NC0020354_Permit Modification_20020626

OF W A rF�Q Michael F. Easley
OCA QG Governor
(3\William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
W)7
'< Alan W. Klimek, P.E., Director
Division of Water Quality
June 26, 2002
MR. HUGH MONTGOMERY
TOWN MANAGER
TOWN OF PITTSBORO
PO BOX 759
PITTSBORO NC 27312
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 two Industrial User Pretreatment
permit (NP) modifications issued by the Town of Pittsboro for the following Significant Industrial User
(SIC)). These IUP modifications were received by the Division on June 27, 2001.
UP # SIU Name
002 Townsends, Inc.
It is understood that this SIU has ceased discharge to the POTW and there currently are no plans for them
to start up again. The IUP is set to expire on June 30, 2002. Please submit a request to drop this SIU
from the POTW's list of SIUs to the Pretreatment Unit by September 1, 2002.
Prior to the POTW granting permission to Townsends to discharge wastewater in the future, the
POTW must address the following comments:
1) Permit History: If a new IUP is issued, it must include a complete history of the previous IUDs.
2) IUP Limits for Phosphorus, Lead and Zinc: See Comprehensive Guide, Appendix 6-E,
page 5.
a) Prior to the POTW granting Townsends to discharge process wastewater, a new evaluation for the
need of an IUP limit for Phosphorus, Lead, and Zinc must be submitted and approved by the
Division. If this is done, please consider the following:
i) 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).
ii) Phosphorus:
(1) The POTW's current MARL is 15.98 lbs/day (approved June 30, 2000). 5% of this
MAHL is 0.8 lbs/day.
(2) Based on the data from the 2001 PAR, the SIU's discharge averaged between 13 and 16
mg/l. At 0.2 MGD, this would represent between 21 and 27 lbs/day, more than the
POTW's entire MAHL.
(3) At 0.2 MGD, the SIU would have to treat its discharge down to no more than 0.48 mg/1
to be below 5% of MARL.
(4) As required by the IUP, Townsends was providing additional phosphorus removal by
injection of after their sample point somewhere within the collection system.
(5) The POTW Headworks Analysis submitted in April of 2001 did discuss phosphorus but
DI
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did not actually provide a new MARL, based on Passthrough or Design, nor did it discuss
how to take into account the additional treatment provided in the collection system by
Townsends. Thus the 15.98 lbs/day still is the approved MARL.
(6) Regardless of whether there are plan for Townsends to discharge again, it is strongly
recommended that development of a Design MARL for Phosphorus be considered with
the HWA due August 1, 2002. You may also wish to discuss how to take into account
any post sample point removal achieved by the SIU, especially if there is any chance
Townsends will wish to discharge again.
iii) Lead:
(1) The POTW's current approved MAHLs for lead is 0.2280 lbs/day.
(2) Based on the February 19, 2001, sample result of 0.175 mg/1 at Townsends, at 0.2 MGD,
this represents 0.292 lbs/day, more than the POTW's entire MARL.
iv) Zinc:
(1) The POTW's current approved MABLs for zinc is 6.4011lbs/day, with 5% MAHL of
0.3201 lbs/day.
(2) Based on the February 19, 2001, sample result of 2.068 mg/l at Townsends, at 0.2 MGD,
this represents 3.449 lbs/day, clearly more than 5% MARL.
3) Sampling: Based on a telephone conversation between Dana Folley of the Pretreatment Unit and
Wally Jenkins of the Town, the weekly sampling regime used in early 2001 was for the SIU to set up
the sampler and the POTW is coming by to pick up the sample and have it analyzed. This is not
appropriate. It was unclear if this had been resolved prior to the SIU's start up in November of 2001,
but in any case it must be resolved if Townsends begins to discharge again. Please consider the
following:
a) 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. Both the POTW and the SIU
must collect separate samples to meet each party's IUP requirement. Alternatively, the IUP could
be written to move all monitoring to the POTW, with the POTW or it's outside designee (not the
SRC) performing all responsibilities.
4) IUP Effective and Expiration Dates: The IUP effective date and expiration dates must be listed on the
IUP limits page. Additionally, the permit history must list the correct IUP effective date.
5) IUP Part Numbering: The IUP appeared to have only Part I, and Part III. Part III began with
conditions 1-6, and then had a separate outline entitled Outline of Part I, II, and III, and then
continued with conditions 1-30. Thus it seems as if there is no Part II, but there are two sets of Part
III, 1-6.
Thank you for your continued cooperation with the Pretreatment Program requirements. If you have any
questions or comments, please contact Dana Rees Folley at [phone] (ext. 523) [email:
[e-mail]], or Tom S. Poe (ext. 522), Supervisor of the Pretreatment Unit.
Sincerely,
�+�. Alan W. Klimek, P.E.
drflpittsboroiup.007.townsends
cc: Mr. John Poteat, Town of Pittsboro
Mr. Perry Dunn, Town of Pittsboro ~~
C'mtr.il Files
DRF, Pretreatment Unit`
"l
Myrl Nisely, Raleigh Regional. Office 111
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