NC0064726_CORRESPONDENCE_19890818

NPDES DOCUWENT SCANNING COVER SHEET
LJ
NPDES Permit:
NC0064726
East Bend Industrial Park WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
August 18, 1989
•
This document ie printed on x-euge paper - ignore any
content on the reverse Bide

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary Director
August 18, 1989
Mr. William R. Smitherman
Rt. 4 Box 37
East Bend, North Carolina 27018
Subject: East Bend Industrial Park
NPDES Permit No. NCO064726
Dear Mr. Smitherman,
I am writing in response to your letters sent August 6th & 13th, 1989, concern-
ing the East Bend Industrial Park discharge into Justice Reynolds Creek. You
expressed concern with the increased wasteflow from 10,000 gallons per day (GPD)
to 50,000 GPD for the East Bend discharge. The Yadkin Board of Commissioners
has voted to withdraw its application for increase to 50,000 GPD for the East
Bend Industrial Park as per letter sent July 31, 1989, from Charles Mashburn,
the County Manager.
The wastewater discharge applications for each flow designated the facility's
effluent to consist of 100% domestic wastewater. Item 15 on the application
states that the facility will contain one or more of the number of toxic sub-
stances listed. This item number was checked "yes" on the application forms for
both 10,000 and 50,000 GPD. Since Domestic wastewater contains ammonia, which
is listed as one of.the parameters within this item number, the item was likely
checked to acknowledge its presence.
The East Bend permit, under General Conditions (Part II), contains a management
requirement for any change in discharge and states the following:
"All discharges authorized herein shall be consistent with the terms
and conditions of this permit. The discharge of any pollutant identi-
fied in this permit more frequently than or at a level in excess of that
authorized shall constitute a violation of the permit. Any anticipated
facility expansions, production increases, or process modifications which
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

•
will result in new, different, or increased discharges of pollutants must
be reported by submission of a new NPDES application or, if such changes
wilf.not violate the effluent limitations specified in this permit, by
.notice to the DEM of such changes. Following such notice, the permit may
be modified to specify and limit any pollutants not previously limited."
The above permit condition protects against any additional or new types of
wasteflow being discharged without an analysis from our staff. The types of
parameters limited in the effluent constitute domestic type wastewater. There-
fore, additional dischargers with metals or chemicals in the effluent will be
carefully considered before an allowance will occur and appropriate effluent
limits to protect aquatic life and human health would be added, where necessary.
You inquired about the discharge location of the East Bend facility. Several
points were evaluated for discharge, including a point approximately 1200 feet
below the Drag.Strip. Presently the discharge point is located roughly 200 feet
above the Drag Strip. The facility -has requested a permit modification to relo-
cate the discharge point to just above the Drag Strip and below the culvert
where an unnamed tributary meets Justice Reynolds Creek (see attached map).
The East Bend Industrial Park started discharging in June 1989. DEM has efflu-
ent flow data for the month of June only. The average flow for June was 1,100
GPD. The facility is required to submit monitoring data each month for the
weekly effluent flow data and instream water quality data to DEM's Central Files
office. The files are available for the public to examine and are located on
the 12thfloor of the Archdale Building (512 N. Salisbury St., Raleigh, N.C.).
The General Assembly approved a Bill effective October 1, 1989, to increase
local involvement in the decision to issue a discharge permit to surface waters.
The Bill will inform local governments (city or county) of a new nonmunicipal
domestic wastewater discharge facility. The city or county will then respond
within 15 days whether the proposed facility is consistent with any zoning or
subdivision ordinance which may be in effect for the area.
If you have any further questions concerning this matter please contact me at
[phone], ext. 506.
nc
ely,�
Trevor Clements, Asst. Chief
Water Quality Section
cc: Dale Overcash
Steve Mauney
Central Files

Aug. 13, 1989
Rt 4 Box 37
East Bend, N.C. 27018
Mr. Trevor Clements 1
N.C. Dept of Natural Resoueces RECEIVED
P.O. Box 27687 E
Raleigh N.C. 27611
AUG 14 1989;
Dear Mr. Clements:
TECHNICAL SUTU&NWe proposed
Please provide to me a copy of the low rate chaarr
discharge point of the East Bend In ustrial Park ref... Yadkin County
Application NCO064726
I have heard that the initial application specified a discharge
point some 1200 ft below ie. southeast of the East Bend DrageStrrip
This point would be in the middle of my farm. I have not been
advised by the NCDNR, by my County Manager, or by the Yadkin
County Board of Commissioners of this proposal.
I am very concerned about the quality of surface water in
this stream Justice Reynolds Creek, as it is used both on my
farm for watering tobacco fields, watering tobacco plant beds,
and libestock consumption. Many of my neighbors furthur down
stream also use this creek water and consider it a valuable
surface water resourse.
In addition to providing the above requested information, please
advise me as to any change or modification of the present issued
permit. Our community in general and the property owners along
the banks of Justice Reynolds Creek are unwilling to except
a low quality of water in this stream. We will actively oppose
efforts to increase the discharge and or any. effort to discharge
Mercury, Lead, Zinc, Phenols ect into this stream.
Will the new regulations which I understand are to be in place by
Oct. of this year require notification of the downstream property
owners,of permit applications which may affect their surface
water quality. I consider the present procedure of placing a
one time public notice in small print inadequate as far as
informing the property owners and community residents of proposed
permit changes. Very few popple read the small print public
notice section of our newspaper each and every day.
Yours truly,
W.R.Smitherman

Mr. T r e Vb'r. C I e m en t s
&N . C . Dept of :Natur.al„Resources
Div of
Environmental
-anagement .
.'P . 0. Bnr 27687
. �Ral"eigF N27611
Dear Mr. Clements:
There has u'een,.a gnowing"-�concern.. i1n. our communityconcerning
sewaged i hto'" Ju it i c e Reynolds Creek by Ue;,Cent u ry
'�- ischarge
Repro.d I u c , tio , n s %'p a n t' an:d'`�6'ther pros pactive ,t en':' ­of'the East Bend
'a n't s i,
Indusi a I Park Th i's ..conc,ern was-increasedwh en*Lpeople of our
community 66me aware;o,f7.:�:the filing of an appl ica'tion to increase
t h e . a 11 c, w a b� I e d I s c h a rg"e. gal per, day�,.,to��,,50,,000 gal per
,f.rom 10 b 0
-i's stream r e a m'-"Wh rc h -'� s S, :families along its
day i6'io:th, erv� the farms and d�.
banks.as an -important -surface water resourse.
We were,; -and .,,are s t' i 1 ,Fi;
s e e co-py ;'e'nc.l:o'.se( .-was�c
The county commi;ss'ioner
jr discfi arg into;thet , e
item . I,5';.was:,checke qe,s
verytoxic el�emen s„
Ph o ie c w'.
of these lifeiihreai�hih
When questioned about,,,,.w
at first sai"d.-,;h he did ,`6
saidii e. o" ,y�were tins
Natural
:r would 7c�o
amon i a,,'l
However`''
chedk'6d'�
all that
that tfi'6
Please
p
'-,-'checked
;;per d a
h a v e b e e
m o s t. P
aproauc
r s
have bee
s :and `in , ,f 'a c t
Sg 0 1 . '19 toN6
are :trace: am
ri or d e'r
mmod e.-Y
eked ,Ye
u5 -',a * nc
uetwc
)hcerned that item 15.:of-thi's application,
�cked yes
,,nave -assured us tha*t',-.a,1-1-'?;--,th'6y..,•wish6d� to
i>.;was treatedbodily ewage, ye.
S you n -see itemt.:,,I5"',.,c:p�n7t:a'ins some
y
�, . Lead
tvely oppose the dumpingor: ischa'rg-ing
-substances into this stream.
,;item 15 was checked; -ye'st-he,:.counti'.:manader
.:k'how. Cat­er.,both he and_.;:the :Commissioners
!uscted by;mbmbers of the N C D e p t*.-,; o f
.o, check Ahi s, blank ybs';-�_,�_as2 the, d i r g e .
o'f,. the-'eT6_me"n'ts',:!I isted:'A1n,-,,;)item 1 a:s..
waste
,.,1-.'6 1 d that '-,-.item '15 did ,.not .haVe to be -
h o i'uld ha'v'e�,beeh checked no; - -i f in fac t
treated was bodily watte ;a:.Lt is understood
nts of a"m"66*44rn th'e6f-r*ea,t-*ed---,di-sch"a'r'g'e.,
to the question; 'D1 d'!i t em'.0 5h'a v eto *.-;b e
appr'­--d 'f o r 1 et. the -a- ;_ 'I i:c 6" 'i o'n".
It would se'e`m'.�. t 6'. m'4- ;_t�h t* should not
0 0 0 gal"
fact
b yes n.,,item 15 this would
or me aj-":ie� ec-" ro p, ha terN,o r: ..-a, c hem' fic a 1,
Q 1_­'.,
�epeople -.'j n+ our. community Iwe'l c ome •The
un ergroun ­wateff.:i-s;;: e "d this coupties
e source e d e s'ir et h a t, t h i s statemenVy`ea,
b
r s w
�fAer'm`an�` '

9. .Description of waste water discharged to surface waters only (check as applicable).
Flow, MGD (million gallons per operating day) Volume treated before
Discharge per discharging (percent)
operating day -- T
. 0- 0.01- 0.05- 10.1- 0.5- 1.0- 5 or None 0.1- 35- 65- 95-
0.0099 0.049 0.099 0.49 0.99 14.9 more 34.9 64.9 94.9 100
(1) (2) (3) (4) (5) i(6) (7) (8) (9) (10) (11) (12)
A. Average X
B. Maximum
10. If any waste water, treated or untreated, is discharged to places other than
surface waters, check below as applicable.
Waste water is
discharged to
0-0.0099
(1)
0.01-0.049
(2)
0.05-0.099
(3)
0.1-0.49
(4)
0.5-0.99
(5)
1.0-4.9
(6)
5 or more
(7)
A. Deep well
B. Evaporation lagoon
C. Subsurface percolation system
D. Other, specify:
11. Is any sludge ultimately returned to a waterway?
A. / /Yes B. IT/No
12. a. Do you receive industrial waste?
1. /V/Yes 2. / /No
b. If yes, enter approximate number of industrial dischargers into system Unknown - future development
13. Type of collection sewer system:
A. /Y/Separate sanitary
B. / /Combined sanitary and storm
C. / /Both
Name of..teceivinx water or waters
%"Does your discharge contain or is it possible for your discharge to contain\
one or more of the following substances: ammonia, cyanide, aluminum, beryllium,
cadmi hromium, copper, lead, mercury, nickel, selenium, zinc, phenols.
A./Ye B. / /No
I certify at I am familiar with the information contained in the application and that
to the best of my knowledee and belief such information is true._comolete. and accurate.
Charles S. Mashburn
Printed Name of Person Signing
County Manager
3-13-d'9
Date Application Si ne
Signature of Applicant
North Carolina General Statute 143-215.6(b)(2) provides that: Any person who knowingly makes any
false statement representation, or certification in any application, record, report, plan, or
other document files or required to be maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, or who falsifies, tampers with, or knowly renders
inaccurate any recording or monitoring device or method required to be operated or maintained under
Article 21 or regulations of the Environmental Management Commission implementing that Article, shall
be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to
exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more
than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary Director
July 24, 1989.
Mr. William R. Smitherman
Route 4, Box 37
East Bend. North Carolina 27018
Subject: Expansion of East Bend Industrial Park Discharge
NPDES No. NCOO64726, Yadkin County
Dear Mr.. Smitherman:
Thank you for your letter of June 17, 1989, regarding the
proposed expansion of the subject discharge. Currently, the
draft permit as prepared by the Division of Environmental.
Management (DEM) is being reviewed by the Division of Health
Services because of the discharge's location in water classified
for water supply protection (i.e., WS-III). If approved, the
draft permit will be sent to public notice. The official notice
will be published in both the Winston-Salem Journal and the
Yadkin Ripple newspapers. Comments may be submitted during
the 30-day period following public notice. Your letter will be
entered into the corresponding public comment file of the draft
permit for further consideration.
The NPDES permit for the proposed expansion has been drafted to
allow discharge of treated domestic wastewater only. No
industrial users will be allowed to tie into the East Bend
facility until an approved pretreatment program is established.
However., the current classification of: the receiving waters
(WS-III) does allow for the discharge of industrial wastewaters
that will meet North Carolina's water quality standards which,
for the toxicants in question, are established to protect
aquatic life to the chronic no effect level. Therefore, at the
concentrations allowed, we would not expect to see any impacts
to aquatic life nor health effects of those using the waters for
secondary recreation.
P.O. Box 27687. P.Acieh, North Camlina 27611-7687 Telephone [phone]
An Equal Oppommity Affirmative Action Employer

Mr. William R. Smitherman
Page Two
Nonetheless, your request for a benthos study of the stream is
well -taken and I have directed my staff to perform an
appropriate biological survey. Data gathered during this survey
will be used to assess the current health of the receiving
waters, and will be helpful in establishing a baseline for
comparison to future studies. No decision regarding the
issuance of the NPDES permit for the expanded discharge will be
made until these studies have been completed and the results
thoroughly evaluated.
Finally, your request for a public meeting has been duly noted.
A final decision regarding a meeting will be made after the
draft permit has been noticed and all interested parties have
had a chance to respond. Any decision to hold a public meeting
will be accompanied by a 30-day advance notice in the newspapers
previously listed.
Thank you again for your honest and straightforward comments. I
appreciate the opportunity to hear from citizens who are
concerned about the current and future quality of our State's
natural resources and I encourage you to continue your efforts
toward maintaining and improving our environment.
If you have any further questions or comments regarding this
matter, please contact either Mr. Trevor Clements or Mr. Arthur
Mouberry at [phone]. _
Sincerely,;
R. Paul Wilms
RPW:TC/am
CC: %Trevor—Cl-ementst4
Arthur Mouberry
Ken Eagleson
Steve Mauney
Central Files

RE .:EiVED
?CRi,QiiS & NQG�Ni�RuNt,
Mr. Paul Wilms
Environmental Management Comm.
P.O. Box 27687
Raleigh N.C. 27611
Dear Mr. Wilms:
June
Rt .
East
,M
k
17 1989
4 Box 37
Bend, N.C. 27018
KT�l reos%
3llp( 22 , ]989
``I" N ADMINISTRATIVE SERVICES
It has come to my attention this week that the
Park has filed an application to increase the
treated wastewater from 10,000 gal per day to
RESOURCE NIANAGEMENT.
East Bend Industrial
discharge of so-called
50,000 gal per day.
As a downstream property owner I am outraged at the possibility that
this application might have been approved without the concerned
property owners on the downstream side of the discharge point being
informed. The county manager Mr. Mashburn was unable to answer my
questions concerning whether or not a ublic notice had be
or just how man days the_ -u. -_.i.c--no_t.i-ce--would sted
w icn paper t,he—no-tice would run. Please advisp me by raturn letter
. 4 o"
-N00064
e
ice and in whice
---Although the present public notice process may satisfy
requirements of the statue, the procedure does little to
affected area and the residents of this area..........
I object to the approval of this application to increase the discharge
from 10,000 gal. per day to 50,000 gal. per day as I and my farming
operation will be directly affected by this increase if this
application is approved and so will be many of my neighbors downstream
of the discharge point. My farm borders the stream Justice Reynolds
creek, refered to as unnamed tributary of Yadkin River, on both sides
of the creek for well over one quarter mile on each side of the stream.
In fact the present discharge point into.this stream is only a few
hundred yards upstream from my property line.
jI herby state my determained opposition to the approval of this
application and urge that the application be denied approval, for
the following and other reasons. In addition I Request A Public
Hearing on this application'here in Yadkin County.
Primary Obiections to the ADDroval of this Application NCO064726
1. The flow rate of this stream in question is far below
10,000 gal per day at the discharge point. Most of the
stream flow at the discharge point and below on my farm
would consist of waste water if even 10,000 gal were
discharged per day let alone 50,000 gal per day.
Have you actually measured the flow rate of this stream
during a dry period or even a typical day ? I think not,
although some calculations may have been made in your
office concerning flow rate.

(2)
R
F
r
i,
Damage to Aquatic life in the stream below the discharge
point would surely result if the application to increase
the Waste Water discharge rate to 50,000 gal per day.
There is an abundance of small fish,crayfish, snails
ect. This indicates to me that at present the water
quality is quite pure........ We should insure that it
remains that pure. It could quickly become a dead stream
unfit for human consumption, unable to support any life
systems if item 15 on this application is allowed, ie.
the discharge of DEADLY POISIONS into this stream, such
as those mentioned on the application ie. Cyanide,
Beryllium, Cadmium, Chromium, Lead, Mercury, Nickel,
Selenium, Phenols. We know that these and other toxic
substances have no place in our streams now or EVER....
The Stream is frequently utilized for receration by
young children playing and wading ect. I played in this
stream when I was a child, my son and his cousins played
in this stream. Furthur downstream there is evidence
that other families small children utilize the stream
for recerational use as well including, but not limited
to the lake at the Historic Butner -Allgood Water Powered
Mill Site.
The Stream has been utilized on my 400 plus Acre farm,
to water Tobacco Plant Beds and Is our primary water
supply when transplanting Tobacco. During these periods
of usage the water frequently comes into contact with the
skin of the farm worker.
This pure stream serves as the primary drinking supply
for livestock, cattle and horses, below the discharge
point. Although at present we have no livestock on our
farm many of my neighbors downstream do. I am quite
sure they do not wish to have their cattle consuming
Waste Water treated or not. If the heavy metals and
salts mentioned in item 15 on the application are
deposited in the stream the cattle and those people
who consume the meat from those livestock could be at risk.
Quality and length of life are more important than
economic growth in my view.
The county or E.B.I.P. has demonstrated no immediate
need to discharge 50,000 gal per day into this stream.
At present they are not discharging but a small fraction
of the presently authorized 10,000 gal per day. This
is an attempt to Reserve the future capacity for the
E.B.I.P. for some future need. The Preservation of
surface is to important to write this blank check on our
our future.

(3)
7. The most important landmark in eastern Yadkin
County, The Butner -Allgood Water Powered Mill
and the 8 acre lake are located some 2to 3 miles
downstream from the discharge point. Besides the
natural historic value of this structure, it provides
swimming and boating recreation in addition to the
opportunity to fish in natural pure clean water.
We do not wish to destroy the life in this millpond
by the upstream discharge of sewage from the E.B.I.P.
Instead we wish to preserve and to maintain this
most important surface water natural resource which
has been utilized and enboyed by the people of our
community and our county for several generations......
This SENIC AND VALUED AREA MUST NOT BECOME A REPOSITORY
OF THE CHEMICAL_ AND UNSANITARY WASTE FROM THE EAST BEND
This lake is not the place to dispose of Industrial Waste
which in the future could contain Cyanide, Zinc Mercury
and Phenols...... see application item 15 of NCO064726
It is of paramount importance to conduct a Bathos Study of the
stream bed area in order to clearly establish a benchmark as to
what life systems are now present in this stream ie. the Justice
Reynolds Creek. This inventory of Aquatic life and the associated
study will provide documation which can be utilized in future years
to establish whether or not damage has been done to the stream.
' This assesment of the conditions which now exist in this clear
clean stream may be impossible to make in the future. Now is the
proper and prudent time to conduct such a study.........
The future of our surface water resources are at stake. We need
a standard to compare future water quality against. Without it
future measurements will be of quistionable validity.
I am convinced that we the downstream affected taxpaying property
owners are entitled to protection from the intended or theu.uhioten-
tional contamination of this unspoiled stream.
Please advise promptly concerning my following concerns and request.
1. The.'Request for a Benthos Study
2. The Request for an Environmental Impact Study
of the creek ecology, the citizenry downstream
and ofcourse the Butner -Allgood Mill and Millpond
3. The request for a public hearing here in Yadkin
County after the above studies have been completed

(4)
Holding a public hearing as a mere formality before the
results of the above studies are complete, would constitute
a violation of public trust and fairness.
This application NCO064726 should not be approved or even
considered until the data from the above studies has been
collected and analyzed. The results of the above studies
should be provided to those parties opposed to and to those
parties favoring the approval of this application.
At this time and only then should a hearing on this application
be set. By adherence to the policy outlined above an intelligent
and prudent decision can result.......
Yours truly
William R. Smitherman
Copy to:
Mr. Jim Johnston
N.C. Dept. Of Natural Resources and Community Dev.
Winston Salem, N.C.
The commissioners of Yadkin County
Other Interested Parties