NC0020354_Monitoring Information_20010323

��0� W A T f h Michael F. Easley
Governor
rWilliam G. Ross, Jr., Secretary
>_ North Carolina Department of Environment and Natural Resources
O Kerr T. Stevens. Director
Division of Water Quality
March 23, 2001
MR. WALLY JENKINS
DIRECTOR OF WATER RESOURCES MSR C 7 20
TOWN OF NORTH WILKESBORO
PO BOX 759 Ul
PITTSBORO NC 27312 CENT RAL PL -110
Subject: Pretreatment Unit Review of Industrial User Pretreatment Permit (IUP)
Town of Pittsboro (NPDES # NC0020354)
Chatham County
Dear Mr. Jenkins:
The Pretreatment Unit of the Division of Water Quality has reviewed the Industrial User
Pretreatment pen -nit (IUP) issued by the Town of Pittsboro for the following Significant
Industrial User (SIU). This IUP was received by the Division on February 16, 2001, with
additional information received on February 13 and March 22.
IUP # SIU Name
002 Townsends, Inc.
The review indicates that more information is needed to determine if the IUP meets the
minimum requirements of 15A NCAC 211.0905 and .0916 and 40 CFR 403.8(f)(1)(iii).
In order for the Division to complete its review of the IUPs, you are required to submit the
following information by April 15, 2001. Examples and descriptions of some of the following
items are in the Comprehensive Guidance for North Carolina Pretreatment Programs
(Comprehensive Guide).
1. Allocation Table (AT): The submission did not include an updated Allocation Table.
Attached please find a copy of the Division's AT for the POTW. Please review this
carefully and submit a copy of your own AT with any corrections noted. If you have
any questions or concerns, please call Dana Folley of the Pretreatment Unit to discuss
the situation. Please ensure future Allocation Table submissions have correct
"renewal" and "modification" effective dates listed, and include an evaluation for
flow.
2. Ammonia Limit: See Comprehensive Guide, Appendix 6-E, page S.
Per the attached AT, the proposed IUP limit results in over allocation based on the
POTW's current approved MAHL for Ammonia is 56.45 lbs/day. The HWA
received on February 16, 2001, does not address Ammonia but does address TKN.
Please see the Division's Headworks Analysis Review letter forwarded to the POTW
NC—DENR, DWQ, PRETREATMENT UNIT Telephone: [phone] Fax: [phone] FlwA
1617 MAIL SERVICE CENTER, RALEIGH, NC 27699-1617 An Equal Opportunity Affirmative Action Employer1
Website: http://h2o.enr.state.ne.us/Pretreat/index.htnil 50% recycled/10% post -consumer paper NCDENR

under separate cover for more details and advise the Pretreatment Unit on this,
revising the HWA and IUP as necessary.
3. Phosphorus Limit: See Comprehensive Guide, Appendix 6-E, page 5.
The IUP does not include a limit for Phosphorus, but does include a monitoring
requirement. SIUs that discharge more than 5% of the POTW's MAHL must have an
IUP limit except under certain circumstances (see Appendix 6-E, page 5, for details).
The POTW's-current approved MAHL for Phosphorus is 15.98 lbs/day. Based on the
data from the application, the SIU's discharge has an average of 13.1 mg/l. At 0.2
MGD, this would represent 21.8 lbs/day, more than the POTW's entire MARL. It is
understood from the IUP that the SIU will provide additional phosphorus removal
above the current treatment. However, in order for the SIU's discharge to represent
less than 5% of the current MAHL of 0.8 lbs/day at 0.2 MGD, the SILT would have to
treat its discharge down to no more than 0.48 mg/l. Please see the Division's
Headworks Analysis Review letter forwarded to the POTW under separate cover for
more details and advise the Pretreatment Unit on your resolution of this issue, either
revising the HWA and/or IUP and/or providing documentation that a limit is not
required as necessary.
4. Lead: See Comprehensive Guide, Appendix 6-E, page 5.
The IUP does not include limit for lead, but does include monitoring requirements.
SIUs that discharge more than 5% of the POTW's MAHL must have an IUP limit
except under certain circumstances (see Appendix 6-E, page 5, for details). The
POTW's current approved MAHLs for lead is 0.22801bs/day. Based on the February
19, 2001, sample result of 0.175 mg/1, at 0.2 MGD, this represents 0.292 lbs/day,
more than the POTW's entire MAHL. This over allocation must be resolved. Please
begin immediate collection of additional data and advise the Pretreatment Unit on
your resolution of this issue, either revising the HWA and/or IUP and/or providing
documentation that a limit is not required as necessary.
5. Zinc: See Comprehensive Guide, Appendix 6-E, page 5.
The IUP does not include limit for zinc, but does include monitoring requirements.
SIUs that discharge more than 5% of the POTW's MAHL must have an IUP limit
except under certain circumstances (see Appendix 6-E, page 5, for details). The
POTW's current approved MAHLs for lead is 6.4011lbs/day, with 5% MAHL of
0.3201 lbs/day. Based on the February 19, 2001, sample result of 2.068 mg/l, at 0.2
MGD, this represents 3.449 lbs/day, clearly more than 5% MARL. Fortunately, the
current reserve still available is 5.9925 lbs/day, and thus the POTW should be able to
develop an IUP limit. Please begin immediate collection of additional data and
review this situation and advise the Pretreatment Unit, either revising the HWA
and/or IUP and/or providing documentation that a limit is not required as necessary.
6. Flow Requirements: There appears to be an error in the listing of the Monthly
Average Flow limit of 6.083 MGD. Perhaps this is a limit on the total amount of
flow allowed in one month. Please advise the Pretreatment Unit on this.
Also, the IUP does not detail the various discharge restrictions you discussed with
Dana Folley of the Pretreatment Unit such as the POTW's right to temporarily stop
the discharge if the WWTP is having problems. Please add these requirements to the
IUP.

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7. Permit Limits: The IUP includes monthly average limitsLf,91 BOD, TSS, and -N-1,13 but
does not include daily maximum limits for these paramggff 1,,Uhe;'_] Vision is
concerned that without daily maximum limits, an SIU can still meet its monthly
average limit by discharging very nigh pollutant concentrations on one day and very
low pollutant concentrations on other days. The high loads could adversely impact
the POTW, including but not limited to slugs of pollutants, and the POTW may be
limited in its ability to take appropriate enforcement.
Please comment on this, and how the POTW will assure that this SIU will not
contribute to pollutant overload of the WWTP and/or its collection system. If there is
concern with a daily maximum limit unnecessarily restricting an SIU's flexibility, one
possibility would be to include an IUP daily maximum parameter limit at a fairly high
level as compared to the monthly average limit.
Until the Division has received the required information, we will be unable to make a decision
on the adequacy of the IUDs. Therefore, as allowed by 15A NCAC 2H .0917 (e)(2), the
Division's thirty day comment period will be suspended untili the additional information is
received, and at that time the full 30 day comment period will recommence. You are encouraged
to notify the affected industries of the extension of the Division's comment period.
The following comments are made concerning the adequacy of the IVPs based on the
information currently available:
8. IUP Signature: _ IVPs are directive documents, not contracts, and thus the IUP must
only be signed by the POTW. If you wish to have the SIU sign something
acknowledging receipt of the IUP, that is acceptable. If an SIU has objections to an
IUP, rather than refusing to sign or accept delivery of the IUP, they must file an
adjudication as outlined in the POTW's Sewer Use Ordinance (SUO). Please ensure
the next IUP addresses this.
9. Sampling: Based on your telephone conversation with Dana Folley of the
Pretreatment Unit, the current weekly sampling regime is for the SILT to set up the
sampler and the POTW is coming by to pick up the sample and have it analyzed.
This is not appropriate. For a sample to satisfy an IUP requirement for a particular
party (the POTW or the SIU), that sample must be set up, collected, and analyzed by
the party themselves, or their designee such as a commercial lab. A POTW cannot be
the designee of the SIU. Please address this, ensuring both the POTW and the SIU
collect separate samples to meet each party's IUP requirement. Alternatively, please
modify the IUP to move all monitoring to the POTW, with the POTW or it's outside
designee (not the SIU) performing all responsibilities.
10. Pretreatment Units: Please ensure the list of pretreatment units in paragraph 2 on the
cover page of the IUP is consistent with the list of pretreatment units on page 7 of the
application. It appears this may be due to a formatting problem with the -table cell as
the wording ends with "or." In any case, the IUP must include all treatment units and
processes, including the various treatment units the wastewater goes through before
the lagoon and the pH adjustment and the phosphorus removal through ferric chloride
addition that occurs after the lagoon. Please ensure the IUP lists the actual units at
the SIU, preferably in the order the wastewater flows through them.

11. IUP Effective and Expiration Dates: The IUP effective date and expiration dates
must be listed on the IUP limits page. Additionally, the listing of the IUP effective
date on the permit history is incorrect.
12. IUP Part Numbering: The IUP appears to have only Part I, and Part III. Part III
begins with conditions 1-6, and then has a separate outline entitled Outline of Part I,
II, and III, and then continues with conditions 1-30. Thus it seems as if there is no
Part II, but there are two sets of Part III, 1-6. Please review the entire IUP and make
appropriate revisions.
Response to this letter is required by April 15, 2001. Please note our mailing address, fax
number, and web site at the bottom of the first page of this letter. Thank you for your continued
cooperation with the pretreatment program. If you have any questions or comments, please
contact Dana Rees Folley at [phone] (ext. 523) [email: dana.folley @ ncmail. net], or Tom
S. Poe (ext. 522), Supervisor of the Pretreatment Unit.
Sincerely,
Kerr T. Stevens
drf/ p i tt s b o ro i u p.004
cc- _ _-- Central -Files
DRF, Pretreatment Unit,
Beth Barnes, Raleigh Regional Office
Ken Schuster/Pretreatment files, Raleigh Regional Office