NC0082949_Permit Modification_20130107

NPDES DOCW4ENT SCANNING% COVER SHEET
NC0082949
Denton WTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Technical Correction
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
January 7, 2013
This document is printed on reuse paper - ignore any
content on the reYerse side

ern
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P.E. John Skvarla
Governor Director Secretary
January 7, 2013
Ms. Tammie Melton, Water Treatment Plant Superintendent
Town of Denton
P. O. Box 306
Denton, NC 27239
Subject: NPDES Permit Modification
Town of Denton WTP
NPDES Permit NC0082949
Davidson County
Dear Ms. Melton:
The Division of Water Quality has reviewed and approved your application for minor modification of
the subject permit. Accordingly we are forwarding the attached modified permit page. Please remove
the existing "Effluent Limitations and Monitoring Requirements" page and replace it with the one
attached to this letter.
Please note that thei modification that has been granted differs from what you requested in your
December 18, 2012 correspondence. Your request asked for an extension of the deadline for installation
of a continuous flow monitoring device as established in the subject NPDES permit. The Division's
NPDES permitting strategy for conventional water treatment plant discharges has been modified since
the permit was most recently renewed, changing the flow threshold at which the Division would require
continuous flow monitoring. A review of reported flow data from the facility shows monthly average
flow values fall below the criterion within the strategy, and therefore, continuous flow monitoring is not
required. As a result, the permit modification removes the requirement that continuous flow monitoring
be conducted, and weekly, instantaneous monitoring shall remain the requirement for flow until the
permit's expiration. Because this change will affect matters associated with the completion of discharge
monitoring reports, the modified monitoring requirement has been made effective January 1, 2013.
This modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1
and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency dated October 15, 2007 (or as subsequently amended).
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or
Local governmental permit that may be required.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX [phone]
Internet www.ncwaterquardy.org
An Equal opportunity 1 Affirmative Action Employer
None Carolina
J1�aturallr�

Ms Tammie Melton
NC0082949 Town of Denton WTP Permit Mod.
p. 2
If you have any questions concerning this permit; please contact Bob Sledge at telephone number (919)
807-6398 or via e-mail at [e-mail].
Charles Wakild, P.E.
cc: Central Files
Winston-Salem Regional Office/Surface Water Protection Section
NPDES Permit File
ec: Aquatic Toxicology Unit

Permit NC0082949
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Duringtheperiod e beginning on January 2 and lastinguntil expiration, the Permittee is authorized
bg garyl, 013
to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
` EFFLU€NT
CH,�ARACTERISTI.
: LIMITS
: MONITORING REQUIREMENTS
.
Monthly
Average
Daisy
Maximum .
Measurement
==µ r
Frequency `.
Sample Type '
Sample Location
Flow
Weekly
Instantaneous
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
Total Residual Chlorine1'
17 pg/L
2/Month
Grab
Effluent
pH2
2/Month •
Grab
Effluent
Turbidity
2/Month
Grab
Effluent
Aluminum
Quarterly3
Grab
Effluent
Manganese
Quarterly3
Grab -
Effluent
Fluoride
Quarterly3
Grab
Effluent
Total Zinc
Quarterly3
Grab
Effluent
Total Copper
Quarterly3
Grab
Effluent
Total Iron
Quarterly3
Grab
Effluent
Total Nitrogen
Quarterly3
Grab
Effluent
Total Phosphorous
Quarterly3
Grab
Effluent
Whole Effluent Toxicity4 '
Quarterly
Grab
Effluent
Footnotes:
1. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance
with the permit. However, the Permittee shall continue to record and submit all values reported by
a North Carolina certified laboratory (including field certified), even if these values fall below 50
AWL
2. The pH shall not be less than 6.0 standard units, nor greater than 9.0 standard units.
3. Monitoring should be performed in conjunction with toxicity testing.
4. See Condition A. (2.) for toxicity testing requirements. Toxicity sampling should coincide with
sampling for parameters covered by footnote 3.
All samples collected should be of a representative discharge.
There shall be no floating •solids or foam in other than trace amounts.

AwA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Memorandum
To:
Through:
From:
Date:
Re:
Jeff Poupart9
Tom Belnick132,
Julie Grzyb
10/14/2009
Changes to Water Treatment Plant Strategy (October 2009)
I. Flow Limit and Monitoring
• Remove Flow Limit on all WTPs
Unlike Wastewater treatment plants, flow data has not been used as much in the design of
backwashing treatment units. Also, flow data from Discharge Monitoring Reports will be available
to perform Reasonable Potential Analyses. Finally, WTP strategy still precludes new or expanding
RO/IE plants to freshwater streams.
• Require Continuous flow monitoring for Conventional and RO facilities discharging
50,000 gallons per day. (previous policy > 10,000 gpd)
Facilities discharging less than 50,000 gpd and intermittent dischargers require instantaneous flow
measurements along with the duration. Many facilities with wastewaters less than 50,000 gpd
discharge to POTWs or are considering discharging to a POTW. The WTP strategy which includes
additional testing by the Pernuttees is facilitating such decisions and removing the necessity for
smaller facilities to purchase recording equipment seems prudent at this time.
Note: Ion Exchange and Green Sand WTPs require instantaneous flow measurements along with the
duration. The monitoring frequency for flow should be as frequent as the minimum frequency of
monitoring for any parameter listed.
II. Calcium and Magnesium (Conventional WTPs, not parameters of concern in other WTPs)
• Remove monitoring for calcium and magnesium from the Conventional WTP effluent page.
There is no Water Quality Standard for Calcium or Magnesium. As a result, there is no limit to
compare the data obtained from monitoring these parameters.
III. Changes to tonics monitoring:
• Conventional WTP Effluent page: To make permitting less complicated, monitoring for fluoride,
zinc, copper and iron were changed to quarterly sampling to align with quarterly sampling of
aluminum, manganese and toxicity testing. Previously it was monthly if discharge < 0.5 MGD and
2/month if discharge > 0.5 MGD.
• Green Sand WTP Effluent page: To make permitting less complicated, monitoring for fluoride,
zinc, manganese and iron were changed to quarterly sampling. Previously it was monthly if
discharge < 0.5 MGD and 2/month if discharge > 0.5 MGD.
1617 Mail Service Center. Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] t FAX' 919-807.64921 Customer Service: 1-877-623-6748
Internet: www.nrwaterquality.org
An Equal Opportunity 1 Affirmative Ac .ien Employer
North Carolina
Natural/If

Month Year Value UoM
1 2006 0.00675 mgd
2 2006 0.0019 mgd
3 2006 0.0022 mgd
4 2006 0.001925 mgd
5 2006 0.001728 mgd
6 2006 0.003775 mgd
7 2006 0 01135 mgd
8 2006 0.01208 mgd
9 2006 0.00325 mgd
10 2006 0.01185 mgd
11 2006 0.0039 mgd
12 2006 0.00485 mgd
1 2007 0.0039 mgd
2 2007 0.005925 mgd
3 2007 0.002725 mgd
4 2007 0.004325 mgd
5 2007 0.00474 mgd
6 2007 0.011875 mgd
7 2007 0.005925 mgd
8 2007 0.00432 mgd
9 2007 0.00485 mgd
10 2007 0.00602 mgd
11 2007 0.003775 mgd
12 2007 0.003775 mgd
1 2008 0.00346 mgd
2 2008 0.002975 mgd
3 2008 0.004325 mgd
4 2008 0.00518 mgd
5 2008 0.00485 mgd
6 2008 0.002725 mgd
7 2008 0.0039 mgd
8 2008 0.008633 mgd
9 2008 0.007 mgd
10 2008 0.0039 mgd
11 2008 0.002975 mgd
12 2008 0.0024 mgd
1 2009 0.002725 mgd
2 2009 0.002975 mgd
3 2009 0.00325 mgd
4 2009 0.00376 mgd
5 2009 0.003775 mgd
6 2009 0.003775 mgd
7 2009 0.00582 mgd
8 2009 0.0073 mgd
9 2009 0.01782 mgd
10 2009 0.002975 mgd
11 2009 0.00485 mgd
12 2009 0.00432 mgd
1 2010 0.005925 mgd
2 2010 0 009725 mgd
NC0082949
Town of Denton WTP
Monthly Avg. Flow Values 2006 - 2012
Month Year Value UoM
3 2010 0.0067 mgd
4 2010 0.0046 mgd
5 2010 0.004325 mgd
6 2010 0.00496 mgd
7 2010 0.007675 mgd
8 2010 0.0086 mgd
9 2010 0.0043 mgd
10 2010 0.004575 mgd
11 2010 0.00865 mgd
12 2010 0.00476 mgd
1 2011 0.004025 mgd
2 2011 0.005125 mgd
3 2011 0.00474 mgd
4 2011 0.001925 mgd
5 2011 0.007575 mgd
6 2011 0.0103 mgd
7 2011 0.005925 mgd
8 2011 0.00864 mgd
9 2011 0.005925 mgd
10 2011 0.0081 mgd
11 2011 0.00776 mgd
12 2011 0.0043 mgd
1 2012 0.005125 mgd
2 2012 0.00324 mgd
3 2012 0.002675 mgd
4 2012 0.004325 mgd
5 2012 0.010329 mgd
6 2012 0.0051 mgd
7 2012 0.009175 mgd
8 2012 0.0186 mgd
9 2012 0.007 mgd
Period of Review Maximum = 0.0186 MGD

December 18,1012
NC Division of Water Quality
Compliance and Expedited Permits Unit
Attn: John E.I,Hennessy, Supervisor
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDE Permit Compliance — Extension Request for Flow Monitoring Requirement
Town of Denton WTP
NPDES Permit NC0082949
Davidson County
Mr. Hennessy:
In the Town's quest to meet the permit compliance objectives outlined under their current
NPDES permit, the Town has received Authorization to Construct approval from DWQ and
PWS for upgrades to the existing facility including construction of a new 200,000 gallon
backwash lagoon, sludge transfer pump station, continuous flow monitoring, and drying beds (2)
to improve alum sludge residuals management at the existing Denton WTP (see attached
drawings). These improvements (PROJECT) will allow the Denton WTP to address compliance
initiatives including the continuous flow monitoring as well as chlorine and toxicity
requirements. However, in order to be cost effective for the Town, the improvements need to be
accomplished under a comprehensive project as there is not currently electrical service in this
area of the treatment facility.
As of my e-mail correspondence of March 8, 2012 to NC DENR / DWQ / NPDES unit; Denton
had presumably received all approvals necessary to proceed with construction. However, the
timeline of events below have delayed the Town of Denton in meeting these objectives:
• March, 2012 — NC DENR / PWSS informed the Town of Denton they were to receive $2.4 M in
principal forgiveness and the remaining $1.204M in 0% loan under the 2011 DWSRF
program. We discussed with Denton and replied to NC DENR / PWSS by e-mail we desired
these terms.
• March,12012 — Denton requested clarification from DWQ on expectations for NPDES permit
compliance via my e-mail of March 8, 2012
• April 4, 2012 —NC DENR / DWQ NPDES unit supplied a letter to Town of Denton outlining
several compliance requirements including a deadline of January 1, 2013 for continuous flow
measurements and stating the facility may be subject to appropriate enforcement action beyond
this deadline, as addressed in the current NPDES permit
• 3/22/12 —NC DENR / PWSS formally submitted the PROJECT request to LGC for approval with
the loan terms outlined above
• 6/4/12 —NC DENR / PWSS notified the Town of Denton's engineering agent via e-mail "there
were additional documents needed before they could issue the Part A (Offer and Acceptance of

the Loan Agreement)" including an update to the Town's Water System Management Plan
(WSMP) and a clear site certification. Prior to 6/4/12, we had reasonably assumed we had met
RTP status based upon the prior submittals deeming the WSMP complete. We received no
indication to the contrary from PWS between 3/22/12 and 6/4/12. The clear site certification
was submitted in August, 2012, with the updated WSMP, but could have been submitted at any
time prior to 5/31/12 had it been communicated to us we were not in RTP status as of 3/22/12
when the project went forward to LGC. As stated, there were no land acquisition requirements
associated with the project.
• July, 2U 12 - LGC approved the financing terms
• June through August — HUA and Denton staff worked diligently updating the WSMP. Denton
had a new Town Manager so this led to some delays in gathering documentation
• 8/23/12 — WSMP was submitted
• 10/23/12 — NC DENR / PWSS notified Denton's engineering agent the Town of Denton would
not be eligible for principal forgiveness since we had not met RTP status by May 31, 2012.
Prior to 6/4/12, we were operating under the presumption we had already met RTP status based
upon the facts above and the 3/22/12 correspondence by NC DENR/PWSS to LGC.
• 10/25/12 — Town of Denton supplied NC DENR / PWSS with a timeline of events and submittals
demonstrating we had previously met the terms of RTP status by May 31, 2012.
• 10/30/12 — Per telephone conversation between NC DENR / PWSS and Denton's engineering
agen, NC DENR / PWSS acknowledged a mistake had been made and they intended to make
the original loan offer whole again
• 12/18/12 — Per discussion between NC DENR / PWSS and Denton's engineering agent, the Part
A Offer and Acceptance of Loan agreement would be mailed to Denton by the end of this
week, thus allowing the project to proceed under the following estimated schedule
oReceipt of Part A Offer of Loan Agreement — 12/21/12
oAcceptance of Loan Agreement and Approval of Minority Business Requirements and
other Construction Contract Documentation requirements associated with DWSRF
approvals —1/25/13
oBid Opening Date — 2/28/13
oBid Award and Approvals by NC DENR — 3/29/13
oConstruction Start — 4/1/13
oConstruction Completion — 7/1/14
We respectfully request assistance from the NPDES unit to provide an extension to the existing
NPDES permit continuous flow monitoring deadline of January 1st, 2013 to allow for completion
of construction under Denton's comprehensive plant improvement project. We appreciate your
assistance in our efforts and let us know if we may provide anything additional.
Sincerely,
TOWN OF DENTON
\L-A--2--93 •
Tammie Melton
Denton WTP Superintendent
Cc: Mr. Victor Pizzurro, Denton Town Manager
Mr. Bob Sledge, NPDES Unit
Bradley H. Bucy, P.E., Hobbs, Upchurch & Associates, P.A.
Attachments

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• Sledge, Bob
From: Brad Bucy [[e-mail]]
Sent: Monday, December 17, 2012 5:06 PM
To: Sledge, Bob
Cc: 'Victor Pizzurro'; 'Scott Morris'
Subject: FW: Denton
Attachments: 20121217170207173.pdf
Importance: High
Bob:
As a follow up to my previous voicemail, the attached minor modification to the Denton NPDES permit extended the
deadline for continuous flow monitoring until January 1, 2013. Unfortunately, the financing for the referenced
comprehensive upgrade, including improvements to the wastewater residuals including expanded lagoons, on -site
drying beds, and flow monitoring has been delayed as funds were rescinded and then reinstated per the e-mail below
from Doug Newhouse at NC DENR / PWSS.
On behalf of Denton, we respectfully request an additional extension to allow for implementation of these
improvements. To install the continuous flow monitoring requires an expensive extension of the electrical service to the
monitoring point which was incorporated in the approved plans. With the current issuance of the Part A Loan offer from
DWSRF, the project is expected to be bid no later than March, 2013 and the improvements to the residuals including the
continuous flow monitoring will be installed in the 2013 calendar year.
Please give me a call (704.512.9008)if you have any questions or if I can provide additional information.
Thanks!
Brad
Bradley H. Bucy, P.E.
Hobbs, Upchurch & Associates, P.A.
9140 Arrowpoint Blvd., Suite 120
Charlotte, NC 28273
704.342.3000
From: Newhouse, Doug[mailto:doug.newhouseOncdenr.govl
Sent: Tuesday, December 04, 2012 1:51 PM
To: bbucyCu�hobbsupchurch.com
Subject: Denton
Importance: High
Brad -- I will be drafting Denton's Part A letter this week. It will be the Part A they're expecting
to get. I'll notify you when it's been mailed. You're receiving this message b/c I was asked to
respond to your recent inquiry to Vince regarding the status of the funding. I trust this news will
be agreeable to all persons involved. Best regards -- DN
Doug Newhouse
Funding -Application Reviewer/Contact
NCDENR Regions: Asheville, Mooresville & Winston-Salem
Loan & Grant Unit
1