NC0026441_Historical information_20141231

77 T
January 10, 2014
Subject:
Dear Mr. Thompson:
To address the three Action Items:
An Equal Opportunity\Affirmative Action Employer
Mr. Bryan Thompson, Town Manager-
Town of Siler City
P.O. Box 769
Siler City, North Carolina 27344-0769
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.ncwaterqual'rty.orq
Many of your listed concerns regard the Transmittal Letter. The transmittal letter is associated with the
permit, but is not a legal part of the permit. It is used in this case to communicate specific information to
you, but is not enforceable like the terms and conditions in the actual permit document. The discussion
on nutrients in the cover letter is intended to remind you that this is a concern. Our planning section is
working on a Nutrient TMDL for the Rocky River, including Loves Creek. Your last NPDES permit
renewal was contested in court over nutrient concerns. That court case was lost by the Friends of the
Rocky River, but they are still keeping a close eye on the operation of your WWTP. EPA is also pushing
the State NPDES Programs to develop numeric nutrient standards and apply them in permits.
1. Revisit the Reopener Language to better identify what triggers this clause.
Reply: The clause has been revised to better identify (he triggering events. See the revised permit
draft attached.
Response to Draft Review Comments
NPDES Permit NC0026441'
Siler City WWTP
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Thomas A. Reeder
Director
Thank you for your summation of the Town’s concerns regarding the draft renewal of your WWTP
NPDES Permit. I am sorry that I could not attend the meeting arranged for November 5, 2013, due to a
death in my family. I understand that you did meet with my supervisor, Tom Belnick, and staff from the
Raleigh Regional Office to discuss your concerns, and reached agreement on most of them, except for
three remaining Action Items. In this letter I will address the three Action Items.
2.
This draft permit has the following changes from the first draft:
1.
• TN monitoring has been corrected to” Calculated” from “Composite”.
2.
3
Page 2 of 3
The draft permit has been revised based on comments received from Siler City and the interested public. A copy of
the modified draft permit is attached for your review. Please review it carefully to understand the changes and
send any comments or questions to me by January 24,2014.
Recheck Cadmium Data from LTMP to insure that effluent data, not influent data was used.
Reply: The data used was LTMP discharge data that was included on your monthly DMR reports of
effluent. I will grant you an 18 month compliance schedule in order to allow time to collect 12
monthly samples for analysis. If all 12 results are less than 2.1 pg/ L, then you can petition the
NPDES Complex Unit to remove the Cadmium limits from the permit. If any of the 12 monitoring
results are greater than 2.1 pg/ L, the limits will go into effect immediately after the 18 month
compliance schedule expires.
Added new Condition A.(4) NUTRIENT WATER QUALITY MODELING REOPENER in accordance
with the Basinwide Nutrient program.
Added new Condition A (7) ELECTRONIC REPORTING OF DISCHARGE MONITORING
REPORTS in accordance with EPA requirements for electronic DMR reporting. Proposed federal
regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the Environmental Protection Agency (EPA). The Division anticipates that these
regulations will be adopted and is beginning implementation.
On Sheet A.(l) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS:
• Regarding new Monthly Monitoring and Limits for Cadmium, the limits were determined by the
Division’s standardized method for evaluating discharge data and assigning limits. Data used for
this review was from LTMP discharge data that was included on DMRs submitted by the WWTP.
There were three positive data points above the allowable concentration. Only one is required for a
limit to be added. A Compliance Schedule of 18 months is provided. If 12 months of cadmium
data show no values at or above 2.1 pg/ L, the facility can petition the Division to remove cadmium
limits and monitoring from the permit. Cadmium monitoring would still remain in the LTMP.
Otherwise, the Cadmium Limits will go into effect 18 months after the effective date of the permit.
3. Change PPA years to years 2013, 2014, 2015.
Reply: The NPDES Program has several permits which are very delayed for renewal: We have
decided to make this renewal for a full five years. The permit period should be from March 1, 2014 to
February 28, 2019. The PPAs will be required in years 2016, 2017 and 2018, which should give
plenty of time to schedule the three quarterly tests. The permit renewal in 2019 would be for less than
five years in an attempt to return to the basinwide schedule.
http.7/portal.ncdeni,.org/web/wq/admin/bog/ipu/edmi’.
Sincerely,
Page 3 of 3
for information on EPA’s proposed NPDES Electronic Reporting Rule, please visit the following
web site: http://www2.epa.gov/compliance/proposed-npdes-electronic-reporting-rule
Jim McKay
Complex NPDES Permitting
The requirement to begin reporting discharge monitoring data electronically using the NC DWR’s
Electronic Discharge Monitoring Report (eDMR) internet application has been added to your
NPDES permit. [See Special Condition A (7)] For information on eDMR, registering for eDMR
and obtaining an eDMR user account, please visit the following web page:
CC: Raleigh Regional Office, Attn. Danny Smith - via email
NPDES files
C'l/13/2014 15:31 FAX [phone] SILER CITY WASTEWATER PT ©002
Permit Number:
If YES, estimated number offish killed:
Person submitting claim:
Title: it
Pagel
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office
within five (5) days of first knowledge of the bypass with reference to the incident number (the incident number is
only generated when electronic entry of this form is completed, if used).
Owner:
City:
Incident #:
Region:
County:

This form shall be submitted to the appropriate DWQ Regional Office within five days of the first knowledge of the
unanticipated bypass or upset.
Form WWTP-BYPASS/UPSET
Treatment Plant (WWTP) Bypass/Upset Reporting Form 5 Day Report
PARTI
XYes
□Yes
No
XNo
Incident End Dt:
As a represenfat/ve for the nesponsib/e party J certify that the information
contained in this report is true and accurate to.thebest of my knowledge.
□Unknown
□Unknown
(mm-dd-yyyy)
Facility:
Estimated volume of the bypass/upset:
Describe how the volume was determined:
Weather conditions durin^ivpasVuDset event:
WWTP-Bypass/Upset Form October 17, 20'1'1
Was the WWTP compliant with permit requirements?
Were samples taken during bypass?
Incident Start Dt: J Inll4 Time:
mn>dd-yyyy)
> ILjtwSJg
(hh:mm AM/PM)
/Lpx) gallons

-----------------= —— ----------= _ __________________

Did bypass/upset reach surface waters? J^Yes □ No DUnknown Volume reached surface waters (gallons):
Surface water name;
Did the bypass/upset result in fish kill? QYes NonUnknown
SPECIFIC cause(s) of the bypass/upset;
SgMAWU
(Always use treatment plant permit number)
of Incident#: - ‘
. S»jLuZ- Region: t&JoteJA_________________________
County:
SPECIFIC location of the treatment units bypassed or where the upset occurred in the facility:
_________>Te.gAJ.o>gut C'.YtleS___________)_______________
Signature:
Telephone: AyicC y&ai
Time:
(hh:mm AM/PM)
Romanski, Autumn
i
From:
Sent:
To:
Subject:
Smith, Danny
Friday, September 12, 2014 9:28 AM
Romanski, Autumn
siler city
Please call Sunny Cousler?
[phone]
He had questions about repairs of treatment units for Siler City that Jim McKay required?
Danny Smith
Regional Supervisor
Raleigh Regional Office
NCDENR-Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
[phone]
[e-mail]
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
fit i'll
Ci/13/2014 15:31 FAX [phone] ©001SILER CITY WASTEWATER PT
Date: 1-13-14
Here is my five day report for bypass on 1-11-14.
If you have any questions please let me know.
pages 2
I
Comments:
Raleigh Regional Office,
To: Raleigh Regional Office
Fax number:919-788-7159
From: Chris McCorquodale
Fax number: 919-742-5499
Regarding:
Bypass - 5 day report
Thank you,
Chris McCorquodale
Superintendent
Siler City WWTP
919-742-4581 office
919-742-5499 fax
[e-mail]
Town of Siler City
P.O.Box 769
311 N. Second Ave.
Siler City N.C 27344
[e-mail]
Phone number for follow-up:
919-742-4581
coo :----oog ------OOP ----------coo -------
Cashion, Ted
Mr. Keisler,
http://portal.ncdenr.org/web/wi/contacts
Please feel free to contact me if I can be of further assistance.
Sincerely,
Autumn Romanski
NC DENRDWR
nrji ww
Ajtumn Romanjki
E.-wrf-'w-o' Co
3KC <«n Dnx
taoyh NCJ710*
From:
Sent:
To:
Cc:
Subject:
Mr. Ted Cashion is the Raleigh Regional facility inspector for Siler City WWTP (this quarter) and I have
communicated your request to receive a copy of the inspection results upon completion.
From: Romanski, Autumn
Sent: Wednesday, September 24, 2014 3:08 PM
To: Smith, Danny
Cc: Cashion, Ted
Subject: FW: Rocky River in Chatham County- IN the office 1230-2 pm Today
i
Email correspondence to and from this address is
subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the
content is exempt by statute or other regulation.
PfKKW 1*1 M: -4555
• 788-ZIS*
Romanski, Autumn
Monday, September 29, 2014 2:23 PM
Sonny Keisler
Cashion, Ted; Smith, Danny
FW: Rocky River in Chatham County- IN the office 1230-2 pm Today
I have provided the contacts link below for the CG & L, now called the Division of Water Infrastructure. I think
the question on whether the Siler City Wastewater Treatment facility was designed to treat 4 MGD with the
permitted treatment units at the site should go to the Water Infrastructure engineers, as they approve/review
the construction designs and work with the NPDES Permitting Unit on as built and permitted flows.
Danny,
What do you think?
Thank You,
Autumn Romanski
Ms. Romanski,
Sonny Keisler
Mr. Keisler,
Thank you,
Autumn Romanski
Mr. Keisler,
Thank you for your follow-up e-mail and inquiry.
2
I think we have answered Mr. Keisler’s questions for the Raleigh Region. This the only question to be
confirmed and I am thinking this should probably be directed to CG&L engineers or permit writer as to 4 MGD
permitted?
From: Sonny Keisler [mailto:[e-mail]]
Sent: Wednesday, September 24, 2014 8:00 AM
To: Romanski, Autumn
Subject: RE: Rocky River in Chatham County- IN the office 1230-2 pm Today
When you visit the Siler City Wastewater Treatment Plant can you determine the capacity of the plant to
process waste at the NPDES permit standards? Is it 4,000,000gpd or less than that. Thanks,
From: Romanski, Autumn [mailto:[e-mail]]
Sent: Tuesday, September 23, 2014 11:25 AM
To: Sonny Keisler
Subject: FW: Rocky River in Chatham County- IN the office 1230-2 pm Today
From: Romanski, Autumn
Sent: Monday, September 22, 2014 12:30 PM
To: 'Sonny Keisler'
Subject: RE: Rocky River in Chatham County
I have completed the file review on the questions presented to DWR Raleigh Regional Office, and I have some
of the information you have requested.
I had a delay today and will out of the office until 12:30 pm, but I am available to speak with you between 12:30
and 2 pm today forthat works please feel free to call me at 919-791-4255.
Sincerely,
Autumn Romanski
Ms Romanski,
Thanks,
3
Sonny Keisler, Board Member
Rocky River Heritage Foundation
Email correspondence to and from this address is
subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the
content is exempt by statute or other regulation.
From: Sonny Keisler rmailto:[e-mail]]
Sent: Monday, September 22, 2014 10:08 AM
To: Romanski, Autumn
Subject: Rocky River in Chatham County
I appreciate your taking the time to speak with me last week concerning the Rocky River and the Siler City
WWTP. As I mentioned then, I am attempting to find answers to various questions concerning both the river
and the WWTP. These questions are listed below. I would appreciate any information you can provide. If you
do not have the information, perhaps you could refer me to a party who might have the information. I will call
perhaps later today or tomorrow.
AiXur*! Ro'njrrtkKs'NCDENR.GO'/
hnp j',‘www ixwMer.or®
(1) What is the estimated cost of repairing the Siler City WWTP basins 4 A&B?
(2) Has the backup generator been repaired and if not what would be the cost?
(3) Are any other repairs needed and, if so , at what cost?
(4) I understand the WWTP now has the capacity to process only 1,500,000 GPD instead of the permitted
4,000,000GPD. Is this correct. If not, what is the current capacity.
(5) What would be the estimated cost of installing nitrogen removal technologies at the WWTP including
constructed wetlands? The estimate can be an approximate range rather than an exact figure. My
contact who may be interested in helping upgrade the WWTP has asked me to obtain this type of cost
information?
(6) What would be the approximate cost of repairing Siler City sewer lines so as to prevent any future l&l
problems? A linear foot cost estimate for liners would be helpful.
Autumn Romanski
E^vcnmenol Pryfrtiv. Ceaulur’.
JBCO Barmr
NC 27609
NC DENR DWR
StXwf Waic Rnoorat Oftnlc
I will work on your inquiries today. If you would like to call me tomorrow^uesday, September 22nd’ I will be
available to speak by phone between 11:30 AM and 02:00 PM. If this time range doesn’t work for you, I can
schedule an alternate day and time.
Phooe(9i9|79!-QS5
F*x (919,788-7159
4
(7) What needs to be done to indj^e dissolved oxygen levels in the river rrom the Charles Turner Dam to
Varnell Creek below US Hwy. 64 so they do not fall below 4mg/l... preferably 6mg/l?
(8) What would be the preferred concentration of nitrogen (TN?) in the Rocky River below Loves Creek:?
North Carolina Department of Environment and Natural Resources
October 7, 2014
Subject:
Dear Mr. Thompson:
follows:
I.
2. The permit was reissued effective June 1, 2014 and will expire May 31, 2019.
3.
4. A cursory review of laboratory and DMR data showed consistent reporting of results.
5.Stream sampling is conducted by the Upper Cape Fear Association.
6. Units at the facility included a manual and mechanical bar screen, influent composite sampler (3
7. The treatment plant has sufficient sludge storage volume, > 6 months.
Pat McCrory
Governor
John E. Skvarla, III
Secretary
Mr. Bryan Thompson, Town Manager
Town of Siler City
311 North Second Avenue
Siler City, NC 27344
Compliance Evaluation Inspection
Siler City WWTP
NPDES Permit No. NC0026441
Chatham County
NCDENR
On September 26, 2014, Ted Cashion of this office conducted a Compliance Evaluation
Inspection of the Town of Siler City’s wastewater treatment plant. The cooperation of Chris
McCorquodale, ORC, and Ann Clark, Chemist, was appreciated. Findings during the inspection were as
degrees C), influent ultrasonic flow meter (calibrated 11-7-13), parshall flume, grit removal,
influent pump station (4 pumps), emergency generator (tested weekly under load), Zone 2 EQ
basin (1 MG capacity, almost empty at time of inspection), Zone 3A & B EQ/sludge storage (not
in use, not needed at time of inspection), 2 oxidation ditches, 2 circular clarifiers, 4 tertiary filters,
chlorine contact chamber, SO2 dechlorination, effluent composite sampler (2 degrees C), step
aeration, filter backwash basin, DAF unit (used as needed), sludge thickening basin, and 2 aerobic
digesters.
Zone 4 EQ basin has been taken out of service and is no longer listed as a treatment unit in the
permit. The pipe leading to Zone 4B from the Zone 3 effluent splitter box has been capped,
preventing waste from entering Zone 4B. The unit was empty at the time of inspection. The
treatment plant has sufficient capacity without use of this unit. If the Town considers placing this
unit back in operation, the crack in the Zone 4B wall must be repaired and the permit must be
modified to include this unit as a treatment unit prior to operation.
I he treatment plant appeared to be operated and maintained properly. The effluent was clear and
free of solids.
•n ditch effluent for phosphorus removal.’
cc:
S. Daniel Smith, Supervisor
Water Quality Regional Operations
Chatham County Health Dept.
RRO, SWP
Central Files
If you have questions concerning this report please contact Ted Cashion at 919-791-4254.
Sincerely,
8. Alum is added to the oxi
9. Sludge is land applied by Synagro through permit WQ0003226. This permit expires March 31,
2017. Sludge was last hauled from the facility the week of July 6, 2014.
EPA
Section A: National Data System Coding (i.e., PCS)
yr/mo/day Inspection TypeNPDES
3 J11I I17 18NC002644114/09/26
21
Bl QA ■Reserved-
71I 72 73
Section B: Facility Data
Entry Time/Date Permit Effective Date
09:00AM 14/09/26 14/06/01
Siler City WWTP
Exit Time/Date370 Waste Treatment Plant Rd
14/09/2612:45PMSiler City NC 27344
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
ContactedJoel J Brower,311 N Second Ave Siler City NC 27344//919-742-2323/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Ted A Cashion RRO WQ//919-791-4200/
Numbers
1Page#
Permit
9 Self-Monitoring Program
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES oermit Number)
H Flow Measurement
Facility Site Review
Operations & Maintenance | Records/Reports
Effluent/Receiving Waters
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Permit Expiration Date
19/05/31
///
Chris McCorquodale/super wwtp//
Christopher Michael McCorquodaie/ORC/919-742-4581/
Transaction Code
1 N
Facility Self-Monitoring Evaluation Rating
70 I I
EPA Form 3569^ (Rev 9-94) Previous editions are ol
121
Fac Type
20U
m74 75i 111111180
Sjgnatura of Management 0'AReviewer/V Agency/Office/Phone and Fqx Numbers Data
EPA Form 3560^13 (Rev 9-94) Previous editions are obsolete.
Inspector
19 LJ
i-1 Li 11 1111111111111 111111 111111 11111111111 r6
Inspection Work Days
671
2 LI
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Comment:
Permit Yes No NA NE
■
Is the facility as described in the permit?
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Comment:
Flow Measurement - Influent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
Bar Screens Yes No NA NE
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?
Page#3
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Owner - Facility: Siler City WWTP
Inspection Type: Compliance Evaluation
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Permit: NC0026441
Inspection Date: 09/26/2014
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(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Bar Screens Yes No NA NE
Is the unit in good condition?■
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical ■
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Equalization Basins Yes No NA NE
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?■
Is the site free of excessive buildup of solids in center well of circular clarifier?■
Are weirs level?
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 drive unit operational?
Is the return rate acceptable (low turbulence)?■
4Page#
Owner - Facility: Siler City WWTP
Inspection Type: Compliance Evaluation
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Permit: NC0026441
Inspection Date: 09/26/2014

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Secondary Clarifier Yes No NA NE
Comment:
Oxidation Ditches Yes No NA NE
Comment:
Disinfection-Gas Yes No NA NE
J
Comment:
De-chlorination Yes No NA NE
Type of system ?Gas
5Page#
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?
Is the DO level acceptable?
Are settleometer results acceptable (> 30 minutes)?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes)
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
Permit: NC0026441
Inspection Date: 09/26/2014
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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?
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Owner - Facility: Siler City WWTP
Inspection Type: Compliance Evaluation
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De-chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type?
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
Is sampling performed according to the permit?■
Comment:
Upstream / Downstream Sampling Yes No NA NE
■
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
■
Comment:
6Page#
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Is the facility sampling performed as required by the permit (frequency, sampling type, and
sampling location)?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Permit: NC0026441
Inspection Date: 09/26/2014
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Owner - Facility: Siler City WWTP
Inspection Type: Compliance Evaluation
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