. Y’ J 45. Does the PO fW keep pollutant loading in reserve for future growth / safety? YES If yes, what percentage of each parameter. There is no standard percentage that is kept. 46' Ifye^ex^i™ eXPerienCed difficulty in allocation? (For example: adjudication by an industry) YES As stated before. Gold Kist, Inc., has required more flow than has been allotted to them. 47. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (For example- listed on the application limited; categorical parameters; NPDES Pollutants of Concern) The POTW bases its decision on NPDES Pollutants of Concern. 48. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits’ Explain Monitoring frequency will increase for an industry if it is deemed problematic or is likely a source of negahve impact Permit Compliance 49. Does the POTW currently have or during the past year had any permits under adjudication? NO It yes, Which Industries, and what was (will be) the outcome of the adjudication? 50. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits reporting requirements, and permit conditions, as well as for SNC. ’ rePoran& Monitoring data are analyzed on the computer and violations are noted. 51. Does the POTW use the Division’s model inspection form or equivalent? YES If no, does the POTW form include all DWQ data? N/A 52. Were all SIUs evaluated for the need of a slug and spill control plan during their most recent inspections? YES no, explain. ------ that representative samples will be taken by the POTW or SIU each time? Phone: ()ext: 62. In general, what is the most limiting criteria of your HWA? Pass Through Page 5 60. Do you complete your own headworks analysis (HWA)? YES If no, Who completes your HWA? Pretreatment Audit Report Revised: 10/27/00 Long Term Monitoring Plan (LTMP) and Headworks Analysis (HWA) 59. Is LTMP maintained in a table? YES Review data and explain. The data are well organized and maintained in the state's LTMP version. or at then end of its treatment prior to 53. What criteria are used to determiTOif a slug control plan is needed? St0ra9e’location- and its Potential to enter the system are the criteria used to determine if a slug control plan is I cu u 11. 64. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No significant changes to the WWTP or pretreatment program are predicted. 61. Do you have plans to revise your headworks in the near future? NO If yes, What is the reason for the revision? N/A Explain. 56. Has the POTW established a procedure to ensure f (Example: swirling the sample bucket uniformly) YES If yes, explain. Treatment plant operators will mix and swirl their samples to ensure representativeness. 57. Who performs sample analysis for the POTW?: Metals: Meritech Laboratories Conventional Parameters: Certified plant laboratory Organics: Meritech Laboratories 58. Explain the Chain of Custody Procedure used for both in house and commercial lab samples. Commercial chain of custodies are used for sample management. The WWTP lab also uses in-house chains of custodies. 54. What criteria does the POTW7 use to review a submitted slug control plan? After inspecting the industry, plans are reviewed to address whether or not a potential to contaminate exists. 55. How does the POTW decide where the sample point for an SIU should be located? Typical sampling points are either where the industry waste first enters the system entering the system. 63 Explain566 inCreaSe y0Ur loadings the (Example: obtaining more land for sludge disposal)? YES Currently, the POTW hauls and land applies it sludge via Synagrow. This will increase the WWTP's sludge capacity. Summary 1. Gol ist, 74. YES I YES Such poor organization led to lost or missing files. All sampling chain of custodies are kept at the Town's WWTP. Paged YES NO YES YES Pretreatment Audit Report Revised: 10/27/00 a. YES b. YES a. N/A b. N/A FILE REVIEW COMMENTS: The files were scattered throughout numerous folders and locations. 84. 85. 86. YES a. YES b. N/A —N/A a. NO b. N/A "YES YES YES "YES YES a? YES b. N/A N/A a. NO b. N/A YES NO NO~ "no" NO YES 0007 YES 12/31/05 N/A YES YES a. YES b. N/A N/A a. NO b. N/A YES YES NO YES NO N/A NO YES VIEW (3 IUP FILE REVIEWS) 2. Townsends, Inc; 0008 ~ YES ~ 12/31/05 N/A ~ YES 3. Acme-McCrary 0005 " |p YES | = 12/31/05 |P N/A |p YES ir None of the files contained the original permit review letter from the Division. __________________ ____________________YES During the Most Recent Semi-Annual Period, Did the POTW Identify YES Was the POTW Notified by SIU (Within 24 Hours)*of All Self- a. YES . b. YES I I [ Mr. Green was unable to locate the daily flow sampling conducted by Gold Kist, Inc. from 2004 - present. SIU self-monitoring violations are not kept on record at either Town Hall or the WWTP. The SIUs, however, do notify the WWTP operators of any violations. Typicatly, the Division prefers that such violations be faxed so that a hard copy can be kept on file to document a violation's existence. INDUSTRIAL USER PERMIT (I 65. User Name 66. IUP Number 67. Does File Contain Current Permit? 68. Permit Expiration Date 69. Categorical Standard Applied (LE, 40 CFR, Etc.) Or N/A 70. Does File Contain Permit Application Completed Within One Year Prior to Permit Issue Date?_____ _71. Does File Contain an Inspection Completed Within Last Calendar Year? 72. a. Does the File Contain a Slug Control Plan? ~ --------b- K iXio> *s Qne Needed? (See Inspection Form from POTW) 73. 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? 75. During the Most Recent Semi-Annual Period, Did the POTW Complete its Sampling as Required by IUP? _7_6. Does File Contain POTW Sampling Chain-Of-Custodies?_____________ N0 77. During the Most Recent Semi-Annual Period, Did the SIU Complete its Sampling as Required by IUP? 78. Does Sampling Indicate Flow or Production? 79. r ■ ——------------------------- All Non-Compliance from Both POTW and SIU Sampling? 80. a.T" 7TTT———————x ----------------- Monitoring Violations? b. Did Industry Resample Within 30 Days? 81. Was the SIU Promptly Notified of Any Violations (Per ERP)? 82. During the Most Recent Semi-Annual Period, Was the SIU in SNC? f 83. During the Most Recent Semi-Annual Period, Was Enforcement Taken f as Specified in the POTWs ERP? Does the File Contain Penalty Assessment Notices? Does The File Contain Proof Of Penalty Collection? a. Does the File Contain Any Current Enforcement Orders? b. Is SIU in Compliance with Order? 87. Did the POTW Representative Have Difficulty in Obtaining Any of This Requested Information For You? any of its flow violations even t been in SNC for at least 3 straight semi- Page 7 Gold Kist, Inc. was not a^^M annual periods from 2004 - 2005. Pretreatment Audit Report Revised: 10/27/00 It IS possible that Acme-McCrary might be in SNC for the second half of 2005 for violations related to the red dye incident. No permit modification for the name change of Acme-McCrary, formerly Phantom-Glendale, was sent to Division staff for approval poor to issuance. The latest permit modification that is on file with the Division occurred on 6/06/2001 when the SIU changed its name to Phantom-Glendale. While the SIU made a request for an ownership change to Acme-McCrary on 2/05/2004, no formal modification was ever submitted for approval. Such approval is mandatory. Since 2002, Townsends, Inc. has been allowed to discharge at a flow rate of 0.650 MGD. The permit, however, limits the flow at 0.625 MGD and no modification was ever approved by the Division. All permit modifications must be submitted and approved by Division staff. Townsends, Inc. has violated the 0.625 MGD limit numerous times but was never issued a violation letter (unless the flow was greater than 0.650 MGD). The Division does not deem it necessary to enforce the previous flow violations against Townsends, Inc. ram. The files, however, are improved, efficient filing system. Satisfactory Unsatisfactory | |Marginal Audit COMPLETED BY: Christopher Wu Date: 10/19/2005 Deborah Gore Date: 10/19/2005 xMain Program Permit Number MM/DD/YY Inspec.Type Inspector Fac.Type I N I C , 0 , 0 I 2 6 ; 4 I 4 1 ;LNJ Page 8 I—S__l (INSP) IJU (FACC) Pretreatment Audit Report Revised: 10/27/00 NOD: NO NOV: YES QNCR: YES POTW Rating: l_IO (TYPI) 10 / 19 / 05 (DTIA) Recommendations: The files need to be kept in better order. The program would benefit greatly from an 1. Industry Inspected: Gold Kist, Inc. 2. Industry Address: 602 S. Chatham Ave. Siler City, NC 3. Type of Industry/Product: Poultry 4. Industry Contact: Fred Thomen Phone: ( ) ext: 5. Title: Wastewater manager Fax: ( ) ext: Does the POTW Use the Division Model Inspection Form or Equivalent? YES INDUSTRY INSPECTION PCS CODING: Trans. Code Requirements: All permit modifications must be submitted to the Division for approval prior to implementation. The Long Term Monitoring Plan needs to be updated. There are some discrepancies in detection limits and 4 of the listed SIUs are no longer there. For the SIU daily flow monitoring data, violations should be flagged or highlighted, and the POTW must judge compliance with the daily flow limit for those SIUs with daily flow monitoring requirements. . Audit SUMMARY AND COMxME, Audit Comments: Mr. Green is quite knowledgable of the industries in Siler City and of the pretreatment progi extremely disorganized and such poor record keeping was problematic during the audit. The approval letters for the Sewer Use Ordinance and industrial Waste Survey were missing. The missing SUO letter however, is excused due to the fact that the Division pretreatment unit does not have a copy either. Acme-McCrary has reduced production throughout 2005 and will very likely move to Asheboro, NC by year's end. 1 6. B. E. North Carolina Prctreatment Audit Form Page 9 Exit Interview; Yes Plant Tour: Yes C. Pretreatment Tour Yes D. Sampling Review: Yes Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly? Comments: A. Initial Interview: Yes Industrial Inspection Comments: All facets of the inspection were conducted thoroughly and according to the Division Model Inspection form. Mr. Curtis Brown, ORC of the wastewater facility, and Mr. Green both conducted the inspection. Gold Kist, Inc. slaughters and prepares approximately 135,000 chickens per day. The industry has a permitted flow of 650,000 GPD and is often in violation of that limit. Currently, the industry is considering the construction of an equalization basin that will allow a controlled discharge of wastewater to the POTW. Gold Kist, Inc. is also considering establishing a water reuse system that will save water and help clean drains. It was recommended by Division staff that until such construction is complete, Gold Kist, Inc. be put under a consent order that would temporarily increase their permitted flow so they would no longer be in SNC. Michael F. Easley, Governor November 4, 2005 Dear Ms. Stewart: Sincerely An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper copies: SWP-RRO-P&H Chris Wu, DWQ, SWP Subject: Approval for Pump and Haul Carolina Analytical Services Chatham County If you need additional information concerning this matter, please contact Barry Herzberg at (919) 791-4200, or by email to barry.herzberg@ncmail.net. Kenneth Schuster, P. E. Regional Water Quality Supervisor Raleigh Regional Office 1628 Mail Service Center William G. Ross. Jr.. Secretary North Carolina Department of Environment and Natural Resources Phone(919)571-4700 FAX (919) 571-4718 Alan W. Klimek. PE. Director Division of Water Quality Ms. Jennie B. Stewart Carolina Analytical Services, LLC 17570 NC Highway 902 BearCreek, NC 27207-9159 North Carolina Division of Water Quality Internet: h2o.enr.state.nc.us Surface Water Protection Raleigh. NC 27699-1628 In response to your application received by the Division of Water Quality’s Raleigh Regional Office on October 31, 2005, we hereby grant approval for the pumping and hauling of wastewater from the Carolina Analytical Services facility located at 17570 NC Highway 902, Bear Creek, North Carolina. Up to 1,000 gallons annually of laboratory sink wastewater will be pumped from your wastewater storage containers by Shamrock Environmental and hauled to the Shamrock Environmental Wastewater facility for treatment and disposal. This approval shall become voidable unless the agreement between Carolina Analytical Services and Shamrock Environmental Corporation for the acceptance and final treatment of the wastewater is in full force and effect. NorthCurolina____ Naturally Customer Service I-877-623-6748 This pumping and hauling shall be performed in accordance with the description, terms, and conditions specified in this document. Pumped wastewater will be hauled by Shamrock Environmental and disposed of at the Shamrock Environmental wastewater treatment facility located in Greensboro, North Carolina. 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. fOUJCC PERMISSION IS HEREBY GRANTED TO 5. 8. for the operation of a wastewater pump and haul activity which will consist of the pumping and hauling of up to 1,000 gallons annually of industrial wastewater from laboratory sinks to Shamrock Environmental’s wastewater treatment plant for final treatment and disposal, pursuant to the request received on October 31, 2005. This approval shall become voidable unless the agreement between Carolina Analytical Services and Shamrock Environmental for the acceptance and final treatment of the wastewater is in full force and effect, and shall be subject to the following conditions and limitations: In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, Carolina Analytical Services shall cease operation of all pump and haul activities and take such immediate corrective actions as may be required by this Division. a) the date wastewater is removed from the facility, b) the name and permit number of the carrier (hauler) of the wastewater, c) the name of the facility receiving the wastewater, and d) the volume of wastewater removed Carolina Analytical Services Bear Creek, North Carolina Chatham County 2. This approval is effective only with respect to the nature and volume of wastes described in your request of October 31, 2005, and additional information included with your facsimile transmittal dated November 3, 2005. No types of wastes other than those described shall be included in these pump and haul activities. 7. Carolina Analytical Services 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 Carolina Analytical Services, affecting any aspect of the pump and haul process including any significant changes which could affect the type or character of the wastewater. An accurate record of the pump and haul activities must be maintained by Carolina Analytical Services, indicating: 4. 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. 6. Carolina Analytical Services is liable for any damages caused by a spill or failure of the pump and haul operations carried out within their premises. 3. The facilities for the wastewater storage shall be properly operated, maintained and inspected at all times. Storage facilities (tanks, drums, etc.) shall be equipped with drip pans or containment curbs. 1. 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. The records as required in paragraphs 7 and 8 shall be submitted quarterly not later than the 15th of the months of April, July, October and January, to the Surface Water Protection Regional Supervisor, Department of Environment and Natural Resources, 1628 Mail Service Center, Raleigh, NC 27699-1628. Noncompliance Notification: Approval granted this the 4th Day of November, 2005. Page 2 10. Failure to abide by the conditions and limitations contained in this approval may subject Carolina Analytical Services to appropriate enforcement actions available to the Division. 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, tanks, aerators, compressors, etc. Carolina Analytical Services Bear Creek, North Carolina Chatham County 9. 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. 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. 4-, Kenneth Schuster, P. E. Regional Supervisor Surface Water Protection Section Raleigh Regional Office Carolina Analytical Services shall report by telephone to the Raleigh Regional Office, 919-791-4200, 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: 11. The granting of this approval does not preclude Carolina Analytical Services 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. b. Any failure of a pumping station, sewer line, storage tank, containment wall, 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. filtrate 10 8 9sand washer 2 feed pipe 7 airlift pipeline dirty sand 6 Figure 1: Operation of the ASTRASAND Filter Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification RETURN TO TABLE OF CONTENTS ) Anthony J. Freed, Jr. USFilter Davco Products, 1828 Metcalf Ave., Thomasville, GA 31792 ABSTRACT: As effluent discharge permit limits become more stringent, utilities are constantly searching for efficient and cost- effective methods to meet these tighter restrictions. One effluent parameter that is drawing increased scrutiny is nitrogen, usually measured as either nitrate-nitrogen (NO3-N) or total nitrogen (TN). Many different technological strategies have been developed that attempt to address this growing concern. This paper illustrates the refinement of an established wastewater process to accomplish biological nitrogen removal, describing the design, pilot testing and start-up of a full scale, continuous backwash denitrifying filter which utilizes an innovative process control system to regulate the sand circulation rate to maintain an optimum biomass concentration within the media. KEYWORDS: continuous backwash filtration, moving bed biofiltration, denitrification, process control, Enhanced Nutrient Removal, ENR, Biological Nitrogen Removal, BNR DENITRIFICATION: The basic configuration and operation of a CBF can be utilized as a bioreactor to achieve biological denitrification. Within the filter bed anoxic conditions prevail, enabling the denitrifying biomass to grow on the surface of the sand grains and in the pores of the bed. The sand filter media acts to support heterotrophic bacteria which use an external carbon source fitter bed 4 Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification 1 influent —> effluent 5 wash water 3 distributors THE PROCESS: Continuous backwash filters (CBF) have been successfully employed for many years to remove solids from secondary effluent. Figure 1 shows the typical operation of a CBF. Secondary effluent is transported into the filter by means of an Influent Pipe (1). The water enters the Filter Bed (4) through the Feed Pipe (2) and the Distributors (3). The dirty water flows in an upward direction where solid particles are trapped within the sand filter media and purified filtrate (10) is discharged from the top of the filter through the Effluent Pipe (5). The filter bed is continuously moving downward as the water flows up. Sand circulation is accomplished using an airlift to force the dirty media (6) from the bottom of the bed upward through a central airlift pipeline (7). The Sand Washer (9) is positioned around the top of the airlift pipe. The sand particles fall through the washer and the intense scouring action within the airlift wash-box separates most of the contaminating biomass from the sand filter media, discharging dirty water from the top of the filter (8) and depositing washed, clean sand back to the top of the media bed. ch3oh^>* t .1 wetwell screen Discharge backwash waterHeadworks Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification RETURN TO TABLE OF CONTENTS (typically methanol) injected into the influent stream to convert nitrate into nitrogen gas. In this so-called “moving bed biofilter” (MBBF) the sand is continuously washed and the excess biomass produced by this biological reaction is continuously removed. The airlift rate for media washing must be carefully controlled to insure optimum biomass retention, especially under fluctuating hydraulic and nitrate loading conditions. Media washing at too aggressive a rate may reduce the effective bacterial population within the bed and may result in inefficient biological activity and nitrate breakthrough. Secondary Effluent The process was designed to achieve an effluent nitrate nitrogen concentration of less than 10 mg/L and a removal efficiency of greater than 88%, as well as effluent suspended solids concentrations less than 10 mg/L and a COD increase, due to over feeding methanol, no greater than 20 mg/1. THE DESIGN: The discharge permit for the 27.5 MGD De Groote Lucht wastewater treatment plant in the Netherlands was modified to include a total nitrogen limit of 10 mg/L as an annual average. The basic plant treatment scheme consisted of headworks screening and primary clarifiers, followed by two stage aerobic treatment for BOD and ammonia removal. In order to meet the more stringent discharge limits for nitrogen, both an expansion/upgrade of bypass Table 1: Filter Design Data______ Value 15,850 ____6.1 2,580 ____12 32,203 3,500 Figure 2: Tertiary Treatment Scheme the original process and an addition of tertiary post-denitrification treatment were considered. Tertiary filtration was selected over plant process expansion based on a restricted footprint, easier planning and construction as there was no interference with the existing plant process during construction, and the lower capital investment and operating costs. An ASTRASAND MBBF was installed as a post-denitrification stage in order to meet these new effluent limits. As the discharge limits are related to annual average N-levels, it is not necessary to treat the full wet weather flow of 27.5 MGD. As can be seen in the flow schematic in Figure 2, flows exceeding the maximum design flow bypass the filter and are discharged directly to the receiving stream. The required hydraulic capacity of the filters was determined to be 15,850 gpm, with a specific hydraulic load of 6.1 gpm/ff based on an expected denitrification efficiency of 88%. Design data for the filter is outlined in Table 1. The installation consists of six concrete filter units, each with 430 ft2 of filter area. The effective bed height for filtration 12 ft, resulting in a bioreactor volume of about 32,000ft3. Parameter_________ Hydraulic Load (gpm) Dosing Rate (gpm/ft~) Filter Area (ft~)______ Bed Height (ft) Bed Volume ( ft3) NQ.rN Load (Ibs/day) Period Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification ( RETURN TO TABLE OF CONTENTS J 30 76 72 63 64 60 56 52 43 44 40 36 32 23 24 20 16 12 03 04 00 2 2 4 Filtrate NO3-N (mg/L) 2.98 1.80 0.52 0.60 Efficiency (%) 87.1 93.2 97.4 98.0 Filter Control No Control Moderate Enhanced Optimized 40 33 36 34 32 30 23 26 24 22 20 13 16 14 12 10 8 6 4 2 0 During the pilot phase of operation, various automation strategies were tested in order to determine the relative Table 2: Optimizing Backwash Control Strategy Feed NO3-N (mg/L) 23.1 26.5 20.3 30.1 The prevention of nitrate breakthrough during periods of fluctuating hydraulic loads by automated control of the sand recirculation or backwash rate is demonstrated in Figures 3 and 4 showing denitrification performance under two different control strategies. The data in Figure 3 demonstrates the denitrification performance with no automated airlift control, simply allowing the self-regulating mechanism described above to take place. As can be seen, there are significant periods of excessive nitrate breakthrough due to the insufficient volume of biomass within the bed and the resultant inability to respond to fluctuating loads. When the control algorithms are utilized to automatically adjust the backwash rate to maintain an optimal amount of denitrifying biomass, nitrate breakthrough was eliminated, as demonstrated in Figure 4. This indicates the filter’s ability to handle high nitrate loads and easily adapt to volatile swings both hydraulic and nitrate loads. PROCESS CONTROL: Due to the normal differential pressure between the bed headloss and the airlift, an increased hydraulic load automatically results in higher sand circulation (backwash) rates without adjusting the compressed air flow to the airlift. Therefore, the sand circulation rate can be considered to a large extent to be self-regulating. However, in some cases, such as applications with broad variations in process conditions or one with strict effluent limits, it may be useful to amplify this self regulating function by employing automated control of the air flow to the airlift. contribution of denitrifying biomass to the measured headloss in terms of denitrification efficiency. The data in Table 2 demonstrates the results of the effort to optimize the control methodology. Wide fluctuations in hydraulic loads are often experienced at this plant. In order to achieve optimum filter performance and avoid nitrate breakthrough, a process control system has been developed to maintain high biological activity within the filter at varying loading conditions. The key element of this control system is the automatic adjustment of the sand recirculation rate (or backwash rate) based on the desired biomass content in the filter bed. The volume of solids and/or biomass present in the bed is directly related to the headloss over the filter bed. The principle of this strategy is to maintain a sufficient amount of denitrifying biomass, measured principally by headloss, in order to anticipate increasing nitrate loads during the day. By continuous measurement of headloss and other important process parameters such as feed flow and water temperature, the compressed air flow to the airlift is regulated by means of calibrated process algorithms within a local PLC. Figure 3: No Backwash Control I -o- rjO3-N Fees NO3-M Filtrate Filtrafron Rate igpmugj 4- : zz=1 Date Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification Q RETURN TO TABLE OF CONTENTS ^ The results show an average nitrate removal efficiency of 95.6% with an average influent NO3-N concentration of 11.1 mg/L. Methanol dosing employs feed forward control based on continuous measurement of influent nitrate concentration and flow. This assures an efficient chemical feed with limited COD increase in the effluent, as indicated by the slight average COD increase shown in Table 3, with the feed COD measured prior to methanol addition. An on-line effluent COD analyzer has also been used for feed back control of methanol addition to avoid over-dosage. The total phosphorus showed a slight decrease in concentration across the filter, mainly due to uptake by the biomass. npyi (mg/L) 38------------------------ 36------------------------ 34 TSE----------------- 32 30 ----U-® — 28---- ------------ 26 -I— -------------■ 22----- 20--------- 18--------- 16------ 12------ 10------ 8------ 6------ 4------- 2------- ( tetMW Filtrate NO3-N (mg/L) 0.43 0.94 0.46 0.43 0.17 0.49 Feed COD (mg/L) 39.0 26.0 30.0 26.0 22.0 28.6 Feed Total-P (mg/L) 2.5 1.5 1.6 1.5 1.3 1.7 Filtrate Total-P (mg/L) 1.9 1.0 1.2 1.2 1.0 1.3 Feed NO3-N (mg/L) 16.42 11.63 9.70 8.70 9.05 11.10 NO3-N Efficiency (%) 97.4 91.9 95.3 95.1 98.1 95.5 8/16 8/17 8/18 8/19 8/20 Average COD mg/L +5.0 -2.0 + 1.0 -1.0 -1.0 +0.4 Filtration Rate (gpm/ft2) ----------176 ----------L 72 r 68 1 64 60 56 i- 52 1 48 44 i 40 i- 36 + 32 1 28 :■ 24 1 20 :• 16 :■ 12 1 08 1 04 00 PERFORMANCE DATA: The full scale installation was completed in February 1999 and started up biologically in April 1999. Full denitrification was established in about four weeks. Table 3 shows results of a representative period in August 1999. Over the next three years of operation, performance data was continually collected and is summarized in Table 4. Given that the plant is required to meet a 10 mg/L total nitrogen effluent limit on an annual average basis, with the average filtrate NO3-N concentration of 2.5 mg/L and average nitrate removal efficiencies of 86%, the data recorded between 2000-2002 clearly indicates that the filter was successful in achieving this goal. Efficient methanol feed was also demonstrated, as indicated by the net negative change in COD concentration across the filter. Allowing for an average 10% consumption of methanol to remove the residual dissolved oxygen carried over from the secondary­ treatment process, the average specific methanol consumption of 3.3 mg CHjOH/mg N removed is well within the expected range and demonstrates an efficient and effective organic carbon utilization by the denitrifying biomass contained within the filter bed. This is very important as the chemical cost for methanol is one of the single biggest expenditures in the operation of a denitrification filter. E=l==--------------- Figure 4: With Backwash Control | -a-11034/ Feea -e- M03-N Filtrate Filtration Rate igprrulgj Table 3: Results of Full Scale Installation (24 hour flow proportional composite samples) Filtrate COD (mg/L) 44,0 24.0 31.0 25.0 21,0 29.0 I 1 Period Enhanced Nutrient Removal Using a Continuous Backwash Filter for Secondary Effluent Denitrification RETURN TO TABLE OF CONTENTS~) Although data was not presented in this study, recent work has demonstrated that simultaneous nitrogen and phosphorus removal, through the addition of metal salt solutions, can be accomplished using this technology, achieving effluent phosphorus levels below 0.3 mg/L while maintaining filtrate total nitrogen level well below 3 mg/L. SUMMARY & CONCLUSIONS: Continuous Backwash Filtration (CBF) is a well established, effective and easy to operate tertiary solids removal process that has been successfully used for many years throughout the world. With the growing pressure to reduce nutrient discharges into many watersheds in the US, CBF has been taken to the next step and adapted to be an efficient nitrogen removal device as well. Utilizing the filter sand bed as an anoxic bioreactor and controlling the retention of the denitrifying biomass through the automation of the airlift, a conventional CBF becomes a Moving Bed Biofilter with exceptional capabilities to fulfill even the strictest of effluent nitrogen discharge limits. Feed NO?-N (mg/L) 17.9 19.7 16.2 17.9 NO3-N Efficiency (%) 87.1 87.5 83.9 86.2 Feed COD (mg/L) 37.2 37.0 41.0 38.4 Filtrate COD (mg/L) 33.5 36.5 32.3 34.1 Filtrate NOj-N (mg/L) 2.3 2.5 2,6 2.5 2000 2001 2002 Average _COD mg/L -3.7 -0.5 -8.7 -4.3 CH3OH Consumed (mg/mg N) 3.2 2.9 3.8 3.3 Table 4: Long Term Performance Data Feed Flow (MOD) 16.6 15.3 15.4 15.8 ©00111/30/2005 08:58 FAX 910 29i RETENTION PONDS To: SHI -Fax Number: V\ JFrom: Notes: P.O.&ox 15650 • Wilmington.NC 23403 • 910.313.6830 • 333.791.3600 • Fax 910.313.6370 www.retentionponds.com Retention Pond Services, Inc. Specializing In all phases of Aquatic and Wetland Maintenance pt pe •FAX COVER Number of Pages (including cover sheet) : y d Q 2005 sUtyvi, - O5T DATE PRICE AMOUNT A \ v4 Vo IU d^yfe cf 's&iaswi 0> m C3» / Ocz, CM CMr- O'»=7 s o _y^£^0 CHARGE V^SVa- -Wxeev SCRfPTION: ' 1 I MATERIALS & LABOR -IO Gm_ u- X<U. ojmo O 1 O o cOz S oLO c*^exj<>AVJVii’FV_^ Qj-^O r<sCL, 854-2671 \\ - li. sIO co KOro i fe g DES a ------Hw ai -----z S<<\ %SM^fyVe v<k ^V*VkJK_ ______ I TG<AL Signature Signature spy gija'?r,te*d ‘o'36 as speafted-AH wwk to he completed in a workmanlike manner according to standard practices hXm» fnfa ^waMon ’rom above specifications involving extra costs will be exeorted only upon written orders and S cS C^nocawfire fl5ttrr*ate M agreements contingent upon strikes, accidents or delays beyond ourcontrol, owner to carry fire, tornado and ottier necessary insurance. ACCEPTANCE OF PROPOSAL - The above prices, specifications, and conations are satisfacloiy and are hereby accepted. You are authorized to do the above work as specified. Payment will be made as outlined above. DATE OF ACCEPTANCE: y bft i tA^rV^AbVe,^ y s ZSZSZSZES5 rill W Ty^r CrR.Qjpx.Ss^ ; ke-fi'aia-l M-T~ VoR V ^6*. \ »sc.. a ‘ EMERGENCY <-voqX. / QrO SEWER & DRAIN SERVICE P.O. BOX 36501 ~ * GREENSBORO, N.C. 27416 Submitted to ^MoacSL,^^^Jo^loTation <KjCx\XXy\«\—G A Date of Plans --- ; C\-Vm CASHV- QUANTITY & HOURS “ ® 003RETENTION PONDS11/30/2005 09:03 FAX 910 AMATERIAL MANIFEST Page D US EPAID NO. Phone No, Contact HM Type a. I b. c. b. Q. Mo. / Day / Yr. Unit No.NCD986232221 i Signature NCD986232221 Saw; Name TRANSPORTER INFORMATION environmental and industrial services EMERGENCY PHONE NO. ( 800 ) 434 > 7750 Containers Qty. I COPY 2 - Return tn (Vnpratnr 6EB-1 2SSZIS89EE ■-775Q -7752 I UN/NA ■| ID No. ]Unit Wt J V. Shipment Date ’escribed materials were ncelvea Signature thereby < trom the generator site I no' we. Total Quantity Phone (336) 434-7750 Hazard H Class or Div, mt I Packing ____[ Group U| /V'Ig J ii i mi Manifest Document No. QC | of ERG No. hl^/1 jl ADDITIONAL INFORMATION " "j ’ mix I •"? ORIGINAL - Facility Retain 2H-d ZO/ZOd I Signature g FACILITY INFORMATION I hereby acknowledge except for anytfbcnpt Facility A & D ENVIRONMENTAL AND INDUSTRIAL SERVICES Address 2718 UWHARRIE ROAD ARCHDALE. NC 27263 Facility or” EPA tO No Phone (336)434^7750 Contact ~ eric McManus DESCRIPTION OF MATERIALS USDOT Proper Shipping Name (Complete All Items fbr Hazardous Materials) /\)or'0 - i Iri ptea mX; J__ iiSSiSW Transporter^^^*""*** A &DEN~---- ---------- Address 2718 UWHARR1E ROAD ARCHDALE. NC 27263 Transporter or EPA ID No. Environmental and Industrial Services, Inc. \ POST OFFICE BOX 484. TEL (336) 431 HIGH POINT, NC 27261 FAX (336) 43f GENERATOR INFORMATION H : Mailing Address ““ GENERATOR’S CERTIFICATION! Printed/Typed Name j«gn«tur»---------------------1-------- ----------------------------------------------------------- I. ifld|o:|(| 90-ZZ-AON COM " yVXAC Street Address j tr''| C<ly n’G ; i hereby acknowledge receipt o/ t/i» afiove-dwer/bec/^ma/e.'/a/s ro/^nspe from the generator site listed above. *_ M-%v_ acknowledge hat the abovetdes generator site and were'trans ported to the facility listed below. //-/Z-^J Delivery Date l "sag ece/pr of the materials covered by Ms manifest icy noted below. ;C^ ^^■^Dis.crtbiiricfai ARoutlrMXodpg /^indnnq^Athdds COPY 3 . TMnrnArtnr Dfttnin mflV 4 3801$ Sdn 3Hi-“«Jd December 16, 2005 Subject: Dear Mr. Brower: Mr. Joel Brower Town Manager Town of Siler City P.O. Box 769 Siler City, NC 27344 Raleigh, NC 27699-1617 Raleigh, NC 27609 An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper • The updated Long Term Monitoring Plan was received by Division staff. A review letter has been written and you should receive it soon. Phone(919)791-4200 FAX (919)571-4718 Alan W. Klimek, P.E. Director Division of Water Quality NC DWQ/PERCS Unit 1617 Mail Service Center Internet: h2o.enr.state.nc.us/Pretreat/index.html 3800 Barrett Drive o > I o' Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Response to Mr. Terry Green’s NOV Response Program: Town of Siler City Chatham County NPDES Number NC0026441 ♦ Gold Kist has consistently violated their flow limit during the past 3 semi-annual monitoring periods. Although, EPA does not require significant non-compliance judgment to made be for flow, the Division believes that allowing Gold Kist to violate their flow limit is poor implementation of the Pretreatment Program. Therefore, the Town must either: 1) modify the Gold Kist permit to give them a flow limit with which they can comply, or 2) enter into a Consent Agreement with Gold Kist with a timeline for implementing water conservation or some other form of flow control. Please submit the permit modification or copy of the Consent Agreement to the Division by February 1, 2006. Failure to take action may prompt escalated enforcement action by the Division. ♦ The Town of Siler City was found to be in violation for failure to submit Industrial User Permit (IUP) modifications to the Division for approval. Mr. Green provided documentation, a signed return receipt, showing that the modification increasing Townsend’s flow limit was submitted as required. It appears that the paper work was, regretfully, lost within the Division. Unfortunately, the Town must be included on the next EPA Quarterly Noncompliance Report for failing to submit the name change modification made to Acme-McCrary IUP (formerly Phantom-Glendale). NorthCarolina -------------Jvaturally Customer Service 1 -877-623-6748 On October 22, 2005 the Division of Water Quality issued the Town of Siler City a Notice of Violation for failing to adequately maintain its pretreatment program. On November 30, 2005 Mr. Terry Green, pretreatment coordinator for the town, wrote a requested response to the NOV that was received by Division staff on December 14, 2005. Several more comments must be made. Sincerely, Cc: Deborah Gore, DWQ - PERCS Unit Christopher Wu - RRO Mr. Terry Green, Town of Siler City Central Files ♦ The Division understands that sometimes paperwork goes missing, (see #3 above), and is happy to recognize Mr. Green’s efforts to improve his filing system. It is expected that these improvements will make for a smoother inspection next year. Mr. Joel Brower Page 2 of 2 10/21/2005 Christopher Wu Environmental Specialist If you have any questions or comments, please contact Christopher Wu at (919) 791-4260 [or email: chris.wu@ncmail.net] or Deborah Gore at (919) 733-5083 ext. 593 [or email: deborah. gore@ncmail .net].