NC0026441_Historical information_20131025

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October 25, 2013
Submitted via First Class Mail and E-mail
Dear Mr. McKay:
p. o. BOX 769
31 1 N. SECOND AVE.
©mint nf S’ilrr Ctty
SILER CITY, NORTH CAROLINA 27344-0769
On the basis of our review of the transmittal letter, the Draft Permit, and preliminary review of the
supplemental information provided, it is clear to the Town that you and the Division have considered a
significant amount of information in developing the proposed renewal that we have had limited
opportunity to review. Because of the significance of the changes you have proposed in this Draft
Renewal as compared to our current permit, we believe it is appropriate to delay issuance of this
permit until we have an opportunity to more completely review the basis the agency used for
proposing these changes and to work with DWR to resolve concerns we have about some of these
proposed changes. We believe that addressing these concerns prior to issuance of the renewal is the
most effective way to complete this permit renewal process. Because the Town is committed to
continuing its consistent compliance with the NPDES Permit, it is essential that we understand the basis
Mr. Jim McKay
Complex NPDES Permitting
North Carolina Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27604
Subject: Town of Siler City’s Comments
Draft Renewal NPDES Permit
Town of Siler City WWTP
NPDES Permit Number, NC0026441
V'
The Town of Siler City appreciates the opportunity to comment on the subject renewal NPDES Permit for
our Wastewater Treatment Plant. In accordance with your letter transmitting the Draft, the Town is
submitting these comments within 30 days following our receipt of the Draft Permit. We also want to
thank you for the supplemental information that you have provided via e-mails on October 17Ih, 18lh and
21s1. This additional information was provided in response to a request submitted to you by our
consultant, McGill Associates, on behalf of the Town.
phone. [phone]
FAX: [phone]
z
Page /, Paragraph 2, Transmittal Leiter: Holding nutrient loads constant for new or expanded
discharges. The Town has no current plans to expand the WWTP. While this point is noted in relation to
what may happen with future pennit actions, it is not a factor for this renewal.
In preparation for further discussion with you and the Division, I am providing comments for your
consideration. The summary comments below address important issues reflected in the transmittal letter,
including the letter’s description of proposed permit revisions:
Page J, Paragraph 2, Transmittal Lett (^Nutrient Re opener Clausetrlggered by connection of "a new
nutrient discharging industry ” allowing the~dgency to modifv the permit and add new limits. The Town’s
WWTP capacity is 4.0 MGD and is permitted for this flow. Our average discharge flow is currently
approximately 1.5 MGD. The term “a new nutrient discharging industry” is nebulous. Virtually any new'
discharger of wastewater to our system will contain some level of nutrients. Commercial and residential
wastewater can be expected to contain a certain “standard” level of nutrient content (TN and TP) and this
reopener would not apply to such additions. Even if such a reopener is appropriate (and we would like to
discuss that issue), more specific definition of how the reopener would be triggered is needed.
Page 1, Paragraph 2, Transmittal Letter: Concerns related to excess nutrients in Loves Creek and the
Rocky River. The Town acknowledges that monitoring and evaluation of these waters have indicated
increased growth of attached and suspended algae. However, data available shows that nutrient
contributions from the entire watershed are resulting in these conditions. Excessive aquatic vegetative
growth is occurring above and below the treatment system discharge. The Town’s WWTP is one source
of nutrients in the watershed, but there are many others. There doesn’t appear to be any definitive
technical conclusion about how nutrient loading shouldbe addressed at this point.
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of these proposed changes, are clear on the approach the agency will use to regulate these conditions, and
that these conditions are appropriate for our facility.
17^'^^
Page 1, Paragraph 3, Transmittal Letter: Compliance inspection issues. The Town would like to offer
some general comments on the four issues the letter raises:
1) Standby power capacity. DWR’s inspections have noted that the current backup generator
cannot run all components of the facility in the event of a power outage. The system in place
was permitted by the agency al the time it was built/installed and is consistent with that
authorization to construct. As a result, the current standby power capability is not a permit
compliance issue. The Town acknowledges that upgrade of the generator system would be a
desired action, however sewer service revenue (as the Division’s Fact Sheet for the draft
renewal notes) has dropped dramatically. The Town has a capital improvements plan and
will continue to pursue improvements as resources allow. We would like to clarify that this
issue isn’t a compliance problem under the Town’s permit and existing agency approvals.
2) “Lock-out” of basins 4 A and B. The Town is well aware of its decision to remove these
basins from the treatment process. The action taken was to protect the treatment process and,
avoid any issues with the management of flow within the plant. The remaining operational
treatment system components are capable of providing the necessary treatment function
properly at the plant’s design capacity. Repair of the basin is a needed improvement, but not ; (
Page 2, Second Paragraph. Item 2, Transmittal Leiter, Proposed Permi! Revision for ihe Supplement lo
Cover Sheet, updated equipment description. The Town would like to review with you the changes
proposed to the equipment list to make sure the list properly reflects the treatment train at the plant.
Page 2, Second Paragraph, Item 3 b, Transmittal Letter, Proposed Permit Revision, addition o f Cadmium
monitoring and limit. The Town has reviewed the supplemental information you provided on your
Reasonable Potential Analysis (RPA) concerning Cadmium. You noted that the dataset you used was not
collected under the NPDES monitoring requirements. The data came from the Town’s Pretreatment
Program Long Term Monitoring Plan (LTMP). The tabular presentation of the RPA you provided notes
that the data available is “a limited data set.” The Town is concerned that the Division is proceeding
toward establishing a limit without sufficient data to confirm the need for a limit. The Town has no
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essential to the current plant’s treatment ability. Repair is a capital improvement objective,
but as noted in 1) above tlie Town has to be judicious in the use of its available resources.
This too is not a compliance issue under the permit.
3) Excessive I&I. Your letter refers to a specific three day period in June of this year. It is well
know that 2013, particularly in the first half of the year, has been a high rainfall year in NC.
It would not be difficult to look at virtually any municipal sewage collection systems in NC
within a specific few days in 2013 to find a significant increase in flow due to high
rainfall/stream flows. Standard I&I evaluations look at plant flows and rainfall conditions
over long periods to determine the relative role of infiltration and inflow to the collection
system to characterize it as “excessive” or “normal.” The Town operates under an agency
issued system-wide collection system permit. We are doing our best to comply with the
collection system pennit requirements, including inspections, improvements, and the
development and implementation of a capital improvements plan for the system. I&I is an
important consideration for the Town and we certainly are working to eliminate non­
wastewater flows to our system. The determination that I&I is “severe” or “normal” has to be
made on the basis of a more comprehensive evaluation. References to the benefits of I&I
reduction by the agency are certainly valid, but the Town is certainly not ignoring this
important system management responsibility.
4) Process changes to reduce TN levels in the effluent. As your letter notes and as addressed in
the supplemental information you provided, the Town doesn't have a TN limit in its current
permit and a limit is not being proposed for this renewal. We acknowledge that the reduction
of nutrients in the Loves Crcck/Rocky River watershed is an important objective. As noted in
my comments above relative to the proposed “reopener” on nutrients, the Town’s discharge is
one source of nutrients in the watershed. The level of effort and cost associated with
significant process changes to our facility which could result in biological nutrient reduction
is a significant undertaking. While reductions are desirable, there are important regulatory
evaluations concerning the appropriate distribution of nutrient reduction goals by the several
categories of sources in the watershed. As noted, the Town will certainly undertake
improvements of our waste water collection/treatment system as resources allow, based on
priority. Achieving treatment results beyond that required under the permit is always
considered a positive.
J
Sincerely,
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information indicating that there are specific sources of Cadmium in our collection system. Before taking
the step of requiring an effluent limit, we believe it is prudent and reasonable to collect significantly more
data on which to base a limits decision.
Bryan Thompson
Town Manager
1
Page 2, Second Paragraph, Item 7, Transmittal Letter, Proposed Permit Revision, Nutrient Reopener
Clause. We addressed this issue in our comments on Paragraph 2 of Page 1 above. I want to reiterate
that we see this proposed condition as too "open-ended” and not specific enough to determine what would . .
trigger the application of this clause. k i
Page 2, Second Paragraph. Item 8, Transmittal Letter, Proposed Permit Revision, Mercury Minimization
Plan (MMP). The Town would like to discuss this with the Division to clarify this requirement and to
more completely understand its application under the State’s Mercury TMDL.
----------------~~
Part 1 A. (6), Pollutant Scan, Draft Permit: Effluent Pollutant Scan. This condition requires the
collection and analysis of a pollutant scan sample in 2014, 2015 and 2016. The permit is drafted to expire
October 31, 2016, and the renewal application must be submitted no later than 180 days prior to
expiration. This doesn’t give the Town much timing flexibility in securing the results of the 2016 sample
before the renewal application. Additionally, this condition requires the pollutant scan to be collected in
conjunction with a toxicity test and that each of the annual pollutant scan samples must be taken in a
different quarter. The Town would like to discuss how best to provide the necessary samples and to be
able to review and submit that data as part of the renewal package. ■ T?
Again, I would like to express the Town’s appreciation for the opportunity to review the Draft and to
provide comments prior to the agency’s issuance decision. We look forward to being able to further
discuss our comments and to address those prior to renewal issuance. Please contact me with any
questions you may have and to schedule a follow-up meeting to go over the issues we have raised.
Romanski, Autumn
Autumn,
Dear Mr. McKay,
Best,
1
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Bryan Thompson [mailto:[e-mail]]
Sent: Friday, October 25, 2013 11:19 AM
To: Mckay, James
Cc: [e-mail]; Terry Green; Siler City Waste Water; [e-mail]
Subject: Town of Siler City's Comments, Draft Renewal NPDES Permit Number NC0026441
From:
Sent:
To:
Subject:
Attachments:
If you have any more current data regarding stream concentrations of nutrients, or any other pertinent information,
please bring it too. I have not heard anything from Danny about this meeting, Hopefully he will be able to be there. We
are meeting in the 9'th floor conference room Tuesday at 2:00 PM. I have the room reserved for two hours, hopefully
we will be finished before then, [e-mail]
Mckay, James
Friday, November 01, 2013 4:03 PM
Romanski, Autumn
FW: Town of Siler City's Comments, Draft Renewal NPDES Permit Number NC0026441
Draft Renewal NPDES Permit - Siler City Comments - October 25, 2013.pdf
Jim McKay
Environmental Engineer
NCDWR/ Complex NPDES Permitting Unit
[phone] - Voice/ [phone] - Fax
1617 Mail Service Center, Raleigh, NC 27699-1617
Bryan Thompson
Town Manager
Siler City, NC
[phone] office
[phone] cell
[e-mail]
This is the letter I received from Siler City regarding the draft permit comments. I am hoping that we can work together
Tuesday to answer their concerns.
Please find attached to this message the Town of Siler City's comments respective of the Draft Renewal NPDES
Permit. A hardcopy of the same is being forwarded to you as well. Thank you in advance for your
consideration.
September 25, 2013
Dear Mr. Thompson:
This draft permit has the following changes from your current permit:
An Equal OpportunityXAffirmative Acton Emoloyer
L.
Mr. Byran Thompson
Town Manager
Town of Siler City
P.O. Box 769
Siler City, North Carolina 27344-0769
Enclosed with this letter is a copy of the draft renewal permit for your facility. Please review the draft
carefully to understand the conditions, measurement units, and requirements.
As you know, excess nutrients in Loves Creek and Rocky River are a major concern of both the residents
and land owners in the area, but also DENR. Since your two large poultry processing industries have shut
down operations, the nutrient discharge of the Siler City WWTP has been much reduced. This permit
renewal does not contain any new nutrient limitations or requirements. In the event that you do attract a
new nutrient discharging industry, a Nutrient Reopener Clause has been added to the Draft Permit so that
appropriate limits can be added to the permit. The current Basinwide Planning Documents require that
existing nutrient loads be held for new or expanding dischargers.
Pat McCrory
Governor
John E. Skvarla, III
Secretary
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ Fax: [phone]
Internet:: www.ncwaterquality.org
Subject: Draft Renewal of
Permit No. NC0026441
Siler City WWTP
Chatham County
Class IV WWTP
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Thomas A. Reeder
Director
1. Changed "Division of Water Quality" to "Division of Water Resources" on Permit.
a. Changed Director to Thomas A. Reeder.
2. On Supplement to Cover Sheet, updated the equipment description.
3.
b.
c.
8.
9.
Sincerely,
Page 2 of 2
Concurrent with this notification, the Division is publishing a notice in the newspaper having circulation
in the general Chatham County area, soliciting public comments on this permit draft. Please provide any
comments yon may have regarding this draft to DENR - DWR, NPDES Program no later than 30 days
after receiving this draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft for your
facility, please call me at [phone] or by email at [e-mail].
4.
5.
6.
7.
Jim McKay
Complex NPDES Permitting
If no adverse comments are received from the public or from you, this permit will likely be issued in
November, with an effective date of December 1, 2013, expiring on May 31, 2016.
On Sheet A.(l) EFF
a.
Attachments: NC0026441 Draft Renewal
CC:
Raleigh Regional Office/ Attn: Danny Smith - via email with fact sheet
NPDES File
EPA Region IV with application and fact sheet
Steve Reid - via email
Aquatic Toxicology Attn: Susan Meadows - via email with fact sheet
Monitoring Coalition Program - Steve Kroeger & Carrie Ruhlman - via. email with fact sheet
PERCS Unit - Sarah Morrison - via email with fact sheet
Hobbs, Upchurch & Associates, P.A./ Attn: Mr. Fred Hobbs. - via email - [e-mail]
Mr. John D. Runkle, Attorney at Law - via email
Rocky River Heritage Foundation and Friends of the Rocky River/ Attn.: Mr. Sonny Keisler - via email
sfjones@mindspring:com - via email
'f^NT LIMITATIONS AND MONITORIN^EQUIREMENTS:
Moved pH and Dissolved Oxygen requirements up to the table and deleted their
footnotes.
Added Monthly Monitoring for Cadmium to the permit with new Monthly Average and
Daily Maximum limits, based on statistical analysis of LTMP data. Cadmium had
previously been monitored only on the LTMP.
Copper, Zinc, and chloride data showed reasonable potential to exceed action level
standards; monitoring will remain in the permit with no limits. Monitoring will be
changed to quarterly in accordance with the Division's Permitting Strategy for metals and
toxicants.
Removed old Condition A.(3) regarding Nutrient Optimization Plan as it has been completed.
Renumbered existing Condition A.(3) Chronic Toxicity Permit Limit to A.(5).
Renumbered existing Condition A.(5) Effluent Pollutant Scan to A.(6).
Added a new requirement A.(3) Nutrient Reopener Clause providing for DWR to reopen the
pennit and add nutrient mass limits in the event that Siler City proposes to accept waste from a
nutrient discharging industry.
Added a new requirement A.(4) for a Mercury Minimization Plan (MMP) as required by the
Implementation Plan for Mercury TMDL. The plan must be developed within six months of the
permit effective date. The actual due date will be added to the permit on issuance.
Updated A.(5) Chronic Toxicity language to current version.
10. Updated A.(6) - PPA requirement to three PPAs in specified years in accordance with EPA
requirements.
Permit NC0026441
SUPPLEMENT TO PERMIT COVER SHEET
The Town of Siler City is hereby authorized to:
■
This facility is located at the Siler City WWTP on Wastewater Plant Road near Siler City in Chatham County.
Page 2 of 7
2. Discharge from said wastewater treatment works through Outfall 001 into Loves Creek (see attached map), a
stream classified as C waters within the Cape Fear River Basin.
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any
previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this
facility arises under the permit conditions, requirements, terms, and provisions included herein.
ZonM A & B used as needed)
1. Continue discharging 4.0 MOD of treated process-contact and domestic wastewater from a treatment
facility consisting of
• Automatic and manual bar screens
• Grit collection unit
• Influent pump station
• Influent Equalization Basin (Zone 2)
• Dual oxidation ditches with surface jet aeration
• Flow Splitter Box
o Alum feed station
o Lime feed station
• Dual secondary clarifiers
• - Dual Aerobic digestefs.——
Return Activated'Sllidge
Sludge Transfer Station
Dissolved Air Flotation Unit
Dissolved Air Floatation Sludge Thickener Basin
InfluenWt’^rudge Storage Basins (Zone 3 A &
Four (4) tertiary filters
Filter Backwash Basin
Gaseous O^orine Disinfection- X,
Chlorine contact chamber
Gaseous Sulfur dioxide Dechlorination
Step-Aeration
Permit NC0026441'
DRAFT PERMIT
Town of Siler City
is hereby authorized to discharge wastewater from a facility located at the
This permit shall become effective .
This permit and authorization to discharge shall expire at midnight October 31, 2016.
Signed this day.
DRAFT
Page 1 of 7
Town of Siler City WWTP
370 Wastewater Plant Road
Chatham County
to receiving waters designated as Loves Creek within the Cape Fear River Basin, in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV
hereof.
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended, the
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
Thomas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
Permit NC0026441
Parti
A. (1)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
PARAMETERS
Flow 4.0 MGD Continuous Recording
5.0 mg/L 7.5 mg/L Daily Composite
10.0 mg/L 15.0 mg/L Daily Composite
30.0 mg/L 45.0 mg/L Daily Composite
1.0 mg/L 3.0 mg/L Daily Composite Effluent
6.0 mg/L2.0 mg/L Daily Composite Effluent
200/ 100 ml 400/ 100 ml Daily Grab Effluent
17pg/L
Weekly Composite Effluent
0.5 mg/L (quarterly average)Weekly Composite Effluent
2.0 mg/L (quarterly average)Weekly Composite Effluent
2.1 pg/ L 15.5 pg/L
Effluent
Monitor and Report Effluent
3.
b. Effluent shall contain no floating solids or foam visible in other than trace amounts.
Page 3 of 7
Weekly
Average
Daily
Maximum
Sample
Type
1.
2.
4.
5.
6.
7.
Daily average > 6.0 mg/L
> 6.0 and < 9.0 standard units
Weekly
Weekly
Daily
Daily
Daily
Daily
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Footnote 7
Grab
Grab
Grab
Grab
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Sample
Location 1
Influent or
Effluent
Influent and
Effluent
Influent and
Effluent
Influent and
Effluent
MONITORING REQUIREMENTS
Measurement
Frequency
a. During the period beginning with the effective date and lasting until expiration, the Pennittee is authorized to discharge
treated wastewater through Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
_______EFFLUENT LIMITS
Monthly
Average
Total Copper
TotaFZiac I
^Chloride/
Ghrpnic Toxicity 5
Effluent Pollutant Scan
Footnotes:
Instream monitoring shall be performed in accordance with A. (2).
The monthly average effluent BODS and Total Suspended Solids concentrations shall not exceed 15 % of the respective
influent value (i.e., 85% removal is required).
The Permittee shall report all effluent TRC values reported by a NC-certified laboratory [including field-certified].
Effluent values below 50 pg/L will be treated as zero for compliance purposes.
Compliance with the Total Phosphorus limits shall be based on a calendar-quarter average of weekly samples.
Chronic Toxicity (Ceriodaphnia) at 90 %; quarterly during March, June, September, December [see A. (5)].
Sample Quarterly in conjunction with Chronic Toxicity Test.
The permittee shall perform three Effluent Pollutant Scans during the term of this permit [see A.(6)].
Monthly
Quarterly6
Quarterly6
Quarterly6
Quarterly
Footnote 7
BOD, 5 day, 20°C 2
(April 1 thru October 31)______
BOD, 5 day, 20°C 2
(November 1 thru March 31)
Total Suspended Solids2
NH3 as N
(April 1 thru October 31)______
NH3 as N
(November 1 thru March 31)
Fecal Coliform
(geometric mean)____________
Total Residual Chlorine (TRC)3
Temperature (°C)
Dissolved Oxygen
PH
Total Nitrogen
(NO2 + NO3 + TK.N)
NO3-N + NO2-N (mg/L)
TKN (mg/L)_______________
Total Phosphorus 4
(April 1 thru September 30)
Total Phosphorus4
(OctofegiU through Inarch 31)
T^tai Cadrpi^m
Permit NC0026441 ■
A. (2)INSTREAM MONITORING REQUIREMENTS
Location 1Sample TypeParameter
Dissolved Oxygen Grab LCU, LCD, RRU, RRD
Temperature Grab LCU, LCD. RRU, RRD
1.
I
A.(3)NUTRIENT REOPENER
A.(4)MERCURY MINIMIZATION PLAN (MMP)
I
Page 4 of 7
Grab
Grab
Grab
LCU, LCD, RRU. RRD
LCU, LCD, RRU, RRD
LCU, LCD, RRU, RRD
Total Phosphorus
TKN
no3-n + no2-n
7
In the event that Permittee proposes to accept future waste from a nutrient discharging industry (such as a poultry
processing plant), the Permittee shall notify the NPDES Complex Permitting Unit of the Division at 1617 Mail
Service Center, Raleigh, NC 27699 and the Raleigh Regional Office at 3800 Barrett Drive, Raleigh, NC 27609 at
least 180 days prior to the start of the proposed discharge. The notification shall contain information regarding the
proposed discharge flow, composition and compatibility with the Siler City WWTP.
Footnotes:
LCU - Loves Creek, upstream of the discharge; LCD - Loves Creek, downstream of the discharge and above the
confluence with the Rocky River; RRU - Rocky River, upstream of the confluence with Loves Creek; RRD - Rocky
River, downstream of the confluence with Loves Creek.
2. All monitoring is required to be performed at the above-mentioned monitoring locations. Instream Monitoring
may be performed by the Upper Cape Fear River Basin Association as outlined in the Memorandum of Agreement
(MOA) between the association and the permittee. If so, the data is to be collected and submitted to DWR in
accordance to the terms of the MOA. Should membership in this association terminate for any reason, the permittee
shall immediately notify the Division’s NPDES Unit in writing and resume responsibility to monitor and report the x
above parameters as specified in this permit. , \ \
^>D 7
1 V A
A
' V
//
I /
Pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found in Title 15A of the North
Carolina Administrative Code, Subchapter 2H, specifically, 15ANCAC 2H.0112(b) (1) and 2H.0114(a), and Part
II, Sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to require supplemental
nutrient limits for Total Nitrogen and Total Phosphorus in accordance with the current Basin Plan for the Cape
Fear River Basin. «. t a
\ (J
The permittee shall develop and implement a mercury minimization plan (MMP) during this permit term. The
MMP shall be developed within 180 days of the NPDES Permit Effective Date, and shall be available for
inspection on-site. A sample MMP was developed through a stakeholder review process and has been placed on
the Division website for guidance (http://porta 1.ncdenr.org/web/wq/swp/ps/npdes. under Model Mercury
Minimization Plan). The MMP should place emphasis on identification of mercury contributors and goals for
reduction. Results shall be summarized and submitted with the next permit renewal.
Measurement Frequency “
3/Week (June - September),
1/Week (October-May)
3/Week (June - September),
1/Week (October-May)
Monthly
Monthly
Monthly
\)
Permit NC0026441
Attention:
Page 5 of 7
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the “North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,” Revised December 2010, or subsequent versions or
“North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure” (Revised- December 2010) or
subsequent versions. The tests will be performed during the months of March, June, September and
December. These months signify the first month of each three month toxicity testing quarter assigned to the
facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of “No
Flow” in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the pennittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is required
by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Resources indicate potential impacts to the receiving stream, this permit may be re-opened and modified to include
alternate monitoring requirements or limits.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple-concentration testing shall be performed at a minimum, in each of the two
following months as described in “North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure” (Revised-December 2010) or subsequent versions.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such monitoring
shall be included in the calculation & reporting of the data submitted on the DMR & all AT Form submitted.
North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
A. (5) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)^
The effluent discharge shall at no time exhibit observable inhibifibn of reproduction or significant mortality to
Ceriodaphnia duhia at an effluent concentration of 90%. /
Permit NC002644i’
EFFLUENT POLLUTANT SCAN
Page 6 of 7
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
2-ch loronaphxhalene
4-chlorophenyl phenyl ether
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
1.2- dichlorobenzene
1.3- dichlorobenzene
1.4- dichlorobenzene
3.3- dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2.4- dinitrotoluene
2,6-dinitrotoluene
1,2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclo-pentadiene
Hexachloroethane
lndeno(l,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
Phenanthrene
Pyrene
1.2.4- trichlorobenzene
Ammonia (as N)
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate/Nitrite
Kjeldahl nitrogen
Oil and grease
Phosphorus
Total dissolved solids
Hardness
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury (EPA Method 163IE)
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total phenolic compounds
Volatile organic compounds:
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1.1- dichloroethane
1.2- dichloroethane
Trans-1,2-dichloroethylene
1.1- dichloroethylene
1.2- dichloropropane
1.3- dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1.1.2.2- tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1 -trichloroethane
1.1.2- trichloroethane
Trichloroethylene
Vinyl chloride
Acid-extractable compounds:
P-chloro-m-cresol
2-chlorophenol
2.4- dichlorophenol
2.4- dimethylphenol
4.6- dinitro-o-cresol
2.4- dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophenol
Phenol
2.4.6- trichlorophenol
Base-neutral compounds:
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4 benzofluoranthene
Benzo(ghi)perylene
B enzo(k)fl uoranthene
Bis (2-chloroethoxy) methane
A. (6)
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below. One scan
must be performed in each of the following years: 2014, 2015, and 2016. Analytical methods shall be in accordance
with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters are present in
concentrations greater than applicable standards and criteria. Samples should be collected with one quarterly toxicity
test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year]. Unless
otherwise indicated, metals shall be analyzed as “total recoverable.”
Reporting. Test results shall be reported on DWR Form-A MR-PPA1 (or in a form approved by the Director) by
December 31s1 of each designated sampling year. The report shall be submitted to the following address>N£
DENR / DWR / Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Permit NC0026441
Page 7 of 7
latitude:
North
Facility
Location
not to scale
NPDES Permit No. NC0026441
______Chatham County______
4' j
N- " ‘ '
i,- . - , f ;r; .
i /> .< “’C • w'C i
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' ■ '
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State Crid/Quad: E21 NW/SiJerCity, NC
Permitted Flow: 4 0 MOD
Drainage Barin: Cape Fear River Bai in
SABarin: 03-06-12
HUC: 030300030503
L z -
OutfallOOl
(flow's east) \
i ■ - xr"'.**?11111' - • - a
35’43’45"N
Loncjxrie: 79*25’ 42" W
Recewint; Stream: Lovet Creek
Stream Ch»; C
NC0026441 Siler City WWTP
\ 030300030503HUC:
Summary:
County:
Regional Office:
USGS Topo Quad:
USGS Quad Name:
Siler City WWTP
4.0 MOD
ww'fv
Full LTMP
Active/ Renewal
Chatham County
Raleigh
E21NW
Siler City
7.9
' 0.25
1 °-4
TTt~
! 96.1
The Siler City WWTP is rated at 4.0 MGD. It is an activated sludge secondary treatment system with
tertiary filtration. The plant serves 7,877 people along with commercial and one SIU - Brookwood
Farms, Inc. Siler City has lost most of it's industries over the past few years, loosing two major
chicken processing facilities and one textile facility. The lost industry represented over 1 MGD of
wastewater, and five million dollars per year City Water demand. Loss of industries, and the
population and revenue from them, has severely impaired the Town's finances.
The WWTP discharges into Loves Creek, which is a tributary to Rocky River, which in turn flows
into the Deep River before it joins the Haw River to form the Cape Fear River. Loves Creek and
lower Rocky River have experienced problems with high nutrients, algae. Low Dissolved Oxygen and
Periphyton for many years.
The Siler City WWTP is the only Major WWTP in this part of the Cape Fear basin, but it is not the
only source of nutrients, as Loves Creek is impaired above the discharge as well as below, Rocky
River is also impaired for chlorophyll- a above the confluence with Loves Creek.
The 2012 303(d) final list of Impaired Waters lists Loves Creek as Impaired for Ecological/ biological
Integrity Benthos from the source to Chatham Avenue. Loves Creek is listed as Impaired for Low
Dissolved Oxygen from Chatham Avenue to the Siler City WWTP, and is listed as Impaired for
Ecological/ biological Integrity Benthos from the WWTP to Rocky River. The current Cape Fear
Basin Plan gives potential sources as stormwater (MS4 NPDES) and the WWTP. The basin plan
goes on to state “a stressor study completed in the Loves Creek watershed indicated toxic chemicals
in runoff from Siler City are the main stressors to the benthic community. Streambank erosion,
sedimentation, and excessive algal growth are also stressors. The WWTP was not the main stressor,
and agricultural land uses are also a source. The study noted runoff from animal operations in the
upper watershed might be contributing nutrients and bacteria to the creek.” The basin plan
NCDENR/DWQ
DRAFT FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Facility’ Information
Facility Name:
Permitted Flow MGD):
Facility Class:
Pretreatment Program:
Permit Status:
Stream Characteristics
Receiving Stream:
Sub-basin:
Stream Assessment Unit:
Stream Classification:
303(d) Status:
(Drainage Area (mi2)^
Summer 7Q10 (cfs):
Winter 7Q10 (cfs):
30Q2 (cfs):
i Average Flow (cfs):
I IWC %:
i Loves Creek
’ 03-06-12
' 17-43-IOc __
| C_______________
Listed on Final 2012
303(d) list for
Aquatic life -
Impaired biological
integrity' Benthos.
Data Review:
Table 1: Summary of Monthly Average DMR data - 1/2011-4/2013
Limit 4.0 6-9 17 30 200 >6 0.5 (s)
NPDES Permit Draft Fact Sheet
Page 2
The Siler City WWTP currently has total phosphorus and ammonia limits that are more stringent than
those of many similar facilities statewide.
The facility had one permit limit violation during the review period, which was a failure of a
WET test in March, 2013. The facility had passed the 20 previous quarterly tests, and passed the
two subsequent tests.
Monthly average DMR data was reviewed for the period of January 2011 through April 2013.
That data is summarized below in Table 1. Monthly average flows are at 39% capacity with
maximum monthly average flows at 54% capacity.
The facility is also required to monitor for arsenic, cadmium, chromium, lead, molybdenum,
nickel, mercury and selenium as part of its pretreatment program. RPA of this data showed only
cadmium was detected above the allowable concentration during the 2-yr data review period.
The reported values were 3, 4, and 3 pg/L, compared to the allowable concentration of 2.5 pg/L.
Limits and Monthly Monitoring for cadmium were added to the permit as there was more than
one value above the allowable concentration.
Siler City WWTP
NC002644I
recommends that DWQ continue to monitor the Loves Creek watershed and work with DSWC to
evaluate if BMPs can be implemented to reduce nutrients from animal operations in the watershed.
The 2012 303(d) final list of Impaired Waters lists Rocky River in the Upper Siler City Reservoir to
the dam as Impaired for Chlorophyll a and Low Dissolved Oxygen. From the lower Siler City
Reservoir dam to Varnal Creek Rocky River is listed as Impaired for Low Dissolved Oxygen. Rocky
River is listed as Impaired for Chlorophyll-a behind Woody's Dam. The current Basin Plan states
"The Siler City WWTP, as well as agriculture and residential activities, are potential sources of
nutrients.”
Avg
Max
Min
BOD
(mg/L)
1.2
4,1
0.1
5(s)
10 (w)
TP
(mg/L)
0.072
0.644
0.005
RPA Analysis:
The facility is required to monitor for copper, zinc and chlorides as part of the NPDES permit.
RPAs were performed for each of these parameters. Cu, Zn, and chloride data showed reasonable
potential to exceed action level standards; therefore monitoring will remain in the permit with no
limits, as the facility has passed all but one WET test. The facility will be required to monitor for
these pollutants quarterly instead of twice per month, in accordance with our permitting strategy
for metals and toxicants.
Flow
(MGD)
1.57
2.15
0.157
pH
(SU)
7.4
8.3
6.4
TN
(mg/L)
17
30.2
8.4
TRC
(pg/L)
1.19
3.0
<10
NH3-N
(mg/L)
0.43
1.22
0.04
l(s)
2(w)
TSS
(mg/L)
1.0
3.6
0.1
D.O.
(mg/L)
8.95
10.90
6.90
Fecal
(#/100
mt.)
3.9
25
1
Parameter
Max Max Min
2.23 12.38
6.23
Parameter
Max MinMax
12.53 12.09 4.18
6.66 7.33 6.98 7.42 5.95
88 15 2.5
21.7 1.9
0.174
NPDES Permit Draft Fact Sheet
Page 3
Mercury data did not show reasonable potential to cause an exceedance of water quality
standards. An analysis of mercury data according to the Statewide Mercury TMDL
Siler City WWTP
NC0026441
WET Test Results:
Siler City WWTP has a chronic whole effluent toxicity testing requirement at 90% effluent
concentration. Since March 2008 they have passed 21/22WET tests. In March 2013 there was
one failure, which resulted in an NOV, but no enforcement taken. The facility was required to
test in the following two consecutive months and passed both of those tests, and passed again in
June 2013.
0.61
0.068
0.29
0.103
10.55
8.48
0.12
1.02
0.06
0.56
6.5
9.9
4,78
0.170
1.05
0.410
12.31
7.61
38
49.8
34.3
0.67
1.42
1.41
1.41
3.21
0. 079
7.55
5,25
4.9
0.18
0.67
13.6
0.061
6.53
7.05
0.06
0.84
37.5
1.75
2.61
36.4
0.147
8.07
14
0.2
1.51
9.89
6.39
6.71
2,50
0.6
0.02
0.20
0.42
0.026
0.02
0.02
0.53
0.024
Instream Data Review:
Siler City WWTP is a member of the Upper Cape Fear River Basin Association (UCFRBA). The
UCFRBA performs instream monitoring on the Rocky River at a station 900 feet upstream of the
confluence with Loves Creek, and another station 4 miles downstream. They also monitor Loves
Creek upstream and downstream of the discharge point. Instream data was reviewed for the
period of January 2011 through March 2013. A data summary is provided in tables 2 and 3.
Based on this data, it does appear that both Loves Creek and Rocky River are experiencing
elevated nitrite/nitrate levels, however the levels are greatly reduced from prior levels due to the
closing of two poultry processing facilities. Dissolved oxygen is better downstream than
upstream in both streams
Table 2: Summary of UCFRBA Data from 2011-March 2013 - Loves Creek
Upstream - B5890000
Min
Table 3: Summary of UCFRBA Data from 2011- March 2013 - Rocky River
Upstream - B5950000
Min
2.5
1.7
0.02
0.29
0.02
0.023
1.62
5.84
3
3.3
0.02
0.56
0.02
0.046
Downstream - B5920000
Average
8.58
DO(mg/L)________
pH (su)
FSS (mg/L)_______
Turbidity (NTU)
NH3_N(mg/L)
TKN_N (mg/L)
NO2/NO3_N (mg/L)
TP (mg/L)
Average
6.00
Downstream - B5980000
Average
6.92
DO (mg/L)
pH (su)
TSS (mg/L)_______
Turbidity (NTU)
NH3_N(mg/L)
TKNN (mg/L)
NO2/NO3_N (mg/L)
TP (mg/L)
Average
7.16
6.91
1.
a.
b.
c.
4.
8.
9.
Proposed Schedule for Permit Issuance
NPDES Permit Draft Fact Sheet
Page 4
Correspondence File Review/Compliance Flistory:
As previously stated, there have been no violations of the facility’s permit limits (with the
exception of the above mentioned WET test failure) from January 2011 through June 2013.
Inspection reports indicate that the facility is properly maintained and has made efforts over the
years to better organize their filing systems. Several inspections did note, however, that there is
not enough standby power to operate the entire facility. The generator can only operate the
influent pump station, bar screen, and grit removal processes. The inspector recommends that the
town consider adding generator capacity to avoid a potential discharge of partially treated
wastewater to Loves Creek in the event of a power outage. One NOV was issued for failed WET
test on March 2013, resulted in no penalty.
Draft Permit to Public Notice: September, 2013
Permit Scheduled to Issue: November, 2013
2.
3.
5.
6.
7.
Siler City WWTP
NC0026441
Permit History:
Refer to NC0026441 Attachment 1 Siler City NPDES Permit History
Proposed Changes Incorporated into Permit Renewal
Changed "Division of Water Quality" to "Division of Water Resources" on Permit.
a. Changed Director to Thomas A. Reeder.
On Supplement to Cover Sheet, updated the equipment description.
On Sheet A.(l) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS:
Moved pH and Dissolved Oxygen requirements up to the table and deleted their
footnotes.
Added Monthly Monitoring for Cadmium to the permit with new Monthly
Average and Daily Maximum limits, based on statistical analysis of LTMP data.
Cadmium had previously been monitored only on the LTMP.
Copper, Zinc, and chloride data showed reasonable potential to exceed action
level standards; monitoring will remain in the permit with no limits. Monitoring
will be changed to quarterly in accordance with the Division's Permitting
Strategy for metals and toxicants.
Removed old Condition A.(3) regarding Nutrient Optimization Plan as it has been
completed.
Renumbered existing Condition A.(4) Chronic Toxicity Permit Limit to A.(5).
Renumbered existing Condition A.(5) Effluent Pollutant Scan to A.(6).
Added a new requirement A.(3) Nutrient Reopener Clause providing for DWR to reopen
the permit and add nutrient mass limits in the event that Siler City proposes to accept
waste from a nutrient discharging industry.
Added a new requirement A.(4) for a Mercury Minimization Plan (MMP) as required by
the Implementation Plan for Mercury TMDL. The plan must be developed within six
months of the permit effective date. The actual due date will be added to the permit on
issuance.
Updated A.(5) Chronic Toxicity language to current version.
10. Updated A.(6) - PPA requirement to three PPAs in specified years in accordance with
EPA requirements.
State Contact Information
NPDES Recommendation by:
Signature.Date
Regional Office Comments:
Regional Recommendation by:
Signature-Date
Regional Supervisor:
Signature.Date.
NPDES Permit Draft Fact Sheet
Page 5
If you have any questions on any of the above information or on the attached permit, please
contact Jim McKay at [phone], or by email at [e-mail].
Siler City WWTP
NC002644I
d.
e.
a.
b.
c.
e.
f.
NC0026441 Attachment!
Siler City NPDES Permit History
• The Rocky River and Loves Creek tributary have long been troubled by high nutrients, low DO, poor
benthics and high chlorophyll-a. Based on the 2012 Integrated Report:
a.
b.
c.
d.
Upper Rocky River Reservoir is impaired due to Chlorophyll-a standard violations and Low DO.
Rocky River (from dam at lower reservoir to Vernal Creek) is impaired for low Dissolved Oxygen.
Rocky River behind Woody's Dam is impaired for chlorophyll-a standards violation.
Loves Creek from Source to Chatham Avenue in Siler City is impaired for Benthic macroinvertabrates.
From Chatham Avenue to the Siler City WWTP it is impaired for low DO, and from the WWTP to
Rocky River, it is impaired for Benthic Macroinvertabrates. >
Tick Creek is impaired for Fish Community. yQjA
Bear Creek is impaired for Benthic macroinvertabrates.
• Both Loves Creek and Rocky River were impaired both upstream and downstream of the Siler City WWTP
discharge into Loves Creek, but the WWTP was suspected of causing the high nutrient problems and
impairments.
• Permit renewal application submitted April 25, 2006. A permit renewal draft was prepared and issued for
public review and comments September 12, 2007.
• Due to the many public comments and concerns, a public meeting was held on April 17, 2008. Based on
recommendations of the hearing officers, the division added to the pennit:
Winter total Phosphorus (TP) limits of 2 mg/ L in addition to the existing summer limit of 0.5 mg/ L.
Increased frequency of effluent TN and TP monitoring to weekly from monthly.
Reporting of TN, NO2 and NO3 and TKN effluent concentrations in addition to parameters already
reported.
Instream monitoring on Loves Creek Upstream and Downstream of the discharge. Upstream and
Downstream monitoring on the Rocky River was already in the permit.
Development of a Nutrient Removal Optimization Plan required within one year of the permit effective
date.
• The permit was issued on August 29, 2008.
• The Friends of Rocky River and the Rocky River Heritage Foundation contested the permit.
Administrative Law Judge Beecher R. Gray heard the proceedings during June, 2009. The A.L.J. issued a
decision recommending that the EMC affirm the reissuance of the permit. The EMC affirmed the renewal
of the permit on January 13,2010.
• The permit was issued February 22, 2010 with two changes:
a. The Pennit effective date changed to April 1, 2010.
b. Footnotes on the Effluent Limitations and Monitoring Requirements sheet A.(l) were updated to
include revised TRC thresholds in keeping with Division permitting strategy for Total Residual
Chlorine.
• This permit expired on October 31.2011. A renewal application was received in May, 2011.
• Due to staff constraints and a very heavy workload, renewal efforts were made as time allowed. The
renewal draft is now finished and ready to go out to public notice and draft review. Copies of the draft will
be sent to the Friends of Rocky River, Rocky River Heritage Foundation and the attorney-at-law
representing these groups.