NC0064726_Permit Issuance_19920310

NPDES DOCUMENT SCANNING; COVER SHEET
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:
March 10, 1992
Thies document is printed on reuse paper - ignore any
content on the raw -ex -se side

Adjudications 1
ast Bend Ind Park - Yadkin Co.
rmit No. NC0064726
Issued: 1/22/91
RS: Steve Mauney Winston-Salem
Attorney: Betsy Rouse
Region Req: 3/13/91
Recv: 3/19/91
•:L
}
Items Adjudicated:
Denial of relocation of outfall.
Intent to deny permit renewal.
omments:
;Case No.
Env Sci
County: Yadkin
A<`r Reviewer•
Dale Overcash
00/00/00
...........
Recv 00/00/00:..<
Recv:< 3/1,5/
.........:..:..:...:.:.:..............::L:I.Av.41v}.5}i}.Y:•'.•:ik•:Gh�}X•}•fi}:4}'�
Petition Date: ?< 2/27/91
[emo to AG.
Resol - d:
Revised Permit:::
00/00/00
GH2O Req:k;.:,..::...::.:...:.:.:.::::.......,$
yy Recv•$ 00/00/.
�iYhri.}:Lv}�.•.i.Y}:.}}: L.:v}Y.i.YRi. i:{ix:$:::?...$i:$:Liv�/.•M.
41,
'i h•
r ti
..,,ry:tiyti'�k�{ALC L}�ii' i-0:i.'
:.LCjiL:4:l
- ::•h:$:
?v
�.H.
v
fi:;'+}:i}:M1:}L':'i�':'kC•
h.4
}
..
n'+i$'N
•
17/isit�ITl7lT�ilffrlrlT/T!T!T/TfTIT.T/T:�/TITLTIrlTIT AIT IT lT /TA,-/TTIT IT IT:T IT fT /T rTr

r,
CERTIFICATE OF SERVICE
I hereby certify that.I have caused the attached NOTICE OF
WITHDRAWAL OF PETITION to be served on Respondent, by having same
deposited in the United States Mail bearing sufficient postage for
delivery by first class mail and addressed as follows:
March 10, 1992
Date
Elizabeth Rouse
Associate Attorney General
N.C. Department of Justice
P. O. Box 629
Raleigh, North Carolina 27602-0629
Attorney for Respondent
X
ames L. Graham
Attorney for Petitioner
P. O. Box 625
Yadkinville, NC 27055
919-679-8082

STATE OF NORTH CAROLINA
COUNTY OF YADKIN
YADKIN COUNTY
Petitioner
CC: J-- 0,k_
r ov a-✓
Sf MotkvvvAi
f
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
FILE NO. 91 EHR 0193
v. NOTICE OF WITHDRAWAL OF PETITION
NORTH CAROLINA DEPARTMENT
OF ENVIRONMENT, HEALTH, AND
NATURAL RESOURCES
Respondent
Petitioner hereby gives notice of settlement of all matters of
controversy addressed in the Petition filed in this matter and
Petitioner hereby withdraws said Petition.
This the /0 day of March, 1992.
Ja.�es L. Graham
Attorney for Petitioner
P. 0. Pox 625 Yadkinville, NC 27055
919-679-8082

James G. Martin, Governor
William W. Cobey, Jr., Secretary
Charles S. Mashburn
PO Box 146
Yadkinville, NC 27055
State of North Carolina
of Environment, Health and Natural Resources
Department ement
Division of Environmental Management
27611
512 North Salisbury Street' Raleigh, North Carolina
George T. Everett, Ph.D
Director
December 11,1991
Subject: Permit No. NC0064726
East Bend Industrial Park
Yadkin County
Dear Mr. Mashburn:
• discharge permit received on December 31, �Oo thew
In accordance with your application for dl germit. This permit is issued pursuant herewith the subject state - NPDES permit.
and the Memorandum Agreement
areeforwarding dated December Agreement
' menu of North Carolina General Statute 143�-,�2 ��on agency
require Carolina and the US Environmental
between North permit are
sampling requirements contained in this within
uencies or samp g eq heanng upon written rein are
H anb parts, measure aVe thegright to an adjudicatory in the form of a written
unacceptable to you, you h uest must be
thirty (30)days following receipt of this letter. This Carolina General Statutes, and filed W127611
petition,
y to Chapter 150B of the North• at North Carolina
Office
co forming P .
P � istrative Hearings, Post Office Drawer 2744�7 and
binding.
Office of Adnun
-7447.
Unless such demand is made, this decision shall be
Please take notice this permit to
is nottransferable. Part II, E.4. addresses the requirements
be followed in ca
se of change in ownership or control of this discharge.
legal requirements to obtain other permits which icmay be
This permit does not affect the q required by t permit
• Division of Environmental Management perral mits Local governmental
required by the
Resources,f
Coastal Area Management Act or any other
Land
that may be required.
• this permit, please contact Mr. Jule Shanklin at
If you have any questions concerning
telephone number 919/733-5083.
cc: Mr. Jim Pam Regional Office
tri, EPA
Winston -Sale g
Sincerely,
Original Signed By
Geol318oigAgtrett
Pollution Prevention Pays 919 733-7015
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone
An Equal Opportunity Affirmative Action Employer

Permit No. NC0064726
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Yadkin County
is hereby authorized to discharge wastewater from a facility located at
East Bend Industrial Park
on NC Highway 67
East Bend
Yadkin County
to receiving waters designated as an unnamed tributary to the Yadldn River in the Yadkin -Pee Dee
River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall
become effective February 1,1992
This permit and the authorization to discharge shall expire at midnight on May 31, 1994
Signed this day
December 11, 1991
original Signed By
George T. Everett
George T. Everett, Director
Division of Environmental Management
By Authority of the Environmental Management Commission

Permit No. NC0064726
SUPPLEMENT TO PERMIT COVER SHEET
Yadkin County
is hereby authorized to:
1. Continue to operate an existing 0.010 MGD extended aeration treatment plant located at East Bend
Industrial Park, on NC Highway 67, East Bend, Yadkin County (See Part III of this Per
mit), and
2. After receiving an Authorization to Construct from the Division of Environmental Management,
relocate Outfall 001 to the point identified as "Proposed Discharge Point", and
3. Discharge from said treatment works at the location specified on the attached map into an unnamed
tributary to the Yadkin River which is classified Class WS-III waters in the Yadkin -Pee Dee River
Basin.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31) Permit No
. NC0064726
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge
outfall(s) serial number 001- EXISTING DISCHARGE POINT. Such discharges shall be limited and monitored b from
below: y the pe rmi tottee as specified
Effluent Characteristics
Discharge Limitations
Monthly Avg,
Flow 0.010 MGD
BOD, 5 Day, 20 °C*** 5.0 mg/I
Total Suspended Residue*** 30.0 mg/I
NH3 as N 1.0 mg/I
Dissolved Oxygen**
Fecal Coliform (geometric mean) 200.0 /100 ml
Total Residual Chlorine
Temperature
Conductivity
Oil and Grease
30.0 mg/I
Weekly Avg, Daily Max
7.5 mg/I
45.0 mg/I
400.0 /100 mi
Monitoring
Measurement
Frequency
Weekly
2/Month
2/Month
2/Month
Weekly
2/Month
Daily
Weekly
Weekly
45.0 mg/I 2/Month
Requirements
Sample
LYPQ
Instantaneous
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
*Sample
Location
1 or E
E,
E, I
E
E, U, D
E, U, D
E
E, U, D
U, D
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 100 feet, D - Downstream at old dragstrip
** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
*** The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15 % of the respective
(85 % removal), pe a influent value
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent ent by grab
Them shall be no discharge of floating solids or visible foam in other than trace amounts.

A. ( )..e.i.FLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1- March 31) Permit No. NC0064726
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001- EXISTING DISCHARGE POINT. Such discharges shall be limited and monitored by the permittee as specified
below:
Effluent Characteristics Discharge Limitations
Monitoring Requirements
Measurement Sample *Sa m a le
Monthly Avg, Weekly Avg* Daily Max Frequency IY1/2 Location
Flow 0.010 M3D Weekly Instantaneous I or E
BOD, 5 Day, 20 °C*" 10.0 mg/I 15.0 mg/I 2/Month Grab E,l
Total Suspended Residue*** 30.0 mg/I 45.0 mg/I 2/Month Grab E,I
NH3 as N 1.8 mg/I 2/Month Grab E
Dissolved Oxygen'" Weekly Grab E, U, D
Fecal Coliform (geometric mean) 200.0 /100 mi 400.0 /100 mi 2/Month Grab E, U, D
Total Residual Chlorine Daily Grab E
Temperature Weekly Grab E, U, D
Conductivity Weekly Grab U, D
Oil and Grease 30.0 mg/I 45.0 mg/I 2/Month Grab E
* Sample locations: E - Effluent, I - Influent, U - Upstream 100 feet, D - Downstream at old dragstrip
** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
*** The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15 % of the respective influent value
(85 % removal).
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
outfall(s) serial number 001- PROPOSED DISCHARGE POINT. Such discharges shall be limited and
below:
Effluent Characteristics
Flow
BOD, 5 day, 20°C"
Total Suspended Residue"
Dissolved Oxygen*"
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Conductivity
Oil and Grease
NH3 as N: Summer (Apr.1-Oct.31)
NH3 as N: Winter (Nov.1-Mar. 31)
* Sample locations: E - Effluent, I - Influent, U - Upstream at least 100 feet, D - Downstream at least
300 feet
** The monthly average effluent BODS and Total Suspended Residue concentrations shall not exceed
% removal). 15 % of the respective influent value (85
*** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/1.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monito
sample. red 2/month at the effluent by grab
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Discharge _Limitations -
Permit No. NC0064726
is authorized to discharge from
monitored by the permittee as specified
Monthly Avg,
0.010 MGD
30.0 mg/I
30.0 mg/I
Weekly Avg,
45.0 mg/I
45.0 mg/I
200.0 /100 ml 400.0 /100 ml
30.0 mg/I
3.5 mg/I
12.0 mg/I
Daily Max
Monitoring
Measurement
.Frequency
Continuous
2/Month
2/Month
Weekly
2/Month
Daily
Weekly
Weekly
60.0 mg/I 2/Month
2/Month
2/Month
Requirements
Sample *Sample
I,YDA Location
Recording I or E
Composite E, I
Composite E,I
Grab E, U, D
Grab E, U, D
Grab E
Grab E, U, D
Grab U, D
Grab E
Grab E
Grab E

NPDES WASTE LOAD ALLOCATION
foi1 461-to
PERMIT NO.: NC0064726
PERM( 1'1LE NAME:
FACILITY NAME:
Yadkin County
East Bend Industrial Park
Facility Status: Existing
Permit Status: Renewal*
Major Minor
Pipe No.: 001
Design Capacity: 0.010 MGD*
Domestic (% of Flow): 100 %
Industrial (% of Flow):
Comments:
* NOTE: See attached letter draft.
** cf. #5196 A&B
STREAM INDEX: 12-(71)
RECEIVING STREAM: an unnamed tributary to the Yadkin River
Class: WS-III
Sub -Basin: 03-07-02
Reference USGS Quad: C17NW
County: Yadkin
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 6/30/91 Treatment Plant Class: 2
Classification changes within three miles:
na
Requested by:
Prepared by:
Reviewed by:
OODut-t 2
wp/et,
Jule Shanklin
(please attach)
4. O N : 9�lto%i
Date: 1/16/91
4. (,{,�66. - - Date: a/o /q t
A
Date: I of / ci
(2/2.3•I
Modeler
Date Rec.
#
S ktk
9 /tm/li
6,1- 3G1
(A)
Drainage Area (mi ) S Avg. Streamflow (cfs):
7Q10 (cfs) 0.0 Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % Acute/Chronic
Instream Monitoring:
Parameters 7).0. j CEca co—r, `fit nn P tNn11)1.4c.rt u I r 1 C►lL012-1^
Location i]r l,6A5 T k x / uP Gip
Location Pr r ta:A Sr .90 / P9)
iodo0+-p Ii
t7-1
Upstream
V
Downstream Y
Effluent
Characteristics
Summer
Winter
BOD5 (mg/1)
s
1 u
NH3-N (mg/1)
148
D.O. (mg/1)
G
(o
TSS (mg/1)
3o
3 0
F. Col. (/100 ml)
200
Zo€
pH (SU)
G _9
Co 1
€ tt, `+c C< `7 ( pjj
3d C(oo V/$10A:)
30 (60 D41Ly #
Tut_ P.t;s. Git.00tli.
M& Ni t
i o R
flh1TTF
PI
Comments:

gAir
NPDES WASTE LOAD ALLOCATION ` 043
•
PERMIT NO.: NC0064726
PERMITTEE NAME:
FACILITY NAME:
Yadkin County
East Bend Industrial Park
Facility Status: Existing
Permit Status: Mottri Gi-rroN (ggcAC-ATion1�
Major Minor
Pipe No.: 001
Design Capacity: 0.010 MGD*
Domestic (% of Flow): 100 %
Industrial (% of Flow):
Comments:
* NOTE: See attached letter draft.
** cf. #5196 A&B
STREAM INDEX: 12-(71)
RECEIVING STREAM: an unnamed tributary to the Yadkin River
Class: WS-III
Sub -Basin: 03-07-02
Reference USGS Quad: C17NW
County: Yadkin
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 6/30/91 Treatment Plant Class: 2
Classification changes within three miles:
na
(please attach)
Requested by: Jule Shanidin Date: 1/16/91
Prepared by: - �(,Q,te,-t-- Date: 5 3o qt
Reviewed by: 'Q Date: l 0(00,e get
GOP taw!' t
Modeler
Date Rec.
#
sAwJ
l/ic/c l
Co+3c1
l Drainage Area (mi) 0. 32. Avg. Streamflow (cfs): 0. �3
C&>
7Q10 (cfs) B. 05 Winter 7Q10 (cfs) 0. I 30Q2 (cfs)
Toxicity -Limits: IWC
Instream Monitoring:
Parameters 1)• 0 ,,
Upstream Y
Downstream Y
% Acute/Chronic
Ec,4 L CsoL._, Trr, Ca Ai trucTJ Jt r1 eo(t -OtZ04
Location Arr LAST (00 ' ur5.rr w1 t 'ti
Location r : 3..0 ' Po w.N
meJO
Effluent
Summer
Winter
,Characteristics
BOD5 (mg/1)
-5c7
3 o
N3-N (mg/I)
3.
I Z
D.O. (mg/1)
5
5"
TSS (mg/1)
30
30
F. Col. (/100 ml)
Zoo
jo o
PH (SU)
G — '1
Co _ 9
o IL. 4, 4e ,4 ( /0 ,
?7o Ow ;Am M )
3o (co vial A+AA)
'fir: fizs. Ciuoru,W4
/14-cKil To
(-
Comments: Frr2AIT WAS Pa- V1e U50/ TOED• T'1i5 WL4
grPt-twateNDEt, lam. Apis ?I'STRATroN.
0? to-

EAST -BEn1 D
4009
12'30"
4005
W
W
m
ra
4004
•
(L
1,
f�^ J
Jeir
°;
5\ - --f .MiII.er
0,4
0

Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WAS 1'ELOAD ALLOCATION
Request # (0431
E. Bend Industrial Park
NC0064726
Domestic - 100%
Existing
Renewal
UT Yadkin River
WS-III
030702
Yadkin
WSRO
J. Shanklin
C17NW
r RECEIVED
I.C. Dept. NRCD
SEP 2 0 1991
Winston-Salem
Regional Office
rn
-a
;v
Stream Characteristic:
USGS # �?
Date: Est 1987
Drainage Area (mi2): 70.32
Summer 7Q10 (cfs): gl.05
Winter 7Q10 (cfs): 0.1
Average Flow (cfs): 0.33
30Q2 (cfs):
IWC (%): 23.6
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
The existing discharge point is to a zero 7Q10 positive 30Q2 flow stream. The 9/91 mandated
draft permit (previously denied) indicates 5/1 limits for the zero flow location and secondary limits
when the facility relocates to the positive flow portion of the stream after the confluence of the two
UT's (at the drag strip).Technical Support recommends that, if the facility is to be permitted at the
site below the confluence, the limits given on page two should be maintained.
D.O. values less than 5 mg/1 have been reported both up and downstream. The facility is required
to perform acute toxicity monitoring monthly; LC50 values <3% have been reported. The facility
has also not been reporting toxicty tests on several occasions.
An A to C was issued in 1988 for 0.015 MGD1 bIA-per ws.►4 .15.Co b.014
SpeRial Schedule Requilpments and additional comments from Reviewers:
n /Ai"' I E oI � 11A-2 L7AU 0 t4s e DMiYu /4 / d `G' co /4,M,.v 4„/j444eit, /-1,
atRtatiy:�,,ar,-r• �,(/1�-- Date: A 7 /9
Reviewed by Instream Assessment: G // Date: q/1 7/6
Regional Supervisor: . — Date: 9 -2 1- l
Permits & Engineering: � �x a 0 o Oki can't Date: p! � r4/
RETURN TO TECHNICAL SERVICES BY: OCT 17 1991

Existing Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/I):
Fecal Cot. (/100 ml):
pH (SU):
Residual ¶h1orine (µg/1):
Oil & Grease (mg/1):
Recommended Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1)
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Residual Chlorine (4/1):
Oil & Grease (mg/1):
2
CONVENTIONAL PARAMETERS
Monthly Average
Summer
0.01
30
5
30
1000
6-9
30
Winter
0.01
30
5
30
1000
6-9
30
ex1M )6c0+ova.
Above confluence
7Q10 = 0.0
Monthly Average
Summer Winter
0.01
5
1
6
30
200
6-9
Mo►hroR
30 30
0.01
10
1.8
6
30
200
6-9
60(daily
max)
WQ or EL
vJ
vJQ
wq
**
Tgeloco,-4- \oA`
Below confluence
7Q10 > 0.0
Monthly Average
Summer Winter
0.01 0.01
30 30
3.5 12 **
5 5
30 30
200 200
6-9 6-9
Mom I vie
30 30
**NOTE** The facility should have choice between NH3-N limit (3.5/12) or chronic quarterly
toxicity tesing at 24%
Limits Changes Due To:
Relocation of discharge
New regulations/standards/procedures
New facility information
Parameter(s) Affected
BOD5, NH3-N,DO
Fecal coli
mandated relocation
w9
X Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.

3
INSTREAM MONITORING REQUIREMENTS
Upstream Location: at least 100 ft. upstream
Downstream Location: at least 300 ft downstream
Parameter: D.O., Fecal coliform, temperature, conductivity CLOr ► vim,
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adequacy of Existing Treatment
Has the facility deplonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
gpo gah ' bN 7f& Affri wa 440 he
Special Instructions or Conditions
Wasteload sent to EPA? (Major) _N (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
rmation attached? A (Y or N) If y es ex lain with attachments.
Additional Info) p

s r•
N C-00 c-7
r ! P pptit
w
wsM
-FE Pu f-co tohl._(.30750--uituTs)
! 1 ' -/ 7k 0,32 ," z
‘- ' - \cv� -7Pt °S-=-O.o5;-
/ *PJo
S& t7
�`VJ%'
— a %21P-Bt:-t00) OET
PRt:iv J t.Lu22jr) �.ocl4 S r
eta.1)A 14pote M42--
7QIos = 0.O c11
_3(-.94i. 0.01A
pea uses ctA0/8
szsa: Joc W i 87
i
E�
NoTe
# OZUS0S(h2 2knik6
�scs CAccL4j j 7 > b ; 0 .5SrLitie 77Lo, = 0.058 c-11 Jo.05 T0O.
! ReciOM 6S70MAire A M z A; WE SAA4 POI kir (Wall 7 9!0 s .0 8
sueeo2r CoNSuLI RD (45cs oN ► t l Al ivy c_-M46-- (AP cu rN
/ 5u4 Rill1
(DA• - �� " 0.3 ! 2 z I_ 1 '(05 ' 0,051 c-15_ (Below. Duct STR P_, Dam of ) - -
f 4 9 _44 ems- BkscU - one 7Q1t95 =OAS ch -- irLc_ q't.o wc-r"N rFlls
06 -- - -A -ro _C_ 15,
Ot
co 5PP 2_(Doui _KN W�Iy PF - 0.0k mc,:D)
r eandC1 F LED - A4AcN51 _ vrt r _ re._. _ i e_ Ac 75 To DowASTP-LAnc Pogo.
1/9I - L-Tf2 fg,1 -1Z1 ._ _._sr wi ENIf �__Of'ege,,ir MoiPlcA ftoAl �/�C�LoGli1DNl)_._rt.lZ_G.tm( S
- -M r?i D Cgga .-_gfro[ _ou, MIA1 y �T NATt �rfS - CAN q'(2._To Nod --7)i 5cAki-R4- — -- - - -
2/0 t9.Wr 06 _. l �1 �R 7a `DPW BwNr7 S iiN�' _i�1 Y O(ATL , LO.W - . -; .,43 ovc -
S0;►P-CX(5_7:144-.01..5c1-1.42N�14-41._0.44/75 tiPP-oy) - -
rF�orn WctN45 5TR r111Y 5 Z 4- vim- ur� ?o/Yo &ow - -
Diefiq
is/e--

NC Gq-7 24
WA WAS PaNIEPS'i Tag._ Sur'Pogr _toAi.cul2R d? U'/6D_. ,P 6,
in1T of )4_4p/rep DieRETIN_-_PEQMtr of
't _ 71.6 4 War?oti1 j- 30ZArsiii %&CFaw Ur -- �aGOEVClei
- Cf( _�uPPD2T /IA 77 w ie%tla✓ e) wLfl C) . r
(" EAI
l��yM y NGD r " _---- - . �3.= N77:9,k._--
a f/ACILI-7'�
e
/tt NT/kLy
� o - .717 _ CO , 0ICLC TY C ) 7(�
SrdCe- 107131
5/1o0._ 1ANy N s - RNA- LC, Ds' V gy- BAD
F14‘ -6e s'ery —2 _.-elrQiq [geM --Ad? VA Tor_
ln1D/ CAT6S 3?0, ' 5
__GMw,Nrc/�
C,tP_ bo wNS. ri- 04,N0 .. 0 _ `rM rr of
64-_ Qr'r1*AOC(SiVrietib---DF_ VI4 - or LocArro-_nl P covi ur AT b444 S7tt° - -
Cli
01 A4-1) i dos-0,-05; ?Qrvw =0,1
dill- N CRr--o JA&e) ' _ 3. S m/J 4n+nzcs j 12 q/. W i4JrOZ
71` Mott y 6trktGp i.1AVV Ci/alc AG N3 Ai L-uM1r C3.Sl.Z/ o2 Cao t.c .
C23, 4)
1OX (C (7 y 7 77 /q . f r lrrvc 2`f o — -

STATE OF NORTH CAROLINA
OFFICE OF ADMINISTRATIVE HEARINGS
September 25, 1991
Mr. James L. Graham
County Attorney
Post Office Box 625
Yadkinville, NC 27055
Mr. Edwin L. Gavin
Associate Attorney General
Post Office Box 629
Raleigh, NC 27602
NORTH CAR0U S 0FF10E
AITORNEI GENERAL
pL PROjEG?lON SECI10%
�►v►a0�°►"REallED
RE: Yadkin County v. N. C. Department of Environment,
Health and Natural Resources - Yadkin County -
91 EHR 0193
Dear Gentlemen:
This matter was stayed pursuant to the Respondent's
motion filed with OAH on June 11, 1991. The parties were to
let me know by September 3, 1991 whether or not they were
going to be able to settle this case.
Please let me know the current status of this matter at
your earliest convenience. I have delayed sending a
scheduling order in the other case involving Yadkin County,
91 EHR 0260, until I know whether both of these cases are
going to require a hearing.
Thank you.
Sincerely,
Brenda B. Becton
Administrative Law Judge
POST OFFICE DRAWER 27447 / RALEIGH, NORTH CAROLINA 27611-7447
RULES: 919/733-2678 ADMINISTRATION: 919/733-2691 HEARINGS: 919/733-2698

MEMO o..E qlo/4,
atft l
61-f s BehcL . i 1004k Vnc) -1-. Tl�a Iu %e��. 5U Po/4
a ce i ved 64- —Tan ' l I
(-fir venetvai), Lc)aS Va Cua.ti- . ykl�
6l wl p) denied renewal booed an ,-idhc.i . 14c<.fi.ve
le gel/ 41,k. P. i nc6" Cct.trlo we
(,e —
�h �r t'�'y?i%�/y(, �oU � � 5 f 2 � Gf t l C�- yam. V�
LH& ,c �o r� 0/e iA J
0
A u- A maw ed •r-ee.vA-e%6 .1)1� 1 - .S
06/ ac,04, 5-/eu-i-; 9 p 504-6 • 4kfLy critaAA.6) v
(-6t.6A winds 4,2.t 040 �-
h 65a1 5 �enti . 1Qok..Su p .
� � Gt to/4 SLR �' �21- G� 5� (� .
o r (See aL d S� . Q/YYL 1 5U i1.e
(--1 .P f Lc.�e,►� C C) C 6rv15 i Di.P.rt ems^- h-e_
c1 i5ok cc1,r 3 oo ' c 51, -ram S6 oU (GL I/10,W Late C' A,=vwc,(
-) ,V ` cadvi,L 4LWJ /0('cd
TO: '1[/74/V e va // 5eargld• � j'�
SUBJECT:
� PerrKi f ,Jrpri 6
C Ve lie riQ5 come dowfru f ( 5u.e reY1e
North Carolina Department of Environment,
Health, and Natural Resources c, Printetl on RecycleA Papor

:MEMO
TO:
DATE•
SUBJECT:
TLe CorkM' t (,'v)u'-/3 ;v nee.J /cecdi vi (36o1
d5kiam) anv 6,)1,t . F651-11 loads -/a �
S{ieQ,ri. (-4uGJIs.we([ tlaJdes�"_ E 1.1 Ss Lk^.et4,
5ee *A) /t & 0.7,1ad-10115 (31)/9o) k2,L oJAi'>,
T y-kt;A,14 '-N-° Com-P-3 maobi Grua �d.�.s Penorrrx d u.•-
../.0 05 41,o ad cjiA- 14; 5fruce4-v--.
1:10,Gdi da:te-- S old. h fe. ncfv-tSe,4
kuiO 3,h) a/VY-•
From:
North Carolina Department of Environment,
Health, and Natural Resources
Printed on Recycled Paper
•
1

WHOLE hH.LUT 'OXICITY TESTING 0[SELr MONITORING SUMMARY] Thu, Aug 15, 1991
FACILITY
DURHAM CO.•TRIANGLE WWTP
NPDESN: NC0026051
County: DURIIAM Region: RRO
PF: 3.0
7Q10: 0.00 I W C(%):100.00
REOUIREMP..NT
PERMIT CHRONIC LIMIT:99%
Begin: 1/11/88 Frequency. Q P/F
Months: FEB MAY AUG NOV
SOC/JOC Reg:
YEAR JAN
Y '87 PASS
'88 '(PASS)
'89 PASS
'90 PASS
'91 PASS
DURILAM-ENO RIVER WWTP
M'DFSx; NC0026336
County: DURHAM Rcgicn: RRO
PF: 250
7QI0:1.5 IWC(%):72.1
PERMIT IT CHRONIC LIM I T':72%
Begin:7/189 Fre.quency: Q P/F A
Months: JAN APR JUL OCr
SOC/JOC Rcq:
989-10C AT 72%, EXPIRES 42 MON7}IS AFTER
'87 —
'88 69.5•
'89 FAIL
'90 PASS
'91 PASS
DURHAM-FARRINGTON RD. WWTP
NPDESH: NC0047597
County: DURHAM Region: RRO
PF: 20.00
7Q10: 0.15 IWC(%):9952
PERMIT CI IRONIC LIMrr:99%
Ilcgin:4/1/91 Frequency: Q P/F A
Months: OCT JAN APR JUL
SOC/JOC Rcq:
10C-989.1/92 CHRONIC MONITORING AT99%
Y '87 280V
'88 PASS?
'89 PASS
'90 FAIL
'91 PASS
DURHAM-LICK CREEK W WrP
NPDESN: NC0026310
County: DURHAM Region: RRO
PF:1S
7Q10: 0.00 IWC(%):100.00
PERMIT CHRONIC LIMIT:99% WIZEN 1.5 MGD
Begin: 10/187 Ftcqucncy: Q P/F
Months: OCT JAN APR JUL
SOC/JOC Rcq:
JOC 989-1/91 CHRONIC MONITORING AT 99%
'87 —
'88 37.63•
'89 PASS
'90 FAIL
'91 PASS
DURHAM•NORTHSIDE WWTP
NFDES*: NC0023841
County: DURHAM Region: RRO
PF; 10.0
7Q10: 0.075 1WC(%):995
E. J. POPE AND SONS/HANDY MART 118
NPDESN: NO3078701
County: CRAVEN
PF: 0.0144
7Q10: 0.0 IWC(%):100
Region: WARO
PERMIT CI IRON IC LIMIT:99%(THRU EXP> 10 MGD)
Begin: l0/1089 Frequency: Q P/F A
Months: OCT JAN APR JUL
SOC/JOC Rcq:
JOC 989-1/91 CHRONIC MONITORING AT 99%
PERMIT ACUTE LLMrr:NO ACUTE (FfRo 24 HU( P/F Q
Bcgin:5/30/91 Frequency: Q P/F A
Months: FEB MAY AUG NOV
SOC/JOC Rcq:
'87 —
'88 74.07•
'89 (FAIL)
'90 PASS
'91 PASS
'87
'88
'89
'90
'91
E.M.HOLTELEMENTARY SCHOOL
NPDESN: NC0045179
County; ALAMANCrs Rcgicn: WSRO
PP: 0.011
7Q10: 0.0 I W C(%):100.0
PERMIT 0-IRONIC LIMIT:99% UNTIL 2r28/94-THEN NO
Begin: 3/1/91 Requcncy: Q P/F A
Months: FEB MAY ALIO NOV
SOC/JOC Rcq:
'87
'88
'89
'90
'91
EAGLE SNACKS, INC-002
NI'D1SN: NC0051195
County: MARTIN
PP: 0.30
7Q10; 0.34 IWC(%):58.00
Rcgion: WARO
PERMrr CHRONIC LIMr1':58%
Dcgim 4/1/90 Fnqucncy: Q P/12 A
Months: FEB MAY AUG NOV
SOC/JOC Rcq:
FEB
PASS
PASS
NR
FAIL
PASS
FALL
PASS
PA- SS
FAIL
PASS
PA- SS
PASS
NR
FAIL
PASS
MAR
PASS
FA- IL
PASS
(FAIL)
FAIL
PASS
(--- )
PA- SS
PASS
PASS
FA- IL
FAIL
(FA- IL)
PASS
PASS
'87
'88
'89
'90
'91 — FAIL PASS
EANES 011., COMPANY
NPDESN: NC0070424
County: PERSON Rcgion: RRO
1'P: 0.007
7Q10: 0.00 I W C(%):100.00
PERMIT CI IRONIC LIMIT:99%
Bggin: 11/1287 Frequency: Q P/F
Months: DEC MAR J1)N SE1'
SOC/JOC Req:
'87 —
'88 —
NR
'90 FAIL — bt
'91 FAIL I'ASS PASS
EAST BEND INDUSTRIAL PARK W WTP
NPDESN: NC0064726
County: YADKIN
PF: 0.01
7Q10: 0.05 IWC(%):23.66
Region: WSRO
LETTER ACUTE TARGEr:S IGN IF M ORT REDUCTION
Begin 10/189 F.qucncy: M
Months:
SOC/JOC Req:
'87
'88
'89 —
'90 NR NR
'91 Q' <'
NR
Q•
APR
FAIL
(FAIL)
PASS
PASS
LATE.,
FAIL
PASS
NR
FAIL
PASS
PASS
PASS
(—)
LATE
FAIL
PASS
LATE
FAIL
PASS
FA II.
FAIT.
NR
<1•
MAY
PASS
PASS
FALL
PASS
FAIL
PASS
FAIL
PASS
PASS
FAIL
FAIL
PASS
LATE
PASS
PASS
FAIL
LATE
PASS
PASS
NR
NR
NR
PASS
PAII.
NR
16.97•
2 C9, LerTEes sews
J1JN
FAIL
PASS
(—)
PASS
PASS
(FAIL)
PASS
PASS
FALL
PASS
PASS
(—)
FAIL
PASS
PASS
PASS
NR
PASS
FAIL
NR
NR
JUL.
PASS
(—)
FAIL,bt
PASS
FAIL,bt
PASS
FAIL
FAIL
let
PASS
(—)
PASS,bt
PASS
NONE
(FAIL)
FAIL,bt
FAIL
ht
AIJG
FAIL
FAIL
NR
FAIL
NR
NR
PASS
PASS
FAIL
FAIL
PASS
FAIL
NR
SF.P
FAIL
PASS
(NK)
PASS
(NR)
(—)
FAIL
PASS
FAIL
(NR)
FAIL
NR
FAIL.
N It
NR
NR
0 2 consecutive ABures = significant noncompliance Y Prc1987 data available
LEGEND:
PF=Jcrmittd flow (MGD),7Q10.Rcociving .beam low flow aiterion (cfs), IWC%=batman waste concentration, Begin=Fint month required, Frequency-4Mmitnring frequency): (Q-Quutcrly, M•Monthly, BM -Bimonthly; SA•Scmiamtu lly; A -Annually
OWD-Only when discharging; D-Discontinued monitoring requ'uewant; IS -Conducting independent study], P/P=Pass/Fail chronic bioassay, Ac.Aeutc, Chr--Chronic, A=quuterly monitoring increases to monthly upon single failure,
(Data Notation'; (f.Fathead Minnow, •.Ceriodaphnia sp., my=Mysid shrimp, ON=Chronic valuo, P=MorLJity of stated percentage at highest cauenlnlion, at.Pcrfonned by DEM Aq Toa Group, bt.Bad test',
(Reporting Notation): (---Data not rcqulnd, NR.Not reported, ( ).Beginning of Quuler), [Noah). Activity Status): (1=Inactive, N=Newly lasucd(fo conatruct),11=Active but not discharging]
r
ocr
FAIL
PA- SS
FAIL,bt
NR
FAIL.
FAIL
FAIL
NR
FAIL
PAII.
(—)
PA- SS
PASS PASS
NOV
FAIL
PA- SS.
I AIL
FAIL
FAIL.
PASS
(—- )
PASS
FAIL.
NR
FA 11.
NR
>90'
PASS
PASS
DEC
FAIL
FAIL
FAIL
(---)
P- ASS
FAIL
(•-)
PA- SS
PASS
FAII.
PASS
(—)
NR
PASS
FAIL
let NR
N —
FAIL
NR
FAIT. Nit
NR NR
<5 3.89•
17

DIVISION OF ENVIRONMENTAL MANAGEMENT
August 7, 1991
Memorandum
To: Dale Overcash
From: Carla Sanderson
Through: Ruth Swanek I,'_
Subject: East Bend Industrial Park
NPDES Permit No. NC0064726
Review of Amended
Engineering Economic Analysis
Yadkin County
I have reviewed the Amendment to the October 12, 1990 East Bend Industrial Park
Engineering Economic Analysis and have the following comments:
1) Mentioned in the October 1990 report, was the discharge of only
2,000 gallons per day instead of the 10,000 gallons per day. The report
gave no indication that the lower discharge flow was factored into the
decision to change to sub -surface disposal. The amended analysis seems
to indicate the evaluation is now being considered utilizing flows of
10,000 gallons per day. (The wasteflow of 10,000 gallons per day was
considered in the first engineering analysis.)
2) Dissolved oxygen violations are occurring with current loading to the
creek. The existing outfall location is approximately 300 feet above
the permitted location (the permitted location is just below the drag -
strip). The permit requirements include instream monitoring of dissolved
oxygen. Review of instream data show violations of the dissolved oxygen
standard, down to 3 mg/1, upstream and downstream (apparently) of the
discharge. The instream monitoring reports do not indicate the sampling
locations. If the BOD5 and NH3N limits were changed to 5 mg/1 BOD5 and 1
mg/1 NH3N, at the permit flow of 0.01 MGD, the loading to the creek would
increase. See below for current loads and predicted loads from the
discharge:
Current Loadings - during summer months when D.O. concentrations
instream are below 5 mg/1 (down to 3 mg/1)
(Monthly Averages)
Date Wasteflow (MGD) BOD5 (ma/1) (#/d) NH3N (mq/1) (#/d)
7/90 0.005 7.13 0.29 0.94 0.039
6/90 0.0025 3.28 0.068 1.95 0.04
5/90 0.0035 7.28 0.23 4.32 0.13
4/90 0.002 22.1 0.37 6.72 0.11
Averages
GODS= 0.24 #/d NH3N= 0.08 #/d

• 4
Predicted loads to the stream when the discharge is at design of 0.01
MGD, 5 mg/1 BOD5, and 1 mg/1 NH3N:
BOD5= 0.42 #/d NH3N= 0.08 #/d
The amended engineering report states the alternative of DEM allowing
the discharge to be relocated to 367 feet downstream and meet secondary
limits at that location would be more cost effective than the previous
alternative of sub -surface disposal. A modeling analysis with the cur-
rent instream information would need to be performed by Technical Support
before limits could be applied. Further instream information may be
needed in order to assess the existing stress to the stream along with
the additional waste loading.
I have discussed this situation with David Russell and reviewed his 7/23/91 memo
sent to you. I am in complete agreement with his comments and recommendations.
cc: Central Files
WSRO

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
HEALTH AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
M E M O R A N D U M
TO:
THROUGH:
FROM:
SUBJECT:
July 23, 1991
Dale Overcash
Permits Supervisor
Steve Mauney
Water Quality Supervisor, WSRO
David Russell a
Environmental Specialist, WSRO
Engineering Economic Analyses for
East Bend Industrial Park
NPDES Permit No. NC0064726
Yadkin County
The first of two (2) Engineering Economic Analyses (EEA) was
received October 12, 1990 by DEM's Permits and Engineering
Section. The cover letter to the EEA stated "Upon investigation
of this matter, it became quite clear that the best route for all
concerns is to go to a non -discharge disposal means and eliminate
the point discharge..." The letter recommends "Yadkin County
approach the landowner in the industrial park and come to some
agreement as to the construction of a subsurface disposal
system." The EEA was prepared by Municipal Engineering Company
in Boone, . C .
The original EEA in the "Continuing to Discharge" section
makes a case for not discharging to the stream even if secondary
(30/30) limits are granted. That section states, "Extending the
discharge downstream several hundred feet to the confluence of a
second stream may enable the County to maintain the dual
treatment plant and standby power will remain. The possibility
of these limits being made more stringent in the future is
another item which must be considered." But in the second EEA
submitted in July 1991, the "Conclusions" section states, "The
chief reasons for the reversal of selected alternatives between
this report] and the October 12, 1990 report is the potential for
additional flows, secondary limits...." In other words, the
granting of secondary limits can be viewed positively or
negatively, depending on the conclusion one wishes to make. The
first EEA used secondary limits and discharging as a negative,
but the second EEA viewed secondary limits and discharging as a
positive and discharging was the disposal method recommended.

-2-
The July EEA in the "Subsurface Disposal of Wastewater"
section in the first paragraph states "This evaluation
demonstrates the impact of utilizing flows of 10,000 gallons per
day in lieu of the 2,000 gallons per day in the October 12, 1990
report." In reviewing the October EEA I found only one reference
to 2,000 gallons per day and that was in the "Introduction" which
stated "the average daily flow through the plant is 2,000
gallons". The "Soil/Site Soil and Environmental Consultants,
Inc. for municipal Engineering Services, Co. in October 1990 used
assumed flow values of 10,000 gpd, the permitted flow in the
present NPDES permit. All calculations in the Soil/Site
Evaluation for trench lengths, and disposal areas needed were
based on 10,000 gpd. The statement that 2,000 gpd of flow was
used in the first EEA is not substantiated in that EEA.
Having the same engineering firm perform a second EEA was
much like having the same lawyer represent both sides in a court
case. Using the same information two entirely different
conclusions were drawn. Since the first EEA's recommendation for
a sub -surface system was not favorable with the County and some
of the "industrial" community, there was a foregone conclusion
that the second EEA would have a different recommendation.
The agreement that not allowing a discharge would hinder
industrial growth is not justified. The disposal of 10,000 gpd
of wastewater by any means accomplishes the same goal. There
will never be a "wet" industry locating in the area due to non-
existent large volume disposal alternatives for industrial waste.
The only industries that could locate in the area are "dry"
industries producing domestic wastewater. Using a sub -surface
disposal system for 10,000 gpd would allow the same number and
types of industries with the same number of employees that could
utilize a 10,000 gpd discharging system. Sub -surface disposal of
wastewater for this area would not hinder growth in the area.
It is recommended the non -discharge alternatives for
wastewater disposal be pursued.
DCR/vm
eA Jg/ /es
ose
Cpipt4c5fm6014abii
IDG// c

OPERATION/CONSTRUCTION MANAGERS
Municipal
Services
—'P.O. Box 97, Garner, North Carolina 275
JUL 2 1991
July 1, 1991 Div OF ENVIRONMENTAL MGM.
DIRECTORS OFFICE
Dr. George T. Everett
Permits and Engineering Department
N. C. Department of Environment, Health
and Natural Resources
PO Box 29535
512 North Salisbury Street
Raleigh, NC 27626-0535
Re: NPDES Permit No. NC0064726
Fast Bend Industrial Park
Amendment to October 12, 1990
Engineering Economic Analysis
Dear Dr. Everett:
CIVIUSANITARY ENGINEERS
Engineering
Company, P.A.
P.O. Box 349, Boone, North Carolina 28607 [phone]\--
r1-1.,
it, 6-1
4-1.,„ci 10.h .
el 7771(5'r,
I am enclosing herewith three (3) copies of the Amendment to the October 12, 1990
Engineering Economic Analysis for the East Bend Industrial Park for your review.
If you have questions or comments, please don't hesitate to call me at 919-772-5393.
Very truly yours,
MUNICIPAL ENGINEERING SERVICES CO., PA
L. Harry Dail, PE
LHD:cw
Enclosures
Copy: Attorney Jim Alexander, Yadkin County
Mr. Jim Cain
Century Reproductions
R.Pf
EN ED
JUL u
CO I GA+ . r' i Y COn

MEMO
TO:
14301611
DATE•
ss,^, I
SUBJECT: C�1C1 -2h�l rl�C• ���
r. ,
EGA D' 1 yvios-1-Y ai -Val/ Ec o VtAA- C Atiqk--L'ost
)(WU Cl nt tn)r -rp 1 Ca /off b
EqatrISlov‘.•
o 10 C (L C 0 KYvl( C Cevetq yvkP VN . 1M' a!`P
ack4NG6 Ye 11 wee tit vxci is v ykan, i• K u`J�- t o
vospcec -s . La, c,t a-r cuzut.1 cLbU 60 ►-u.iv(-0 60
\ eC c; IN-t r) r e v i s.(-1' r C l,vst -z> \ c> 1 v
. 1 (GALz)())S — yC 0-}v N 6cv,-11 Cc,c 4 IQ a' Tc`
4-Qv v .-;c"--c
1- _D c r"- - (A)-Rt r-t_ ` Cam
From •
North Carolina Department of Environment,
Health, and Natural Resources,
Printed an Recycled Paper

Page 1
IMO
1
twel
Awl
rinq
INTRODUCTION
Following the receipt and review by the Division of Environmental
Management (DEM) of the October 12, 1990 Municipal Engineering Services
Company, PA Economic Analysis of the East Bend Industrial Park sewage plant, it was
learned that the sole user of this treatment facility was planning an expansion of the
existing facilities.106,7,8,11 Further investigations by the County of Yadkin, the Yadkin
County Chamber of Commerce and others has yielded another industry considering
expansion of an existing business into the East Bend Industrial Park.2 In addition, it
was learned that State and local economic development agencies are aggressively
seeking to market the Industrial Park to industrial prospects. These events in addition to
the lack of available suitable soils have required that Municipal Engineering Services
revisit the conclusions presented in its October 12, 1990 report in order to properly
evaluate the impact of these larger proposed sewer flows. These larger flows mandate
that all evaluations be based on future daily flows no smaller than those currently
permitted; i.e., 10,000 gallons per day.
1.7 1 See Exhibit 1-- Harley Shuford June 18, 1991 letter
2 See Exhibit 2 — Pope Shuford June 10, 1991 letter
IM' 6 See Exhibit 6 — Yadkin County Chamber of Commerce June 12, 1991 letter
8 See Exhibt 8 -- Joseph S. Holbrook, Jr., June 20, 1991 letter
ratI
7 See Exhibit 7 -- Charles Sutton June 12, 1991 letter
11 See Exhibit 11 — George M. Beroth June 11, 1991 letter

MEMO
TO:
144va--h,v-P IJJG.b.i, ,�w-e-v-7
DATE:
SUBJECT:
vv-
oAs riw.1;qq, 1:‘ vvv:t5 ew(r-e-
.b. s any 1 oc� ��� �I itL1
C-)Jv 'f-e\r"*Lkdj, G-1-1,LcAvYvv IrY\bolui.( '4 IA L.)
SV-4 \o(Auk. ro vt.d evk er,kr) VIAA/"
Y\Ai2t
6-5 = O.Db (1Q o
6( ash
8") 0%60 1 Wi \(\t(2. () +AZ VAd41) (SYNASSde fni
ivy,+1,0 5iL4 mi n^-
-1-; low D. 0.
From:
North Carolina Department of Environment,
Health, and Natural Resources cs) �,��,,.�„,
r

Page 2
PER
Ont
EVALUATION PROCEDURE
11151
1. The present worth of a future sum is defined as P/F = 1/(1 + i)n using discrete
compounding. This Present Worth factor is 0.182573 when i = 8 7/8 % and N
= 20 years. This factor when multiplied by the 20 year Salvage Value of the
materials in the evaluation will represent the current or present worth value of
that future sum,
Pal
2. This factor, the Present Worth factor for a Uniform Series, is actually the
product of two(2)factors. The first determines the future sumof annual �•, an an
installment. It is defined as F/A = (1 + Pa-1/i. This factor is equal to
56.684828 when i = 8 7/8% and N = 20 years. The second factor is the
Present Worth factor discussed in (12) above, which is equal to 0.182573. The
product of F/A x P/F = 10.349119. This factor when multiplied by the annual
O& M for 20 years represents a current sum that when invested at 8 7/8 %
interest will yield the Present Worth of this annual 0 & M value.
3. Land purchases are escalated at 2% inflation per year to establish salvage value.
The multiplier factor is 1.4859.

Page 3
rag
Mil
mei
mon
SUBSURFACE DISPOSAL OF WASTEWATER
The following present worth evaluation of this alternative is based on data from
the October 12, 1990 report submitted by this office. This evaluation demonstrates the
impact of utilizing flows of 10,000 gallons per day in lieu of the 2,000 gallons per day
in the October 12, 1990 report.
If utilized, subsurface disposal would require the re -purchase of lands currently
owned by Century Reproductions or of some neighboring properties. None of these
properties are available for purchase by the County of Yadkin.3,4 Furthermore, the
Permittee (County of Yadkin) does not own land suitable for subsurface disposal.14
There would be a significant negative opportunity cost to the citizens of East
Bend, and Yadkin County in general, from the subsurface disposal alternative. As is
indicated by correspondence from the Yadkin County Commerce Program, the East
Bend Industrial Park has been listed for development with County and State economic
development agencies since March of 1990.12,10 According to the Yadkin County
Chamber of Commerce, the East Bend Industrial Park is one of the few locations in
Yadkin. County that is generally level, has state primary highway access and has
attractive water and sewer. All features are a necessity for the industrial expansion and
recruitment which the County Chamber is currently pursuing. According to the
County, "the loss of an adequate sewer system will seriously jeopardize our ability to
recruit or expand industry in this park."6 As is further confirmed by the North
Carolina Department of Economic and Community Development, the East Bend
Industrial Park is currently listed for active sale and "practically no industrial clients
these days are interested in locating a facility on land with a septic system or a sub-
surface sewer system."8 Accordingly, in the opinion of state and local economic

Page 4
development professionals, the conversion to a subsurface system would have a
significant detrimental effect on the marketability of the East Bend Industrial Park in
Yadkin County.
ISE
own
3 See Exhibit 3 -- Harley Shuford June 17, 1991 letter
rugi 4 See Exhibit 4 -- Thomas Y. Wooten June 14, 1991 letter
6 See Exhibit 6 — Yadkin County Chamber of Commerce June 12, 1991 letter
8 See Exhibit 8 -- Joseph S. Holbrook, Jr., June 20, 1991 letter
to See Ehibit 10 -- Richard L. Reese March 30, 1990 letter
12 See Exhibit 12 — James T. Reeves March 19, 1990 letter
A., 14 See Exhibit 14 — Municipal Engineering Services Area Map, July, 1991

Page 5
fun
LOW PRESSURE APPLICATION
COST EFFECTIVE ANALYSIS --10,000 GPD
Service Capital Annual PW Salvage PW Total
Item Life Cost O&M O&M Value Salvage PW
1. Dupl!x P. S.
rim (550 gpm) 30 38,000 1,500 15,524 5,000 (-)912 52,612
2. 1000'16" Force Main30 6,500 200 2,070 -0- -0- 8,570
3. Treatment Site
RIR
4. Buffer Area
(3.7 acres) 20 37,000 400 4,140 51,979 (-)10,038 31,102
5. Subsurface Field
(4.8 acres) 20 48,000 500 5,175 71,323 (-)13,022 40,153
a 0.1 gpd/sq.ft. 20 313,000 1,200 12,419 -0- -0- 325,419
6. Standby Power 20 22,000 200 2,070 5,000 (-)913 23,157
7. Monitoring Wells 20 5,000 2M 2,070 -0- -0- 7,070,
Totals $462,500 $4,200 488,083

Page 6
LAND APPLICATION OF WASTEWATER
PEI
No present worth analysis was prepared for this alternative since an even larger
acreage would be required than the subsurface alternative when the lagoon and buffers
are considered and the potential for warm weather odor complaints from nearby
industry and houses is high.
Poi
PER
vI
Poi

Page 7
MIR
RIR
Mg
Porn
lap
PEI
CONTINUING TO DISCHARGE
This alternative is based on DEM allowing the existing discharge point to be
relocated a proximately 367 feet to a location suitable for secondary (30 ppm BOD5
and 30 ppm SS) limits at the existing plant's flow of 10,000 gallons per day. This
alternative with secondary limits is far more cost effective than the alternative
considered in the October 12, 1990 report. Yadkin County and Century Reproductions
have agreed to share the cost of relocating the discharge point.13 A preliminary of this
proposed relocation is enclosed as Exhibit 9. A deed for the necessary easement is
enclosed as Exhibit 15.
13 See Exhibit 13 — Jim Cain June 27, 1991 letter

Page 8
AEI
Fan
• j DISCHARGE SYSTEM — SECONDARY LIMITS
COST EFFECTIVE ANALYSIS --10,000 GPD
Service Capital Annual PW Salvage PV Total
Item Life Cost O&M O&M Value Salvage PW
1. 10,000 GPD Secon.
Treatment System 20
-0- 18,000186,284 20,000 (-)3,651 200,633
2. Extension of Exist.
Outfall 20 13,000 200 2,070 -0- -0- 15,070
3. Standby Power 20 22,000, 2_(X1 2070 5.000 (-)913 23.157
"m Totals 37,000 18,400 238,860

Page 9
CONCLUSIONS
Given the situation requiring expansion of the existing industry (Century
Reproductions) and the potential location of at least one (1) additional industry, the
flow to the existing wastewater treatment plant will increase by 6-6500 gallons per day
to a total flow of 8-9000 gallons per day. These additional flows increase the cost
effectiveness of the existing discharge system over the next most suitable alternative of
subsurface injection providing that secondary limits can be maintained. These higher
flows require a greater treatment area and higher costs for the subsurface treatment grid
(estimated at $1.50/sq. ft. of treatment area based on recent bids) while the existing
treatment plant will suitably treat expected discharges up to 10,000 gallons per day to
secondary limits with only an extension of the discharge outfall. The chief reasons for
the reversal of selected alternatives between this report and the October 12, 1990 report
is the potential for additional flows, secondary discharge limits, the determination that
land may not be realistically available for subsurface disposal and the conclusion that
the impat of the subsurface alternative on the marketability of the East Bend Industrial
Park would be severe.

Page 10
•
Ain
I mil
Can
RECOMMENDATIONS
After a review of the potential and desire for industrial expansions and new
industryat the East Bend Industrial Park, this office recommends that DEM allow the
County of Yadkin to renew its existing secondary discharge permit for a 10,000 gallon
per daytreatmentplant movingthe current discharge point 367' downstream to allow
g
for a continuation of secondary permit limits, 5,6,8,9,10,14
See Exhibit 5 -- Jimmie Hutchens June 12, 1991 letter
6 See Exhibit 6 — Yadkin County Chamber of Commerce June 12, 1991 letter
8 See Exhibit 8 — Joseph Holbrook June 20, 1991 letter
9 See Exhibit 9 — Municipal Engineering Services Map showing the desired outfall
extension
10 See Exhibit 10 -- Richard. L. Reese March 30, 1990 letter
14 See Exhibit 14 -- Municipal Engineering Services Area Map July, 1991

R CE I1VFL
S 1991
State of North Carolina • r_., LHNR
Department of Environment, Health and Natural Resources CCOU1','S.I_;
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
May 30, 1991
Mr. John Barber, Interim County Manager
County of Yadkin
Post Office Box 146
Yadkinville, North Carolina 27055
Dear Mr. Barber:
George T. Everett, Ph.D
Director
Subject: NPDES Permit No. NC0064726
East Bend Industrial Park
Yadkin County
As you are aware, representatives of the County of Yadkin and Municipal Engineering Services Company
met with representatives of the Department of Environment, Health and Natural Resources on May 29,
1991, to discuss the current status of the subject permit application.
Based upon this meeting, I have decided to grant the County of Yadkin until June 30, 1991, to resubmit a
new economic and engineering analysis of the wastewater treatment and disposal alternatives. Attached
you will find the most current version of the Division's guidance for this evaluation.
If you have any questions regarding this analysis or the subject permit application, please contact Mr. Don
Safrit, P.E., Supervisor of the Permits and Engineering Unit at (919 3-5083.
! eorge T verett
cc: Secretary William W. Cobey
Municipal Engineering Services Company, P.A.
Permits and Engineering Unit
Winston Salem Regional Office
Office of General Counsel ..6
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

GUIDANCE FOR EVALUATION OF WASTEW
R DISPOSAL ALTERNATIVES
Proposed Dischar el)
I. General Information
A. Provide the following:
facility name
county
- facility address
report preparer's name
report preparer's North Carolina P.E. certification
number
report preparer's mailing address and telephone number
B . Provide a detailed description of the proposed discharge facilities (you may include a diagram
indica ing the plant components and processes)
C. Describe the project served by the WWTP (i.e. school, subdivision, number of students or
households, total waste contribution calculated according to 15 NCAC 2H . 0219 (1), etc.)
D. Indicate if it is a phased development and provide the estimated wasteflow per phase (indicate
current phase status for existing facilities)
II. Evaluation of Environmental Feasibility of Discharge Alternatives
A. Evaluate the environmental feasibility of all three of the following non -discharge alternatives.
1. Connection to Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit).
b.
Existing Sewerage System: Indicate distance to an existing sewer line within a
five mile radius (radius extension should be considered if cost effective as it
relates to project size) If there are not available sewer lines in the vicinity, please
note this and proceed to entry 1(b) below.
(1) Provide description of sewer facilities necessary to connect to
receiving wastewater treatment plant.
(2) Provide preliminary indication of flow acceptance from municipal or
private WWTP under consideration for connection (documentation
should include NPDES permit number and county of the accepting
WWTP). If a municipal or private WWTP cannot accept the wastewater,
please explain.
(3) Indicate if third party agreements or easements would be necessary.
(4) Attach a topographic map or, if appropriate, a site drawing showing the
physical aspects of this alternative (i.e. proximity to sewer system, route
for sewer line, property difficulties, etc.)
(5) Proceed to Alternative II. A (2) - Subsurface Disposal Systems.
Planned Sewerage System: Determine if an area wide sewerage system within a
five mile radius is projected to be available within the next five years to receive
waste from the project under study. Determine availability date and flow
acceptance projection with appropriate regulatory authority. Identify your contact

Page 2
in the public utility or private management group that assisted you in this
determination. Should a sewer line be available for connection within the next
five years entry (1) (a) should be evaluated.
2. Subsurface Disposal System ( Installation of nitrification systems, low pressure pipe
systems and mound systems)
Note: Subsurface disposal systems (i.e., low pressure systems and nitrification systems) are
o y permitted by DEM for the following types of facilities: city owned facilities, county
o ned facilities, public utility facilities and industrial facilities with an industrial
wastewater component. Other categories of facilities (i.e., privately owned mobile home
parks, homeowner associations, nursing homes, industrial facilities with 100% domestic
waste, etc.) are permitted by local county health departments. Any facility in the latter
category must obtain a statement from the local County Health Department concerning
suitability/unsuitability of soils for subsurface systems.
a. Determine if permittee currently owns land that is available and suitable for a
ground absorption system.
b.
(1) Provide a preliminary report from a soil scientist with a
loading rate recommendation based on soil type.
(2) Provide calculations to determine land size requirements based
on design and loading rate characteristics.
Note: Disposal systems require 100% reserve area.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC 2H
.0219 (j). Provide a site plan indicating proposed layout of subsurface
system.
(4) If there is sufficient usable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate usable land on the
site.
(5) If there is insufficient usable land on the project site, proceed to
entry 2 (b) below, if applicable. Otherwise, proceed to Alternative II A
(3) - Spray Irrigation Systems.
Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 2 (a).
3. Spray Irrigation System
a.
Determine if permittee currently owns land that is available and suitable
for a spray irrigation system.
(1) Provide a preliminary report from a soil scientist with a loading rate
recommendation based on soil type.

Page 3
b.
B.
C.
(2) Provide calculations to determine land size requirements based on design
and loading rate characteristics.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC
2H .0219 (j). Provide a site plan indicating proposed layout of
spray irrigation system.
(4) If there is sufficient usable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate usable land on the
site.
(5) If there is insufficient usable land on the project site. Refer to entry
3 (b) if applicable. Otherwise, proceed to Section II. B.
Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 3(a) immediately above.
If one or more of the three non -discharge alternatives, II. A (I), (2) or (3) were found
to be environmentally feasible, select one and notify DEM that the alternative will be
undertaken in lieu of submitting the NPDES application. If a non -discharge
application is selected, the rest of this guidance is not required to be completed.
If one or more of the three non -discharge alternatives were found to be
environmentally feasible, but the permit applicant does not wish to select one because
he claims doing so would be unreasonably costly, cost estimates prepared according
to Section III of this Guidance must be submitted to DEM. Proceed to Section II.C.
If none of the three alternatives, II.A.(1),(2), or (3) were found to be
environmentally feasible, proceed to Section II.C.
Evaluate the environmental feasibility of the discharge to a flowing stream (defined as
a stream with 7Q10/30Q2>0 cfs flows).
NOTE: This section is not required to be completed unless the three
non -discharge alternatives evaluated in Section II.A. were found to be
environmentally infeasible, or if one or more of the alternatives were found to be
environmentally feasible but the permit applicant claims that selecting any of the
environmentally feasible alternatives would be unreasonably costly.
1. Indicate distance to nearest stream with positive flow meeting the above criteria
(attach topographic map indicating current existing/proposed discharge point and new
proposed location).
2. Provide documentation as to whether or not third parties agree to provide necessary
easements if applicable. Proceed to Section III.

Page 4
III. COST ESTIMATION AND COMPARISON
NOTE: Section III must be completed only if one or more of Alternatives (1), (2), and (3)
evaluated in Section II.A. or if the proposed discharge evaluated in Section II.C. were found to
be environmentally feasible and the permit applicant claims that selecting the least costly of the
feasible alternatives would be unreasonably costly.
A. Prepare cost estimates in accordance with the following guidelines for each of Alternatives 1,
2 and 3 that were found to be environmentally feasible in Section II. Be sure to convert all
costs to present value as described in Section III.E.
1.
2.
Connection to a Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit.).
a. Provide detailed cost estimate of an installed sewer line interceptor and pump
station(s) if applicable (i.e. materials and labor).
b. Determine the operating expenses of the sewer extension (i.e. materials, utilities,
maintenance and operator costs) for the design period.
c. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
d. Indicate connection fees and/or surcharge required by the WWTP under
consideration.
Note: If a periodic surcharge is required, please consider cost in analysis.
surface Disposal System (Installation of nitrification systems, low pressure pipe
systems and mound systems).
a. Provide a detailed cost estimate for the installed cost (i.e. materials and
labor) of treatment facilities.
b. Determine the opportunity cost of any land under current ownership to be utilized
under this alternative.
c. Provide the cost of any land to be purchased and/or cost of the permanent
easement (include letter of offer to sell or provide permanent easement with dollar
amount from appropriate party) to be utilized under this alternative.
d. Determine the operating expenses of the subsurface disposal system (i.e.
materials, utilities, maintenance and operator costs) for the design period.
3. Spray Irrigation System
a. Provide a detailed cost estimate for the installed cost (i.e. materials and labor) of
treatment facilities.
b. Determine the opportunity cost of the land or portion thereof under current
ownership utilized under this alternative.
c. Provide the cost of anyland to be purchased p sed and/or cost of the permanent

Page 5
fkap
easement (include letter of offer to sale or to provide permanent easement with
dollar amount from appropriate party).
d. Determine the operating expenses of the spray irrigation system (i.e. materials,
utilities, maintenance and operator costs) for the design period.
B. If discharge to a flowing stream was found to be environmentally feasible in Section II.C.,
prepare a cost estimate in accordance with the following guidelines. Be sure to convert all
cons to present value as described in Section III.E.
1. Provide detailed cost estimate of installed effluent line and pump station(s) if applicable
i.e. materials and labor) to proposed discharge point.
2. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
3. Determine the operating expenses of the WWTP (i.e. materials, utilities, maintenance
and operator costs) for design period.
D. Cost Comparison
Title 15 NCAC 2H.0105(c)(2) requires that the most environmentally sound wastewater
disposal alternatives be selected from the reasonably cost effective options. The three
non -'discharge alternatives evaluated in Section ILA. are assumed to be roughly equivalent
alternatives where they are found to be environmentally feasible, and preferable to a
proposed discharge. Therefore, if a permit applicant has determined the environmental
feasibility of one or more of the non -discharge alternatives, but he claims the alternative(s),
compared to a proposed discharge, would be unreasonably costly, he must present
justification of the claim based on the appropriate cost comparisons as to why the difference
between the costs would be unreasonable.
E. Present Value of Costs
Costslincurred in different time periods must be converted to a common time period before
they can be accurately combined or compared. Performing this calculation is known as
"computing the present value," or "discounting" the costs. Present value is also sometimes
called "present discounted value or "present worth".
The fallowing standard formula for computing the present value must be used in all cost
estimates made under this evaluation guidance.
Where:
PV =
Co
Ct
n
PV= Co + I C
t
r=1 (1+r)t
Present value of costs.
= Costs incurred in the present year.
= Costs incurred in time t.
t = Time period after the present year ( The present year is t = 0)

Page 6
r
Ending year of the life of the facility.
= Discount rate. for these calculations, use the rate that is required to be used by all
Federal agencies in the formulation and evaluation of water and related land
resources plans. The rate is computed annually in accordance with Sec. 80 (a)
Public Law 93-251 [88 Stat. 34] and 18 CFR 70439, and published in the
Federal Register. The current rate (for Federal Fiscal year 1989-90) is 8 7/8%.
Therefore in the above formula for this year, r = .08875.
However, if the costs are the same in every time period from year one through year n (i.e.,
Ct = C, a constant for t = 1,2,..., n ), then the formula reduces to:
PV= Co + C
In this case, the present value may also be looked up in a table containing the present value of
annuities (an annuity is a constant amount payable in each year for a certain number of years).
Such tables are available from financial institutions.

Steve,
ICI
MAY 22 1991
I talked to George Sherril in Community Develppm e. Gt = EN
me the following:
He's never heard of a city getting money for an industrial
park. All CDBG money must be for a specific industry. One
where they know that new jobs will be created. He just
didn't think a city could get money for a park.
. He said most money was for water and sewer lines and
rarely for a wwtp although he didn't deny they couldbe
funded.
• He said there were two kinds of CDBG monies. One for
social type improvements such as housing renovation and
one for low income area industrial incentives.
▪ He said state law prevented a town from giving land to
an industry. It is a law that if they sold n industry
land, it must be at the appraised value. jpoA,
A town can get a loan from CDBG and give it to an
industry. It must be repaid. The town used to be able to
keep the money. Now, it must go back to the State.
• George Sherril said they keep good records on who got what
grants and for what and that info was readily available.
He said Bob Hinshaw had it and knew more about the
program than anyone.
A, J
MAY 22 1Sc
.1L' 1;

State of North Carolina
Department of Environment, Health and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
April 30, 1991
Mr. James L. Graham
P. 0. Box 625
Yadkinville, North Carolina 27055
RE: Yadkin County v. DEHNR
(91, EHR 0193)
Dear Mr. Graham:
John C. Hunter
General Counsel
Office of General Counsel
Edwin L. Gavin 11
David G. Herter
James C. Holloway
Robert R. Gelblum
Elizabeth E.Rouse
John P. Barkley
J. Peter Rascoe, III
Leigh L. Stallings
Billy R. Godwin
Jay L. Osborne
I have made a number of attempts to phone you since Friday,
April 26, but have got repeated busy signals, so I'm writing
instead.
This department is aware of Yadkin County's concerns as
expressed by County Manager Mashburn's petition for a hearing on
the permit renewal matter. I have been asked to invite you to
bring a couple of county representatives to Raleigh to discuss
them with out staff. Please give me a call and let's discuss
this idea further. If we agree on the meeting idea, I intend to
let Don Safrit make further arrangements and identify the staff
people who need to attend the meeting. We all want to work with
the county, but at the same time, we must do so in the context of
the law and rules.
ELGI I \rbw
Very truly yours,
16tAA.L.(6L
Edwin L. Gavin II
Deputy General Counsel
P0. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An I,,.,JI MMMe enint Aihr n.4uis Ar4,n irmn1M1Pr

Division of Environmental Management
April 26, 1991
Chronoloev
Subject: County of Yadkin - East Bend Industrial Park
NPDES Permit No. NC0064726
7/14/86 Original permit issued to John S. Clark.
12/3/87 Permit reissued to the County of Yadkin.
1/23/88 Authorization to Construct issued. Incorrect discharge point not discovered during
review or subsequent inspections.
3/22/89 Permit modification requested to correct improper discharge point.
5/89 Facility began operation.
12/14/89 Permit modification sent to notice.
3/2/90 Public meeting noticed.
4/17/90 Public meeting held.
5/22/90 At the request of Hearing Officer, Director requested evaluation of Non -Discharge
alternatives.
10/12/90 Yadkin County's Consulting Engineer submitted report concluding that discharge
should be eliminated and system converted to a subsurface disposal system. In the
following months, DEM staff requested a schedule from the County and Engineer
that could be incorporated into a reissued permit to allow time for construction of
the new subsurface system. The County refused to provide a schedule and
essentially, refused to follow the advise of their Consulting Engineer.
12/31/90 Renewal of permit requested.
1/22/91 Director denied request for modification and gave notice of our intent to deny
renewal request.
1/23/91 Winston Salem Regional Office recommended enforcement action for permit
violations of effluent limitations.
2/18/91 County of Yadkin assessed civil penalty of $ 3,219.14 for 6 of 7 permit effluent
limitation violations (< 5% of maximum penalty allowed by G.S. 143-215.6.
2/27/91 Petition filed for administrative hearing for denial of permit modification
request.
3/25/91 Petition filed for administrative hearing of civil penalty assessment. •
4/8/91 Denial of permit renewal sent to notice.
6/30/91 NPDES Permit expires.

RECEIVED
APR 1 i 1991
EHNR.
GENERAL COUNSEi
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett,Ph.D.
William W. Cobey, Jr., Secretary Director
April 12, 1991
MEMORANDUM
To: John Hunter
Office of General Counsel
From: George T. Everett
Subject: NPDES Permit No. NC0064726
County of Yadkin - East Bend Industrial Park
Yadkin County
Staff of the Division of Environmental Management have reviewed the petition filed February
27, 1991, concerning the denial of Yadkin County's request to relocate their existing discharge.
The Division denied the request by a letter dated January 22, 1991 (attached). The petition
actually appears to be adjudicating the anticipated denial or intent to deny the renewal of the subject
NPDES permit. Regardless of the action the County of Yadkin is petitioning, the Division will
defend its decision to deny both the modification and renewal of the NPDES permit due to the
availability of a more environmentally sound and cost effective alternative as documented by
County of Yadkin's consulting engineering firm, Municipal Engineering Services Company, P.A.
(attached letter of October 12, 1990).
The following is a brief chronology concerning the modification/ renewal of NPDES Permit
No. NC0064726:
April 17, 1990 -
April 27, 1990 -
Due to significant public concerns, a public meeting was
conducted at East Bend Elementary School in Yadkin County.
Recommendations from meeting officer, Mr. Roy Davis, Regional
Supervisor of the Division's Asheville office were prepared. Mr.
Davis recommended that the applicant evaluate non -discharge
alternatives in accordance with the requirements of 15A NCAC 2H
.0105 (c)(2) (Memo attached).
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Page 2
County of Yadkin
May 22, 1990 -
July 13, 1990 -
August 1, 1990 -
Request made of applicant to evaluate alternatives as outlined by
the Water Quality Section's "Guidance for Evaluation of
Wastewater Disposal Alternatives". Report was to be prepared
and was to be submitted by July 15, 1990 (letter attached).
County of Yadkin requested extension until August 1, 1990, to
submit engineering analysis of alternative.
Copy of "Guidance for Evaluation of Wastewater Disposal
Alternatives" sent to Mr. Charles Sutton, President of Century
Reproductions (see June 13, 1990 letter) and Mr. Charles
Mashburn, County Manager of Yadkin County. Extension until
September 1, 1990 granted.
August 29, 1990 - Request by Consulting Engineer to extend due date until October
15, 1990 granted.
October 12, 1990 - Engineering Analysis submitted by the County of Yadkin's
consultant. The conclusion reached by the consultant was that the
discharge (NPDES Permit) should be eliminated and the system be
converted to a subsurface disposal system (copy of letter and
report attached).
October 16, 1990 - Telephone conversation between Dale Overcash, NPDES Permit
Group Supervisor, and James Diehl, Municipal Engineering
Services Company, concerning the Division's need for a
proposed schedule to be incorporated into a reissued permit for
elimination of the discharge through construction of a
non -discharge system.
November/December, 1990 - Several more requests for a schedule by Dale Overcash to James
Diehl. During one of these conversations, it was learned that the
County of Yadkin had no intentions of adhering to
recommendation of their engineer to convert to a non -discharge
system.
January 22, 1991 -
Division decided to deny request for modification and gave notice
of our interest to deny the County's renewal request.
Clearly, the Division is authorized to require an evaluation of the non -discharge alternatives in
accordance with 15A NCAC 2B .0201 (c)(1). Since the County of Yadkin's consultant has
evaluated the alternatives and has determined that there exists a more environmentally sound and
cost effective alternative to a discharge and the County of Yadkin itself has not provided any
additional information to discredit the consultant's conclusions, the Division proceeded to deny
their request.
The following options appear to be available to the Division:
1. Proceed with the formal adjudicatory process and if the Administrative Law Judge concurs
with our actions, recommend a schedule to either be incorporated into a reissued NPDES
permit or a court order.

Page 3
County of Yadkin
2. Proceed with the intent to deny their renewal request with no schedule. This option will
probably lead to option number one.
3. Proceed with a renewal of the NPDES Permit with a schedule for elimination of the discharge
mutually agreed upon between the Division and the County of Yadkin.
The Division is prepared to assist the Office of General Counsel in this matter and if any
additional concerns need to be addressed, please contact Mr. Donald Safrit, Supervisor of the
Permits and Engineering Unit at 733-5083, ext. 542.
cc: Mr. Steve Tedder
Mr. Larry Coble
Mr. Donald Safrit
Mr. Dale Overcash

JAMES L. GRAHAM
COUNTY ATTORNEY
COUNTY OF YADKIN
THE OFFICE OF COUNTY ATTORNEY
P. O. BOX 625
YADKINVILLE, N. C. 27055
April 9, 1991
Mr. Edwin L. Gavin II
Deputy General Counsel
NC Dept. of Environment, Health and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina 27611
Re: Yadkin County v. DEHNR, File No. 91 EHR 0193
Dear Mr. Gavin:
TELEPHONE [phone]
RECEIVED
APR 1 5 1991
EHNR
CENERAL COUNSEL
Enclosed please find Stipulation for extension of time to file
Prehearing Statement as discussed earlier by telephone. Please insert
in the blank the maximum number of days applicable for an extension of
time to file Prehearing Statement. Please file a copy with the
Office Of Administrative Hearings and request they send me a copy
showing the file date.
Thanking you kindly, I am,
Very truly yours,
ames L. Graham
JLG/ls
Enclosure
CC: Mr. Dean C. Farrar
Chief Hearings Clerk
P. O. Drawer 27447
Raleigh, NC 27611-7447

STATE OF NORTH CAROLINA
YADKIN COUNTY
YADKIN COUNTY
Petitioner
v.
N.C. DEPARTMENT OF ENVIRONMENT,
HEALTH AND NATURAL RESOURCES
Respondent
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
91 EHR 0193
STIPULATION ENLARGING TIME
It is stipulated that the time for filing a Prehearing Statement
is enlarged for days to and including day of
, 1991.
This the 9th day of April, 1991.
J=mes L. Graham
Attorney For Petitioner
P. O. Box 625
Yadkinville, NC 27055
919-679-8082
Edwin L. Gavin II
Attorney For Respondent
512 N. Salisbury St.
Raleigh, NC 27611
919-733-7247

STATE OF NORTH CAROLINA
YADKIN COUNTY
YADKIN COUNTY
Petitioner
v.
N.C. DEPARTMENT OF ENVIRONMENT,
HEALTH AND NATURAL RESOURCES
Respondent
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
91 EHR 0193
STIPULATION ENLARGING TIME
It is stipulated that the time for filing a Prehearing Statement
is enlarged for days to and including day of
1991.
This the 9th day of April, 1991.
•
mes L. Graham
Attorney For Petitioner
P. O. Box 625
Yadkinville, NC 27055
919-679-8082
Edwin L. Gavin II
Attorney For Respondent
512 N. Salisbury St.
Raleigh, NC 27611
919-733-7247

PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
POST OFFICE BOX 27687
RALEIGH, NORTH CAROLINA 27611- 7687
NOTIFICATION OF INTENT TO DENY ISSUANCE OF A
STATE NPDES PERMIT
Public notice of intent to deny issuance of a State NPDES permit to the following:
•
1. NPDES Permit No. NC0064726. Yadkin County, P. O. Box 146, Yadkinville, NC 27055
has applied for a permit renewal for a facility located at East Bend Industrial Park on NC Highway
67 in Yadkin County. The facility discharges 0.010 MGD of treated domestic wastewater from
one outfall into an unnamed tributary to the Yadkin River a Class WS-III stream in the Yadkin -Pee
Dee River Basin which has a 7Q10 flow of 0 cfs and a 30Q2 flow of 0.07 cfs.
On the basis of preliminary staff review and application of Article 21 of Chapter 143, General
Statutes of North Carolina, Public Law 92 - 500 and other lawful standards and regulations, the
North Carolina Environmental Management Commission proposes to deny issuance of a permit to
discharge to the persons listed above effective May 31, 1991.
Persons wishing to comment upon or object to the proposed determinations are invited to submit
same in writing to the above address no later than May 16, 1991. All comments received prior to
that date will be considered in the formulation of final determinations regarding the permit denial.
A public; hearing may be held where the Director of the Division of Environmental Management
finds a significant degree of public interest in this permit denial.
The existing permit file is available for review by writing or calling the Division of Environmental
Management, Water Quality Section, Permits and Engineering, P.O. Box 27687, Raleigh, NC
27611 919/733-5083 or the Winston-Salem Regional Office, 8025 North Point Boulevard, Suite
100, Winston-Salem, NC 27106.
at these locations during application and other information may be inspected g normal office
hours. Copies of the information on file are available upon request and payment of the costs of,
reproduction. All such comments or requests regarding the proposed permit denial should make
reference to the NPDES permit number listed above.
George T. Everet , Director
Division of Enir'• onmental Management

cc
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
WINSTON-SALEM REGIONAL OFFICE
MEMORANDUM
TO:
THROUGH:
FROM:
SUBJECT:
March 19, 1991
Donald Safrit, Supervisor
Permits and Engineering Unit
Steve Mauney w
Water Quality Supervis r, WSRO
David Russell
Environmental Specialist, WSRO
East Bend Ind. Park WWTP
Objections to Intent to Deny Permit
NPDES Permit No. NC0064726
Yadkin County
Renewal.
�fiR�iT.s ,� FNr
The denial of the renewal of the existing 0.01 mgd NPDES
permit does not prevent this facility from having a wastewater
disposal option. A recently prepared Engineering Economic
Analysis (EEA) concluded that there is a non -discharge
alternative for wastewater disposal available at this site. If
the non -discharge alternative is followed, the park could still
receive 0.01 mgd of flow which is the same volume permitted by
the NPDES permit. There would be no loss of flow capacity below
what presently exists with the NPDES permit.
It should also be remembered that the existing package plant
has resale value. If it is taken out of service, the plant could
be sold and the money used towards the installation of the
non -discharge system. The county would not use its entire
original investment in the plant.
Based on present policy, it is recommended the permittee
follow the recommendation of the EEA.
Should you have questions, contact our office.
DR/dh
Ce afgeA)
Tfj 'ter
" C ektijr1-
MAR2
1997

0\)'\
STATE OF NORTII CAROLINA
COUNTY OF (I) YADKIN
IN TILE OFFICE OF
ADMINISTRATIVE HEARINGS
(2) Yadkin County
Petitioner,
(Your Name)
Department of Environment,
(3) and Natural Resources
Respondent.
(The State Agency or Board about which you are
complaining)
)
)
)
)
PETITION
- FOR A
CONTESTED CASE HEARING
1 hereby ask for a contested case hearing Ms.provid d for by G.S. 150B-23 because the
(4) Dept. of Envirorrent, fiealtn and Natural has (briefly state facts showing how you believe you have
Resources (name of agency)
been harmed by the state agency or board)
SEE ATTACHED
(if more space is needed, use additional sheets and attach)
(5) (Check all that apply):
Because of these facts, the agency has:
deprived me of property;
X ordered me to pay a fine or civil penalty; or
has otherwise substantially prejudiced my rights; and based on these facts the agency has
exceeded its authority or jurisdiction;
X acted erroneously;
failed to use proper procedure;
X acted arbitrarily or capriciously; or
failed to act as required by law or rule.
VERIFICATION
I, the undersigned, first being duly sworn, say that this petition is true to my own knowledge, except as to matters
stated on information and belief, and as to those, I believe them to be true.
SWORN TO AND SUBSCRIBED BEFORE ME
(11) February 27, 1991 (6) February 27, 1991
Date ���/ � Date
r.�.$.A,_, //
..i U- ✓L01.5--,..) (7) &I..��% I / 4.421 44"--
Signatur Your Signature '
(13) () L (8) P. 0 . Box 146
(12)
Health
Title of person au:
(14) My Commission Expires: (O -- I S—
(15) (Seal)
(9) Yadkinville, NC 27055
Your Address
(10) Area Code e 19) 679-4200
Your Telephone Number
Mail the original to the Office of Administrative hearings, , Raleigh, N.C. 27604 and mail
a copy to the State agency involved.
tk - (revised 08-01-90)
STATE( OF P�ORTH CAROLINA
OFFICE OF ADMINISTRATIVE HEARINGS
POST OFFICE DR'.wER 27447
RALEIGH, NORTH CAROLINA 27611.7447
RECEIVED
MAR 0 8 19`i l
ExH NcR

February 27, 1991
Permit was originally issued for discharge of waste from Industry
into stream close to Industrial Park near East Bend, North Carolina.
After Sutton Reproduction, Inc. located in the Industrial Park and
began operations, the County began operating waste water treatment
facility. Then in January, 1991 the County received notice of intent
to deny renewal of NPDES permit. The County will suffer considerable
damage in that Industry located in the Industrial Park on condition the
County would operate waste water treatment facility and Industry will
be inhibited from further expansion it desires and County will not be
able to recruit other industries for the Industrial Park. Also, County
will lose c9nsiderable amount of money it has invested for waste water
treatment facility.

CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State agency named below by depos-
iting a copy of it with the United State Postal Service with sufficient postage or by delivering
it to the named agency.
Served on: (16) George T. Everett
(name)
(17)Deiartment of Environment, Health, and Natural Resources
(agency)
(18) 512 North Salisbury Street
(address)
Raleigh, North Carolina 27611
(19) This the 27th day of February , 19 91
(20)dietk.44_
Petitioner co
tk - (revised 08-01-90 11-06

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0064726
PERMIIIIEE NAME: Yadkin County / East Bend Industrial Park
Facility Status: Existing
Permit Status: Renewal*
Major Minor
Pipe No.: 001
Design Capacity: 0.010 MGD*
Domestic (% of Flow): 100 %
Industrial (% of Flow):
Comments:
* NOTE: See attached letter draft.
** cf. #5196 A&B —+--
STREAM INDEX: 12-(711
RECEIVING STREAM:
Class: WS-III
an unnamed tributary to the Yadkin River
Sub -Basin: 03-07-02
Reference USGS Quad: C17NW (please attach)
County: Yadkin
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 6/30/91 Treatment Plant Class: 2
Classification changes within three miles:
na
Requested by: Jule Shanklin j Date: 1/16/91
Prepared by: wne+. �iQ,�e�� Date:
Reviewed by: �[!)+,ri7�� ;,��� Date: 3 9
Modeler
Date Rec.
#
S{q.u.)
kk t l (
49001
Drainage Area (mi2 ) . I g Avg. Streamflow (cfs):
7Q10 (cfs) 0 Winter 7Q10 (cfs) 30Q2 (cfs) o. 07
Toxicity Limits: IWC % Acute/Chronic
Instream Monitoring:
Parameters
Upstream Location
Downstream Location
Effluent
Characteristics
Summer
Winter
BOD5 (mg/1)
NH3-N (mg/1)
D.O. (mg/1)
TSS (mg/1)
F. Col. (/100 ml)
pH (SU)
47
-
\
p!
r
,
Comments: �,6coM M EN h DtN i A (. o f ►'bt i T B,A SE b
0n1 Ao/4w15VA ',l/6 L-rr4R t /tiz/G l .

Facility Name
NPDES No.
Type of Waste
Facility Status
Permit Status
Receiving Stream
-1-
FACT SHEET FOR WASTELOAD ALLOCATIONS
:East Bend Industrial
:NC0064726
:100% Domestic
:Existing
:Renewal
:UT Yadkin R. (Justice
Stream Classification:WS-III
Subbasin :030702
County :Yadkin
Regional Office
Requester
Date of Request
Topo Quad
:WSRO
:J. Shanklin
:1/16/91
:C17NW
Park/ Yadkin Co.
RECEIVED
N.C. Dept. NRCD
FEB 21 1°Q1
Reque Vd ; .#.. 007, 4„ rn
Reynolds Creek `AR 1991
PF9MITS r FmpANFroinir
Stream Characteristics:
USGS # est per USGS Date 9/87
Drainage Area: 0.18 sq.mi
Summer 7Q10: 0.0 cfs
Winter 7Q10: cfs
Average Flow: cfs
30Q2: 0.07 cfs
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
This is a very controversial wasteload in regard to flow and discharge
point. The facility has received a letter from DEM denying any
modification request to move the discharge point to below the confluence
with the UT (where it is currently permitted with secondary limits, but
never actually located the discharge point there). The current discharge
location is estimated to be zero 7Q10s, so the facility was warned that
upon renewal of the permit, limits of 5/2 would be implemented.
An engineering report for E. Bend indicated that non -discharge
alternatives were available. The facility has been out of compliance with
TSS and effluent DO. East Bend was also required to perform monthly
toxicity testing (by Admin. letter)- two tests have been reported at this
time (one being acutely toxic).
Instream data indicate DO problems both up and downstream of E. Bend.
Recommend removal of discharge based on available alternatives and DO
problems, as well as detrimental impact to pond downstream.
Special Scheduled Requirements and additional comments from
Reviewers:TJ.45 revc-pajal i5 fe, 4,e denied Pa6ed oft et ale
awyat.4 — ' t .Duz. /z.J$)-ioRo
Recommended by: c44 C , /44.1_ Date: 216/1f
Reviewed by
Instream Assessment: 0401LA.Date: ci-11 I f
Regional Supervisor: ,S� ,ZQ , GJ, Date: 2-2,9- 5 /
Permits & Engineering: Date: 3 7f1/
MAR 2 G 1991
RETURN TO TECHNICAL SERVICES BY:

Existing Limits
Wasteflow (MGD) :
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1) :
TSS (mg/1):
Fecal Coliform (/100 ml):
pH (SU) :
Oil & Grease (mg/1):
Toxicity:
Recommended Limits
Wasteflow (MGD):
BOD5 (mg/1):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Coliform (/100 ml):
pH (SU) :
Oil & Grease (mg/1): 30
TP (mg/1) :
TN (mg/1):
Toxicity:
-2-
CONVENTIONAL PARAMETERS
Monthly Average
Summer/Winter
0.010
30/30
5/5
30
Administrative
acute toxicity
Monthly Average
Summer/Winter
0.010
5/10
1/1.8
6/6
30/30
200
Q P/F at 99%
Daily Maximum
6-9
60
letter to perform monthly
testing
Daily Maximum
6-9
60
INSTREAM MONITORING REQUIRMENTS: DO, Fecal coli, Temp, conductivity
Upstream: y Location: at least 100 ft. upstream
Donwstream: y Location: at least 300 ft. downstream
Limits Changes Due To: Parameter(s) Affected
Instream Data
Ammonia Toxicity
Chlorine
New facility information
NH3-N
BOD5, NH3-N, DO
Other
Facility never relocated discharge point, so more stringent limits should
be implemented.
(explanation of any modifications to past modeling analysis
includidng new flows, rates, field data, interacting discharges, etc.)

10/89
Facility Name
114
Permit # NG0O4047z
CHRONIC TOXICITY TESTING REQUIREMENT (QR'I'RLY)
The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity tests,
using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is lot % (defined as treatment two in the North Carolina procedure
document)...The permit holder shall perform grrterly monitoring using this procedure to establish
compliance with the permit condition. The. first test will be performed after thirty days from
issuance of this permit during the months of FHB, M,4y, Au,ct Nab . Effluent
sampling for this testing shell be performed at the NPDES permitted final effluent discharge below
all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in.association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
7Q10 • 0 cfs :0
Permited Flow o. o I MGD Recommended by:
IWC% (vo.0
Basin & Sub -basin 03o70Z..
Receivin StreaUT'AVILIN Q. siic.E F YuouPS t,R.ic ,��j.9� ike7—,mVg�
•
. .
County 'A6v44,1 Date Z/t5/41 '
**Chronic Toxicity (Ceriodaphnia) P/Fat 9i %, Peel M»yA�yIt ,See Part 3, Condition 44 .

14:3 IeU r 41cS/ S-4.3
Car+%-.-:')
c f2Yfgq
State of North Carolina
Department of Environment, Health, And Natural Resources
Division ofEnvironmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph. D.
William W. Cobey, Jr., Secretary Director
Charles S. Mashburn, County Manager
Yadkin County
PO Box 146
Yadkinville, NC 27055
January 22, 1991
Subject: NPDES Permit No. NC0064726
East Bend Industrial Park
Yadkin County
Dear Mr. Mashburn:
Your application for a NPDES permit modification of the 0.010 MGD discharge of treated
wastewater into an unnamed tributary to the Yadkin River from the subject wastewater treatment
facility was received on March 22, 1989. The existing wastewater treatment plant discharges into a
stream that has no natural flow on at least seven (7) consecutive days during a ten (10) year period,
but has flow on at least thirty (30) consecutive days during a two (2) year period. Current regulations
require a BOD5 limit of 5 mg/1, an ammonia limit of 2 mg/1, and a dissolved oxygen limit of 6 mg/1
for a stream with the above -listed 7Q10 and 30Q2 characteristics.
The permit modification was to move the discharge to a location where there was 7Q10 and
30Q2 flow. There were adverse comments submitted on the request for relocation of, the outfall.
Subsequently, a Public Meeting was held on April 17, 1990 for purposes of receiving public input.
As a result of recommendations made by the Meeting Officer and on my direction, you submitted an
Engineering Economic Analysis in accordance with Title 1SA, North Carolina Administrative Code,
Subchapter 2B .0105(c)(2) which indicated that a more environmentally sound cost 'effective
alternative is available. Therefore, your request for a relocation of the outfall is denied. The County
should pursue abandonment of the treatment plant and permitting of a subsurface system as outlined
in the engineer's report.
As mandated, you submitted your renewal request which was received on December 31,
1990. As outlined in the first paragraph, the current discharge is into a zero 7Q10 flow stream and a
more environmentally sound cost effective method to surface discharge is available in the form of
subsurface disposal. Therefore, in the near future, this Division will send your permit renewal
application to public notice stating our intent to deny your request for renewal of the subject NPDES
permit. The Division intends to deny your request for renewal prior to expiration of the permit.
Consequently, continued operation of the WWTP after denial or permit expiration, whichever is
later, will subject Yadkin County to enforcement action as outlined in the North Carolina General
Statutes.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Charles Mashburn, Page 2
If you wish to withdraw your request for renewal of the NPDES permit, you may do so by
stating that desire in a letter to our office. Your letter must be received by our office within thirty (30)
days of your receipt of this letter.
If this -decision is unacceptable, you have the right to an adjudicatory hearing upon written
request withal thirty (30) days following receipt of this letter. this request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with
the Office of Administrative Hearings, Post Office Drawer 11666, Raleigh; North Carolina 27604.
Unless such demand is made, this decision shall be final and binding.
If you have any questions on this permit application, please contact Mr. Dale Overcash of
my staff at telephone number 919/733-5083.
cc: Winston-Salem Regional Office
gr hits ancbM,,.Engineering4Ui iti
Central Files
SteveiTedder

p2t;So57150 t57
N422(14726
b r y/)_kt R_ . [Jk T«W G = yNoLpf C2z .7) vas -L-
CattirwAT
EPCf'll®eVt - cur Trf Ey
N6VE-- rinaJcp F{Ege-ghaw ur
( 3of3n . M rTs-)— —
14 e. 07g 445 '? 7
1'.ortt5o5t69
Aa.I.�».Z
7oroy = 0.2 ,
•
I�`ir - Sul; &m14 Frta, k4 1i T STATE f . fLCT TaTievitV3rAttik
PND.
I/gl - Lltr2____EnonA 77Eitn 72N4 7;t%0141, QF P E(2.ur i 44112�ac, iFtv14 6getctAT/oN)
r, 5/2 t.'M,-r5. -Ar aff?giN_T
(oh° - SuP�M, tEQ �ricrl?._ �p�� _iJGt7LIN,NUJ A1-T PN6r1VCNv0 ->r5cN 24--
LFarr Ta p, ant Ce r/i 2 :'74i N4 7;+l6.y LocAle fiee;✓t
14a4E
ID(Sc-� �WK� Z �(�r uneas APPLY) -- - -
. (O/B 7 - l�17-ly I/20kt ' w r t.rtti5 7IN4 S/Z C& ovt i,¢AC,r, (P) 63e'ww D2ASS rrzl P7/oc_wp,_ �0 ✓Fcuil7c
is
1- fL85o1<usr% _4AE02.0IkTio,t) QF=iNt:_ FLo AT- Cu2iCENLDt5( 12124_S-_ -
4A) C57rM.r1TE of D.A. = D • le ml z (97- Pbtnj; 4&o ✓E 72,g/j1L (c 1 2A4 S721 P'
..,E57-/m4TE:0 7Q IOs • 0 rrwru. 4o W/7a( Till 5
7 rlc/LE

INSTREAM SELF -MONITORING DATA
MONTHLY AVERAGES
Discharger: t• rg&JD
Receiving Stream:
Upstream Location:
DATE
DEC-90
NOV-90
OCT-90
SEP-90
AUG-90
JUL-90
JUN-90
MAY-90
APR-90
MAR-90
FEB-90
JAN-90
EC-8 9
NOV-89
OCT-89
SEP-89
AUG-89
JUL-89
JUN-89
MAY-89
APR-89
MAR-89
FEB-89
JAN-8 9
DEC-88
NOV-88
OCT-88
SEP-88
AUG-88
JUL-88
JUN-88
MAY-88
APR-8 8
MAR-88
FEB-88
JAN-88
DEC-87
NOV-87
OCT-87
SEP-87
AUG-87
JUL-87
JUN-87
MAY-87
APR— 8 7
MAR-87
FEB-87
JAN-87
•
Permit No. : NCO() 64124.
Sub -basin:
Downstream Location 7
Upstream
TEMP!, D.O. COND
9. 5Ci1) f o(9)
(Liao .
ram.
P
N44
27,5(2 144 00
2.i• S(Z ?. 2 t}, 4
Iq.2(Z•
lZ(Zo)
'390°)
Go)
00)
2,0 (40)
140(570)
`t(3 )
3-!@) ALP)
3 4v)
Downstream
TEMP D.O. COND
lo•a(i) "CO _iii2P5
1y:3(te) EEO JAL?
17; (8.,) a g (F9 ..(24c)
zz. Zs) 4(3) 4 ((
2 ) 2214
�) 3
ZtZe) s 3 Z _
9.a((17) ;,3() Rio) _
S(to) 2 154(Izvo _
8. ��IQ� 3� fSI %oo _

Division of Environmental Management
MEMORANDUM
To:
March 13, 1991
Steve Mauney
Water Quality Regional Supervisor
Winston-Salem Regional Office
From: Donald Safrit, Supervisor
Permits and Engineering Unit
Subject: East Bend Ind Park - Yadkin Co.
Permit No. NC0064726
Yadkin County
As per current procedures, please review the attached petition filed with the
Office of Administrative Hearings. Please evaluate the objections raised by the
permittee and provide me with your comments within ten (10) working days
(based upon your receipt).
If you have any questions relating to this matter, please do not hesitate to
contact Dale Overcash at 733-5083.
cc:
Office of General Counsel
Permits and Engineering Unit
Dale Overcash

To:
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 13, 1991
Trevor Clements
stant Chief for Technical Support
From: Donald Safrit, Supervisor
Permits and Engineering Unit
Subject:
County of Yadkin
East Bend Industrial Park
Permit No. NC0064726
Yadkin County
As per current procedures, please review the attached petition filed with the
Office of Administrative Hearings. Please evaluate the objections raised by
the, permittee and provide me with your comments within ten (10) working
days (based upon your receipt).
If you have any questions relating to this matter, please do not hesitate to
call.
cc:
Office of General Counsel

Facility
East Benci Ind Park - Yadkin Co.
Permit No.
NC0064726
County
Yadkin
Region
Winston-Salem
WQRS
Steve Mauney
OGC Attorney
Not Yet Assigned
Reviewer --O\
ercash
Permit Issued
01 / 2 2 / 91
OAH Petition
0 2 / 2 7 / 91
.Reg Com Req
03/13/91
Reg Com Rec
GW Com Req
GW Com Rec
Tech Sup Com
03/13/91
Tech Sup Com
Env Sci Com Req
Env Sci Com Rec
Permit Adjudication
If any questions, please
contact Reviewer or Don
- Safrit- at 733-5083..
Revised Permit
Memo from
Resolved
1.
Denial of relocation of outfall.
2.
Intent to deny permit renewal.
3.
4.
S.
6.
7.
8.
Comments

STATE OF NORTH CAROLINA
COUNTY OF (I) YADK I N
1
IN TIIE OFFICE OF
MINISTRATIVE IIEARINGS
(2) Yadkin County
Petitioner,
(Your Namc)
De Partment of EnvEiron lent, Health
(3) and Natural Resources
Respondent.
(The State Agency or Board about which you are
complaining)!
M.r '
VAR 6 ‘951
`zi •
)
)
)
)
).
)
PETITION
- FOR A
' CONTESTED CASE HEARING
DECEIVED
MAR o I 1991
BciunEs ASSESSMENT UNIT
I hereby ask foxa contested c4§e a ring �s,provid for byG.S. 1 SOB-23 because the
(4) pea. of ;virrct n 3it, tiBa� aTIQ fvdUiralhas (befly state facts showing how you believe you have
ribSOul CeS (name of agency)
been harmed by the state agency or board)
SEE 'ATTACHED
(if more space is needed, use additional sheets and attach)
(5) (Check all that apply):
Because of these facts, the agency has:
deprived me of property;
X ordered me to pay a fine or civil penalty; or
has otherwise substantially prejudiced my rights; and based on these facts the agency has
exceeded its authority or jurisdiction;
X acted erroneously;
failed.to use proper procedure;
X acted arbitrarily or capriciously; or
failed to act as required by law or rule.
VERIFICATION
I, the undersigned, first being duly sworn, say that this petition is true to my own knowledge, except as to
stated on infor ation and belief, and as to those, 1 believe them to be true.
SWORN TO AND SUBSCRIBED BEFORE ME
(11) February 27, 1991
Date
(12) i�..
Signatur
(13)
Title of person mu rued to administer oaths
(14) My Commission Expires: I O -- (' i
(15) (Seal)
February 27, 1991
Date
/z2
Your Signature
P. 0. Box 146
matters
Yadkinville, NC 27055
Your Address
(10) Area Code a 19) 679-4200
Your Telephone Number
Mail the original to the Office of Administrative Hearings, , Raleigh, N.C. 27604 and mail
a copy to, the State agency involved.
STATE OF NORTH CAf OLINA
OFFICE OF ADMINISTRATIVE HEARINGS
DRAWERPOST OFFICE
RALEIGf , NORTH CAROL NA2/611-74477
tk - (revised 08-01-90)
11-06

February 27, 1991
Permi was originally issued for discharge of waste from Industry
into stream close to Industrial Park near East Bend, North Carolina.
After Sutton Reproduction, Inc. located in the Industrial Park end
began operations, the County began operating waste water treatment
facility. Then in January, 1991 the County received notice of intent
to deny renewal of NPDES permit. The County will suffer considerable
damage in that Industry located in the Industrial Park on condition the
County would operate waste water treatment facility and Industry will
be inhibited from further expansion it desires and County will not be
able to recruit other industries for the Industrial Park. Also, County
will lose considerable amount of money it has invested for waste water
treatment facility.

CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State agency named below by depos-
iting a copyof it with the United State Postal Service with sufficient postage or by delivering
ffi
it to the named agency.
Served on: (16)
(17)Department of Environment, Health, and Natural Resources
(agency)
George T. Everett
(name)
(18) 512 North Salisbury Street
(address)
Raleigh, North Carolina 27611
(19) This the 27th day of February , 19 91
(20) dL4 )72a
Petitioner ceu-. gro,
tk - (revised 08-01-90 1I-06

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Govemor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
February 18, 1991
CERTt1ED MAIL
RETURN RECEIPT REQUESTED
Mr. Charles Marshburn
East Bend Industrial Park
P. O. Box 146
Yadkinville, North Carolina 27055
SUBJECT: Assessment of Civil Penalties for Violations) of N.C.
General Statute(s) 143-215.1(a)(6)
Yadkin County
File No. LV 91-03
Dear Mr. Marshburn:
This letter transmits nbtice of a civil penalty assessed against East Bend Industrial Park
in the amount of $3219.14 including $219.14 in investigative costs.
Attached is a copy of the assessment document explaining this penalty. This action was
taken under the authority vested in me by delegation pursuant to N.C.G.S. 143-215.6(a)(8).
Any continuing violation(s) may be the qubject of a new enforcement action, including an
additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment, Health, and Natural Resources (do not include waiver limn).
Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s);
Pollution Prevention Pays
P.O. Box 27687, Raleigh. North Carolina 27611-7687 Telephone [phone]

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
•
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure
for contesting the accuracy of any of the statements contained in the
assessment letter. Because a remission request forecloses the option of an
administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this office
the attached waiver and stipulation form and a detailed statement which you
believe establishes that:
(a) one or more of the civil penalty assessment factors in G.S. 143B-
282.1(b) were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage
resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous
violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Mr. Steve W. Tedder
Water Quality Section Chief
Division of Environmental Management
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must
request an administrative hearing. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 11666, Raleigh, North Carolina 27604. A copy of the petition
must be served on the Department as follows:
Mr. John C. Hunter
Registered Agent
Office of General Counsel
Department of Environment, Health, and Natural Resources
Post Office Box 27687
Raleigh, North Carolina 27611-7687

Failure to make payment or exercise one of your options listed above within thirty
days will result in this matter being referred to the Attorney General's Office with a request
to initiate a civil action to collect the penalty. Please be advised that additional assessments
may be levied for future violations which occur after the review period of this assessment.
If you have any questions, please contact Mr. Kent Wiggins at [phone].
Sincerely,
George T. Everett
ATTACHMENTS
cc: Regional Supervisor
Compliance/Enforcement File
Central Files

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF YADKIN
IN THE MATTER OF
EAST BEND INDUSTRIAL PARK
FOR VIOLATIONS OF:
NPDES PE IT NO. NC0064726
AND NORT CAROLINA GENERAL
STATUTE 43-215.1(a) (6)
Acting pursuant to North Carolina General Statute (G.S.)
143-215.6., I, George T. Everett, Director of the Division of
Environmntal Management, make the following:
f
I. FINDINGS OF FACT:
File No. LV 91-03
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
A. Yadkin County operates a .010 MGD wastewater treatment
plant at East Bend which is located in Yadkin
County, North Carolina.
B. The County of Yadkin was issued NPDES No.
NC0064726 effective on December 3, 1987, with an
expiration date of June 30, 1991.
C. Said permit contains the following relevant monthly
average effluent limitations:
Parameter Limitation Units
Flow .010 MGD
BOD 30 mg/1
TSS 30 mg/1
D.0 5.0 mg/1
Fecal Coliform 1000/100 mi
Oil & Grease 30 mg/1
pH 6-9 SU
D. Monthly self -monitoring reports revealed the
following concentrations of parameters in violation
of permit effluent limits: (See Attachment A)
E. Notices of Violation concerning the operational
deficiencies at the subject plant were sent to
Mr. Charles Mashburn by the Winston-Salem
Regional Office.

F. None of the above exceedances of the permit effluent
limitations were the result of a bypass or power
failure at the Plant as defined in the permit condition.
G. Staff costs and expenses associated with detecting
the violations, defining their nature and extent, and
bringing the enforcement action, totalled
$219.14.
Based upon the above Findings of Fact, I make the
following
II. CONCLUSIONS OF LAW:
A. The County of Yadkin, is a "person"
within the meaning of G.S. 143-212(4).
B. NPDES Permit No. NC0064726 is required by G.S.
143-215.1.
C. The effluent limitations contained in subject permit
are terms, conditions or requirements of said permit.
D.
E.
F.
The County of Yadkin, violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 3 occasions between December 1989 and March
1990, in the manner and to the extent as
described in Attachment A when The County of
Yadkin permitted waste to be discharged into the
waters of the State in violation of permit
effluent Limits for pH.
Th%County of Yadkin violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 3 occasions between February 1990 and April
1990, in the manner and to the extent as
described in Attachment A when The County of
Yadkin permitted waste to be discharged into
the waters of the State in violation of permit
effluent limits for TSS.
The County of Yadkin violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 1 occasion in May 1990, in the manner and to
the extent as described in Attachment A when The
County of Yadkin permitted waste to be
discharged into the waters of the State in
violation of permit effluent limits for fecal
coliform.

H.
I.
General Statute 143-215.6(a)(1) provides that a
civil penalty of not more than ten thousand dollars
per violation may be assessed against a person who
violates or fails to act in accordance with the
terms, conditions, or requirements of a permit
required by G.S. 143-215.1.
General Statute 143-215.3(a)(9) provides that
reasonable costs of any investigation,
inspection, or monitoring survey, may be
assessed against a person who violates any
regulations, standards, or limitations, adopted
by the Environmental Management Commission or
violates any terms or conditions of any permit
issued pursuant to G.S. 143-215.1, or special
order, or other document issued pursuant to G.S.
143-215.2.
The Director, Division of Environmental
Management, pursuant to delegation authorized by G.S.
143-215.6(a)(8), has the authority to assess civil
penalties.
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Pursuant to G.S. 143-215.6(a)(3), in determining the amount
of the penalty, I have taken into account the Findings of
Fact and Conclusions of Law and the factors set forth at
G.S. 1438-282 .1(b), which are:
1) The degree and extent of harm to the natural
resources of the State, to the public health, or to
private property resulting from the violation;
2) The duration antigravity of the violation;
3) The effect on ground or surface water quantity or
quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or
intentionally;
7) The prior record of the violator in complying or
failing to comply with programs over which the
Environmental Management Commission has regulatory
authority; and
8) The cost to the State of the enforcement procedures.

Accordingly, The County of Yadkin shall be, and hereby
is, assessed a civil penalty of:
IDNKg
$ 3000. cm For 014 of 7 violations of G.S.
143-215.1(a)(6) and NPDES Permit No.
NC0064726, by discharging waste into
the waters of the state in violation
of permit effluent limits.
00 o, o-D
TOTAL CIVIL PENALTY, which is
4 5 percent of the maximum
penalty authorized by G.S.
143-215.6.
$ ;a �S1 4 Investigation costs.
$ 3 of PD ! y'' TOTAL AMOUNT DUE
/8` /90)
(Date)
•
orge T. Everett, Director
Division of Environmental Management

DATE
Dec. 1989
Jan. 1990
Feb. 1990
Mar. 1990
Apr. 1990
May 1990
NA = not assess
Attachment A
Effluent T imit Violations
pH SU TSS_mg/1 Fecal Coliform
4.5
4.5 56
5.5 NA 41
128
1245

SUBJECT
MRO
Fast Track Review
East Bend Industrial
NC0064726
Yadkin County
NUMBER
+
LOCATION
ERROR
1)
File No.
Type in LV 91-03
2)
1st paragraph
Reference to G.S. 143-215.6 should be143-215.6A
3)
I.D.
limits (attachment A).
4)
I.G.
no comma needed after action
5)
II.D.
the, not The County
6)
II.G.
143-215.6A(a), not 143-215.6(a)(1)
7
II.I.
143-215.6A(h),not 143-215.6(a)(8)
III
143-215.6A(c), not 143-215.6(a)(3)
9)
III
CIVIL PENALTY reference as 143-215.6A not 143-215.6
*If this is the way I understand things, I don't think we would want to include the
December 1t989 pH violation. That would change II.D. to 2 violations and the Price tag
page to a total of 6 violations. Please tell me if this is how it works.
g,ctu r L‘.) ��e w

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Winston-Salem Regional Office
January 23, 1991
MEMORANDUM
TO: Steve Tedder
THROUGH Larry Coble
Steve Mauney
FROM: Jim Johnston 19
SUBJECT: Fast Track -Civil Penalties Assessment
Effluent Limit Violations
East Bend Industrial Park
NPDES Permit No. NC0064726
Yadkin County
East Bend Industrial Park has violated monthly average
effluent permit limitations for pH, TSS and Fecal Coliform
on seven (7) occasions as documented by self -monitoring
reports submitted to DEM for the period December 1989
through November 1990. Attached are three copies of the CPA
detailing the violations.
The following items are relative to this case:
A. Contact person: Charles Mashburn
Title: County Manager
B: Address of the assessable party: P. O. Box 146
Yadkinville, N.C. 17055
C: Facility status:
1. Recent inspections (Date and Findings) -
CEI/April 17, 1990 - No chlorine Tablets
in chlorinator, no monitoring for Oil
and Grease or toxicity.
CEI/September 12, 1990 - few solids in
aeration basin, mosquito larvae in
clarifier. Monitoring deficiencies
have not been corrected'.
CEI/November 1, 1990 - Plant meeting -2' ,:1
secondary limits, larvae still
observed in clarifier. JAN 29 1991
I::iNTRAL FILE COPY

2. Recent meetings with facility -None from
the WSRO.
3. SOC negotiations - On July 12, 1988, an
SOC was hand delivered to the County
Manager. He refused to sign the Order.
4. The Instream Waste Concentration after
moving the discharge would be 23.66%.
However, at the present discharge the Flow
would be 95% or greater.
If you have any questions or comments, please call.
•
29 1991
CENTRAL FILE COPY

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF YADKIN
IN THE MATTER OF
EAST BEND INDUSTRIAL PARK
FOR VIOLATIONS OF:
NPDES PERMIT NO. NC0064726
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1(a) (6)
File No. *****
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to North Carolina General Statute (G.S.)
143-215.6., I, George T. Everett, Director of the Division of
Environmental Management, make the following:
I. FINDINGS OF FACT:
A. Yadkin County operates a .010 MGD wastewater treatment
plant at East Bend which is located in Yadkin
County, North Carolina.
B. The County of Yadkin was issued NPDES No.
NC0064726 effective on December 3, 1987, with an
expiration date of June 30, 1991.
C. Said permit contains the following relevant monthly
average effluent limitations:
Parameter Limitation Units
Flow .010 MGD
BOD 30 mg/1
TSS 30 mg/1
D.0 5.0 mg/1
Fecal Coliform 1000/100 ml
Oil & Grease 30 mg/1
pH 6-9 SU
D. Monthly self -monitoring reports revealed the
following concentrations of parameters in violation
of permit effluent limits: (See Attachment A)
E. Notices of Violation concerning the operational
deficiencies at the subject plant were sen )21; 1`N
Mr. Charles Mashburn by the Winston-Salem
Regional Office. `""�
AN 29 1991
CENTRAL FILE, COPY

F. None of the above exceedances of the permit effluent
limitations were the result of a bypass or power
failure at the Plant as defined in the permit condition.
G. Staff costs and expenses associated with detecting
the violations, defining their nature and extent, and
bringing the enforcement action, totalled
$219.14.
Based upon the above Findings of Fact, I make the
following:
II. CONCLUSIONS OF LAW:
A. The County of Yadkin, is a "person"
within the meaning of G.S. 143-212(4).
B. NPDES Permit No. NC0064726 is required by G.S.
143-215.1.
C. The effluent limitations contained in subject permit
are terms, conditions or requirements of said permit.
D. The County of Yadkin, violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 3 occasions between December 1989 and March
1990, in the manner and to the extent as
described in Attachment A when The County of
Yadkin permitted waste to be discharged into the
waters of the State in violation of permit
effluent limits for pH.
E. The County of Yadkin violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 3 occasions between February 1990 and April
1990, in the manner and to the extent as
described in Attachment A when The County of
Yadkin permitted waste to be discharged into
the waters of the State in violation of permit
effluent limits for TSS.
F. The County of Yadkin violated G.S.
143-215.1(a)(6) and NPDES Permit No. NC0064726
on 1 occasion in May 1990, in the manner and to
the extent as described in Attachment A when The
County of Yadkin permitted waste to be
discharged into the waters of the State in
violation of permit effluent limits for feca ,a -„
•;l
1`?/ lr�
conform.- (��
JAN 29 1991
cm,1TRAL FILE COPY

G. General Statute 143-215.6(a)(1) provides that a
civil penalty of not more than ten thousand dollars
per violation may be assessed against a person who
violates or fails to act in accordance with the
terms, conditions, or requirements of a permit
required by G.S. 143-215.1.
H. General Statute 143-215.3(a)(9) provides that
reasonable costs of any investigation,
inspection, or monitoring survey, may be
assessed against a person who violates any
regulations, standards, or limitations, adopted
by the Environmental Management Commission or
violates any terms or conditions of any permit
issued pursuant to G.S. 143-215.1, or special
order, or other document issued pursuant to G.S.
143-215.2.
I. The Director, Division of Environmental
Management, pursuant to delegation authorized by G.S.
143-215.6(a)(8), has the authority to assess civil
penalties.
Based upon the above Findings of Fact and Conclusions of
Law, I make the following:
III. DECISION:
Pursuant to G.S. 143-215.6(a)(3), in determining the amount
of the penalty, I have taken into account the Findings of
Fact and Conclusions of Law and the factors set forth at
G.S. 143B-282 .1(b), which are:
1) The degree and extent of harm to the natural
resources of the State, to the public health, or to
private property resulting from the violation;
2) The duration and gravity of the violation;
3) The effect on ground or surface water quantity or
quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or
intentionally;
7) The prior record of the violator in complying or
failing to comply with programs over which the
Environmental Management Commission has regulatory
authority; and
8) The,cost to the State of the enforcement,_procedures
J ti JAN 29 1991
c041.014L flt.E COPI

Accordingly, The County of Yadkin shall be, and hereby
is, assessed a civil penalty of:
For each of 7 violations of G.S.
143-215.1(a)(6) and NPDES Permit No.
NC0064726, by discharging waste into
the waters of the state in violation
of permit effluent limits.
$ TOTAL CIVIL PENALTY, which is
percent of the maximum
penalty authorized by G.S.
143-215.6.
$ Investigation costs.
$ TOTAL AMOUNT DUE
(Date) George T. Everett, Director
Division of Environmental Management
JAN 29 MI
c:NTRAL FILE. COPY

ATTACHMENT A
EFFLUENT LIMIT VIOLATIONS
DATE pH SU TSS mg/1 Fecal Coliform m/1
Dec. 1989 4.5
Jan. 1990
Feb. 1990 4.5 56
Mar. 1990 5.5 41
Apr. 1990 128
May 1990 1245
2:g
T
29 JAN 1991
CENTRAL FILE COPY

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Enforcement Case Assessment Factors
Violator:
Identification Number
Regional Office: Winston-Salem
1. Degree and extent of harm and risk of harm caused by the
violation(s) East Bend Industrial Park discharged
wastewater in violation of the final effluent
limitations for TSS, pH, and Fecal Coliform.
2. Number of violations: 7 violations.
3. Duration of violation(s): pH was exceeded 3 months in
the review period, TSS was exceeded 3 months in the
review period and Fecal Coliform was exceeded one
month in the 12 month review period from 12/89 through
11/90.
4. Degree and extent of violation(s): See 1 and 3 above.
5. Cause of violation(s) (Intentional, Negligence, or
Otherwise): Characteristics of loading on plant and
the fact that an operator is at the plant
approximately 2 hours a day.
6. Economic benefit gained by violator by noncompliance:
Unknown
7. Type of violator and general nature of business (i.e.,
individual vs. large corporation): Industrial Park
with one customer - Century Reproductions. This is a
furniture company with only domestic waste.
8. Violator's history of compliance or noncompliance:
This is the first enforcement action initiated against
East Bend Industrial Park. Ten NOV's have been sent
to East Bend Industrial Park since December 1989.
• i
JAN 29 1991
(AN { PAL, f' 1LE COPY

Page 2
DEM Enforcement Case Assessment Factor
I.D. Number
9. Violator's degree of cooperation (including efforts to
prevent or restore) or recalcitrance: Most actions by
the Yadkin County Board have been to try to circumvent
that which should have been done. An SOC was drafted
for East Bend Industrial Park. When taken to the
county to be signed, the County Manager refused to
sign. The ORC told this Office that he had very
little contact or input from the County and that he
was not notified at times of requirements that had
come down from the State.
10. Costs of detecting violation, defining its extent, and
bringing enforcement action: The cost of the
investigation is $219.14.
11. Mitigating circumstances, such as noncompliance
attributable to Government or factors beyond
violator's control: Not known.
Investigator
Regional Supervisor ,C C`
Date
©11271)
JAN 29 1991 4.1
7.NATRAL.. FILE COPY •

I certify that the information in this report is true to the
best of my knowledge and that all violations of self -monitoring data
have been verified by hard copy review of the monthly reports and the
applicable permit.
Signature of Principal Investigator(s):
Date:
JAN 29 1991
C.EP4TRAL FILE COPY

State of North Carolina
Department of Environment, Health, And Natural Resources
Division ofEnvironmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph. D.
William W. Cobey, Jr., Secretary Director
January 22, 1991
Charles S. Mashburn, County Manager
Yadkin County
PO Box 146.
Yadkinville, NC 27055
Subject: NPDES Permit No. NC0064726
East Bend Industrial Park
Yadkin County
Dear Mr. Mashburn:
Your application for a NPDES permit modification of the 0.010 MGD discharge of treated
wastewater into an unnamed tributary to the Yadkin River from the subject wastewater treatment
facility wag received on March 22, 1989. The existing wastewater treatment plant discharges into a
stream that has no natural flow on at least seven (7) consecutive days during a ten (10) year period,
but has flow on at least thirty (30) consecutive days during a two (2) year period. Current regulations
require a BOD5 limit of 5 mg/1, an ammonia limit of 2 mg/1, and a dissolved oxygen limit of 6 mg/1
for a stream with the above -listed 7Q10 and 30Q2 characteristics.
The permit modification was to move the discharge to a location where there was 7Q10 and
30Q2 flow. There were adverse comments submitted on the request for relocation of the outfall.
Subsequently, a Public Meeting was held on April 17, 1990 for purposes of receiving public input.
As a result of recommendations made by the Meeting Officer and on my direction, you submitted an
Engineering Economic Analysis in accordance with Title 15A, North Carolina Administrative Code,
Subchapter! 2B .0105(c)(2) which indicated that a more environmentally sound cost 'effective
alternative is available. Therefore, your request for a relocation of the outfall is denied. The County
should pursue abandonment of the treatment plant and permitting of a subsurface system as outlined
in the engineer's report.
As ;mandated, you submitted your renewal request which was received on December 31,
1990. As outlined in the first paragraph, the current discharge is into a zero 7Q10 flow stream and a
more envir 9 nmentally sound cost effective method to surface discharge is available in the form of
subsurface disposal. Therefore, in the near future, this Division will send your permit renewal
application to public notice stating our intent to deny your request for renewal of the subject NPDES
permit. The Division intends to deny your request for renewal prior to expiration of the permit.
Consequently, continued operation of the WWTP after denial or permit expiration, whichever is
later, will subject Yadkin County to enforcement action as outlined in the North Carolina, General
S
te r' ? � c ee
��t• ? tatutes. .; _. .•.. ; ,�;
Pollution Prevention Pays ,14i 2 c,3 199
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] CQPi
An Equal Opportunity Affirmative Action Employer

110.
Charles Mashburn, Page 2
If you wish to withdraw your request for renewal of the NPDES permit, you may do so by
stating that desire in a letter to our office. Your letter must be received by our office within thirty (30)
days of your receipt of this letter.
If this:decision is unacceptable, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. this request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with
the Office of Administrative Hearings, Post Office Drawer 11666, Raleigh, North Carolina 27604.
Unless such demand is made, this decision shall be final and binding.
If you have any questions on this permit application, please contact Mr. Dale Overcash of
my staff at telephone number 919/733-5083.
cc: Winston-Salem Regional Office
Permits and Engineering Unit
Ceniles
Steve Tedder
f '
r' 1
JAN 25 1991 '
C NI PAL 1=11,g COPY

.. ltA �t. sat •• t t ..;..
di SENDER: .Complete Items ,1 and 2 when additional services are desirtd and complete items •.
lor 3 6nd'4. .� . t �; ,1
Put your address in the "RETURN TO'.' Space on the'reverse side Failure to do this will prevent�this'
card from being returned to you. The return receipt fee will provide you the name of the person delivered
to and the'date of delivery. For additional fees the following services are available. Consult postm'ester
for fees and check boxes) for additional service(s) requested. .
1. 0 Show to whom delivered, date, and addressee's address. 2. 0 Restricted Dei ery
(Extra(Extra charge
4. Article Number —•
3. Article Addressed to:
Ch rn
cgs P ir }�
© P4
4cA W-'J1tt.r C a 7ds.s'
Pure Ad
6. Signature — Agent
X
'ape of Service:
U Registered : ❑ Insured
M Certified . 0 COD
Express Mail Return Receipt
-, ,., ..-for-Merchandise
Always o• otalrj stg at re� adir
ore
7. Date of Delivery
t-3.44t
PS Form 3811, Mar. 1988
* U.S.G.P.O. 1988-212-865
UNITED STATES POSTAL SERVICE
OFFICIAL BUSINESS ,
SENDER INSTRUCTIONS
Print your name, address and -ZIP Code
in the space below.
• Complete items 1, 2, 3, and 4 on the
reverse.
• Attedh to front of article if space
permits, otherwise affix to back of
t
• Endorse article "Retum Receipt
Requested" adjacent to number.
RETURN
TO IW
111111
0 4,4 E?
FEB 19s1
•
`agen(-end DATED LI R
8 }Addressee'sAl park fON
equesud� feed jl
} ,i\i I RA-. FILE
COPY
DOMESTIC RETURN RECEIPT
PENALTY FOR PRIVATE
USE, $300
Print Senders name, address, and ZiP Code In tie space bolo*.
OU.U•C A4 3 A
Pi. 2e.. 7 9- .57a.Al..3IiS6i,5
41e.;.e a71/

DIVISION OF ENVIRONMENTAL MANAGEMENT
January 18, 1991
MEMORANDUM
TO:
Harry Bunting
Attorney General's Office, Tort Claims
Raney Building
FROM: Steve W. Tedder, Chief
Water Quality Section
SUBJECT: Suit by John Pruett/East Bend Industrial Park
NPDES Permit, Yadkin County
In regard to our phone conversation on January 1, 1991 concerning the above referenced
suit, I have evaluated the case in question. This correspondence is to advise you that all files in
the possession of the Section are at your disposal for review and copying as necessary. Please be
aware that Divisional policy does not allow us to loan files to be taken out of the Archdale
Building if a working file.
The permit file can be obtained from Dale Overcash in the Permits & Engineering Unit, 9th
Floor, Archdale Building. Additional environmental information on this case can also be obtained
from Ken Eagleson of the Environmental Services Branch, 9th Floor, Archdale Building and
Carla Sanderson of the Technical Support Branch, 9th Floor of the Archdale Building.
As I have not been provided a copy of the suit, it is difficult to provide a name of the most
appropriate staff to serve as your main witness. At this time I would have to suggest Steve
Mauney who is the Water Quality Supervisor of our Winston Salem Regional Office and/or Mr.
Ken Eagleson of our headquarters staff.
Please give me a call when you wish to discuss further.
SWT: ps
cc: Don Safrit
dale Overcash
Carla Sanderson
Ken Eagleson
Steve Mauney
Larry Coble

LACY H. THORNBURG
ATTORNEY GENERAL
MEMORANDUM
DATE:
TO:
FROM:
SUBJECT:
Pursuant
complaint
HB / kg
State of North Carolina
Department of Justice
P.O. BOX 629
RALEIGH
27602-0629
January 15, 1991
Larry Tedder
Water Quality Section Chief
NC Department of Environment, Health
& Natural Resources
Archdale Building
Barry Bunting
Special Deputy Attorney General
Tort Claims Section
Raney Building
wrr�
-JAN 18 199
WATER QUALITY
SECTION
John Whidden Pruett v. DE%3NR, LC. Docket No.
TA-11992, AG File No. 90-969
to our telephone conversation of 1-15-91 enclosed find a copy of the
filed in the above action. Any help would be appreciated.
An Equal Opportunity/Affirmative Action Employer

796 : g)--
.his
NORTH C •.OLINA INDUSTRIAL COI.IMISSI0f _�1001
1. ('. 1.T(,Is N. 'r-
T RALEIGIi
CLAIM FOR DAMAGES UNDER TORT CLAIMS ACT, G. S. 143-291 et. seq.
FATE OF NORTH CARQLINA
COUNTY OF YADKIN
AFFIDAVIT
JOHN WH.IDDEN PRUETT , being duly sworn, deposes and says:
(PRINT NAM Or CLAIMANT)
1. That his name is
JOHN WHIDDEN PRUETT
2. That he lives at IkQ.VTE 4,, BOX 1801 EAST BEND, NC 27018
and that his mailing address is ROUTE. .4.,...BOX REND.,...NC..Z7.Ra.$
3. That he hereby files a claim against
N. C. DEPT. OF ENVIRONMENT,, HEALTH & NATURAL RESOURCES
(STATE AGENCT OR COUNTY BOARD OF EDUCATION)
for damages resulting from the negligence of 4- "` r '' .....6...ti .12 1
PRINT NAME or EMPLOYEE OR AGENT INVOLVED)
4. That he has been damaged in the amount of $ ' 41.4.c.r .c (7' by reason of the negligent conduct of the
employee or agent named above.
5. That the injury or accident giving rise to this claim occurred at
.BUTNER MILL ROAD, EAST BEND, NC
BUTNER MILL POND,
(PRINT NAME OF COUNTY ANO EXACT LOCATION WHOM ACCIDENT OCCYIIRED)
on 19 , at M.
(MONTH) (DAY) (TIME)
G. That the injury or property damage occurred in the following manner:
(GIVE BRIEF STATEMENT Or WHAT HAPPENED. NAMES OF WITNESSES, ETC.)
Plaintiff owns a lake and stream directly downstream from Yadkin County's sewage treatment
plant. According to state regulations there was not an appropriate 7-Q-10 flow rate and
effluent has been out of compliance with the permit issued by the N.C.E.H.N.R., permit
number NC0064726. Further, the actual point of emission is out of compliance with said
permit by 1400 feet. Defendant's conduct has actually and proximately caused Plantiff
damage. Plantiff has,
since inception• of flow, been continuously damaged by the activity.
Defendant's conduct was continuing and with full knowledge of the wrong.
7. That the damages claimed above consist of +L
(ITEMIZE REPAIR SILL. MEDICAL BILLS. ETC.)
\•..4rf
IN TESTIMONY WHEREOF, the said
ri
land and seal, this day of
Subscribed and sworn
1.
SIGNATURE ANO SEAL
to before me
day of
• A...:7......41..: ..C.>t.c:,t7 has hereunto set his
19..:' �)
OF CLERK OF COURT OR NOTARY PUOLIC
(NAME OF CLAIMANT)
UMW r ,19 '
Zeifje9X;rde----
(SIGNATURE OF CLAIMANT)
Iv
COMMISSION EXPIRE.'
FILE FOUR COMPLETE
Cnl'i1:S WITH TH1 INDUSTRIAL COMMISSION
M 1.1.70 (Ti 1.1t1)1111teM of dittunges tiro submitted Itttach 2 copies)
SEE grvrRSE •sIOr :C FORM FOR r,LING INSTRUCTIONS

IV
7.
EXHIBIT "A"
a) loss of income, enjoyment and use of
grist mill and dam $400,000
b) 1/2 mile irrigation system with pump 2,500
c) swimming facility of lake 4,000
d), lake restoration within last 20 years 20,000
e) fishing utility [$200/year x 20 years] 4,000
f) depreciation of land around settling
pond TBD*
g) irrigation water for leafy vegetables
in garden [$200/year x 20 years]
TOTAL
TO BE DETERMINED
EXCLUSIVE OF ITEM f).
4,000
$434,500 *

Oai
OPERATION/CONSTRUCTION MANAGERS
-'P.O. Box 97, Gamer, North Carolina 27529 [phone]
October 12
, 1990
Mr. M. Dale Overcash, P.E.
Division of Environmental Management
N.C. Department of Environment, Health
and Natural Resources
Room 925-0
512 North alisbury Street
P.O. Box 2 687
Raleigh, N.C. 27611-7687
Re: East Bend Industrial Park
Yadkin County, N.C.
NPDES Permit No. NC0064726
Dear Mr. Overcash:
CIVIL/SANITARY ENGINEERS
Engineering
Company, P.A.
P.O. Box 349, Boone, North Carolina 28607 [phone]\--
• cc+
ou 1;, • 3 U
PERMITS & E7,1MIEFRit+1(;
Enclosed herewith are three (3) copies of an Engineering Economic Analysis
which has seen prepared for the County of Yadkin as required by Mr. George T.
Everett in his letter of May 22, 1990. This report was originally due on
July 15, 1990, but time extensions were granted with the new due date being
October 15, 1990.
As you will observe, the enclosed report is not as detailed as the guidelines
sent to the County require. Upon investigation of this matter, it became
quite clear that the best route for all concerns is to go to a non -discharge
disposal means and eliminate the point discharge, thus a costly analysis was
not performed.
It is our
industrial
subsurface
recommendation that Yadkin County approach -the -landowner in the
park and come to some agreement as to the const �-,�;�p a
disposal system. , `�, N 'r I f
6_., JAii 28 1991
CENTRAL rtredPY

04,
Mr. M. Dale Overcash, P.E.
October 12, 1990
Page 2
If you have any questions or desire any additional information, please feel
free to contact either Mr. Harry Dail or myself.
Yours very Itruly, a
MUNICIPAL ENGINEERING SERVICES CO., P.A.
Gar er 0ff i1ce'" F
' N
Grp �� OCT
•
19JU
s ePOWS
i
Ja C.
D'' hl P.E.
Enclosures
cc: Mr. Charles S. Mashburn, Yadkin County Manager, w/encl.
Mr. L. Harry Dail, P.E.
Mr. Jim Woodie, P.E., R.L.S.
JCD
G 90085
csu daim,„ Pieo. ge_ 5,4A. 66di.
�-, L ca4.4. (fie mx-J,t, /z. 61P.-
.f e S ke crime_ 1 S-Pf . ce, d aviztot 4
£ c1 c,r
toot
JiAta.L.() 1991 c.„i
C c N T R. i Ft; t ,-,
%lAt! 1991
CENTRAL L FILE COPY

,,ytao¢7sa�a,°�
���CA; »! J e0,0
ee��©nooaoa0. 'l4+4�'SAvn
t p
f �
i448A
t�,rrt s ` ��
10/iz /q'
ENGINEERING ECONOMIC ANALYSIS
East Bend Industrial Park
Yadkin County, NC
October 12, 1990
Prepared by:
Municipal Engineering Services Co.," P.A.
P.O. Box 97
Garner, N.C. 27529
Telephone: [phone]
9 fl v t r: r
OCT izs 1 JU
PERMITS A ?..:;! t.'FP1tr:C:
liIIIilll'
v :Y I R:tiL. FILE COPY

INTRODUCTION
The East Bend Industrial Park, located on N.C. Highway 67 Bypass at the eastern
town limit of East Bend, N.C., was developed as a joint effort with the participation
of Yadkin County and a private concern. This project was undertaken in the late
1980's to attract new industry to the northeast region of Yadkin County.
One of the features of the Fast Bend Industrial Park is the provision of "city" water
and wastewater services, that is centralized services which do not require prospective
purchasers to install individual wells and wastewater disposal means. These utility
services are provided by a connection to the Town of East Bend water distribution
system for water supply and a package wastewater treatment facility with a point
discharge which is operated and maintained by Yadkin County. This discharge was
perriiitted by the Division of Environmental Management of the N.C. Department of
Natural Resources and Community Development under permit number NC0064726
on July 14 of 1986, which was issued to the John S. Clark Company and later
transferred to Yadkin County.
The package type extended aeration treatment plant is permitted and sized for a flow
of 10,000 gallons per day. The receiving stream has a 7Q10 low flow of
approximately 0.058 cfs according to the U.S.G.S. Currently, due to limited
development in the park, the average daily flow through the plant is 2000 gallons,
which occurs only during normal work hours. This low loading has resulted in
continual operating difficulties and records obtained from the Division of
Environmental Management indicate numerous periods which the effluent limitations
were not met.
Ownership of the undeveloped portion of the East Bend Industrial Park has been
recently transferred to Century Reproductions, the firm which is presently located in
the park and is the sole contributor to the wastewater flow at this time. With one
entity owning the remaining land in the park, it is questionable whether growth will
occur in the near future, if ever, therefore additional revenues cannot be taken into
consideration for justifying improvements.
The discharge permit for the East Bend Industrial Park expires on June 30, 1991..
During a public meeting regarding the renewal of this permit, there was an
expression of opposition to renewal by the public. This opposition has initiated a
detailed study into the feasibility of continuing to discharge wastewater from the
East Bend Industrial Park versus other means of disposal.
This analysis will investigate various wastewater disposal methods for the East Bend
Industrial Park and the benefits of each method. A detailed economi was�i;
not performed as will be explained in the Summary. r a
+.::F:;NTR.AL F1Lc, COPY

fai
CONNECTION TO OFF -SITE DISPOSAL SYSTEM
According to Mr. Charles Mashburn, Manager of Yadkin County, there are no
publicly or privately owned wastewater treatment facilities in the area with
collection systems within five miles of the East Bend Industrial Park which can be
utilized to receive wastewater from the Park. In addition, there are no plans for
either a publicly or privately owned system in the future that he is aware of.
This alternative will not receive any further consideration.
OCT I 1990
PERitAM-;
1991
its

SUBSURFACE DISPOSAL OF WASTEWATER
In order to evaluate the suitability of the undeveloped portions of the industrial park
for subsurface disposal of wastewater, Soil and Environment Consultants,
hereinafter referred to as S&EC, was engaged to make a preliminary investigation.
Their report is included in the appendix of this document.
According to the S&EC report, there are three regions of undeveloped land in the
industrial park site which exhibit characteristics suitable for either conventional or
low pressure type subsurface disposal methods. The most suitable site is an area in
the southeast portion of the tract, which is adjacent to the existing treatment facility
and is currently covered by hardwoods. This site encompasses approximately seven
acres which is sufficient for the application and repair area for either subsurface
disposal method. Since this is a portion of the original land intended for sale as a
building site, the total expected wastewater flow would be reduced if a subsurface
disposal system were located here.
In order to utilize a subsurface disposal system, Yadkin County would have to
obtain the site from Century Reproductions. The prospect of obtaining a site from
landowners adjacent to the industrial park is very doubtful based on the public
opposition already voiced.
Since there is already a central collection system in place, it would be most
advantageous to utilize a low pressure system with the septic tank and pumping tank
located in the vicinity of the existing treatment facility.
Maintenance requirements on a low pressure subsurface system are moderate,
consisting mainly of pumping solids out of the septic tank occasionally, flushing
distribution piping and monitoring the pump operation. Power consumption is
minimal. If a subsurface disposal system were employed, the existing treatment
plant could be removed and sold to offset the cost of the subsurface system. The
expense of sludge disposal would be eliminated as would the cost of disinfection and
the majority of the required laboratory testing.
OCT i 1990
PERMITS & FT,:nla�-
"•°yhFRfivp

_._ ... �.�. ...�. .r J.3:
LAND APPLICATION OF WASTEWATER
The suitability of the site for land application of the treated wastewater from the East
Bend Industrial Park was also included in the S&EC report. Land application
requires a slightly smaller application area, but the required buffers along with
stricter access restrictions can possibly encumber a larger area than subsurface
disposal. As mentioned previously, the application site would have to be obtained
from Century Reproductions.
The land application disposal system will require construction of a holding lagoon to
store, effluent during periods of wet weather and disinfection of the wastewater. If
the existing treatment plant were utilized for pretreating the wastewater, there will
be a need for sludge disposal as now exists along with the operating and
maintenance requirements now associated with the plant. Additional maintenance
requirements include care of the sprinkler nozzles, flushing of the piping and cover
crop disposal.
Other than simply eliminating the discharge to the creek, there is no other advantage
to a land application system.
c_.,. e„-;
CENTRAL r.__ COPY

CONTINUING TO DISCHARGE
4'.:1"q\VED
U L, i 1 1990
t.RMil:• �. ',INFF?Il4 F�•_f r.
If the ultimate disposal of wastewater from the East Bend Industrial Park were to
remain as a point discharge of treatment plant effluent at the present location,
modifications to the treatment plant would be imperative to achieve the effluent
quality of 5 ppm BOD and 2 ppm NH3 which will be required. A dual train plant
and standby power will also be required by DEM. Rough estimates for completing
these modifications are in the $30,000 to $40,000 range. The modifications to the
plant will reduce its capacity to 5000 GPD, thus necessitating the installation of a
second treatment unit if additional capacity should be required. Extending the
discharge downstream several hundred feet to the confluence of a second stream may
enable the County of maintain the 30/30 limits, but the requirements for the dual
train plant and standby power will remain. The possibility of these limits being made
more `stringent in the future is another item which must be considered. The disposal
of wastewater treatment plant sludge will also continue to be a matter of concern for
this facility.
The estimated cost of operating this treatment plant, approximately $12,000 per
year, far exceeds the revenue generated by present user fees. The hopes of
recovering the expense for improvements which may be required to continue to
discharge are quite small.
' J
JAr
J � . jj
f
8 1991
CENTRAL FILE COPY

�3r
SUMMARY
Without performing a detailed economic analysis, it is quite apparent that it would
be in fie best interest of Yadkin County to further consider the construction of a
subsurface disposal system and abandon the treatment plant and point discharge. As
it now stands, the cost of modifying the treatment plant to meet effluent quality
stand ds will probably equal or exceed the cost of constructing a subsurface system.
The overall operating and maintenance cost savings realized by going to a subsurface
system may pay for the improvements in a matter of a few years.
Since the entire industrial park is now owned by one entity, it may be beneficial for
the County to enter into an agreement with the owner to acquire the responsibility of
wastewater disposal for their operations.

\*� w RECEIVED ")/0
!/ OCT 1 '' !am
SFAV/rxc rnt`APPN`t
•
Soil & Environmeiiial C� sultants, Inc.
1125 Cedarhurst Drive i Raleigh, North Carolina 27609 9 [phone]
Municipal Engineering Services Co.
Attn: Mr. James Diehl
P 0 Box 97
Garner, NC 27529
October 2, 1990"`
- I��'J
Preliminary* Soil/Site Evaluation and Recommendations - East Bend
Industrial Park, South of Highway 67, Yadkin County, N. C.
A soil site evaluation of the above named property was performed
by Kevin C. Martin, Certified Professional Soil Scientist, to
determine its suitability for an on -site waste water treatment
system. The evaluation was performed by making hand auger borings
to depths sufficient to determine any soil limitations and to
identify the soil to the series level.
Soils examined were in a wooded area as shown on the attached map.
Soils in this area are most like the Cecil or Pacolet Series
(clayey, kaolinitic, thermic typic Hapludults) or taxadjuncts of
those series. Such soils are suitable for conventional septic
systems, but can be used for Low Pressure Pipe or spray irrigation
systems.
The Cecil Series is a gently sloping, well drained, deep piedmont
soil which formed under forests in material weathered from acid
crystalline rock. Organic matter content and natural fertility is
low and shrink -swell potential is low to moderate. The soils are
naturally acidic. Depth to the water table and bedrock at this
site is greater than 10 feet. Typical Unified classification of
the Bt horizons are CL, MH. Typical AASHO classification of the
Bt horizons are A-6, A-7. Cation Exchange capacity of the Bt
horizon is usually around 5-10 meq/100g. The Pacolet series is
similar to the Cecil except that saprolite is encountered at less
than 30 inches. Typical profile descriptions taken from county
soil surveys are attached for the Pacolet and Cecil Series.
Land Area Requirements (Exclusive of DEM Required Buffers)*
Assumptions: Permitted Flow - 10,000 gpd
Present Average Flow 2,000 gpd.
* Prior to a detailed system design, a more detail,e.d soils
evaluation of the site would be needed.
Soil/Site Evaluation, Mapping and Physical Analysis
Wetland Mapping and Mitigation, Environmental Audits
On -Site Waste Treatment Systems, Evaluation and Design
ri,rl,rJ,r101
CENTRAL. FILE COPY

Acceptable Conventional Ground
Absorption Loading Rate: .25 gpd/sq.ft. to .35 gpd/sq.ft.
Acceptable Low Pressure Pipe
Ground Absorption Loading Rate: .1 gpd/sq.ft. to .15 gpd/sq.ft.
Acceptable Spray Irrigation
Surface Application Loading Rate: .5"/wk. to 1"/wk.
Conventional System Requirements:
The linear feet of conventional trench needed for the permitted
flow is 9500' to 13,300'. This would translate into a minimum
system area of 2 to 2.75 acres for the system alone. An equal
amount of repair area will be needed also. We have noticed that
an additional 15% of land area is normally needed on large systems
to account for topographic irregularities (e.g. gullies, swales,
diverging contour lines, etc.). Therefore, as much as 4.6 acres
to 6.3 acres may be needed for system and repair areas to handle
the permitted flow.
Low Pressure Pipe (LPP) System Requirements:
The line
ar feet of low pressure pipe laterals needed for the
permitted flow is 13,300 to 20,000 feet. This translates into
1.53 to 2.3 acres for the system alone. An equal amount of repair
area sill be required also. We have observed that large LPP
systems often require 25% more area than originally expected when
installed in wooded sites such as this. This is mainly due to
topographic irregularities and "dodging" large trees which causes
some laterals to be installed on spacings of greater than the 5'
on center design and thus translates into utilization of
additional area so that the minimum linear feet of laterals can be
installed. Because of this,as much as 3.83 to 5.75 acres may be
required for system and repair areas to handle the permitted flow.
DEM permitted conventional and LPP systems
must
' or moreon the
be located a
least 50' from property lines. We recommend s
5"down hill" side to allow for proper monitoring well instal -
Spray Irrigation System Requirements:
The area required for a spray irrigation system with a flow of
10,000 gpd on a Cecil or Pacolet soil will be 2.8 to 5.15 acres.
Spray systems do not require an equivalent repair.,ar a:.
- These
t jam-
:. N RAL FILE COPY

Oa?
systems also do not normally need the additional area required in
large conventional and LPP systems discussed previously since the
laterals feeding the sprinklers can be located in any pattern as
long ash the sprinklers themselves are properly located.
However, spray systems must be located a minimum of 150' from
property lines and 400' from any residence of place of public
assembly off the property. Spray systems over 1,000 gpd also
require a minimum 30 day holding lagoon.
I believe that the information in this report along with the
attached site map should be sufficient for a preliminary assess-
ment of the potential on -site waste water treatment alternatives
for this project. If you have questions or•would like for us to
assist you pursuing one or more of these alternatives, please
call.
Sincerely, Waiki
E
r
Kevin C1 Martin,
President
Enc.
•
77,

uecii ieries
The Cecil series consists of well drained, moderately
permeable soils on uplands. They formed in residuum •
weathered from felsic igneous and metamorphic rock,
such as granite. Slope ranges from 2 to 15 percent.
These soils are clayey, kaolinitic, thermic Typic
Kanhapludults.
Cecil soils are commonly adjacent to Appling,
Gaston, Madison, and Pacolet soils. Appling soils are
more yellow. Gaston soils are darker red in the upper
part of the Bt horizon, and Madison soils have a high
content of mica. Pacolet soils are on side slopes and
have a thinner subsoil.
Typical pedon of Cecil sandy clay loam, 2 to 8
percent slopes, eroded; 3 miles northwest of Cherryville
on North Carolina Highway 274, 1.5 miles west on State
Road 1650, 50 feet northwest of intersection with State
Road 1647:
Ap-0 to 6 inches; yellowish red (5YR 4/6) sandy clay
loam; weak medium granular structure; very friable;
common fine and medium roots; medium acid;
abrupt smooth boundary.
Bt1-6 to 26 inches; red (2.5YR 4/6) clay; moderate
medium subangular blocky structure; firm, sticky
and plastic; common fine roots; common fine pores:
common distinct clay films on faces of peds; few
fine flakes of mica; strongly acid; gradual wavy
boundary.
Bt2-26 to 45 inches; red (2.5YR 4/8) clay; moderate
medium :subangular blocky structure; firm, sticky
and plastic; few, fine roots; few fine pores; common
faint clay films -on faces of peds; few fine flakes of
mica; strongly acid; gradual wavy boundary.
BC-45 to 58 inches; red (2.5YR 4/6) clay loam; few
medium distinct brownish yellow (10YR 6/8) mottles;
weak medium subangular blocky structure; friable;
common fine flakes of mica; few pockets of
saprolite; strongly acid; gradual wavy boundary.
C-58 to 80 inches; red (2.5YR 4/8) saprolite that has a
loam texture; common medium distinct brownish
yellow (10YR 6/8) mottles and few fine faint dark
red mottles; massive; friable; common fine flakes of
mica; strongly acid.
Cecil soils have a loamy A horizon and a
predominantly clayey Bt horizon that extend to a depth
of 30 to 58 inches. The solum is 35 to 60 inches thick.
Depth to bedrock is more than 6.5 feet. The A horizon
is medium acid to very strongly acid unless lime has
been added. The Bt and BC horizons are very strongly
acid or strongly acid. Content of mica flakes ranges
from few to common in most pedons.
The A or Ap horizon has hue of 2.5YR to 7.5YR,
value of 4 or 5, and chroma of 3 to 8.
The Bt horizon has hue of 1OR or 2.5YR, value of 4
or 5, and chroma of 6 to 8. Hue can range to 5YR in
some pedons where the soil is not mottled. The Bt
horizon is clay or clay loam. The BC horizon has hue of
2.5YR to 5YR, value of 4 to 6, and chroma of 4 to 8. It
is clay loam or sandy clay loam.
The C horizon is reddish or multicolored saprolite
weathered from felsic igneous and metamorphic rock.
The texture is variable but typically is loamy.
•

horizon.
The C horizon is multicolored saprolite weathered
from felsic igneous and metamorphic rock. The texture
I'acolet Series
The Pacolet series consists of well drained.
moderately permeable soils on uplands. They formed in
residuum' weathered from felsic igneous and
metamorphic rock, such as granite and gneiss. Slope
ranges from 8 to 45 percent. These soils are clayey,
kaolinitic, thermic Typic Kanhapludults.
Pacolet soils are commonly adjacent to Cecil,
Madison, and Wedowee soils. Cecil soils have thicker
subsoils. Madison soils have a high content of mica.
Wedowee soils have a more yellow Bt horizon.
Typical pedon of Pacolet sandy loam, 15 to 25
percent slopes; 2 miles northeast of Dallas, 800 feet
northeast of intersection of State Road 1804 and State
Road 1800:
A-0 to 5 inches; brown (7.5YR 4/2) sandy loam;
moderate medium granular structure; friable; many
fine and medium roots; strongly acid; clear wavy
boundary.
BA-5 to 8 inches; red (2.5YR 4/8) clay loam; •weak fine
subangular blocky structure; friable; common fine
and medium roots; few fine flakes of mica; very
strongly acid; clear wavy boundary.
Bt-8 to 27 inches; red (2.5YR 4/6) clay; few medium
distinct reddish yellow (7.5YR 7/6) mottles;
moderate medium subangular blocky structure; firm;
sticky and plastic; common faint clay films on faces
of peds; common fine flakes of mica; very strongly
acid; gradual wavy boundary.
BC-27 to 39 -inches; red (2.5YR 4/6) clay loam;
common` medium distinct dark red (2.5YR 3/6),
reddish:yellow (7.5YR 7/6), and brownish yellow
(10YR 6/8) mottles; weak medium subangular
blocky structure; friable; common fine flakes of
mica; very strongly acid; gradual wavy boundary.
C-39 to 60 inches; mottled red (2.5YR 4/6), dark red
(2.5YR 3/6), yellowish red (5YR 4/6), and brownish
yellow (10YR 6/8) saprolite that has a loam texture;
massive; friable; common fine flakes of mica; -'very
strongly acid.
Pacolet soils have a loamy A horizon and a
predominantly clayey Bt horizon that extend to a depth
of 20 to 30 inches. The solum is 30 to 50 inches thick.
The depth to bedrock is more than 5 feet. Content of
mica flakes ranges from few to common in most
pedons. The Pacolet soils are medium acid to very
strongly acid unless lime has been added.
The A or Ap horizon has hue of 5YR to 10YR, value
of 4 or 5, and chroma of 2 to 8. Some pedons have an
E horizon that has hue of 5YR to 10YR, value of 4'tb 6,
and chroma of 3 to 8. _
The Bt horizon has hue of 1OR or 2.5YR, value of 4� 'rl 't� �! �;1' 1Q
or 5, and chroma of 6 to 8. It is clay loam, sandy clay�,�
or clay. The BC horizon is mottled in shades of red,
_� y tcgt v"
yellow, or brown. It is clay loam, sandy clay loam, or
sandy loam. Some pedons do not have have a BC r cp.TRAL PILE COPY
..,.inhle }„,1 t..nir&lly is Innmv

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. 'n, Governor George T. Everett, Ph.D.
Wiliam W. Cobey, Jr., Secretary August 29, 1990 Director
Mr. L. Haxry Dail, P.E.
Municipal' Engineering Services Company
P.O. Box 97
Garner, N.C. 27529
SUBJECT: NPDES Permit No. NC0064726
East Bend Industrial Park
Yadkin County
Dear Mr. Dail:
AUG 31 .ti99°
SECT ON
This is to acknowledge my concurrence in your request to
extend the deadline for submittal of a detailed alternatives
analysis for the subject facility from 1 September 1990 to 15
October 1990.
If you have any questions, please call Mr. Larry Coble,
Regional Supervisor in our Winston-Salem Regional Office,
telephone number [phone].
GTE/jho
cc: Lar oble
eve Tedder
dail.1
Sinc
fog George T. Everet*-:1
_j
3 r- r 0 41990 JAN 26 1991 -.-j
< N1*) 1_ FILE COPY

Oh,
Yadkin County• •
P. O. Box 146
CHARLES S. MASHBURN Yadkinville, N. C. 27055
COUNTY MANAGER
August 2, 1990
Mr. George T. Everett, Director
State of North Carolina
Department of Environment, Health
and Natural Resources
512 North Salisbury Street
Raleigh, NC 27611
Dear Mr.
Everett:
TELEPHONE
[phone]
'AUG 6 1990
A IMINIMATRIVE sositr8 to r�}
Re: NPDES Permit # NC0064726
East Bend Industrial Park
Yadkin County
MUG 1 , 1
99Q
.r•rt'tj�T` is • .Ir..I`I
Mr. Jim Woodie of Municipal Engineering, Garner, advises me that he
needs additional time to complete the ECA report that was
originally due July 15, 1990. He also reported that he discussed
and received permission for additional time from you.
Thus, please allow us until September 1, 1990, to complete the ECA
report on East Bend. Industrial Park. We appreciate your
cooperation.
Sincerely,
Charles S. Mashburn
County Manager
CM : pm
cc: Jim Woodie
r
•
AUG . 4 1992
'JAN 23 1991
CENTRAL FILE COPY

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph. D.
William W. Cobey, Jr., Secretary Director
August 1, 1990
Mr. Charles B. Sutton
President
Century Reproductions
PO Drawer 1700
East Bend, NC 27018-1700
Subject: NPDES Permit No. NC0064726
East Bend Industrial park
Yadkin County
Dear Mr. Sutton:
The Division of Environmental Management (DEM) has reviewed your letter of June 6,
1990, concerning the subject facility. There are several issues involved with the permit for
this wastewater plant. The DEM will address them in this letter.
When the facility was initially permitted to John Clark in 1986, the discharge was
required to be piped downstream of the dragstrip to a specified location. The permit was later
reissued to Yadkin County with a condition that the treated effluent was to be piped to a specified
location below the dragstrip. The plant was constructed, but the effluent was not piped to the
location specified in the permit. As a result, the facility is discharging into a stream that has
zero flow during critical times of the year. Current DEM regulations and policy require
stringent limitations (BOD5 = 5.0 mg/I; NH3 as N = 2.0 mg/I; Dissolved Oxygen = 6.0 mg/1)
and removal of the discharge if determined to be feasible for zero flow streams. It is not
environmentally sound to discharge wastewater into a stream with no natural flow.
As a result of a new review, relocation of the outfall downstream to the original
permitted discharge point would result in the retaining the current limits for the permit. The
DEM noticed its intent to reissue the permit for a discharge at the originally permitted
dragstrip location. Due to public input, a public meeting was scheduled on April 17, 1990.
During the public meeting period, the DEM staff was able to determine that there
appeared to be ample land available to install a subsurface or spray irrigation. system. There is
63 acres of undeveloped land in the park. DEM Regulation 15 NCAC 2H .105 (c) (2) requires
the staff to rassure that the most environmentally sound alternative was selected from the cost
effective options." After reviewing the situation and realizing that the park had not been
developed as originally planned, the DEM meeting officer recommended that other options be
evaluated to determine if the requirements of the above -cited regulation are being met. This,
and for the reasons stated above, is the reason that the DEM states that subs lagextrl,spray
irrigation m y be the best option. ��� �, ` ; r:•
fr�
AN 28 1991 '
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] CENTRAL FILE COPY
An Equal Opportunity Affirmative Action Employer

Oh,
Mr. Sutton
Page Two
It is expected that additional costs will be incurred by the county if the plant is
upgraded to meet the stringent limitations listed above. This is one reason that an
environmental economics analysis was required to be completed by the county (see my letter to
Mr. Mashburn dated May 22, 1990 - copy attached). The county may find that when taking into
account operation and maintenance costs that another option of wastewater disposal is more
practical from an economic standpoint as well as an environmental standpoint.
Most of the questions about costs and alternative systems feasibility should be
answered by the county's consultant. These questions should be answered as a result of the
environmental economics analysis. The county should have submitted the required report by
July 15, 1990, as specified in my May 22, 1990, letter to Mr. Mashburn. Please provide this
evaluation within thirty (30) days. Failure to provide this report in the required time period
will subject the permit to be issued with a schedule to eliminate the discharge in the near
future.
I hope this addresses your concerns in regards to the permit for Yadkin County. If you
have any q estions, please contact Mr. Dale Overcash at [phone].
Sincerely,
George T. erett
cc: Mr. Larry Coble
Mr. Charles Mashburn
.� 28 ►991
c : 1 NhL IL. Z copy

GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
' Proposed Discharge
I. GeneralInformation
A. Provide the following:
facility name
county
facility address
report preparer's name
report preparer's North Carolina P.E. certification
number
report preparer's mailing address and telephone number
B . Provide a detailed description of the proposed discharge facilities (you may include a diagram
indicating the plant components and processes)
C. Describe the project served by the WWTP (i.e. school, subdivision, number of students or
households, total waste contribution calculated according to 15 NCAC 2H . 0219 (1), etc.)
D. Indicate if it is a phased development and provide the estimated wasteflow per phase (indicate
curre t phase status for existing facilities) .
II. Evaluation of Environmental Feasibility of Discharge Alternatives
A. Evaluate the environmental feasibility of all three of the following non -discharge alternatives.
1. Connection to Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit).
existing Sewerage System: Indicate distance to an existing sewer line within a
five mile radius (radius extension should be considered if cost effective as it
relates to project size) If there are not available sewer lines in the vicinity, please
note this and proceed to entry 1(b) below.
(1) Provide description of sewer facilities necessary to connect to
receiving wastewater treatment plant.
(2) Provide preliminary indication of flow acceptance from municipal or
private WWTP under consideration for connection (documentation
should include NPDES permit number and county of the accepting
WWTP). If a municipal or private WWTP cannot accept the wastewater,
please explain.
Indicate if third party agreements or easements would be necessary.
Attach a topographic map or, if appropriate, a site drawing showing the
physical aspects of this alternative (i.e. proximity to sewer system, route
for sewer line, property difficulties, etc.)
(3)
(4)
(5) Proceed to Alternative II. A (2) - Subsurface Disposal Systems.
b. Planned Sewerage System: Determine if an area wide sewerage systenLwithin. a
five mile radius is projected to be available within the next ;ve years to receive
waste from the project under study. Determine availability dateia:,an43 flp>y
acceptance projection with appropriate regulatory authority. Identify your contact

Page 2
in the public utility or private management group that assisted you in this
determination. Should a sewer line be available for connection within the next
five years entry (1)(a) should be evaluated.
2. Subsurface Disposal ( Installation of nitrification systems, low pressure pipe systems and
mound systems)
Note: Subsurface disposal systems (i.e., low pressure systems and nitrification systems) are
only permitted by DEM for the following types of facilities: city owned facilities, county
owned facilities, public utility facilities and industrial facilities with an industrial
wastewater component. Other categories of facilities (i.e., privately owned mobile home
parks, homeowner associations, nursing homes, industrial facilities with 100% domestic
waste, etc.) are permitted by local county health departments. Any facility in the latter
category must obtain a statement from the local County Health Department concerning
suitability/unsuitability of soils for subsurface systems.
a. Determine if permittee currently owns land that is available and suitable for a
ground absorption system.
b.
(1) Provide a preliminary report from a soil scientist with a
loading rate recommendation based on soil type.
(2) Provide calculations to determine land size requirements based
on design and loading rate characteristics.
Note: Disposal systems require 100% reserve area.
(3) Indicate if all buffer zone requirements are met according to
15 NCAC 2H .0219 (j). Provide a site plan indicating
proposed layout of subsurface system.
(4) If there is sufficient useable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate useable land on the
site.
(5)
If there is insufficient useable land on the project site, proceed to
entry 2 (b) below, if applicable. Otherwise, proceed to Alternative II A
(3) - Spray Irrigation Systems.
Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 2 (a).
3. - Spray Irrigation System
a. Determine if permittee currently owns land that is available and suitable
for a spray irrigation system. �%: y `^
(1) Provide a preliminary report from a soil scientist ail h a loading rate`"
recommendation based on soil type. 28 1991
CENTRAL. F(LE COPY

Page 3
(2) Provide calculations to determine land size requirements based on design
and loading rate characteristics.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC
2H .0219 (j). Provide a site plan indicating proposed layout of
spray irrigation system.
(4) If there is sufficient useable land, considering the existing
project development plan, what modifications to the plan (such as
reducing the number of units produced, the reduction of design flow,
etc...) would be necessary to allow for adequate useable land on the
site.
(5) If there is insufficient useable land on the project site. Refer to entry
3 (b) if applicable. Otherwise, proceed to Section II. B.
b. Determine if adjacent land could be acquired through purchase or
permanent easement. Provide documentation of availability. If adjacent
land could be acquired, evaluate according to entry 3(a) immediately above.
B . If one or more of the three non -discharge alternatives, II. A (1), (2) or (3) were found
to be environmentally feasible, select one and notify DEM that the alternative will be
undertaken in lieu of submitting the NPDES application. If a non -discharge
application is selected, the rest of this guidance is not required to be completed.
If one or more of the three non -discharge alternatives were found to be
environmentally feasible, but the permit applicant does not wish to select one because
he claims doing so would be unreasonably costly, cost estimates prepared according
to Section III of this Guidance must be submitted to DEM. Proceed to Section H.C.
C.
If none of the three alternatives, II.A (1),(2), or (3) were found to be
environmentally feasible, proceed to Section II.C.
Evaluate the environmental feasibility of the discharge to a flowing stream (defined as
a stream with 7Q10/30Q2>0 cfs flows).
NOTE: This section is not required to be completed unless the three
non -discharge alternatives evaluated in Section II.A. were found to be
environmentally infeasible, or if one or more of the alternatives were found to be
environmentally feasible but the permit applicant claims that selecting any of the
environmentally feasible alternatives would be unreasonably costly.
1. Indicate distance to nearest stream with positive flow meeting the above criteria
(ttach topographic map indicating current existing/proposed discharge point and new
proposed location).
2. Provide documentation as to whether or not third parties agree to rouide eoe -sry:
easements if applicable. Proceed to Section III. ••
JAN 28 99
,� r

Page 4
III. COST ESTIMATION AND COMPARISON
NOTE: Section III must be completed only if one or more of Alternatives (1), (2), and (3)
evaluated in Section II.A. or the proposed discharge evaluated in Section II.C. were found to be
environmentally feasible and the permit applicant claims that selecting the least costly of the
feasible alternatives would be unreasonably costly.
A. Prepare cost estimates in accordance with the following guidelines for each of Alternatives 1,
2 and that were found to be environmentally feasible in Section II. Be sure to convert all
costs to present value as described in Section III.E.
1. Connection to a Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit.).
2.
3.
a. Provide detailed cost estimate of an installed sewer line interceptor and pump
station(s) if applicable (i.e. materials and labor).
b. Determine the operating expenses of the sewer extension (i.e. materials, utilities,
maintenance and operator costs) for the design period.
c. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
d. Indicate connection fees and/or surcharge required by the WWTP under
consideration.
Note: If a periodic surcharge is required, please consider cost in analysis.
Subsurface Disposal (Installation of nitrification systems, low pressure pipe systems
and mound systems).
a. Provide a detailed cost estimate for the installed cost (i.e. materials and
labor) of treatment facilities.
b. Determine the opportunity cost of any land under current ownership to be utilized
under this alternative.
c. Provide the cost of any land to be purchased and/or cost of the permanent
easement (include letter of offer to sell or provide permanent easement with dollar
amount from appropriate party) to be utilized under this alternative.
d. Determine the operating expenses of the subsurface disposal system (i.e.
materials, utilities, maintenance and operator costs) for the design period.
Spray Irrigation System
a. Provide a detailed cost estimate for the installed cost (i.e. materials and labor) of
treatment facilities.
b. Determine the opportunity cost of the land or portion thereo de,p e t
ownership utilized under this alternative. Avg,
c. Provide the cost of any land to be purchased and/or cost of th
rmanent28 1991
CENTRAL FILE COPY

Page 5
easement (include letter of offer to sale or to provide permanent easement with
dollar amount from appropriate party).
d. Determine the operating expenses of the spray irrigation system (i.e. materials,
utilities, maintenance and operator costs) for the design period.
B . If discharge to a flowing stream was found to be environmentally feasible in Section II.C.,
prepare a cost estimate in accordance with the following guidelines. Be sure to convert all
costs to present value as described in Section III.E.
1. rovide detailed cost estimate of installed effluent line and pump station(s) if applicable
..e. materials and labor) to proposed discharge point.
2. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party).
3. Determine the operating expenses of the WWTP (i.e. materials, utilities, maintenance
and operator costs) for design period.
D. Cost Comparison
Title 15 NCAC 2H.0105(c)(2) requires that the most environmentally sound wastewater
disposal alternatives be selected from the reasonably cost effective options. The three
non -discharge alternatives evaluated in Section II.A. are assumed to be roughly equivalent
alternatives where they are found to be environmentally feasible, and preferable to a
proposed discharge. Therefore, if a permit applicant has determined the environmental
feasibility of one or more of the non -discharge alternatives, but he claims the alternative(s),
•
compared to a proposed discharge, would be unreasonably costly,, he must present
justification of the claim based on the appropriate cost comparisons as to why the difference
between the costs would be unreasonable.
E. Present Value of Costs
Costs incurred in different time periods must be converted to a common time period before
they can be accurately combined or compared. Performing this calculation is known as
"computing the present value", or discounting the costs.
The following standard formula for computing the present value must be used in all cost
estimates made under this evaluation guidance.
PV =
Co=
Ct =
t
n
r
PV= Co +
Present value of costs.
Costs incurred in the present year.
Costs incurred in time t.
= Time period after the present year ( The present year is t = 0)
= Ending year of the life of the facility.
= Discount rate. for these calculations, use the rate that is required
Federal agencies in the formulation and evaluation of water
resources plans. The rate is computed annually in accordance
eria1/41-4,66Li 4:4 1:1,
ith S,. �o (a
�$ 99i
Public Law 93-251 [88 Stat. 34] and 18 CFR 70439, and published in th
Federal Register. The current rate (for Federal Fiscal year 198g7, 9,1 ..70% coPY
Therefore in the above formula for this year, r = .08875.

......._ .:,:_...ups+
CHARL
CC
Pis
fGCIM-f gi'i" frt
44-15
Yadkin County.
P. O. Box 146
Yadkinville, N. C. 27055
July 13, 1990
Mr. George T. Everett, Director
State of North Carolina
Department of Environment, Health
and Natural Resources
512 North Salisbury Street
Raleigh, NC 27611
Dear Mr. Everett:
TELEPHONE
[phone]
Rig Cd2/ 11?4,42)
JUL 16 i
MOWN � SEa VIcEai k
JULu
PERMITS & r.::::,;. ; :,, a
., ,fir
Re: NPDES Permit # NC0064726
East Bend Industrial Park
Yadkin County
Because of an extra busy budget season, and other things, we have
not yet completed the requirements of your letter dated May 22,
1990. Besides, we either did not receive or have lost the EEA form
referred to. Will you please send me another one and we will
respond by August 1, 1990.
Thank you for your assistance.
Sincerely,
(141
CharlesS. Mashburn
County Manager
CM:pm
ri
r14, t
JAN 28 1991 �-.✓
CENTRAL FILE COPY

CENTURY REPRODUCTIONS
"1'he British National Trust Collection • Te_S,utton Collection • The Smithsonian Collection
June 6, 1
990
George T. Everett, Ph.D.
Director
Division of Environmental Management
512 North Salisbury Street
Raleigh, North Carolina 27611
Dear Dr. Everett,
•. ; I1--V
tk,
1,... 1
•
Subject: NPDES Permit No. NC0064726
East Bend Industrial Park
//)Yadkin County
I received a copy of your May 22 letter to Mr. Charles Mashburn,
and I attended the April 17 public meeting. My purpose in writ-
ing is to ask for further information and clarification in order
to be sure that we are providing all relevant information during
this decision making process.
What exactly is not environmentally sound with the present waste
treatment plant? What test(s) have been conducted and are those
test results available? I know that the waterflow is not up to
10,000 gallons per day, but is less waterflow considered to be
environmentally unsound?
You note in your May 22 letter that "spray irrigation or subsur-
face disposal of the waste water may prove to be the best option."
What information is there to suggest that this might be an option?
In other words, are you saying that the present waste treatment
plant is not sound environmentally or that it cannot be made to
be sound?
What woul
d the more "stringent effluent limitations" be? Would
such new limitations require any additional cost to the county?
And if so, how much additional cost?
On the surface, abandoning the existing plant and having the coun-
ty purchase another system does not seem to be cost effective if
the present plant can be changed to meet your new limitations.
When should the waste treatment plant come back on line r ^.ja-a.;--;.-
ternative system is in place? How would we know that s ycO- i''zie '-1;
system would be sound environmentally? Do you consideriuch an ''=l' �; ►;
J�if� �g 1991��t
Century Reproductions, Inc. is a Division of Century Furniture Company .: f . L,u Opy
P.O. Drawer 1700 • East Bend, N.C. 27018-1700 • Hwy 67 East Bend industrial Park
919-699-3700 • Fax [phone]

04,
Dr. Everett
Page Two
alternative system to be temporary or permanent? What is the
growth potential of such an alternative system and how does it
relate to the already existing plant? Could both be operation-
al at the same point?
We are certainly concerned about the future of the East Bend
Industrial Park and the county's ability to meet our growth
needs. I would like to provide you with additional informa-
tion as I come to understand the questions before you.
Sincerely, �^
1/.4;(am►
Charles B. Sutton
President
cc: Buck Shuford
Harley -Shuford Jr.
Richard Reese
Charles Mashburn - Please send me a copy of your report.
5-7-71
L f�
1,
JAN 28 1991
CF. N URAL FILE COPY

James G. M
William W.
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
tin, Governor George T. Everett, Ph. D.
obey, Jr., Secretary Director
May 22, 1990
Mr. Charles S. Mashburn
County Manager
Yadkin County
Yadkin County Courthouse
Box 146
Yadkinville, NC 27055
Subject: NPDES Permit No. NC0064726
East Bend Industrial Park
Yadkin County
Dear Mr. Mashburn:
Tlie Division of Environmental Management (DEM) has reviewed the record of the
meeting held on April 17, 1990. Additional information is required before the division can
make a decision on issuance or denial of the permit.
Yadkin County initially planned to develop approximately 50 acres of land in East Bend
into an industrial park. The county applied for and received a NPDES permit from the DEM for
10,000 gallons per day to handle the domestic wastewater from the park. Currently one
business has located at the park, and only a couple of acres have been developed leaving over 45
acres undeveloped. The wastewater flow from the business has averaged at best 2000 gallons
per day.
Apparently for economic reasons or reasons unknown to the division, the park has not
been developed as initially planned. DEM Regulation 15 NCAC 2H .0105 (c) (2) requires that
the most environmentally sound alternative be selected from the reasonably cost effective
options. As a result of the current situation with development at the park, the DEM cannot
assure that continued operation of the wastewater treatment plant is the most environmentally
sound option. Even though the current plant is in operation, spray irrigation or subsurface
disposal of the wastewater may prove to be the best option. The costs of building and operating
another treatment system may outweigh the costs of extending the outfall line and operating and
maintaining', the existing plant. Therefore, Yadkin County must complete and submit the attached
Engineering Economic Analysis (EEA). The EEA form is designed for proposed facilities, but the
county should be able to utilize the form with few if any modifications to the form.
Lill instruct the DEM Water Quality Staff to scrutinize the EEA very closely. The
environmental benefits will be evaluated carefully. If there is no decided economic benefit or if
there are environmental benefits as a result of another treatment system the county may be ,
required' to, install another type of treatment system.
59 T?
Pollution Prevention Pays. J:
;.S 1991 4 •
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer CENTRAL FILE COPY

Mr. Mashburn
Page Two
A response to this letter must be received by July 15, 1990. If no response is
received by July 15, the DEM will deny your permit modification request and will initiate
action to either modify the existing permit to add more stringent effluent limitations or revoke
the existing permit in lieu of a more environmentally sound system.
If you have any questions regarding this matter, please contact Mr. Dale Overcash at
[phone].
cc: Mr. Lan
Mr. Roy
Coble
Davis
Sincerely,
eorg : Everett
1991
CENTRAL FILE COPY

State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
James G. Martin, Governor
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 27, 1990
MEMORANDUM
TO:
FROM:
SUBJECT:
George T. Everett, Director
Division of Environmental Management
Roy M. Davis, Regional Supervisor
Division of Environmental Management
NPDES Number NC0064726
East Bend Industrial Park
Yadkin County
Ann B. Orr
Regional Manager
.
r mow. .-,,.
Pursuant tolyour instructions, a hearing was held on April 17, 1990, at
7:00 p.m. at East Bend Elementary School to receive public comment
regarding the proposed reissuance of NPDES Permit Number NC0064726 to
the Yadkin County Commissioner. The wastewater treatment plant
authorized under this permit, has a design capacity of 10,000 gpd and
serves a fifty (50) acre industrial park all of which, I am told, now
belongs to 1Century Reproductions. The proposed permit allows
relocation of the point of treated wastewater discharge to a point in
a U.T. to the Yadkin River where a positive 7 day-10 year low flow
exists thereby avoiding more restrictive effluent limits. The
receiving stream is classified WS III.
Of the approximately eighty (80) persons attending, nineteen (19)
presented testimony. Ofthese, thirteen (13) were opposed to the
presence of treated wastewater •in the receiving stream. Almost
everyone opposing the discharge mentioned the presence of Butner Mill
Pond downstream which is used for swimming and fishing.
The present draft permit allows the discharge of 10,000 gpd of
wastewater having domestic characteristics. The one industry (Century.
Reproductions) presently served by the East Bend Indu.stri.a _ Park
wastewater treatment plant uses an average of 21, 24-18);6;/:4tr?.;o.f
water. Thil leads one to the conclusion that the Cptn y s treat,
plant treats approximately 1,000 gpd of wastewater. 3
2 8 1991 -"
•
Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801 • Telephone 704-254i TP; i L. FILE copy
An Equal Opportunity Affirmative Action Employer

George T. Everett
Membrandum
April 27, 1990
Page Two
No testimony was presented which would lead me to believe that issuance
of the draft permit would result in violation of any statute or
regulation administered by the Division of Environmental Management.
Given the small volume of wastewater to be treated and given that the
industrial park occupies fifty (50) acres of land, it is my
recommendation that the applicant be di cted to comply with the
requirements of 15 NCAC 2H . . (c)(2) which states that the applicant
will submit a summary of waste treatment and disposal options which
were considered. All of this leading toward selection of the most
environmenta�.ly sound reasonably cost effective alternative. Receipt
of this information will then allow final decision relating to permit
action.
RMD:ls
xc: Steve Tedder J
Dale Overcash with attachments
Larry Coble/Steve Mauney
J
�7 t (/ l rJ1 •- � 1 '/ c i f
1
JAN 28 1991 j1 f
CENTRAL FILE COPY

.17
di SENDER: Complete ; items 1 3 and : and 2 when additional services are desird,�and :complete items
•
4.• ,.
Put your address.in•the .', RETURN. TO" Space on the•reverse side: Failure to do' this will. prevent' this
card from being returned to you. The retum receipt fee will provide you the name of the rierson delivered
to and the'date of delivery. For additional fees the following services are available: Consult postm`aster
tor fees and check box(es) for additional service(s) requested.
1. 0 Show to whom delivered, date, and addressee's address. 2. 0 Restricted Del ery
(Extra charge), (Extra charge
4. Article Number r
3. Article .Addressed to:
Ch ah,Q,ti 2 . 'Yn o�,cati lu a,K.
771 avn
#4604-1-.
tti W :.LtLL, c
g; lure— Ad
6. Signature — Agent
X
7. Date of Delivery
PS Form 3811, Mar. 188
Type of Service:
o Registered • 0 Insured
MCertified - 0 COD
Ex rasa Mail...., Return Receipt
p �, , , fior_Merchandise
A1ii�ay 6 talk, igciat re l'r�alit
or`agenfend DATE DELI�EREi
8 3A,fON
ddressee' Address_
e
P )1
Qt-INTRAL FILE COPY
* _ U.S.G.P.O. 1988-212-865 DOMESTIC RETURN RECEIPT 1
UNITED STATES POSTAL SERVICE
OFFICIAL BUSINESS
SENDER INSTRUCTIONS
•
Print your name, address end ZIP Code
in .the space below.
• Complete items 1, 2, 3, and 4 on the
reverse. .•
• Attach to front of art a if space
permits, otherwise affix to back of
article. t
• Endorse article "Return Receipt
Requested" adjacent to number.
RETURN
TO
FEB 1 ,, 7991
i
r
Print Senders name, address, and ZIP Code In tlfr
space below.
FiIi C FRXIAf!'cRrNl' USE, $300
PENALTY FOR PRIVATE
ank. Ov,ericfa A
Po. hex a sta.w• 141156us

Discharger
Receiving Stream
MODEL RESULTS
: EAST BEND INDUSTRIAL PARK
: UT YADKIN RIVER
SUMMER
NOV.9,'89 / 0.01 MGD 30/5
ABOVE DRAGSTR BELOW CULVERT
The End D.O. is
The End CBOD is
The End NBOD is
8.01 mg/l.
1.95 mg/l.
1.43 mg/1.
Segment 1
Reach 1
Reach 2
Reach 3
Reach 4
Reach 5
Reach 6
Reach 7
Reach 8
Reach 9
DO Min
(mg/1) Milepoint Reach #
5.68 0.00
1
WLA
CBOD
(mg/1)
45.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
WLA
NBOD
(mg/1)
90.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
WLA
DO Waste Flow
(mg/1) (mgd)
0.00 0.01000
0.00 0.00000
0.00 0.00000
0.00 0.00000
0.00 0.00000
0.00 0.00000
0.00 0.00000
0.00 0.00000
0.00 0.00000

MODEL RESULTS
Discharger : EAST BEND INDUSTRIAL PARK
Receiving Stream : UT YADKIN RIVER
SUMMER
NOV.9,'89 / 0.05 MGD 15/4/5
ABOVE DRAGSTR BELOW CULVERT
The End D.O. is
The End CBOD is
The End NBOD is
7.99 mg/l.
2.82 mg/1.
1.44 mg/l.
Segment 1
Reach 1
Reach 2
Reach 3
Reach 4
Reach 5
Reach 6
Reach 7
Reach 8
Reach 9
WLA WLA WLA
DO Min CBOD NBOD DO Waste Flow
(mg/1) Milepoint Reach # (mg/1) (mg/1) (mg/1) (mgd)
5.96 0.00 1
22.50 18.00 5.00 0.05000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000
0.00 0.00 0.00 0.00000

*** MODEL SUMMARY DATA ***
Discharger : EAST BEND INDUSTRIAL PARK Subbasin : 030702
Receiving Stream : UT YADKIN RIVER Stream Class: WS-III
Summer 7Q10 : 0.05 Winter 7Q10 : 0.1
Design Temperature: 25.
'LENGTH' SLOPE' VELOCITY 1 DEPTH' Kd 1 Kd 1 Ka I Ka I KN 1
I mile 1 ft/mil fps 1 ft Idesign l @204 Idesign l @204 Idesignl
Segment 1
Reach 1
1 1 1 1 1 1 1 I
0.251 73.201 0.138 10.26 1 0.66 1 0.52 120.33 118.231 0.73
1 1 1 1 1 1 1 I
Segment 1 I 0.101 73.201 0.184 1 0.34 1 0.66 10.52 127.01 1 24.221 0.73
Reach 2 1 1 1 1 1 1 1 1 I
1 1 1 1 1 1 1 1 I
Segment 1 1 1.001 40.001 0.149 1 0.40 1 0.50 10.39 111.99 1 10.751 0.73
Reach 3 1 1 1 1 1 1 1 1 I
1 1 1 1 1 1 1 1 I
Segment 1 1 0.341 29.401 0.135 1 0.45 1 0.42 1 0.33 17.99 1 7.161 0.73
Reach 4 1 1 1 1 1 1 1 1 I
1 1 1 1 1 1 1 1
Segment 1 1 0.701 42.301 0.151 1 0.45 1 0.48 1 0.38 112.82 1 11.501 0.73
Reach 5 1 1 1 1 1 1 1 1 I
1 1 1 1 1 1 1 1 I
Segment 1 1 0.101100.001 0.195 10.41 1 0.61 1 0.49 139.13 135.101 0.73
Reach 6 1 1 1 1 1 1 1 1 I
1 1
Segment 1 1 0.041250.001 0.255 0.36 0.78 0.62 55.75 50.00 0.73
Reach 7 1 1 I
1 1 1 1 1 1 1 1
Segment 1 1 0.101100.001 0.195 1 0.41 1 0.61 1 0.48 139.23 1 35.191 0.73
Reach 8 1 I I I I I I
1 1 1 1 1 1 1 1 I
Segment 1 1 0.521 30.001 0.139 10.50 1 0.40 1 0.32 1 8.35 I 7.491 0.73
Reach 9 1 1 1 1 1 1 1 1 I
I Flow 1 CBOD 1 NBOD 1 D.O. 1
I cfs 1 mg/1 1 mg/1 1 mg/1 I
Segment 1 Reach 1
Waste 1 0.078 1 22.500 1 18.000 1 5.000
Headwaters) 0.050 1 2.000 I 1.000 1 7.440
Tributary 1 0.000 1 2.000 1 1.000 1 7.440
* Runoff 1 0.080 I 2.000 I 1.000 1 7.440

Segment 1 Reach 2
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.170 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 3
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 4
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 5
Wastee I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 6
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 7
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 8
Wastie I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
Segment 1 Reach 9
Waste I 0.000 I 0.000 I 0.000 I 0.000
Tributary I 0.000 I 2.000 I 1.000 I 7.440
* Runoff I 0.080 I 2.000 I 1.000 I 7.440
* Runoff flow is in cfs/mile

Seg # I Reach I# I Seg Mi I D.O. I CBOD
1 1 0.00 5.96 14.46
1 1 0.05 6.51 13.88
1 1 0.10 6.87 13.33
1 1 0.15 7.10 12.82
1 1 0.20 7.25 12.34
1 1 0.25 7.36 11.88
1 2 0.25 7.40 6.59
1 2 0.26 7.45 6.57
1 2 0.27 7.50 6.54
1 2 0.28 7.54 6.51
1 2 0.29 7.57 6.49
1 2 0.30 7.61 6.46
1 2 0.31 7.64 6.44
1 2 0.32 7.67 6.41
1 2 0.33 7.69 6.39
1 2 0.34 7.72 6.36
1 2 0.35 7.74 6.34
1 3 0.35 7.74 6.34
1 3 0.45 7.73 6.11
1 3 0.55 7.74 5.89
1 3 0.65 7.75 5.69
1 3 0.75 7.76 5.49
1 3 0.85 7.78 5.31
1 3 0.95 7.79 5.13
1 3 1.05 7.81 4.96
1 3 1.15 7.83 4.80
1 3 1.25 7.84 4.65
1 3 1.35 7.86 4.51
1 4 1.35 7.86 4.51
1 4 1.37 7.85 4.48
1 4 1.39 7.84 4.45
1 4 1.41 7.83 4.43
1 4 1.43 7.83 4.40
1 4 1.45 7.82 4.38
1 4 1.47 7.82 4.35
1 4 1.49 7.82 4.33
1 4 1.51 7.81 4.30
1 4 1.53 7.81 4.28
1 4 1.55 7.81 4.25
1 4 1.57 7.81 4.23
1 4 1.59 7.80 4.20
1 4 1.61 7.80 4.18
1 4 1.63 7.80 4.16
1 4 1.65 7.80 4.13
1 4 1.67 7.80 4.11
1 4 1.69 7.80 4.09
1 5 1.69 7.80 4.09
1 5 1.76 7.85 4.00
1 5 1.83 7.88 3.92
1 5 1.90 7.91 3.85
1 5 1.97 7.93 3.77
1 5 2.04 7.95 3.70
1 5 2.11 7.96 3.63
1 5 2.18 7.97 3.56
1 5 2.25 7.98 3.50
1 5 2.32 7.99 3.43
SUMMER
NOV.9,'89 / 0.05 MGD 15/4/5
ABOVE DRAGSTR BELOW CULVERT
I NBOD I Flow I
11.33
10.84
10.38
9.95
9.54
9.16
4.79
4.77
4.75
4.73
4.71
4.69
4.67
4.65
4.63
4.61
4.59
4.59
4.37
4.16
3.97
3.79
3.61
3.45
3.30
3.16
3.02
2.89
2.89
2.87
2.84
2.81
2.79
2.76
2.74
2.71
2.69
2.67
2.64
2.62
2.59
2.57
2.55
2.53
2.50
2.48
2.48
2.41
2.34
2.28
2.22
2.16
2.10
2.04
1.99
1.94
0.13
0.13
0.14
0.14
0.14
0.15
0.32
0.32
0.32
0.32
0.32
0.32
0.32
0.32
0.32
0.32
0.33
0.33
0.33
0.34
0.35
0.36
0.37
0.37
0.38
0.39
0.40
0.41
0.41
0.41
0.41
0.41
0.41
0.41
0.42
0.42
0.42
0.42
0.42
0.42
0.42
0.43
0.43
0.43
0.43
0.43
0.43
0.44
0.44
0.45
0.46
0.46
0.47
0.47
0.48
0.48

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
I Seg # 1
5
6
6
6
6
6
6
6
6
6
6
6
7
7
7
7
7
8
8
8
8
8
8
8
8
8
8
8
9
9
9
9
9
9
9
9
9
9
9
9
9
9
Reach #
2.39 7.99 3.37 1.89 0.49
2.39 7.99 3.37 1.89 0.49
2.40 8.01 3.36 1.88 0.49
2.41 8.03 3.35 1.87 0.49
2.42 8.05 3.34 1.87 0.49
2.43 8.06 3.34 1.86 0.49
2.44 8.07 3.33 1.86 0.49
2.45 8.08 3.32 1.85 0.49
2.46 8.09 3.31 1.85 0.49
2.47 8.10 3.30 1.84 0.50
2.48 8.11 3.29 1.84 0.50
2.49 8.12 3.28 1.83 0.50
2.49 8.12 3.28 1.83 0.50
2.50 8.12 3.28 1.83 0.50
2.51 8.13 3.27 1.82 0.50
2.52 8.14 3.26 1.82 0.50
2.53 8.14 3.25 1.81 0.50
2.53 8.14 3.25 1.81 0.50
2.54 8.15 3.24 1.81 0.50
2.55 8.15 3.24 1.80 0.50
2.56 8.15 3.23 1.80 0.50
2.57 8.15 3.22 1.79 0.50
2.58 8.15 3.21 1.78 0.50
2.59 8.16 3.20 1.78 0.50
2.60 8.16 3.20 1.77 0.51
2.61 8.16 3.19 1.77 0.51
2.62 8.16 3.18 1.76 0.51
2.63 8.16 3.17 1.76 0.51
2.63 8.16 3.17 1.76 0.51
2.67 8.13 3.14 1.73 0.51
2.71 8.10 3.11 1.70 0.51
2.75 8.08 3.08 1.68 0.52
2.79 8.06 3.05 1.65 0.52
2.83 8.04 3.03 1.63 0.52
2.87 8.03 3.00 1.60 0.53
2.91 8.02 2.97 1.58 0.53
2.95 8.01 2.94 1.55 0.53
2.99 8.01 2.92 1.53 0.54
3.03 8.00 2.89 1.51 0.54
3.07 8.00 2.87 1.49 0.54
3.11 7.99 2.84 1.46 0.55
3.15 7.99 2.82 1.44 0.55
I Seg Mi I D.O. I CBOD I NBOD 1 Flow I