NC0021121_Permit Issuance_20020521

NPDES DOCIMENT SCANNIN`: COVER SHEET
NPDES Permit:
NC0021121
Mount Airy WWTP
Document Type: `,
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 21, 2002
This document is printed on reuse paper - more any
content on the re-srerse side

8/Late of North Carolina
vepartment of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
May 21, 2002
Mr. Victor R. Quick
City of Graham
P.O. Drawer 357
Graham, North Carolina 27253
•
• v
NCDENR
Subject: Issuance of NPDES Permit NC0021211
Graham WWTP
Alamance County
Dear Mr. Quick:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended.)
The final permit authorizes The City of Graham to discharge up to 3.5 MGD of treated wastewater from the
Graham WWTP to the Haw River, a class C-NSW water in the Cape Fear River Basin. The permit includes discharge
limitations for flow, biochemical oxygen demand (BOD), total suspended solids (TSS), ammonia, dissolved oxygen,
fecal coliform bacteria, pH, total phosphorus, and chronic toxicity.
The following modifications have been made to the final permit:
• The Division may re -open this permit to require weekly average limits for ammonia. After
calculating allowable concentrations, the Division will perform an analysis of past ammonia data to determine
if there is a reasonable potential for this discharge to exceed these potential limits. If there is, this permit will
be re -opened. If there is not, the permit will not be re -opened, but will contain weekly average limits for
ammonia upon renewal
• The effluent limitation for cyanide of 22 µg/1 has been deleted from the final permit based on
evaluation of the laboratory data submitted by the City. After review of the laboratory sheets, it was
determined that the elevated cyanide value reported on March 16, 1999 was probably in error. Since the
subsequent cyanide data from the Graham WWTP has been below detection level, the Division has not
included a cyanide limit or monitoring in this permit.
• The phrase "intermediate clarifiers" was deleted from the facility description per the Town's
recommendation.
• Mercury continues to be a water quality concern throughout North Carolina. NPDES permittees have
worked with the state to reduce potential risks from this pollutant, including tasks associated with collecting
and reporting more accurate data. The most commonly used laboratory analysis (EPA Method 245.1) has a
detection limit of 0.2 µg/L while the current water quality standard is an order of magnitude lower at 0.012
µg/L. A more recently approved analytical test (EPA Method 1631) should produce a detection limit below
the level of the standard. This will allow the Division to assess potential water quality impacts from
discharges more accurately. Therefore, beginning on or before September 1, 2003, you will be required
to begin using EPA Method 1631 when analyzing for mercury.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Issuance of Permit NC0021211
Page
Please note the modifications that were in the draft permit sent to you on April 4th.
• Instream fecal conform monitoring has been deleted based on revised Division procedure. Graham is a
participant in the Upper Cape Fear River Basin Association and is a part of the environmental monitoring
plan. Individual instream monitoring has been waived from the NPDES permit. In the event that Graham
should leave the Association, instream monitoring for dissolved oxygen, conductivity and temperature will be
reinstated.
• Per North Carolina regulation 15A NCAC 2B .0506(b)(3)0), the results of all tests on the characteristics of
the effluent, including but not limited to NPDES Permit Monitoring Requirements, shall be reported on
monthly report forms. All future effluent metals data submitted for Graham's Pretreatment Long
Term Monitoring Plan should be reported on the Discharge Monitoring Reports (DEM Form MR-1).
Please note that this facility discharges to nutrient sensitive water (NSW) and has an existing total
phosphorus limit. In 1997 the Clean Water Responsibility Act (House Bill 515) was enacted, with the intent to
strengthen the control of nutrients from all discharges to NSW waters. Facilities currently permitted to discharge >
500,000 gallons per day (and any new or expanding facilities) will be subject to nutrient limitations for total nitrogen
and total phosphorus according to House Bill 515 requirements. The nutrient limitations are effective January 1,
2003, unless a compliance extension was received and approved by the Division. The City of Graham was granted a
compliance extension and is currently working jointly on a nutrient response model with eight other facilities. Due to
the approval of an extension, the nutrient limits will be deferred until results of the nutrient response modeling effort
are completed. Please note that modeling results may result in nutrient limits lower than those mandated by
House Bill 515.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, 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, 6714 Mail Service Center, Raleigh, North
Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable. The Division may require modification or revocation
and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may
be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act, or any other Federal or Local governmental permits may be required.
If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone
number [phone], extension 512.
Sincerely,
,GINAL SIGNED BY
SUSAN A. \NILSON
Gregory J. Thorpe, Ph.D.
cc: Central Files
Winston Salem Regional Office / Water Quality Section
Technical Assistance & Certification Unit
NPDES Unit/Permit File ,
Aquatic Toxicology Unit
Roosevelt Childress, EPA Region IV

Permit NC0021211
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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, the
City of Graham
is hereby authorized to discharge wastewater from a facility located at the
Graham WWTP
Gilbreath Road north of Swepsonville
Alamance County
to receiving waters designated as the Haw River in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV
hereof.
This permit shall become effective July 1, 2002.
This permit and authorization to discharge shall expire at midnight on May 31, 2006.
Signed this day May 21, 2002.
ORIGINAL SIGNED BY
SUSAN A. WILSON
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality.
By Authority of the Environmental Management Commission

Permit NC0021211
SUPPLEMENT TO PERMIT COVER SHEET
The City of Graham is hereby authorized to:
1. Continue to operate an existing 3.5 MGD wastewater treatment facility
consisting of the following components:
> Mechanical bar screen
> Grit chambers
> Primary settling
> Extended aeration basin
➢ Final clarifiers
> Aerobic digesters
> Chlorination
> Sand filters
> Post aeration
> Lime stabilization unit
> Sludge storage
This facility is located at the Graham Wastewater Treatment Plant on
Gilbreath Road north of Swepsonville in .Alamance County.
2. Discharge from said treatment works at the location specified on the attached
map into the Haw River, classified C-NSW waters in the Cape Fear River
Basin.

Facility Information
36°02' 44" Sub -Basin
79°22' 06"
C21SE
C NSW
Haw River
3.5 MGD

Permit NC0021211
c ,
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
•
Monthly
Weekly
Daily
Maximum,.
Measurement
Frequency
Sample
Type
Sample Locations
Average
Flow T
3.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day, 20°C
(April 1 through October 31) 2
12.0 mg/L
18.0 mg/L
Daily
Composite
Influent and Effluent
BOD, 5 day, 20°C
(November 1 through March 31)2
24.0 mg/L
36.0 mg/L
Daily
Composite
influent and Effluent
Total Suspended Solids 2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent and Effluent
NH3 as N
(April 1 through October 31) 3
4.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1 through March 31) 3
8.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen 4
Daily
Grab
Effluent,
Upstream & Downstream
.
pH 5
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent,
Upstream & Downstream
Fecal Coliform
(geometric mean)
200 / 100 ml
' 400/100 ml
Daily
Grab
Effluent
Total Residual Chlorine
Daily
Grab
Effluent
Conductivity
Daily
Grab
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Total Phosphorus 6
2.0 mg/L
Weekly
Composite
Effluent
Total Mercury
2/month
Composite
Effluent
Total Copper
Monthly
Composite
Effluent
Total Zinc
Monthly
Composite
Effluent
Chronic Toxicity 7
Quarterly
Composite
Effluent
Notes:
1 Upstream = at Highway 54. Downstream = at NCSR 2158. Stream samples shall be grab samples collected three
times per week during June, July, August and September and once per week during the remaining months of the
year. See section A .(2) for details regarding the provisional waiver of instream monitoring requirements.
2 The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3 The Division may re -open this permit to require weekly average limits for ammonia. After calculating allowable
concentrations, the Division will perform an analysis of past ammonia data to determine if there is a reasonable
potential for this discharge to exceed these potential limits. If there is, this permit will be re -opened . If there is
not, the permit will not be re -opened, but will contain weekly average limits for ammonia upon renewal.
4 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
5 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
6 Compliance shall be based upon a quarterly average of weekly samples.
7 Chronic Toxicity (Ceriodaphnia) limit at 14% with testing in March, June, September and December (see section A.
(3)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

J
Permit NC0021211
SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2) PROVISIONAL WAIVER OF INSTREAM MONITORING REQUIREMENTS
Instream monitoring requirements in this NPDES permit shall be provisionally waived so long as the
Permittee remains a member of the Upper Cape Fear River Basin Association and the Association continues
to function as approved by the Division and Environmental Management Commission. If the Permittee does
not participate in the Association or if the Association ceases to function, the instream monitoring
requirements in this permit become effective immediately; and the Division may reopen this permit by
administrative letter to establish additional instream monitoring requirements it deems necessary to
adequately characterize the effects of the discharges on water quality in the receiving stream.
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality
to Ceriodaphnia dubia at an effluent concentration of 14 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions. The tests will be performed during the months of March, June, September
and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are specified
in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998)
or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B
for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be
sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
(continued on next page)

Permit NC0021211
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
(continued)
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form
indicating the facility name, permit number, pipe number, county, and the month/year of the report with the
notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental
Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will
be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality 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, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last
day of the month following the month of the initial monitoring.

NC0021211 - City of Graham
•
Subject: NC0021211 - City of Graham
Date: Wed, 20 Mar 2002 10:56:44 -0500
From: [e-mail]
To: [e-mail]
CC: [e-mail], [e-mail]
Jackie
Thank you for your 2/14/02 e-mail providing and explanation and RPA for
Fluoride, Arsenic, Cadmium, Chromium, Lead, Nickel, and Selenium. Your
response addresses EPA's concerns.
Please note that this permit is being held by EPA Region 4 due to its
lack of weekly average NH3-N limits per 40 CFR 122.45(d)(1).
Additionally, this permit includes a monitoring requirement for mercury
and no detection limit is recommended in the permit. EPA R4 is in
discussion with NC concerning their standard use of 0.2 ug/1 as a
detection limit for mercury. This value is inconsistent with EPA
approved method 1669 and 1631C listing the detection limit for mercury
as 0.0005 ug/l. The recent NC IG Report documented that NC should
require more sensitive analytical methods as they become available. The
use of a 0.2 ug/1 rather than a 0.0005 ug/1 detection limit is not
consistent with the IG recommendation. NC Water Quality Standards list
a mercury criterion of 0.012 ug/1 and the use of a 0.2 ug/1 detection
limit is not sufficient to determine if RPA exits to exceed this
criterion. An appropriate sensitive detection limit should be required
per 40 CFR Part 136, 40 CFR 122.41 (j) (4) , and 40 CFR 123. 44 (c) (5) .
Dee Stewart
404/562-9334
1 of 1 4/16/02 12:19 PM

Add. info on Cn limit for Graham
Subject: Add. info on Cn limit for Graham
Date: Thu, 14 Feb 2002 12:49:27 -0500
From: Jackie Nowell <[e-mail]>
Organization: NC DENR DWQ
To: "[e-mail]" <[e-mail]>
BCC: Dave Goodrich <[e-mail]>
Dee,
Some additional information has been provided by the City regarding the
CN limit recommended in the draft permit. The RPA emailed to you
earlier today contained revised CN data and indicated that there was no
potential for exceedance of the water quality standard. The rationale
for the change is as follows.
The original NPDES RPA was done using LTMP data (8 values) submitted
from 1999-2000, a CN hit of 157 ug/1 was recorded in a March 1999
sample. In May 2001, Graham submitted lab sheets that showed for that
March 16, 1999 sample, the following data was reported: plant influent
CN: 26 ug/1, primary clarifier effluent CN: <5 ug/1, and plant outfall
effluent CN: 157 ug/1. The clarifier effluent sampling point is located
before the outfall effluent, therefore the sample went from <5 ug/1 to
157 ug/1.
Graham contends that there was probably a laboratory error with the
sample that caused such a high value to be reported. Graham submitted
DMR data from January 1992 to May 1996 (222 samples) to support their
argument that the 157 ug/1 sample was the only sample that exceeded the
proposed CN limit of 22 ug/1. The majority of the other values were
below detection or lower than 10 ug/1. (1 value of 10 ug/1 in 1994).
After review of all the information provided by Graham, NPDES concurred
that a lab error probably occurred, since the 157 ug/1 datapoint was 15
times greater than the highest value reported in the past nine years..
A revised RPA was done using LTMP data back to January 1996, but with
the 157 ug/1 data point considered an outlier, it was now omitted from
the analysis The highest value for CN in the revised analysis is 5.39
ug/1. The results now indicate that the maximum predicted value is
below the allowable concentration and the CN limit is not required. It
is now the recommendation of the NPDES Unit that based on the data and
information provided, the CN limit can be dropped from the draft permit
and will not be in the final permit. Quarterly CN monitoring will be
continued in the LTMP of the pretreatment program and data will be
submitted in the DMRs that are sent to the Division. This data can be
used for future RPA analysis at the next permit renewal.
Please let me know if there are any questions and whether I can proceed
with issuance of this permit after your review. Thanks.
1 of 1 2/14/02 3:01 PM

21211.tox.rev.xls
Subject: 21211.tox.rev.xls
Date: Thu, 14 Feb 2002 10:57:23 -0500
From: [e-mail]
Organization: NC DENR DWQ
To: [e-mail]
BCC: Dave Goodrich <[e-mail]>
Hello Dee,
Attached is the RPA that was done for the City of Graham. Data was
submitted on arsenic, cadmium, chromium, lead, nickel and selenium from
the Long Term Monitoring Plan (LTMP) of their pretreatment program.
This data was used to determine whether limits or monitoring would be
required for any of these constituents. While these parameters are
monitored quarterly by the discharger, they do not always submit the
data on their DMRs. NPDES is now requesting that all sampled effluent
data be put on the DMR form, whether or not it is required by the NPDES
permit.
Regarding the presence of fluoride, this parameter is not required to be
sampled in the LTMP and there was no data to analyze. Graham has
indicated that fluoride was marked as "may be present" based on being
added to their drinking water at the water treatment plant. Their
pretreatment coordinator has said that none of their SIUs have any
fluoride and the only possible source would drinking water.
Please let me know if any other questions.
D21211.tox.rev.xls
Name: 21211.tox.rev.xls
Type: Microsoft Excel Worksheet (application/vnd.ms-excel)
Encoding: base64
1 of 1 2/14/02 11:38 AM

City of Graham
Subject: City of Graham
Date: Mon, 11 Feb 2002 09:00:27 -0500
From: [e-mail]
To: [e-mail]
Jackie,
I have the following questions/comments concerning the City of Graham,
NC0021211.
1) The application used was the EPA Standard Form A which includes a
"Believed Present" checklist of pollutant parameters. There were
several parameters listed as believed present which have NC numeric
water quality standards and I did not see any data contained in the file
or the certification DMR which would enable a reasonable potential
determination. These parameters include:
Fluoride
Arsenic
Cadmium
Chromium
Lead
Nickel
Selenium.
Please explain how RP for a numeric NPDES permit limit was determined
for these parameters.
Thank you for your response.
Dee Stewart
EPA R4
404/562-9334
1 of 1 2/11/02 10:18 AM

Comment on NPDES permit #NC0021211... of Graham WWTP in Alamance County
Subject: Comment on NPDES permit #NC0021211 - City of Graham WWTP in Alamance
County
Date: Tue, 12 Jun 2001 12:15:35 -0400
From: [e-mail]
To: [e-mail]
CC: [e-mail]
Jackie,
NC has action levels for several criteria (Cu, Zn, Ag, Cl,Fe, chlorides),
instead of numeric criteria. If application data for these indicate a
reasonable potential to exceed the action level instream AND there are WET
test failures, the permit should be drafted with numeric limits for the
parameter(s) of concern. If it's not clear that exceedance of the action
level is the cause of the toxicity, the permittee is supposed to be given
time to find the source(s) of toxicity and if the cause isn't determined
after a date certain, numeric limits for the action level(s) kick in. If
the application data show the action level to be exceeded instream and
there aren't WET failures, the permit should contain monitoring for the
parameter(s) of concern.
Please address this comment prior to issuing the City of Graham WWTP NPDES
permit.
Caroline Ejimofor
Environmental Engineer
Permits, Grants and Technical Assistance Branch
EPA Water Management Division
e-mail address: [e-mail]
phone number: 404-562-9309
fax number: 404-562-9318
1 of 1 12/13/01 1:3 8 PM

21474 transmittal letter
Subject: 21474 transmittal letter
Date: Thu, 31 May 2001 14:43:28 -0400
From: [e-mail]
Organization: NC DENR DWQ
To: "[e-mail]" <[e-mail]>
Caroline, the attached transmittal letter does not clearly state this,
but Mebane and Graham were granted compliance extensions to House Bill
515 (by Senate Bill 1366) and are working with seven other
municipalities on a calibrated nutrient response model. These nine
cities will not receive mass based nutrient limits in their permit until
the model has been completed and reviewed. The model results are due
April 2002. Existing concentration based TP limits of 2 mg/1 are in
both permits.
I assumed that since both cities were aware of their status, I did not
have to repeat it in their letters. However, I will add an additional
sentence to make it clear in the final permit letter.
D 1 21474 draft.doc
Name: 1_21474 draft.doc
Type: Microsoft Word Document (application/msword)
Encoding: base64
1 of 1 12/14/01 4:07 PM

ovit >ir0-
— 7[4,441
'/0/
Dear Ms. Nowell,
Titg of (rattclm
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
336) 570-6700 / Fax: [phone]
May 9, 2001
IECE HED
MAY - 9 2001
DENR-WATER QUALITY
POINT SOURCE BRANCH
Subject: Draft NPDES Permit
Permit No. NC0021211
Graham WWTP
The City of Graham received the draft NPDES permit during April 2001.
City staff began reviewing this document and desires to submit the following
comments concerning it.
1. Under "SUPPLEMENT TO PERMIT COVER SHEET." The following
changes should be made due to the current plant construction upgrade:
a. Delete intermediate clarifiers. We are now operating four final
clarifiers and no immediate clarifiers.
b. Prior to the end of 2001, the WWTP will have two new
processes: (1) Hycor Rotorary Drum Sludge Thickener and (1)
Sludge Storage Unit of 0.75 million gallons.
2. Effluent limitation for Cyanide of 22 ug/I was added to the permit. The
City believes that this parameter should not be listed nor limited on our
permit. Also, Cyanide is typically collected by grab sample but is listed
on the draft permit as composite sample.

2
We understand the reason for adding the cyanide limit was based on your
evaluation using the reasonable potential analysis. Also, we understand that you
were limited on the amount of data to use to perform this analysis. We have
sampled effluent cyanide 222 times since January 1, 1992. There was one
sample result of 157 ug/I in March, 1999. The next highest result was 10 ug/l in
December 1994. Therefore, out of 222 effluent samples analyzed, only once
was the proposed effluent limit violated. We are submitting this data for your
review and feel it should be incorporated into the analysis.
We believe the March 16, 1999 effluent sample was an anomaly. On the
day that this result was obtained, cyanide was analyzed, additionally, on the plant
influent and primary clarifier effluent (See attached). The results are as listed:
Plant Influent
Primary Clarifier Effluent
Plant Effluent
26 ug/I
<5 ug/I
157 ug/I
These results are not logical and follow no pattern of inhibition or pass
through at the POTW. One would think that the primary clarifier effluent would
have the highest level of cyanide. We believe there is a strong likelihood of a
laboratory error or sampling error. We believe that due to the suspect nature of
this one result — IT SHOULD NOT BE USED for NPDES permitting decisions.
The City of Graham does not have a Significant Industrial User that
generates cyanide in their manufacturing process, nor does the City have a metal
finisher or electroplating facility discharging to the WWTP.
The City has had the plant effluent analyzed for toxicity 24 times since
1995. A pass result was obtained on 22 times. The two times that a failure
occurred, there was no mortality of the ceria daphnia, merely a reduction in
reproduction.
We believe that when the above evidence is included in your review of our
draft permit that you will concur that the cyanide limit is not warranted.

3
If you need additional information or clarity on our position of the draft
permit, please, call either Victor R. Quick at 336.570.6700 or myself at
336.570.6721.
Sincerely,
David w. Lawson
Plant Supervisor,
City of Graham
Cc: Victor R. Quick, City of Graham

BURLINGTON
Aquatic Bioassay Testing • Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments • NPDES Testing
Reporting & Data Handling Services
1302 Belmont Street • Burlington, NC 27215-6935 • Phone [phone] • Fax [phone]
RESEARCH
ANALYTICAL REPORT
CUSTOMER: City of Graham
REPORT TO: Mr. David Lawson
SAMPLE DESC: MAR. MONITORING
SAMPLE TYPE: WASTEWATER, INFLUENT GRAB
COLLECTED: 03/16/99 07:50
WORK ORDER #: 9C370-002
RECEIVED: 03/16/99
REPORTED: 03/26/99
PO NUMBER: 990896
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Cyanide, Total
EPA 335.2
Started 03/23/99 16:00 0.005
Analyzed 03/24/99 by LLW at BRI - Burlington
0.026 mg/L
MQL = Minimum Quantitation Limit
Water Environmental Services - Eden
Division of Burlington Research, Inc.
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
BB.2 1/99
Page 2
Water Environmental Services - Kinston
Division of Burlington Research, Inc.
100 E. Gordon Street • Kinston, NC 28501
Phone [phone] • Fax [phone]

BURLINGTON
Aquatic Bioassay Testing • Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments • NPDES Testing
Reporting & Data Fiandling Services
1302 Belmont Street • Burlington, NC 27215-6935 • Phone [phone] • Fax [phone]
RESEARCH
ANALYTICAL REPORT
CUSTOMER: City of Graham
REPORT TO: Mr. David Lawson
SAMPLE DESC: MAR. MONITORING
SAMPLE TYPE: WASTEWATER, EFFLUENT GRAB
COLLECTED: 03/16/99 07:55
WORK ORDER #: 9C370-004
RECEIVED: 03/16/99
REPORTED: 03/26/99
PO NUMBER: 990896
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Cyanide, Total
EPA 335.2
Started 03/23/99 16:00 0.005
Analyzed 03/24/99 by LLW at BRI - Burlington
0.157 mg/L
MQL = Minimum Quantitation Limit
Water Environmental Services - Eden
Division of Burlington Research, Inc.
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
811.2 1)99
Page 4
Water Environmental Services - Kinston
Division of Burlington Research, Inc.
100 E. Gordon Street • Kinston, NC 28501
Phone [phone] • Fax [phone]

BURLINGTON
Aquatic Bioassay Testing • Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments • NPDES Testing
Reporting & Data Handling Services
1302 Belmont Street • Burlington, NC 27215-6935 • Phone [phone] • Fax [phone]
RESEARCH
ANALYTICAL REPORT
CUSTOMER: City of Graham
REPORT TO: Mr. David Lawson
SAMPLE DESC: MAR. MONITORING
SAMPLE TYPE: WASTEWATER, EFFLUENT GRAB
COLLECTED: 03/16/99 07:40 SITE: Primary
WORK ORDER #: 9C370-006
RECEIVED: 03/16/99
REPORTED: 03/26/99
PO NUMBER: 990896
PARAMETER
DATE/TIME/ANALYST MQL RESULT
Cyanide, Total
EPA 335.2
Started 03/23/99 16:00 0.005 <0.005 mg/L
Analyzed 03/24/99 by LLW at BRI - Burlington
MQL = Minimum Quantitation Limit
Certifications:
BRI - Burlington
NC Chemistry: #85, Biomonitoring: #002, Drinking Water: #37743, Radiation License: #00I-0904-0G
VA SWCB ID: #000061, Drinking Water: #00018
SC Laboratory ID: #99042
EPA Chemistry Lab ID: NC00137, Bioassay Lab ID: NC2721500
Water Environmental Services - Eden
Division of Burlington Research, Inc.
370 W. Meadow Road • Eden, NC 27288
Phone [phone] • Fax [phone]
8R-2 1/99
Page 6
Water Environmental Services - Kinston
Division of Burlington Research, Inc.
100 E. Gordon Street • Kinston, NC 28501
Phone [phone] • Fax [phone]

SAMPLE DATE
09/25/1996
12/05/1996
03/13/1997
06/10/1997
08/20/1997
11/20/1997
03/27/1998
06/04/1998
09/15/1998
11/03/1998
03/16/1999
06/16/1999
08/25/1999
11/10/1999
03/23/2000
05/12/2000
08/16/2000
12/06/2000
03/23/2001
LOCATION RESULT
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
Plant Influent
8.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
18.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
26.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/l
<5.0 ug/I
<5.0 ug/I
CITY of GRAHAM
WASTEWATER TREATMENT PLANT
CYANIDE FROM HEADWORKS SINCE SEPTEMBER 1996
LOCATION RESULT LOCATION RESULT LOCATION RESULT
Primary Effluent Aeration Basin Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin 53.0 ug/l Plant Effluent
Primary Effluent Aeration Basin Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin <5.0 ug/I Plant Effluent
Primary Effluent Aeration Basin Plant Effluent
Primary Effluent 5.0 ug/I Aeration Basin 8.0 ug/I Plant Effluent
Primary Effluent Aeration Basin Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin <5.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
Primary Effluent Aeration Basin <5.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
Primary Effluent Aeration Basin <5.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
Primary Effluent Aeration Basin 10.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
Primary Effluent Aeration Basin 29.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
Primary Effluent Aeration Basin <5.0 ug/I Plant Effluent
Primary Effluent <5.0 ug/I Aeration Basin Plant Effluent
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
5.0 ugll
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
157.0 ug/t
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/I
<5.0 ug/l

ruu�it
•
AFFIDAVIT OF INSERTION OF ADVERTISEMENT'
The Times -News Publishing Company
Burlington, NC
Alamance, County
I, LINDA WHITAKER, Legal Advertising Manager
Publishing Co., do certify that the advertisement of
Entitled
of the Times -News
NCDENR/DWQ/Budget
Public Notice
State Of North
Notice
State Of
North Carolina
Environmental Management
CommissionlNPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notification Of Intent To
Issue A NPDES
Wastewater Permit
On the basis of thorough staf
review and application of NC
General Statute 143.21 Pubik
Law 92-500 and other lawfu
standards and regulations, the
North Carolina Environmenta
Management Commission pro
poses to issue a National Pollu
tent Discharge Elimination Sys
tem (NPDES) wastewater dis-
charge permit to the persons:
listed below effective 45 daye
from the publish date of this no
1100.
Written comments regardinc
the proposed permit will be ao
cepted until 30 days after the
publish date of this notice. Al
comments received prior to iha
date are considered in the Tina
determinations regarding the
proposed permit. The Director
of the NC Division of Watei
Quality may decide to hold a
public meeting for the proposec
permit should the Division re-
ceive a significant degree o
Car public interest.
Measuring 88 lines appeared in the Times -News, a newspaper
published in Alamance County, Burlington, NC, in issue of April 9,
Legal Advertising Manager
Sworn to and described before me this C, day of
My commission
expires
Ndtary ublic
Copies of the draft permit anc
other supporting information or
file used to determine condi-
tions present in the draft perms
are availabte upon request anc
payment of the costs of repro-
duction. Mail comments and/or
• requests for information to the
NC Division of Water Quality a
the above address or call Ms
Christie Jackson at (919;
733-5083, extension 538
Please include the NPOES per-
mit number (attached) in ant
communication. Interested per-
sons may.also visit the Divisior
of Water Quality at 512 N
Salisbury Street, Raleigh, NC
27604-1148 between the hour,
of 8:00 a.m. and 5:00 p.m. tc
, review information on file.
NPDES Permit
# NC0021211
Graham, City of P.O. Drawee
357, Graham, NC 27253 hae
applied for a permit renewal fo.
a facility located in Alamance
County discharging treatec
wastewater into Haw River it
the Cape Fear River Basin
Currently BOD5, NH3, dis
solved oxygen, fecal coliform
cyanide and total phospharue
are water qualify limited. Thit
discharge may affect future at
locations in this portion of the
ZQ receiving stream.
April 9, 2001

DENR/DWQ RECEIVED
FACT SHEET FOR NPDES PERMIT DEVELOPMENT �,roan
�.ff��}.(
NPDES No. NC0021211
APR 0 9 2001
Facility Information
Applicant/Facility Name:
City of Graham- Graham WWTP tiff TI S 1 O 11 " u
Applicant Address:
P. O. Drawer 357 Graham, N.C. 27278 Regional Of
Facility Address:
1204 Gilbreath St. Graham, N.C.
Permitted Flow
3.5 MGD
Type of Waste:
Domestic and industrial
Facility/Permit Status:
Renewal
Facility Classification
IV
County:
Alamance
Miscellaneous
Receiving Stream:
Haw River
Regional Office:
Winston-Salem
Stream Classification:
C NSW
USGS Topo Quad:
C21SE/Mebane,ria
Jackie Nowe.11`
Il
303(d) Listed?:
No
Permit Writer:
Subbasin:
03-06-02
Date:
March 19, 200V
Drainage Area (mi2):
614
'
C�
5
N
----
ri
d
Summer 7Q10 (cfs)
34
" =
,
'
Winter 7Q10 (cfs):
85
Average Flow (cfs):
553
IWC (%):
14
Primary SIC Code:
4952
SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION
The City of Graham has requested renewal of the Graham WWTP permit. The 3.541CVUP
discharges into Haw River, a class C NSW stream, in CPF02 subbasin.
The Haw River is listed on North Carolina's 2000 303(d) list. The segment from NC Highway
87 to NC Highway 49 is listed as partially supporting its uses. The causes of impairment is
fecal coliform, turbidity, and biological impairment (sediment) for a 19.2 mile stretch, with
potential sources of agriculture, storm sewers and urban runoff. DWQ will develop a TMDL for
fecal coliform'this segment and a management strategy for turbidity. However, the Graham
WWTP discharges into the Haw River below this 303d listed segment.
The 1998 biological rating for Haw River at NC 54 near Graham is Good -Fair. This segment
was also rated Good -Fair in 1993 and 1989, which was an improvement from the Fair rating in
August 1987. Haw River from NC 49 to a point 0.4 miles dwnstrm of Cane Creek (South side of
Haw River) has a use support rating of fully supporting. Problem parameters are turbidity with
the major source being nonpoint. The chemical rating from 94-98 is partially supporting. The
benthos rating is Good at Highway 54; at SR1005, the rating is Good -Fair.
Graham currently has an active pretreatment program with Long Term Monitoring Program.
There are six significant industrial users discharging to the system. The facility has an average
industrial flow of 0.633MGD (per 1996 headworks analysis). The permitted industrial flow is
0.7168 MGD.
SIUs - for Graham WWTP are as follows:
• BFI Medical Waste, Inc. - incineration of solid medical waste - 0.017 MGD - intermittent
flow
• Culp Weaving - woven fabric - 0.305 MGD- intermittent flow
• Uni-Chem Hose Corp. - rubber & plastics hose - 0.015 MGD- intermittent flow
• Luxfer Gas Cylinders - aluminum gas cylinders - 0.057 MGD - intermittent flow
• Nannoflex - narrow elastic - 0.020 MGD - intermittent flow
• G & K Services- industrial laundry - 0.072 MGD - intermittent flow
Graham WWTP Fact Sheet
NPDES Renewal
Page 1

Graham is currently in the middle of construction for plant improvement. hydraulic
expansion is involved. ATC issued in 1994 for upgrade of existing digestors with new pumps -\h\5 RZ(,
•
and blowers, the construction of sludge stabilization/mixing tanks, and new sludge loading w`
storage.
\a-\-k-(i\tiA
Facility submitted letter on June 8, 2000, reporting on the progress the Town's efforts to
address compliance with the Nitrogen Discharge Limits proposed for the Haw River in the CPF
basin. The city has addressed nutrient removal by 1) redesigning the alum feed facilities to
allow continual treatment for P removal. 2) proposed improvements to the sludge digestion and
storage capabilities to allow regular sludge wasting, Additional final settling tanks will be half
the current rate. Evaluation of methods to reduce the discharge from the Graham plant,
included a review of land application. Also standby generators and upgrading a pump station,
improve reliability and reduce the possibility of untreated discharge.
In Sept. 1997, orthophosphate sampling requirement was deleted from the Graham permit
because of Memorandum of Understanding with the City of Burlington.
In July 1997, mercury limit was removed and twice per month monitoring was included.
Existing Effluent Limits @ 2.5 MGD
Qw = 3.5 MGD
BOD5 = 12.0 mg/1 (summer)
BOD5 = 24.0 mg/1 (winter)
NH3 = 4.0 mg/1 (summer)
NH3 = 8.0 mg/1 (winter)
DO = 6 mg/1
TSS = 30 mg/1
Fecal Coliform = 200/ 100m1
TRC = 17 ug/1
pH = 6-9 SU
Total Phosphorus = 2 mg/1
Monthly monitoring for copper and zinc. Twice per month monitoring for mercury,
Chronic Toxicity P/F @ 14%; March June September December
TOXICITY TESTING:
Current Requirement: Chronic Toxicity P/F @ 14%; March June September December
The Graham WWTP has passed the toxicity test most of the time since 1997. There were FAILs
in June 1999 and June 2000. Recommend renewal of chronic toxicity test @ 14%.
Checked with Aquatic Tox on any reported basis for fails. There was no info in AQ TOX
suspense files.
COMPLIANCE SUMMARY:
Facility's compliance record since 1998 has been marked by exceedances in TSS and TP. The
improvements that are currently under construction should help with meeting these limits.
Graham has passed all compliance evaluation inspections.
For January 2001, Qw = 1.64 MGD (approximately 46% of capacity), BOD5=1.67 mg/1,
NH3=1.68 mg/1, TSS=17.9 mg/1, TN=27.6 mg/ and TP=1.15 mg/1.
In 2000, Avg. Qw = 1.67 MGD (approximately 47% of capacity), BOD5=2.29 mg/1, NH3=0.28
mg/1, TSS=40.2 mg/1, TN=7.7 mg/ and TP=1. 67 mg/1. Three exceedances of the TSS limit
in January, February, and March 2000.
In 1999, Avg. Qw = 1.87 MGD (approximately 53% of capacity), BOD5=2.35 mg/1, NH3=0.0
mg/1, TSS=23.6 mg/1, TN=9.7 mg/ and TP=1.75 mg/1.
In 1998, Avg. Qw = 1.98 MGD (approximately 56% of capacity), BOD5=3.18 mg/1, NH3=0.01
mg/1, TSS=28.6 mg/1, TN=8.7 mg/ and TP=2.13 mg/1. Two exceedances of the TSS limit in
February and March 2000.' i exceedances of the TP limit in
"Cwo `\v•Q.
tP.c\2:�5
CORRESPONDENCE REVIEW:
Graham WWTP Fact Sheet
NPDES Renewal
Page 2

10/27/00 -CEI - NOTED THAT FACILITY IS UNDER CONSTRUCTION PER ATC ISSUED ON
12/17/00. VIOLATIONS FOR TSS AND FECAL COLIFORM ARE NOTED.
8/22/00 - NOV FOR TOXICITY TESTING
8/11/00 - REMISSION REQUEST OF CIVIL PENALTY ASSESSMENT - CIVIL ASSESSMENT MODIFIED
FROM $3689 TO $1064.
7/ 11 / 00 - REMISSION REQUEST OF CIVIL PENALTY ASSESSMENT
6/ 16/ 00 - NOV AND CIVIL PENALTY FOR $1314 FOR TSS VIOLATION.
6/7/00 - REMISSION REQUEST OF CIVIL PENALTY ASSESSMENT
5/5/00 - NOV AND ASSESSMENT OF CIVIL PENALTY FOR $1061 FOR TSS VIOLATION
1/7/00 - YEARLY COMPLIANCE EVALUATION INSPECTION. FACILITY APPEARED TO BE WELL
OPERATED
8/24/99 - NOV FOR TOXICITY TESTING
4/27/99 - NOV FOR TSS
10/22/98 - CEI
10/ 12/98 - RECISION OF NOV AND ASSESSMENT OF CIVIL PENALTY
9/19/98 - NOV AND ASSESSMENT OF CIVIL PENALTY FOR $1070 FOR PERMIT VIOLATION (THIS
WAS FOR TOTAL PHOSPHORUS)
5/18/98 - RESCISSION OF NOV FOR TSS. RIVER WATER WAS BACKING UP THE LINE AND
SAMPLER WAS SAMPLING RIVER WATER AND EFFLUENT. WILL MOVE THE SAMPLING POINT TO
WHERE THE RIVER WATER WILL NOT INTERFERE WITH THE SAMPLE.
4/2/98 - EFFLUENT SAMPLE RELOCATION
3/19/98 - SPEC LIMITS FOR EXPANSION TO 5 MGD
9/17/97 - PERMIT MODIFICATION FOR THE DELETION OF ORTHOPHOSPHATE SAMPLING
REQUIREMENTS. PURSUANT TO MEMORANDUM OF UNDERSTANDING WITH CITY OF BURLINGTON.
8/13/97 - CEI - EXTENDED AERATION CLARIFIERS AND NITRIFICATION CLARIFIERS NEEDED
CLEANING. SKIMMERS TO EXTENDED AERATION CLARIFIERS WERE CLOGGED.
8/12/97 - PRETREATMENT INSPECTION REPORT - APPROVED
7/ 9 / 97 - PERMIT MODIFICATION FOR REMOVAL OF MERCURY LIMIT. TWICE PER MONTH
MONITORING FOR MERCURY NOW REQUIRED.
6/10/97 - SANITARY SEWER OVERFLOW OR BYPASS REPORT - PUMP STATION BYPASS/ INFLUENT
GRATE WAS STOPPED UP BY LARGE AMOUNT OF RAGS, SOCKS, AND PAPER TOWELS.
INSTREAM MONITORING:
Graham is a participant in the Upper Cape Fear River Basin Association and the coordinated
instream monitoring effort. Individual instream monitoring requirements for DO, temperature,
conductivity, and fecal coliform have been waived from the Graham permit effective April 6,
2000. A review of instream monitoring data prior to April 2000 - In April - October 1998 and
1999, instream data looked good most months, monthly instream DO averaged above 5 mg/1.
Only one upstream and one downstream value reported below 5 mg/1 (August 1999). Will
recommend continuation of waiver of instream monitoring for dissolved oxygen and
temperature while Graham is a member of the Upper Cape Fear River Basin Association.
PROPOSED CHANGES:
The following modifications have been made to the permit:
• Addition of effluent limitation for cyanide. RPA was based on values from 1999 -
2000 Long Term Monitoring Plan data. (Will recommend that facility report LTMP
data on DMRs submitted to the Division.) Analysis indicated that cyanide should be
limited based on a predicted value that would exceed the allowable concentration.
Highest data value was 157 ug/1 in March 1999 . The EPA Y2 FAV criteria value of 22
ug/1 will be assigned as a limit per Division policy limits and monitoring for CN and
metals (4/28/99)
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: 04 / 11 / 2001
Permit Scheduled to Issue: 05/25/2001
Graham WWTP Fact Sheet
NPDES Renewal
Page 3

STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Jackie Nowell at [phone] ext. 512.
NAME:
IA,Ate i DATE:
REGIONAL OFFICE COMMENT:
QC M\ \bo\5
NAME:
NPDES SUPERVISOR SUPERVISOR COMMENT:
DATE:
NAME: C_to - t -L DATE: / - % — C'
Graham WWTP Fact Sheet
NPDES Renewal
Page 4

ADDENDUM TO GRAHAM FACTSHEET
COMMENTS RECEIVED:
GRAHAM SUBMITTED COMMENTS ON MAY 9, 2001 AS FOLLOWS:
1) SUPPLEMENT SHEET SHOULD HAVE INTERMEDIATE CLARIFIERS DELETED. WILL HAVE DRUM
SLUDGE THICKENER AND SLUDGE STORAGE UNIT PRIOR TO THE END OF 2001 - NPDES WILL
REMOVE, THE WORD "INTERMEDIATE" FROM THE SUPPLEMENT TO COVER PERMIT PAGE.
gl REQUEST ELIMINATION OF CYANIDE LIMIT AND SUBMITTED LABORATORY INFORMATION TO SUPPORT
REQUEST. - NPDES' REASONABLE POTENTIAL ANALYSIS WAS DONE ON LTMP DATA (8 VALUES)
SUBMITTED FROM 1999 —2000, THE CN HIT WAS FROM A MARCH 1999 SAMPLE. GRAHAM
SUBMITTED LAB SHEETS THAT SHOWED THAT FOR THAT MARCH 1999 SAMPLE THE FOLLOWING
DATA WAS REPORTED, AN INFLUENT CN OF 26 UG/L, PRIMARY CLARIFIER EFFLUENT CN WAS <5
UG/L AND PLANT OUTFALL EFFLUENT CN OF 157 UG/L. SINCE THE CLARIFIER EFFLUENT IS
LOCATED BEFORE THE OUTFALL EFFLUENT, THE SAMPLE WENT FROM <5 UG/L TO 157 UG/L. WILL
CONCUR THAT THERE IS PROBABLY SOME LAB ERROR AND WILL DELETE THE CYANIDE LIMIT FROM
GRAHAM'S PERMIT. GRAHAM SUBMITTED DMR DATA FROM JANUARY 1992 TO MAY 1996 (222
EFFLUENT SAMPLES) TO SUPPORT THE FACT THAT THE 157 UG/L SAMPLE WAS TIID ONLY SAMPLE
THAT EXCEEDED THE PROPOSED CN LIMIT. THE MAJORITY OF THE OTHER VALUES WERE BELOW
DETECTION OR <10 UG/L. WILL ALSO RECOMMEND THAT FACILITY PUT ALL LIMP DATA ON THE
DMR'S SUBMITTED TO DWQ.
Graham WWTP Fact Sheet
NPDES Renewal

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TOXICANT ANALYSIS
Facility Name
NPDES #
Qw (MGD)
7Q 10s (cfs)
IWC (%)
c'ving Stream
Stream Class
graham wwtp
nc0021211
3.5
34
13.76
haw river
c nsw
Mercury
ax. Pred Cw
Allowable Cw
Max. Value
Copper
FINAL RESULTS
0.1
0.1
0.1
ax. Pred Cw 41.6
Allowable Cw 50.9
Max. Value 32
Zinc
ax. Pred Cw 195
Allowable Cw 363.4
Max. Value 150
Cyanide
ax. Pred Cw 8.085
Allowable Cw 36.3
Max. Value 5.39
Arsenic
ax. Pred Cw 2.5
Allowable Cw 363.4
Max. Value 2.5
Cadmium
ax. Pred Cw 1.624
Allowable Cw 14.5
Max. Value 0.58
Chromium
ax. Pred Cw 15.12
Allowable Cw 363.4
Max. Value 5.4
Lead
ax. Pred Cw 69.3
Allowable Cw 181.7
Max. Value 21
Nickel
ax. Pred Cw 8.5
Allowable Cw 639.5
Max. Value 5
Selenium
ax. Pred Cw 12.16
Allowable Cw 36.3
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
5/31/01

TOXICANT ANALYSIS
Parameter = Cyanide
Standard = 5 pg/I
n DL=1/2DLctual DataRESULTS
12/00 1 2.5 <5 Std Dev. 0.9264
2 2.5 <5 Mean 2.85864
3 2.5 <5 C.V. 0.32407
4 2.5 <5
5 2.5 <5
6 2.5 <5 Mult Factor
7 2.5 <5 Max. Value
8 2.5 <5 Max. Pred C
9 2.5 <5 Allowable C
10 2.5 <5
11 2.5 <5
12 2.5 <5
13 2.5 <5
14 2.5 <5
15 2.5 <5
16 2.5 <5
17 2.5 <5
18 2.5 <5
19 2.5 <5
20 5.39 5.39
21 5 5
01 /96 22 5 5
1.5
23
24
25
26
5.39 pg/l
8.085 pg/I
36.34 pg/I
5/31/01

TOXICANT ANALYSIS
Facility Name
NPDES #
Qw (MGD)
7Q1Os (cfs)
1WC (%)
c'ving Stream
Stream Class
graham wwtp
nc0021211
3.5
34
13.76
haw river
c nsw
Mercury
ax. Pred Cw
Allowable Cw
Max. Value
Copper
ax. Pred Cw
Allowable Cw
Max. Value
Zinc
ax. Pred Cw
Allowable Cw
Max. Value
Cyanide
ax. Pred Cw
Allowable Cw
Max. Value
Arsenic
ax. Pred Cw
Allowable Cw
Max. Value
Cadmium
ax. Pred Cw
Allowable Cw
Max. Value
Chromium
ax. Pred Cw
Allowable Cw
Max. Value
Lead
ax. Pred Cw
Allowable Cw
Max. Value
Nickel
ax. Pred Cw
Allowable Cw
Max. Value
Selenium
ax. Pred Cw
Allowable Cw
Max. Value
0
FINAL RESULTS
0.1
0.1
0.1
41.6
50.9
32
195
363.4
150
3061.5
36.3
157
2.5
363.4
2.5
1.624
14.5
0.58
15.12
363.4
5.4
69.3
181.7
21
8.5
639.5
5
12.16
36.3
6.4
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
trt• 9 Pate_
I 'Z -�Vx l 4il !ry t,. 7erwf)
bY�lov
ug/I bo,fi
ug/I
p
ug/I LN�
g ug/I 1-1
ug/I
ug/I
zr hit 12
ug/I LM
ug/I
ug/I LrM I
ug/I
zo
3/21/01

TOXICANT ANALYSIS
arameter =
Hg
Standard = 0.012 NA
n BDL=1/2DL tual Data RESULTS
1 0.1 <0.2
2 0.1 <0.2
3 0.1 <0.2
4 0.1 <0.2
5 0.1 <0.2
6 0.1 <0.2
7 0.1 <0.2
8 0.1 <0.2
9 0.1 <0.2
10 0.1 <0.2
11 0.1 <0.2
12 0.1 <0.2
13 0.1 <0.2
14 0.1 <0.2
15 0.1 <0.2
16 0.1 <0.2
17 0.1 <0.2
18 0.1 <0.2
19 0.1 <0.2
20 0.1 <0.2
21 0.1 <0.2
22 0.1 <0.2
23 0.1 <0.2
24 0.1 <0.2
25 0.1 <0.2
26 0.1 <0.2
27 0.1 <0.2
28 0.1 <0.2
29 0.1 <0.2
30 0.1 <0.2
31 0.1 <0.2
32 0.1 <0.2
33 0.1 <0.2
34 0.1 <0.2
35 0.1 <0.2
36 0.1 <0.2
37 0.1 <0.2
38 0.1 <0.2
39 0.1 <0.2
40 0.1 <0.2
41 0.1 <0.2
42 0.1 <0.2
43 0.1 <0.2
44 0.1 <0.2
45 0.1 <0.2
46 0.1 <0.2
47 0.1 <0.2
48 0.1 <0.2
49 0.1 <0.2
50 0.1 <0.2
51 0.1 <0.2
52 0.1 <0.2
53 0.1 <0.2
54 0.1 <0.2
55 0.1 <0.2
Parameter= Cu
Standard =
7
{1gA
n DL=1/2DLtual Data RESULTS
Std Dev. 4.53428E-09 1 26 28 Std Dev. 4.54366
Mean 0.1 2 22 22 Mean 22.9
C.V. 4.53428E-08 3 28 28 C.V. 0.19841
4 24 24
5 18 18
Mult Facto 11 6 17 17 Mutt Factor
Max. Value 0.1 µg/l 7 19 19 Max. Value
Max. Pred C 0.1 pgf 8 19 19 Max. Pred C
Allowable C 0,09 pg/I 9 15 15 Allowable C
10 25 25
11 18 18
12 20 20
13 21 21
14 21 21
15 22 22
16 25 25
17 27 27
18 28 28
19 24 24
20 17 17
21 23 23
22 14 14
23 24 24
24 32 32
25 25 25
26 21 21
27 30 30
28 27 27
29 27 27
30 28 28
1.3
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
Parameter = Zn
Standard
32 pglli
41.6 pg/I!,
50.87 pg/l ,c
50
pgf
n DL=1/2DLctual Dat
1 150 150
2 90 90
3 100 100
4 57 57
5 50 50
6 77 77
7 57 57
8 77 77
9 63 63
10 73 73
11 110 110
12 110 110
13 77 77
14 91 91
15 70 70
16 72 72
17 100 100
18 92 92
19 71 71
20 58 58
21 70 70
22 69 69
23 70 70
24 110 110
25 110 110
26 74 74
27 110 110
28 100 100
29 120 120
30 120 120
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
3/21/01

TOXICANT ANALYSIS
Parameter= Cn
Standard =
5
N9n
RESULTS n DL=1/2DLctual DataRESULTS
Std Dev. 23.6841 1 2.5 <5 Std Dev. 51.5
Mean 86.6 2 2.5 <5 Mean 19.6667
C.V. 0.27349 3 2.5 <5 C.V. 2.61864
4 2.5 <5
5 2.5 <5
Mult Factor) 1.3 6 2.5 <5 Mult Factor] 19.51
Max. Value 150 pg/I 7 2.5 <5 Max. Value 157 pg/I
Max. Pred C 195 pg/I 8 2.5 <5 Max. Pred C 3061.5 pg/I
Allowable C 363.36 pg/I 9 157 ottAllowabIe C 36.34 pg/I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
Parameter = Arsenic
Standard =
50
pg/I
n DL=1/2DLctual DataRESULTS
1 2.5 <5 Std Dev.
2 2.5 <5
3 2.5 <5
4 2.5 <5
5 2.5 <5
6 2.5 <5
7 2.5 <5
8 2.5 <5
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
Parameter =
Standard =
n
0 1
Mean 2.5 2
C.V. 0 3
4
5
Mult Factor' 1] 6
Max. Value 2.5 pg/I 7
Max. Pred C 2.5 pg/I 8
Allowable C 363.36 pg/I 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
3/21/01

•
Cadmium
2
sign
DL=1/2DL ctual Data RESULTS
0.25 0.25 Std Dev. 0.1769
0.3 0.3 Mean 0.35
0.5054
0.04 0.04 C.V.
0.3 0.3
0.32 0.32
0.45 0.45 Mutt Factor) 2.81
0.56 0.56 Max. Value 0.58 1.r0/
0.58 0.58 Max. Pred C 1.624 pg/f!'';
Allowable C 14.53 Krgll
TOXICANT ANALYSIS
Parameter = Chromium Parameter = Lead
Siandard a 50 ItglI 1,,4'tandard =
n DL=1/2DLctual Data RESULTS
1 3.2 3.2 Std Dev. 1.36218
2 1.9 1.9 Mean 2.5875
3 2 2 C.V. 0.52645
4 5.4 5.4
5 2.3 2.3
6 3.1 3.1 Mu1t Factor( 2.81
7 0.8 0.8 Max. Value 5.4
8 2 2 Max. Pred C 15.12
9 Allowable C 363.36 j
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
11
=fit
11
ui';
1is{
lfj
25
ign
n DL=1/2DL ctual Data RESULTS
1 5.8 5.8 Std Dev. 5.3551
2 4.9 4.9 Mean 8.8375
3 6.7 6.7 C.V. 0.606
4 7.4 7.4
5 6.3 6.3
6 6.6 6.6 Mutt Factor' 3.31
7 12 12 Max. Value 21 1!
8 21 21 Max. Pred C 69.3 > !U S
9 Allowable C 181.68
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
3/21/01

i
• r
,.Parameter= nickel
»Standard
•
'
88
TOXICANT ANALYSIS
Parameter= selenium
Standard =
n DL=1/2DLctual Data RESULTS
1 3 3 Std Dev. 0.8864
2 2 2 Mean 3.25
3 4 4 C.V. 0.2727
4 3 3
5 3 3
6 3 3
7 5 5
8 3 3
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
Mult Factor' 1.71
Max. Value 5 pgl1
Max. Pred C 8.5 p9/t
Allowable C 639.52 pg/1
5
4rSn
n DL=1/2DLctual Data RESULTS
1 5.6 5.6 Std Dev. 1.31774
2 6.4 6.4 Mean 4.325
3 4.9 4.9 C.V. 0.30468
4 3 3
5 2.9 2.9
6 4.9 4.9 MultFactor! 1.9I
7 3.1 3.1 Max. Value 6.4 pg/I
8 3.8 3.8 Max. Pred C 12.16 iig/I
9 Allowable C 36.34 pg/l
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
3/21/01

Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001 •
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
GNC Energy Corp/ 001 Perm 24hr LC50 ac mono epis fthd (Grab) 1997 - >100 - - - >100 - - - - - >100
NC0074241/00I Begin:6/1/1996 Frequency: A NonComp: 1998 - - - - - >100 - >100 - - - -
County: Guilford Region: WSRO Subbasin: CPFOS 1999 - - - - - - - >100 - - -
PF: VAR Special 2000 - - - - - - - - - - - >100
7Q10: 0.0 IWC(%):100 Orden 2001
Golden Poultry Perm chr lim: 9.0°/. 1997 Pass - - Pass - - Pass - - Pass - -
NC0072575/001 Begin:6/1/1996 Frequency: Q P/F + Jan Apr Jul Oct NonComp:Single 1998 Pass - - Pass - - Pass - - Pass - -
County. Lee Region: RRO Subbasin: CPFI I 1999 Pass - - Pass - - Pass - - Pass - -
PF: 1.0 Special 2000 pass - - Pass - - Pass - - Pass - -
7Q 10: 17.0 IWC(%)9.1 Order. 2001
Goldsboro WWTP PERM CHR LIM: 6% (New perm 11/1/2000)
NC0023949/001 Begin:4/I/1994 Frequency: Q P/F + Jan Apr Jul Oct NonComp:SINGLE
County: Wayne Region: WARO Subbasin: NEU05
PF: 10.10 Special
7Q10: 271.1 IWC(%):6.0 Order.
1997 Pass
1998 Pass
1999 Pass
2000 Pass
2001
Pass - - Pass - - Pass - -
Pass - - Pass - - Pau - -
Pass - - Pass - Pass - -
Pass - - Pass - - Pass - -
Goldsboro WWTP Perm chrlim:2.2%
NC0023949/002 Begin: l I/1/2000 Frequency: Q Jan Apr Jul Oct
County: Wayne Region: WARO Subbasin: NEU05
PF: 4.0 Special
7Q10: 271.1 1 WC(%)2.2 OW.
+ NonComp:Single
1997
1998
1999
2000
2001
1311111•11114,- ^ dttndMlim:.l4%5 1997 - - PBss -
sr ryi119iyd1996 rQ,P/E • +.MixJim Sep Deo NonCamp:Single 1998 - - 'r"PUs�-
11ee R15.1 i0in--CPF02._tir 199999 - - - 'P -
" • +LI , -
4101124
IWC(%):14 Via: 2001
Ares.
Pass
412111.
w
Ph- ee - POW
>56 >56 PAP:
Granite Falls WWTP Perm chr lim: 13 %
NC002I890/001 Begin:7/1/1995 Frequency: Q P/F + Mar Jun Sep Dec
County. Caldwell Region: ARO Subbasin: CTB32
PF: 0.90 Special
7Q l0: 9.3 1 WC(%):13 Order:
NonComp:Single
1997 -
1998 -
1999 -
2000 -
2001
- Pass - - Pass - - Pau - - Pass
- Pass - - Pass - - Pass - - Pass
- Pass - - Pass - - Pass - - Pass
- Pass - - Pass - - Pass - - Pass
Greensboro N Buffalo Cr WWTP Perm chr lim: 90% 1997 Pass - - Fail Pass - Pass - - Pass - -
NC0024325/001 Begin:4/I/1996 Frequency: Q P/F + Jan Apr Jul Oct NonComp:Single 1998 Fail Fall Pass Pass - - Pass - - Pass - -
County: Guilford Region: WSRO Subbasin: CPF02 1999 Pass - - Pau - - Pass - - >100 - -
PF: 16.0 Spccial 2000 >100 - - >100 - - >100 - - >100 - -
7Q10: 0.90 IWC(%)96.5 Orden 2001
Greensboro Osborne WWI? Penn chr lim: 90%
NC0047384/00I Begin l/1/1996 Frequency: Q P/F + Jan Apr Jul Oct
County. Guilford Region: WSRO Subbasin: CPF02
PF: 22.0 Special
7Q10: 2.1 IWC(%):93.7 Order.
NonComp:Single
Y 1997 Fail Fail Pass Pau - - Pass - - Pass - -
1998 Pass - - Fail Pass - Pau - - Pass - -
1999 Pau - - Pau - - Fail,>100 - - >100 - -
2000 >100 - - >100 - - >100 - - 94.9 - -
2001
Greenville WWTP Perm chr lim: 20%(New perm 1/1/2001) Y 1997 - - Pass(s) - - Pass(s) - - Pass(s) - - Pass(s)
NC0023931/001 Begin:6/6/1995 Frequency: Q P/F + Mar Jun Sep Dec NonComp:Single 1998 - - Pass(s) Pass(s) - Pass(s) - - Pass(s) - - Pass(s)
County: Pitt Region: WARO Subbasin: TAROS 1999 - - Pass(s) - - Pass(s) - - Late Pass(s) - Pass(s)
PF: 17.5 Special 2000 - - Fail 69.3 >80 >80 - - >80 - - >80
7QI0: 109 IWC(%)20 Order: 2001
Grover Industries, Inc. Penn chr dim: 6% 1997 - Pau - - Pass - - Pass - - Pau -
NC0004391/001 Begin l/U1999 Frequency: Q P/F + Feb May Aug Nov + NonComp:Single 1998 - Pau - - Pau - - Pass - - Pass -
County: Polk Region: ARO Subbasin: BRD06 1999 - Pass - - Pass - - Pass - - Pau -
PF: 0.45 Special 2000 - Pass - - Pau - - Pass - - Pass -
7Q10: 10.8 IWC(%):6.07 Order: 2001
Grover Industries, Inc. Penn chr lim: 1.8% 1997 - - Pau - - Pass - - Pass - - Pass
N00083984/001 Begin:4/I/2000 Frequency:Q Mar Jun Sep Dec + NonComp:Single 1998 - - Pass - - Pass - - Pass - - Pau
County. Cleveland Region: MRO Subbasin: BRDOS 1999 - - Pass - - Pass - - Pass - - Bt
PF: 0.38 Special 2000 - Pass Pass - - Pass - - Pau - - Pau
7QI0:32 IWC(%):1.8 Order. 2001
Y Pre 1997 Data Available
LEGEND:
PERM - Permit Requirement LET - Administrative Letter - Target Frequency = Monitoring frequency: Q. Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin a First month required 7Q10 Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF - Permitted flow (MGD) IWC% - Instream waste concentration P/F = Pass/Fail test AC = Acute CHR - Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad lest
Reporting Notation: - = Data not required; NR - Not reported Facility Activity Slatus: I - Inactive, N - Newly Issued(To construct); H - Active but not discharging; 1-More data available for month in question; • .• ORC signature needed
23

•
NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form
NPDES OR NONDISCHARGE PERMITTING UNIT COMPLETES THIS PART:
Date of Request hi17.4, co
Facility GrcA.,,,W e.A... i-vJ�-3` "4
Permit# tJ C, o c5 -2..1 z 1
Region s l ir‘sVor •- Swkem,
Requestor -J'C 0,c3ccit `Cl. by,Ne A
Pretreatment A_D Towns- Keyes McGee (ext. 580)
Contact E-L Towns- Vaeaet-Positiert Le y4 -'S °13�
M-R Towns- Dana Folley (ext. 523)
S-Z Towns- Steve Amigone (ext 592)
PRETREATMENT UNIT COMPLETES THIS PART:
Status of Pretreatment Program (circle all that apply)
1) the facility has no SIU's and does have a Division approved Pretreatment Program that isINACTIVE
the facility has no SIU's and does not have a Division approved Pretreatment Program
3) a facility has (or is developing) a Pretreatment Program)
L2
2a is Full Program with LTM J or 2b) is Modified Program with STMP
4) the facility MUST develop a Pretreatment Program - Full Modified
5) additional conditions regarding Pretreatment attached or listed below
Flow Permitted Actual '
% Industrial eftGb O.
STMP time frame:
most recent
c,,1\OS b3a rt,Csb
next cycle
% Domestic 1..-3eS si+tot
(S)
T
MP
Pollutant
Check List
FewNPDES/Non- n—
Discharge
Permit Limit
Required
by EPA'
Required by
503 Sludge"
POC due to SW"'
Site specific POC (Provide Explanation)'"'
STMP
Frequency at
effluent
LTMP
Frequency at
effluent
✓
BOD
✓
../
4
M
✓
TSS
✓
V'
4
,) Q
.M
/NH3
.%
4
Q
M
✓
Arsenic
✓
4
Q
'M
-‘1
Cadmium
.4
✓
✓
4
Q
M
4
Ch_r_ornlum
4
✓
4
Q
M
Capper:: . .
4
N/
✓
4
Q
M
,/
Cyanide
✓'
4
Q
M
4
Lea; r•L,' _
4
✓
✓
4
Q
M
✓
Mercury
1✓
✓
4
Q
M
/Molybdenum
�/
4
Q
q
N(i✓k�`el :t
./
4
�Q
Q
JM
M
Silver
4
✓Selenium
✓
.,
4
Q
M
-4
Zing : =r
-4
✓
✓
4
Q M
✓
"u-ko.V ose1\.
.%/
✓
4
Q) M
4
Q M
•
4
Q M
•
4
Q M
4
Q M
4
Q M
'Always in the LTMP
"Only in the LTMP if the POTW land applies sludge
•" Only in LTMP while the SW Is connected to the POTW •
"" Only in LTMP when the pollutant is a specific concern to the POTW (ex -Chlorides for a POTW who accepts Textile waste)
a= Quarterly
M=Monthly
Comments: O cet rr. Vkkoist S 1z.419L .
2- E.Y. (1., a v
eizN-&-V.--Q-k-etori1 <-‘4.co \ 9 0 Q S k 41 C 2.c V\PSt `1`
) _
version �00 L—cmP Gc. UY�iI V%(. v ov i i LiSr � . i e AlA rb t C.V.
Ate. 42.Z. QQ 0 0 .v. C eivrI,P{tC4
\sc.-)
NPOES_Pretreatment.request.form.000823 �+ D
Revised: August 4, 2000 (5) `� • �. 0. Vt; 0 c
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Tifg of (6rttllam
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
Mr. David Goodrich
NCDENR 1 DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
July 26, 2000
RE: Renewal for NPDES Permit No.NC0021211
City of Graham, Alamance County
Dear Mr. Goodrich:
I enjoyed the opportunity to meet with you earlier in the month to discuss the
NPDES permit application process. You informed me that your office was in the process
of granting extensions to the permittees discharging into the Cape Fear River Basin. I
indicated to you that the City of Graham had already completed the previously used
longer application. You advised that the City may go ahead and submit that completed
application even though we probably will be granted an extension.
The City of Graham request renewal for NPDES permit No. NC0021211 for the
operation of the City of Graham Wastewater Treatment Plant. Please find enclosed the
following required items in the city's application package.
1. One original and two copies of this cover letter.
2. One signed original and two copies of the completed application.
3. Three copies of previously submitted letter showing delegated authority to
Authorized Representative.
4. One signed original and two copies of the narrative description of the Sludge
Management Plan.
Please contact me at 336.570.6700 if you have any questions or need additional
information.
Sincer
Victor R. Quick
Treatment Plants Superintendent
Cc: Ray Fogleman, Manager, City of Graham
David Lawson, Supervisor, City of Graham WWTP

r�o1:1GL� ► oty&
STANDARD FORM A - MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each major industrial facility discharging to the municipal system, usinga separate Section IV for each
facility, description. Indicate the 4 digit Standard Industrial Class�scation (SIC) Code.for the industry, the major product or raw
material. the flow (in thousand gallons per day), and the characteristics of the wastewater discharged from the industrial fadiity
into the municipal system. Consult Table Ill for standard measures of products or raw materials. (see instructions)
1. Major Contributing Facility
(see instructions)
Name 401a
Number & Street
City
County
Stags
Zp Code
2 Primary Standard industrial
Classification Code(see Instructions)
3. Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Flow Indicate the volume of water
discharged into the municipal sys-
tem gallons per day
and whether this discharge is
intermittent or continuous.
5. Pretreatment Provided tnc#c ate if
pretreatment is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401b
401c
401d
401e
401f
402
403a
403b
404a
404b
405
BFI Medical Waste, Inc.
1168 Porter Ave.
Haw River
Alamaooe
North Carolina
27258
4953
incineration
of solid
medical
waste
40©c
403d
Units(See
Quantitv Table 1111
17 thousand gallons per day
Intermittent(int) ❑ Continuous (con)
12; Yes ❑ No
402e
40 f
r
.. •', h.
. o .: 1
��
Parameter
Name
BOO
TSS
Cd
Cu •
Pb
Zn
'Parameter
Number
00310
00530
01027
01042
01034
01051
01092
value
11
4
0.0014
0.02
0.003
0.001
2
0.012
r }v:;z ��

f••
v
: ; : .
• Y 4
p
•I 1
STANDARD FORM A - MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each major industrial facility d ch � to the municipal system, using a separate Section IV for each
faciity description. Indicate the 4 dgit Standard Industrial asSE11caton (SIC) Code -for the industry, the major prior ,
w
material, the flow (in thousand gallons per day), and the characteristics of the wastewater' dscharged the city
into the municipal system. Consult Table Ili for standard measures of products or raw materials. (see instructions)
1. Major Contributing Facility
(see instructions)
Name
Number & Street
City
County
State
p Code
a Primary Standard Industrial
Classification Code(see Instructions)
a Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Row Indicate the volume of water
clischarged into the municipal sys-
temin sand gallons per day
and whether this dscharge is
itemiittient or continuous.
5. Pretreatment Provided Indicate if
pretreatment is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
•
•
401a
401b
401c
401d
401e
401f
402
403a
403b
404a
404b
405
Culp Weaving
300 E. Parker St.
Graham
Alamanoe
North Carolina
2725
2221
woven fabri 4oac
403d
305 thousand gallons per day
© lntermittent(int) [] Continuous (con)
El Yes •®No
Units(See
Table MI •
403e
403f
": -` :}'
wp
Parameter
Name
BOD
TSS
Cd
Cu
Ni
Pb
Zn
,
• -
Pararremr
Number
00310
00530
01027
01042
01067
01051 -
01092
valve
75
8
0.001
0.17
0.007
0.0043
0.08

t
r
STANDARD FORM A - MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each major industrial facility discharging to the municipalsystem, using a separate Section IV for each
fealty description. indicate the 4 digit Standard Industrial ss noa io a(SthC�� industry, framer product or raw
y
material, the flow (En thousand gallons per day), and the characteristics t discharged
into the municipal system. Consult Table Ill for standard measures of products or raw materials. (see instructions)
1. Major Contributing Facility
(see instructions)
Name
Number & Street
City
County
State
Zip Code
2 Primary Standard Industrial
Classification Code(see Instructions)
3. Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Flow Indicate the volume of water
di into the municipal sys-
tem rn oouusand gallons per day
and whether this discharge is
intermittent or continuous.
5. Pretreatment Provided indicate if
pretreatment is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401a
401b
401c
401d
401e
401f
402
403a
403b
404a
404b
405
Uni-Chem Hose Corp
449 Trollingwood Rd
Haw River
Alamance
North Carolina
27258
3052
rubber &
plastics
hose
403c
40 d
15 thousand gallons per day
g lntermittent(int) [] Continuous (con)
Ei Yes ® No
Units(See
Table III)
`^�`"c`
•
. ammeter
Name
BOD
TSS
TRN
Cu •
Ni
Pb
Zn
Vararneter
Number
00310
00530
00625
01042
01067
01051
01092
{
Value
20
18
8
0.13
0.005
0.003
0.08

STANDARD FORM A - MUNICIPAL •
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each major industrial facility discharging to the municipalsystem, usinga separate Secction IV for each
facaiity, description. Indicate the 4 digit Standard Industrial Classification (SIC) the industry, the
major ormw
'not '
material, the flow (in thousand gallons r day), and the characteristics of the wastewater dschargad from facility
into the municipal system. Consult Table III for standard measures of products or raw materials. (see instructions)
•
1. Major Contributing Facility
(see instructions)
Name
Number & Street
City
County
State
Zip Code
2 Primary Standard Industrial
Classification Code(see Instructions)
a Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Flow indicate the volume of water
dischargedinto the municipal sys-
temin ousand gallons per day
and whether this discharge is
intermittent or continuous.
Pretreatment Provided Indicate if
pretreatment is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401a
401b
401c
401d
401e
401f
402
403a
403b
404a
404b
405
Luxfer Gas Cylinders
235 Riverbend Rd.
Graham
Alamance
North Carolina
27253
3354
aluminum
gas
cylinders
403c
403d
57 thousand gallons per day
© lntermittent(int) ❑ Continuous (con)
❑ Yes ® No
Units(See
Table Ill)
. �`
Parameter
BOD
TSS
TOT
CN
d�&G
Cr
Zn
�`` '�
Parameter
Number
00310
00530
00625
00720
00550
01034
01092
Value
66
25
, 4.0
0.005
23.0
0.0014
0.07

•
jr
pTLCIFIh4►[. tuI1j
STANDARD FORM A - MUNICIPAL •
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a desaiption of each major industrial facility dtsch ing -b the municipal system, usinga separate aS�eocction IV for each
facility description. Indicate the 4 digit Standard industrial tion (SIC) Code s frhe om the proindduct
rraw
aa'Iity
material, the flow (in thousand gallons per day), andof the
into the municipal system. Consult Table III for standard measures of products or raw materials. (see instructions)
1. Major Contributing Facility
(see instructions)
Name
Number & Street
City
County
State
ZpCode
2 Primary Standard Industrial
Classification Code(see Instructions)
3. Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Flow Indicate the volume of water
discharged into the municipal sys-
tem in thousand gallons per day
and whether this dscmarge is
intermittent or continuous.
6. Pretreatment Provided Indicate if
pretreabnent is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401a
401b
401c
401d
401e
401f
402
403a
40Cib
404a
404b
405
Nannxflexe Inc
900 Gant Rd
Graham
Alamance
North Carolina
27253
2241
narrow
elastic
403c
403d
Units(See
Quantity Table 1II1 '
20 thousand gallons per day
121 interinittent(int) ❑ Continuous (con)
❑ Yes ® No
,, { . "'``
? '
a.",' _'> ''','.;-,r
STANDARD FORM A - MUNICIPAL •
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a desaiption of each major industrial facility dtsch ing -b the municipal system, usinga separate aS�eocction IV for each
facility description. Indicate the 4 digit Standard industrial tion (SIC) Code s frhe om the proindduct
rraw
aa'Iity
material, the flow (in thousand gallons per day), andof the
into the municipal system. Consult Table III for standard measures of products or raw materials. (see instructions)
1. Major Contributing Facility
(see instructions)
Name
Number & Street
City
County
State
ZpCode
2 Primary Standard Industrial
Classification Code(see Instructions)
3. Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Flow Indicate the volume of water
discharged into the municipal sys-
tem in thousand gallons per day
and whether this dscmarge is
intermittent or continuous.
6. Pretreatment Provided Indicate if
pretreabnent is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401a
401b
401c
401d
401e
401f
402
403a
40Cib
404a
404b
405
Nannxflexe Inc
900 Gant Rd
Graham
Alamance
North Carolina
27253
2241
narrow
elastic
403c
403d
Units(See
Quantity Table 1II1 '
20 thousand gallons per day
121 interinittent(int) ❑ Continuous (con)
❑ Yes ® No
,, { . "'``
? '
a.",' _'> ''','.;-,r
Parameter
Name
BOD
TSS
Cr
Ni
Pb
Zn
Parameter
Number
00310
00530
00625
01034
01067
01051
01092
ar.i`;
.. ;,,„-.
vaeve
325
225
75
0.008
0.01
0.004
1.5

STANDARD FORM A • MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each major industrial facility disch ing ;to the municipalsystem, using a separate Section IV for each
facility description. Indicate the 4 digit Standard Industrial Classiscation SICei, industry, the majorproduct�t
w
material, the flow (in thousand gallons per day), and the characteristics of the or raw materials. (seed instructions)om theindustrial
ity
into the municipal system. Consult Table nil for standard measures ofproducts
1. Major Contributing Facility
(see instructions)
Name 401a G K Services
Number & Street
City
County
State
Zip Code
2. Primary Standard Industrial
Classification Code(see Instructions)
3. Primary Product or Raw Material
(see instructions)
Product
Raw Material
4. Fbw Indicate the volume of water
di ed into the municipal sys-
tem in ousand gallons per day
and whether this dscharge is
intermittent or continuous.
�. Pretreatment Provided Indcate if
pretreatment is provided prior to
entering the municipal system
6. Characteristics of Wastewater
(see instructions)
401b
401c
401d
401e
401f
402
40C3a
402b
404a
404b
405
610 Woody Dr
Graham
Alamanoe
North Carolina
27253
7218
industrial
laundry
403c
40Qd
Quantity
72 thousand gallons per day
® lntermittent(int) ❑ Continuous (con)
® Yes ❑ No
403e
Units(See
Table 1111
Parameter
Name
130D
TSS
TKN
O&G •
Cd
Pb
Zn
Numbermr
00310
00530
00625
00550
01027
01051
01092
Value
425
85
15
55
0.0Q6
0.6
2.26

EXTENDED
...41LUOGE RECIRCULATION
AERATION
CLAR.
NITRIFICATIONFle--
LOGE RECIRCULATION,j
CLAR. era
Soto!
TO FINAL 01SPOS AL
ST LAND SPREAOING
INFLUENT
SCRELNING
8. GRIT REM.
TANKS
AEROBIC
DIGESTERS
�-- wnSTFo
SL.000c
a• en
PUMP
HOUSE
Do- LEGEND
MAIN FLOW
SLUDGE. FLOW
--•�---•-- WASTE SLUDGE
P PUMPS
Z
0
to F:.
0<
sci
FLOW DIAGRAM
FIG. I-1

QIitj of (!ra1am
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
October 28,1999
Division Of Water Quality
D.E.H.N.R.
1617 Mad Service Center
Raleigh, NC 27699-1617
RE: NPDES Permit No. NC0021211 and NPDES Permit No. NC0045292 held by the
City of Graham, Alamance County, NC
Dear Sir or Madam:
By this letter, the City of Graham is notifying the NPDES Permit Issuing
Authority that required permit reports will be signed by the City Manager or his duly
authorized representative. The authorized representative will be the person holding the
position of Treatment Plants Superintendent for the City of Graham.
The person presently holding the Treatment Plant Superintendent position, Martin
D. Wilson, is leaving the City of Graham. Until anew Superintendent is hired, the City
Manger, Ray Fogleman, will sign as the `Permittee." Future reports required by the
NPDES permits for the Water and Wastewater Facilities will be signed by the person
holding the Treatment Plant Superintendent position unless that position is vacant.
The "Operator in Responslle Charge (ORC)" for both the Water and Wastewater
Plants is not changng at this time. The Supervisor of each fatty is designated as the
plant "ORC", and they will continue to sign the reports in that capacity.
If you have any questions please call me at 336-570-6700 or write to my attention
to the address above.
Sincerely,
cc: David Lawson, WWTP Supervisor
James M. Carson, WTP Supervisor

City of Graham Wastewater Treatment Plant
Sludge Management Plan
NPDES Permit No. NC0021211
July 25, 2000
• Wastewater Treatment Plant sludge is aerobically digested, lime stabilized, and
then surface applied to a dedicated land application site.
• Aerobic digestion takes place in the primary and secondary digesters (combined
volume of 375,900 gallons). The digested sludge is then stabilized by adding
approximately 2.7 tons of hydrated lime per 48,000 gallons of sludge (sludge pH
is raised to 12.0 standard units for 2 hours and then held at 11.5 pH for an
additional 22 hours). Two lime stabilization tanks (combined volume of 100,000
gallons) are utilized for this process. Sludge is then pumped to the transport
trucks for delivery to the land application site.
• Stabilized sludge is transported via two sealed tanker trucks to the site. The
delivery vehicle used carries a copy of the Non -Discharge permit and spill control
and prevention policy. Remote routes are used and equipment meets DOT
standards. Drivers are trained and educated concerning operational components
of the permit and receiver site procedures. All drivers have CDL license with
tanker and air brake endorsements.
• The land application site is dedicated city owned land. There are 89.4 acres of
land that is permitted under Non -Discharge permit No. WQ0003824. Sludge is
surface applied in accordance with the permit restrictions using an off -road
vehicle with sealed tank.
• A fescue cover crop is maintained on the fields and is harvested and used for
cattle feed. Fields are maintained and crops harvested in accordance with permit
requirements.
• Nutrient and metal loadings and application rates are calculated and reported in
accordance with WQ0003824 requirements.
• All land application activities are performed in accordance with WQ0003824
requirements and 40 CFR Part 503 federal regulations.
David W. Lawson
WWTP Supervisor
City of Graham
.d4 62.ad
Victor R. Quick
Plants Superintendent
City of Graham

Graham's permit requirments
To: Dave Goodrich <[e-mail]>
CC: Larry Coble <[e-mail]>, Bill Reid <[e-mail]>,
Larry Ausley <[e-mail]>
Dave,
could this be handled with a letter to the permit holder that.rnaintains'ttie
requirement ofisampling4heoffluent-three}days-a`;°while"conit'ilfnaiing'with
tho oalition7 to insulre oneathasosamples-aro,taken..duving ihe„daay-the
ipstr<eam.sample is collected. I think both Graham and the coalition are
amenable to this and it would clarify their responsibility. As Graham is
asking why we haven't responded, I would like to handle this quickly and
be done with it.
I just don't know if an administrative letter is sufficient.
Please let me know.
thanks
Jimmie
Subject: Re: Upper Cape fear River Basin Assoc. Issue
Date: Wed, 17 May 2000 14:10:19 -0400
From: Larry Coble <[e-mail]>
Organization: NC DENR Water Quality
To: Larry Ausley <[e-mail]>
References: <[e-mail]>
/1 Cps 2---1 Zi
I don't really have a preference. It would seem that a combination of 1 & 2 would be most reasonable.
Larry Ausley wrote:
The City of Graham, a member of the UCFRBA has just had its instream
monitoring waived in lieu of coalition monitoring. In its permit
(NC0021211), the facility has effluent phosphorus and ortho-P monitoring
required on the same days that instream monitoring for those parameters
occurs (weekly P , , .) (Facility
Contact -David Lawson 336-570-6721) fr'`1-i`0`l-
The coalition will be sampling total-P downstream of he facility monthly
and biweekly during May -Sept.
The facility now doesn't have that day "hook" for sampling their
effluent.
Let me propose three approaches to resolve this gap:
1 of 2 5/30/00 4:33 PM

Graham's permit requirments
t
1) the facility has offered to keep up the same amount of effluent
sampling (weekly P and 3x/week ortho-P Jun -Sep) but just spread through
the week.
2) have the coalition contractor (Burlington Research) call the facility
and let them know instream sampling date ahead of time (get P- and
ortho-P effluent samples same day as instream but less often than under
the permit)
3)combination of 1 and 2 so that at least SOME of #1 sampling occurs on
the same day as notified like #2.
Please respond with a preference or alternative and also a thought on
how to handle this administratively and I'll be glad to expedite the
solution.
Thanks
Larry W. Ausley, Supervisor
2 of 2 5/30/00 4:33 PM

Tifg of (6rtt4ttm
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
June 8, 2000
Mr. Bill Reid
Supervisor, Point Source Branch
Water Quality Section
NCDENR-DWQ
PO Box 29535
Raleigh, NC 27626-0535
Re: Graham, North Carolina
WWTP Nitrogen Discharge Limit
Dear Mr. Reid:
This letter is to report on progress of the City of Graham's efforts to address
compliance with the Nitrogen Discharge Limits proposed for the Haw River in the
Cape Fear River Basin. This progress report is in response to NCGS 143-
215.1B(d)(5). It is our expectation that this information will satisfy the requirements
for nutrient discharge compliance set forth by NCGS 143-215.1.
The Division of Water Quality gave full approval to the Graham 201 Facility
Plan which recommended wastewater treatment plant improvements to address
hydraulic capacity, solids handling, and flood prevention. The City received
Authorization to Construct the recommended improvements project. Construction is
in progress with an expected completion date of November 2001. We feel that the
improvements will address the following:
1. [143-215.1 B(d)(2)] Evaluate and optimize the operations of the City of Graham
WWTP in order to reduce nutrient loading.
A. The improvements address nutrient removal by redesigning the alum feed
facilities to allow continual treatment for phosphorus removal. Specifically,
the alum feed point has been relocated and new storage and feed equipment
are provided.
B. Phosphorus removal can be increased by feeding alum on a continuous
basis.
2. [143-215.1B(d)(3)] Evaluate methods to reduce the total mass Toad of waste that
is discharged from the City of Graham WWTP and determine whether the
methods are cost effective.
A. The proposed improvements to the sludge digestion and storage capabilities
will allow regular sludge wasting resulting in the ability to control MLSS and
F/M ratio. This is expected to improve treatment performance.
B. With additional final settling tanks, the surface overflow rate will be half the
current rate. Performance will also be enhanced by decreasing the solids
loading by reducing the MLSS concentration.

June 8, 2000
Page Two
3. [143-215.1 B(d)(4)] Evaluate methods to reduce the discharge of treated effluent
from the Graham WWTP and determine whether the methods are cost effective.
A. Land application of effluent was evaluated in the 201 Facility Plan and
determined not to be cost effective.
B. Although Infiltration/Inflow was found to be within limits prescribed by the
regulations during the Facility Planning process, the improvements include
standby generators at several of the pumping stations and upgrading
Backcreek Pumping Station No. 1, thus improving reliability and therefore
reducing the possibility of untreated discharge.
In addition, Graham is currently developing a calibrated nutrient response
model in conjunction with Burlington, Greensboro, Mebane, Orange Water and
Sewer Authority, Pittsboro and Reidsville [143-215.1 B(d)(1)].
We trust this satisfactorily addresses nutrient discharge compliance concems
the Commission may have for the Graham WWTP facility. Please contact us if you
have any questions or comments.
62,d
Victor Quick
Treatment Plants Superintendent
c: Lary Coble, Winston-Salem Regional Office, NCDENR-DWQ
David Hamilton, FPS