NC0020354_NOV - parameter limits_19980210

State of North Carolina
Department of Environment,
Health and Natural Resources 4 • •
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary ED E Fl
A. Preston Howard, Jr., P.E., Director C
February 10, 1998
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Larry Isaacson
General Manager
Hydro Tube South
1755 Hillsboro St. (Hwy 15/501 North)
Pittsboro, NC 27312
Subject: NOTICE OF VIOLATION
Dear Mr. Isaacson:
For the months of November and December, 1997, Hydro Tube was found in violation of the following
parameter limits:
Sample Date
Pie
Parameter
Reported Value/Unit
Limits
11/26/97
001
Phosphorous
38.4 m /l
5.00 mg/1
December Average
001
Zinc
1.5 mg/1
1.48 m /l
Additionally, for the months of October, November and December, 1997, Hydro Tube was found in violation
of the following reporting requirements. Please note the reporting violations for October were inadvertently
left out of the Division's November 26, 1997, Notice of Violation:
Reporting
Period
Pipe
Parameter
Violation
October —
001,002
Flow
failure to report flow values as required by Part I, F, and
December 1997
111, 2, a., of the IUP
October —
001,002
Violations
failure to report violations as required by Part 1, I.,5 of the
December 1997
Follow-up
1UP which states:
- All violations shall be reported by phone message and
fax within 24 hours of becoming aware of the sample
results. *Partially met, see next page.
- All violations shall be reported by mail, postmarked
by the 2nd day the US post office is open after
becoming aware of the sample results.
- All violations shall be resampled and reanalyzed
within 1 week after becoming aware of the sample
results. **See next page for clarification.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

* Part I, I, 5, of the IUP referenced above also requires the SIU to report by phone message and fax within 24
hours of becoming aware of the violation. It appears Hydro Tube is telephoning but is not submitting the
follow-up fax of the report. This must be done for all future reports.
** During our review of your sample results it was noted that while Part I, I, 5, requires resampling and
reanalyzing within 1 week after becoming aware of the violation, Part 111, 2, b of the IUP, requiring resample
within 30 days of becoming aware of the violation. This is inconsistent. It appears that the 30 day resampling
requirement, at least, was met for the October violations for zinc and phosphorus and November violation for
zinc, but was not met for the November violation for phosphorus. The Division regrets any confusion about
these requirements and will be modifying the IUP shortly to resolve this conflict. Until this is done, Hydro
Tube is expected to comply with Part I, I, 5, as it is more stringent.
Keep in mind all notification activities required in Part I., I., 5 are intended to be reported to all three parties
listed.
The above listed limits violation for Phosphorus, in combination with violations outlined in the Division's
earlier Notice of Violation, place Hydro Tube in Significant Noncompliance as defined by 40 CFR
403.8(f)(2)(vi) and NCAC 2H .0903(b)(34). Additionally, the above listed reporting violations also place
Hydro Tube in Significant Noncompliance. As such, the Division will issue a public notice as required by 40
CFR 403.8(f)(2)(vii).
Remedial actions, if not already implemented, must be taken to correct the limits and reporting violations.
Hydro Tube is required to perform the following activities at a minimum:
1. For all reporting violations listed on the previous page, by March 4, 1998, submit an explanation of why
the telephone calls, records, reports, etc. were not submitted as required by the IUP. Also, outline steps
Hydro Tube will take to ensure all reports are correctly filed in the future.
2. Submit any available flow records for October through January by March 4, 1998. Please include a
written explanation of how flow measurement readings are taken. Include photographs and engineering
drawings as appropriate. If records are not available, please provide an explanation as to why not and
outline what steps Hydro Tube will take to ensure appropriate records are collected in the future.
3. Beginning in February 1998, sample Pipe 002 for zinc twice per month until further notice.
4. Beginning in February 1998, sample Pipe 002 for nickel twice per month until further notice. ***See
discussion below.
Beginning in February 1998, sample Pipe 001 for phosphorus once per month until further notice.
By March 13, 1998, submit a schedule of activities outlining the steps Hydro Tube will take, with
beginning and end dates as appropriate, to meet the April 30th deadline listed below. ****
By April 30, 1998, submit a report on the results of an investigation into the sources of phosphorus, nickel,
and zinc and possible alternatives for compliance with the current limits. [Due dates for implementation
of the alternatives will be established at a later date.]
*** During the review, an error in the development of the IUP limit for nickel was discovered. It appears that
the Division may have to modify the IUP to lower the nickel limit to very close to current levels of discharge.
This letter requires the SILT to collect more data to more accurately determine current levels, and to begin an
evaluation into the sources of this pollutant as well as possible methods of treatment. Further instructions will
be made at the time of any IUP modification which should be done in the next few weeks.
**** If January, February, or March sampling indicates violations of IUP limits for zinc or nickel, Hydro Tube
should consider immediately contacting a licensed Professional Engineer with knowledge and experience in
Industrial pretreatment for zinc W r9*GjThe importance of resolving this problem prior to the permit
expiration date of June 30, 1998, should not be taken lightly.
_,ku Clow-

Response to this letter is required by March 4, March 13, and April 30, 1998, as indicated above.
The Division of Water Quality may pursue enforcement actions for this and any additional violations. If you
have any questions, please call Dana Rees Folley of the Pretreatment Unit at [phone] (ext. 523), or
Tom S. Poe, Pretreatment Unit Supervisor (ext. 522).
Sincerely,
A. Preston Howard, Jr., P.E.
drf:Hydronov 002
Ce. Central Files
DRF, Pretreatment Unit
Danny Smith, Raleigh Regional Office
Mr. John Poteat, Superintendent, Town of Pittsboro
86 Z 1833
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