NC0025071_permit modification_20050718

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July 18, 2005
Mr. Dennis Asbury
Director, Public Works
City of Eden
308 East Stadium Drive
Eden, North Carolina 27288
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: Issuance of Major Modification
NPDES Permit NC0025071
Mebane Bridge WWI?
Rockingham County
Dear Mr. Asbury:
Division of Water Quality (Division) personnel have reviewed and approved your
request for a major modification of the subject permit. Accordingly, we are forwarding the
modified pages of the NPDES discharge permit. This permit modification is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental
Protection Agency dated May 9, 1994 (or as subsequently amended).
The following modifications have been made to this NPDES permit and are effective
beginning August 1, 2005:
• An additional effluent sheet with a permitted flow of 10.0 MGD and a color limit of
405 ADMI has been added to this permit. In comparison, the facility's current
permit contains an effluent sheet for 13.5 MGD flow and a color limit of 300 ADMI.
The request for this interim flow of 10 MGD is based on the loss of industrial flow
to the city, and the proposed color limit of 405 ADMI provides some buffer for the
textile facilities. The color limit is based on maintaining the same color "mass"
(i.e., 13.5 MGD x 300 ADMI = 4,050 color units = 10.0 MGD x 405 ADMI). This
color mass balance approach is consistent with the methodology used to develop
previous color limits for this facility, and is based on the DWQ 1990 report "An
Update of Color Control Activities in the Smith and Dan River Basins." No other
parameters have been modified under this permit modification.
• Both Effluent Sheets have been reworded to allow the facility to revert back to the
13.5 MGD Effluent Sheet with a letter request, should the facility add more
industrial flow in the future, or based on the facility reaching 90% of permitted
flow.
• Addition of Special Condition A (4)- Color Condition, which requires the permittee
to initiate additional color removal (back to the previous color limit of 300 ADMI, if
needed) should the City of Danville encounter color problems at their water
treatment plant due to Eden's wastewater discharge.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleiqh, North Carolina 27699-1617
AA
[phone] NCDENR
FAX [phone] Customer Service
On the Internet at httD://h2o.enr.state.nc.us/ 1 800 623-7746

Page 2
NCO025071
NPDES Permit Modification
If any parts, measurement frequencies or sampling requirements contained in
this permit modification 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 demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the
Division. The Division may require modification or revocation and reissuance of the
permit. This permit does not affect the legal requirements to obtain other permits
which may be required by the Division of Water Quality or permits required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal or
Local governmental permit that may be required.
If you have any questions concerning this permit modification, please contact
Tom Belnick at telephone number [phone], extension 543.
Sincerely,
6,07M4t&J,
A�anW. HIimek, P.E.
cc:
EPA Region 3. Attn: NPDES Branch Chief, Water Protection Division, 1650 Arch Street. Philadelphia, PA 19103
EPA Region 4. Attn: Marshall Hyatt, Atlanta Federal Center, 61 Forsyth Street SW, Atlanta, GA 30303
City of Danville, Utilities Department, Atta: Barry Dunkley. P.E., 279 Park Avenue, Danville. VA 24541
Virginia DEQ, Attn: Kirk Batsel, South Central Regional Office, 7705 Timberlake Rd, Lynchburg, VA 24502
Winston-Salem Regional Office/Surface Water Protection
NPDES File
Central File

Permit NCO025071
A. (1 a) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS- 10 MGD
Beginning August 1, 2005 and lasting until a) permit expiration or b) until the last (12) month average flow
exceeds 9.0 MGD or c) until a letter request for additional flow based on new industrial flow commitments, the
Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
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F �_ uenc T e T{
Flow
10.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day 202C 2
30.0 m L
45.0 mg1L
Daily
Composite
Effluent, Influent
Total Suspended Solids2
30.0 m L
45.0 m L
Daily
Composite
Effluent, Influent
NHs as N ril 1.October 31 3
12.7 m L
Daily
Composite
Effluent
NH3 as N November 1—March 31 3
Meek
Composite
Effluent
PH4
Daily
Grab
Effluent
PH
1
Grab
Upstream',
Downstream'
Fecal Coliform
(geometric mean
200 / 100 ml
4001100 ml
Daily
Grab
Effluent
Total Residual Chlorine
28 4L
Daily
Grab
Effluent
Temperature °C
Daily
Grab
Effluent
Temperature (-Q
1
Grab
Upstream',
Downstream'
Conductivity
1
Grab
Upstream,
Downstream
Dissolved Oxygen
Daily
Grab
Effluent
Dissolved Oxygen
1
Grab
Upstream',
Downstream'
Total Nitrogen NO2 + NO3 + TKN
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Chronic Toxicdy5
Quarterly
Composite
Effluent
Total Zinc6
Quarterly
Composite
Effluent
Total Copper
2/Month
Composite
Effluent
Total Silver
2/Month
Composite
Effluent
Color?
405 ADMI
3(Quarter
Composite
Effluent
Color?
1
Grab
Upstream',
Downstream'
Notes:
1. Sample locations: Upstream - Upstream at NCSR 1964; Downstream - Downstream at NCSR 700. Upstream and
downstream samples shall be grab samples. Stream samples shall be collected three times per week during June,
July, August and September and once per week during the remaining months of the year.
2. The monthly average BOD5 and TSS 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 pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Chronic Toxicity (Ceriodaphnia) P/F at 5.1%. Toxicity testing shall be performed in the months of March, June,
September and December (see Part A.(2.).
6. Sampling for zinc should coincide with sampling for chronic toxicity test.
7. Limit is an instantaneous maximum (i.e. not to be exceeded at any time) not a daily maximum.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO025071
A. (lb) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS- 13.5 MGD
During the period beginning upon a) the last (12) month average flow exceeds 9.0 MGD or b) a letter request for
additional flow based on new industrial flow commitments, and lasting until permit expiration, the Permittee is
authorized to discharge from Outfa11001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENt :.�y `` i
,C �RIGTER S GSr f .. L>.,
F�' `LrY�' LIM 5.
r c nfe� ti
.,' .:..� . �;
xy ��
6� • .
oa��
- TKO . IN QU g'
- �:�,,
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Flow
13.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day 20°C 2
30.0 m
45.0 m
Daily
Composite
Effluent, Influent
Total Suspended Solids2
30.0 m
45.0 m
Daily
Composite
Effluent, Influent
NH3 as N (April 1-October 31 3
12.7 m
Daily
Composite
Effluent
NH3 as N November 1-March 31 3
Meek
Composite
Effluent
PH4
Daily
Grab
Effluent
PH
1
Grab
Upstream',
Downstream'
Fecal Coliform
(geometric mean
200 / 100 ml
400 / 100 ml
Daily
Grab
Effluent
Total Residual Chlorine
28 L
Daily
Grab
Effluent
Temperature °C
Daily
Grab
Effluent
Temperature CC)
1
Grab
Upstream',
Downstream'
Conductivity
1
Grab
Upstream,
Downstream
Dissolved Oxygen
Daily
Grab
Effluent
Dissolved Oxygen
1
Grab
Upstream',
Downstream'
Total Nitrogen NO2 + NO3 + TKN
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Chronic ToxicityS
Quarterly
Composite
Effluent
Total Zinc6
Quarterly
Composite
Effluent
Total Copper
2/Month
Composite
Effluent
Total Silver
2/Month
Composite
Effluent
Color?
300 ADMI
3/Quarter
Composite
Effluent
Color?
1
Grab
Upstream',
Downstream'
Notes:
I. Sample locations: Upstream - Upstream at NCSR 1964; Downstream - Downstream at NCSR 700. Upstream and
downstream samples shall be grab samples. Stream samples shall be collected three times per week during June,
July, August and September and once per week during the remaining months of the year.
2. The monthly average BODs and TSS 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 pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Chronic Toxicity (Ceriodaphnia) P/F at 5.1%. Toxicity testing shall be performed in the months of March. June,
September and December (see Part A.(2.).
6. Sampling for zinc should coincide with sampling for chronic toxicity test.
7. Limit is an instantaneous maximum (i.e. not to be exceeded at any time) not a daily maximum.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO025071
A. (4). COLOR CONDITION
If any color problems are encountered at the City of Danville water treatment plant
due to color discharges from the City of Eden/Mebane Bridge WW'TP, then the
permittee will initiate additional color removal to acceptable levels (back to the
previous color limit of 300 ADMI, if needed) .

LOV
cz,
NCDENR/DWQ FACT SHEET
NPDES PERART MODIFICATION
NPDES No. NC0025071
Facility Information
Applicant/Facility Name:
City of Eden / Mebane Bride Wastewater Treatment Plant
Applicant Address:
308 East Stadium Drive, Eden, North Carolina 27288
Facility Address:
191 Mebane Bridge Road, Eden, North Carolina 27288
Permitted Flow
13.5 MGD (REQUESTING PHASED INTERIM 10 MGD
Type of Waste:
domestic (55%) and industrial 45% with pretreatment program
Facility/Permit Status:
Class IV /Active; Permit Mod
County: 1
Rockingham County
Miscellaneous
Receiving Stream:
Dan River
Regional Office:
Winston-Salem
Stream Classification:
WS-IV
State Grid / USGS Quad:
B20NW/SE Eden,
NC
303 d Listed?
No
Permit Writer:
Tom Belnick
Subbasin:
03-02-03
Date:
May 25, 2005
Drainage Area (mi2):
1701
AOW
Lat. 36°28' 17" N Long. 79° 44' 35" W
Summer 7 10 (cfs)
386
Winter 7Q10 (cfs):
594
30 2(cfs)
Average Flow (cfs):
1970
IWC (%):
5.1% (13.5 MGD)
3.8% (10.0 MGD)
Basis for Permit Modification
The City of Eden's Mebane Bridge WWTP has a pemutted flow of 13.5 MGD and a color limit
(instantaneous maximum) of 300 ADNII. The facility serves the City of Eden (pop. 14,000), the
town of Wentworth (pop. 2700) and three Significant Industrial Users (SIUs). These SILTS are
textile plants — National Textiles, LLC, Santee Company, LLC, and Karastan Rug Mill — and are
regulated through the City's pretreatment program.
Due to the loss of industrial flow, the permittee has requested an interim reduction in permitted
flow down to 10.0 MGD, combined with an increase in the color limit to 405 ADMI, which will
provide some additional buffer for the textile facilities. The requested increase in the color limit
would result in no net increase in color "mass", which would be maintained at 4,050 color units
(i.e., 300 ADMI at 13.5 MGD = 4,050 color units = 405 ADMI at 10.0 MGD). This mass
balance approach is consistent with a 1990 color mass balance model that was used to generate
previous color limits for 7.0 MGD (540 ADNM, 9.0 MGD (430 ADMI), and 13.5 MGD (300
ADMI). Color limits were initially imposed to protect for the City of Danville's water supply
intake located approximately 22 miles downstream in Virginia. Since that time, several textile
facilities discharging to this system have closed.
The Eden facility has maintained compliance with the current color limit, and the discharge has
shown no color impact at the downstream station located approximately 4 miles below the
discharge. Since the same color "mass" will be maintained, and since there is significant dilution
and several color dischargers have left, no color impact is anticipated due to this proposal.
However, the proposed permit modification includes a new Special Condition A.(4), which
would require the facility to reduce color back to previous levels (as needed), should the City of
Fact Sheet
NPDES NC0025071 Modification
Paor I

Danville experience color problems arising from this proposal. No other parameters will be
affected by this proposed modification.
The Eden facility will revert back to its current 13.5 MGD, Effluent Sheet upon reaching 90% of
the permitted interim flow (i.e., 0.9 x 10.0 MGD = 9.0 MGD) based on 12-month average flow,
or by a letter request for such change based on new industrial flow commitments.
PROPOSED SCHEDULE FOR PERMIT MODIFICATION ISSUANCE
Draft Permit Mod to Public Notice:
Permit Mod Scheduled to Issue:
NPDES DIVISION CONTACT
May 25, 2005
July 18, 2005
If you have questions regarding any of the above information or on the attached modification, please
contact Tom Belnick at [phone] ext. 543.
NAME: DATE:
Fact Sheet
NPDES NCO025071 .Modification
Page 2

JUL-06-2005 12:13 THE DAILY NEWS 336 623 2228 P.01i01
I
19be
1921 VANCE STREET P-O. OX 2157 REIDSVILLE, NC 27320 336-349-4331
AFFIDAVIT OF PUBLICATION
Clipping of NORTH CAROLINA
Legal Advertisement ROCKINGHAM COUNTY
Attached Here
Before the undersigned, a Notary Public of Said
County and State, duly commissioned, qualified, and
authorized by law to administer oaths, personally
PUBucNOncE appeared Ellen Ishmael, who being first duly sworn,
STATE OF NORTHCA
ENVIRONMENTAL MANAGEMEROLINA
NT
COMMISSION/NPDES UNIT deposes and says- That she is an official of Nledia
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617 General of Reidsville, Inc. engaged in the publication o
NOTIFICATION OF INTENT TO ISSUE A
NPDES WASTEWATER PERMIT a newspaper Known as The Reidsville Review, pu
On the basis at thorough staff review and appli- lashed, issued and entered as second class mall in the
cation of NC General Statute 143.21, Public law
92-500 and other lawful standards and rcgula - City of Reidsville, in said County and State; that she is
tions, the North Carolina Environmental Man
agoment commission proposes 101550E a Na - authorized to make this affidavit and sworn statement,
tional Pollutant Discharge Elimination System
CNPDES) wastewater discharge permit to the that the notice or other legal advertisement, a true copy
pelson(s) listed below effective 45 days from was ublished in The
the publish date of this notice. of which is attached hereto P
written comments regarding the proposed per Reidsville Review on the following dates:
mill will be accepteduntil 3o days after the pub.
liesh date o1 this notice. All comments received ,,11
prior to that date am considered in the bnal de
rm
tinations repardingg the proposed permit.
The Director of the NC Division of water Quality
may decided to hold a8ublic meeting for the
prop degree o1 public m�eroSt n receive a
Copies of the draft permit and other supporting
information on file used to determine condi. and that the said newspaperf in which such notice paper
tions present in the draft permit are available
upon request and payment of the ,,is of re -
document, or legal advertisement was published, at the
nfor
production. Mail comments and/or requests for
imatlon to the NC DIA5lon of WaterOuality time of each and every such publication, a newspaper
at the above address or call the Point Source
Blanch he NPDES permit nu extension
20. Please
meeting all of the requirements and qualifications o
any communication. Section 1-597 of the General Statutes of North Carolina
NPDES Permit Number NC0025071, City of Eden, and was qualified newspaper within the meaning of
PO Boa 70, Eden, NC 27288 has appliod for
modiycation Off Its Mebane Brldgo WWTP per• Section I-5 7 of the General St tes of North Carolina.
hake Rto iver Basin. The e to action would modn River in ify he
y g I
duced ill cihaha, fe w.
limit for color to reflect are- '.`d
Interested persons mayy also visit the Division of
Wale Quality at 512 N. Salisbury Street, Ra -
lelgh, NC 27604.11aR betwoen the hoursof 8:00
a.m.and 400 p.m. to review information on file.
Sworn to an Subs ribed before me, Ilia
May 27.2005 UQ
day of
� „emlNryq,
�P. p,HMSTq y
• O c
O°
My commission exprires the day gfv
IIr I1 NI NNI•
TOTAL P.01

AdJJr1 C'Vlit01 r�a�
Ja�zto sr��s
z
3% G1oe
1< PROSE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER ^ °'�•^ A�^^^ ^^ ^ ^�^
61FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
JU,�J 2 1 2005
Mr. Tom Belnick
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Draft NPDES Permit Modification
Mebane Bridge WWTP
Permit No. NCO025071
Dear Mr. Belnick
l
J U N 27 2005
L��1
DEItR - WER QUALITY
POINT SOURCE BRANCH
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit modification referenced above and have no comments. We request that we be afforded an
additional review opportunity only if significant changes are made to the draft permit modification
prior to issuance or if significant comments objecting to it are received. Otherwise, please send us
one copy of the final permit when modified.
Sincerely,
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (LIRL) • http://www.epa.gov
Recycled/Recyclable . Pdnted with Vegetable 00 Based Inks on Recycled Paper (Minimum 30% Postconsumer)

COMMONWEALTH of VIRGINIA
DEPARTMENT OF ENVIRONMENTAL QUALITY
W. Tayloe Murphy, Jr. SOUTH CENTRAL REGIONAL OFFICE
Secretary of Natural Resources 7705 Timberlake Road, Lynchburg, Virginia 24502
[phone] Fax [phone]
www.deq.virginia.gov
June 20, 2005
Mr. Tom Belnick
NCDENR — DWQ — NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
m4 -,w o/11 &4,
Robert G. Burnley
Director
Thomas L. Henderson
Regional Director
RE: Comments on Draft Permit Modification — City of Eden / Mebane Bridge Wastewater
Treatment Plant; NPDES Permit NCO025071
Dear Mr. Belnick:
On May 31, 2005, we received your letter and draft permit modification package for the above referenced
facility. Upon review, it was noted that concerns associated with Virginia State Waters, principally the Town
of Danville - Public Water Supply Intake, have been adequately addressed in the proposed permit modification.
Additionally, sufficient permit safeguards appear to be in place to address future growth.
Specifically, DEQ concurs with the "mass" based approach utilized for the subject facility's color
limitation. This approach results in a color limitation of 405 ADMI at 10 MGD. The proposed permit also
contains provisions for a color limitation of 300 ADMI at 13.5 MGD. Lastly, the proposed permit contains a
special condition, A.(4) Color Condition, that requires the treatment plant to initiate additional color removal to
acceptable levels (back to the previous color limit of 300 ADMI, if needed) if any color problems are
encountered at the City of Danville Water Treatment Plant located 22 miles downstream.
Should you have any questions, please do not hesitate to contact me at [phone], ext. 6017 or Kirk
Batsel at [phone] ext. 6004 or by email at kabatsel(aidco.virainia.gov.
JUN 2 4 2005
Sincerely,
Robert P. Goode
Water Permit Manager
cc: B. Dunkley, Director of Water and Wastewater, City of Danville
An Agency of the Natural Resources Secretariat

MA Flow, MO
Z005 3 R a
7. 6 3/s m�
7.I$
00
; 7. -L M(rr
8.i3
0
=8.1 rn
7S1
5,c 7
7 0S
nnnn
3780 70 t4lt
54o iOlYj 1
R70
�•7� -
4oso 13,S
3n
K•l

550
500
450
Q
HO,,
350
300
1990 Color Study Data - Table 3
10 11 12 13
Q in MGD

Re: Eden/Mebane Bridge NC0025071 Rockingham County
vi 91 V
Subject: Re: Eden/Mebane Bridge NC0025071 Rockingham County
From: Steve Tedder <[e-mail]>
Date: Mon, 23 May 2005 13:25:06 -0400
To: Tom Belnick <[e-mail]>
CC: [e-mail], Abner Braddy <[e-mail]>
0. A .1-L//�I
(ebq cJT
We are ok with their request. For the past 12 months they are averaging 7.5 MGD. this is about 55% of
the 13.5 permitted flow. If the permitted flow is reduced to 10.0 MGD then they would be at about 75%
of the permitted 10.0 MGD flow requested. They will need to be aware of the 80% rule but this would
not really come into play until March of 2006.
Steve
On 5/23/2005 12:23 PM, Tom Belnick wrote:
Hi Steve- The City of Eden has requested an NPDES permit mod. They currently have a flow limit of
13.5 MGD and a color limit of 300 ADMI. They are requesting an interim phased flow of 10 MGD
and a color limit of 405 ADMI (all other parameters remain the same), which maintains the same color
"mass" (flow x ADMI= 4,050 color units). There is a color model developed in 1990 which used this
mass balance approach to develop color limits at several flows (7, 9, 13.5 MGD). It sounds like Eden
is seeking some relief for their textile discharger. Instream data does not show any color problem at
the downstream station, and they have been discussing the idea with Virginia (Danville and VaDEQ).
I don't have a problem with their request. Let me know if WSRO is ok with this. Thanks.
1 of 1 5/23/2005 1:42 PM

05/19/2005
S
16:54 3366233933
EDEN WATER FILT
PAGE 01
Public Utilities Department
FAX
TO:
Tom Belnick
FAX NUMBER:
919.733-0719
COMPANY:
NC Divison of Water Quality
DATE:
May 19, 2005
SUBJECT:
Requested Information
PAGES:
1 of 4, including this cover sheet
FROM:
Bever Johnson Public Utilitles Secrets
COMPANY:
City of Eden
Public Utllitles Department
191 Mebane Bridge Road
Eden NC 27233-5346
TELEPHONE:
Voice 336-627-1009 Ext. 302 -- FAX [phone]
E-MAIL:
beverly.johnsonQci.eden.nc.ua
COMMENTS:
The following pages are per Dennis Asbury, Public Utilities Director.
Please direct any questions to his attention at 336--627-1009, Ext, 304.
Thank you!
Beverly Johnson
Public Utilities Secretary

05/19/2005 16:54 3366233933 EDEN WATER FILT PAGE 02
z—O.-Jea
DAMMLLE
UTILITIES
o�...u.r.�..K A M-16..
March 22, 2005
CITY OF DANVILLE, VIRGINIA
Utilities Department
Division of Water & Wastewater Treatment
Mr. Dennis Asbury
Director of Public Utilities
City of Eden
191 Mebane Ridge Road
Eden, NC 27288-6346
Re: Mebane Bridge WWTP Color and Flow Limits
Dear Mr. Asbury:
279 Perk Avenue
Danville. Va. 24541
Tel (434) 788-W:t
Fax (434) 799-%W
have received your letter dated February 9, 2005 requesting support for the City
of Eden's efforts to have Its wastewater treatment plant discharge color limits
modified from 300 ADM[ color units at a flow of 13.5 MGD to 430 ADMI color
units at 9 MGD. I have reviewed the information that you submitted previously,
concerning how the limits were arrived at. It Is understood that the 300 CU limit
was dstablished assuming color discharges from the Martinsville/Henry County,
Virginia area. Currently, there are- no discharges from the Martinsville/Henry
County area with color; therefore, the limit imposed on the Eden wastewater
discharge may not be appropriate,
I believe the City of Danvllle can support the proposed color limit and flow
change as requested provided the following issues are addressed.
nal 1. Criteria are put in place in order that color limits can be equitably established
�pc in the future, as needed, should other future wastewater discharges have
color. These criteria should be applied In both North Carolina and Virginia in
order that there be no unfair competition for solicitation of new industries or
expansion of existing Industries.
2. We would request that the City of Eden provide color testing of the Dan River
�A ' at Danville at no cost to the City of Danville. The City of Danville personnel
would deliver samples to the Eden Wastewater Treatment plant for analysis.
The frequency of the testing will have to be established and may need to be
increased or decreased depending on the results of the testing. Initially, I
anticipate that two samples per week should be collected and -analyzed.
FAjh 3. Any problems encountered with color In the Dan River at Danville will result
Ivilt In the City of Eden initiating additional color removal treatment to lower the -
color In their wastewater treatment plant discharge. As discussed, the color
should be removed to acceptable levels at the wastewater treatment plant,

05/19/2005 16:54 3366233933 EDEN WATER FILT PAGE 03
March 22, 2005
Page Two
3. (Con'd)
not at the water treatment plant. During our previous discussions, all agreed
this would be appropriate.
I would suggest that a meeting be set up for all concemed parties to discuss this
issue further. Particularly, of concern, is to have an agreement between the
North Carolina Department of Environment and Natural Resources and the
Virginia Department of Environmental Quality on how to handle or address new
wastewater industrial discharges, which may have .color in It In the future.
Should you have any questions on the above, please feel free to contact me.
Sincerely,
B T. Dunkley, P. E., irector
Division of Water and Wastewater Treatment
mwk
cc: Jerry Gwaltney, City Manager
Joe King, Assistant City Manager for Utilities
Kirk Batsel, DEQ Lynchburg
Bill Albright, North Carolina DPPEA

05/19/2005 16:54 3366233933 EDEN WATER FILT PAGE 04
Dennis Asbury
Full Name:
Last Name:
FIret Name:
Company:
Business Address:
Business:
Business Fax:
E-mail:
Barry Dunkley
Dunkley
Barry
City of Danville
Danville, VA
[phone] Ext. 222
[phone]
[e-mail]

April 6, 2005
Mr. David Goodrich
Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
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fir.. Alt cK..
APO 1 2 2005
DENR - WATER QUALITY
POINT SOURCE BRANCH
Subject: NPDES Permit NC 0025071
Mebane Bridge WWTP
Rockingham County
On behalf of the City of Eden I hereby request that the subject permit be modified to
include a set of limits on the monthly average flow rate and monthly average discharge
color limit to those of the middle case in Table 3 of the Division of Water Quality's
August, 1990 report, An Update of Color Control Activities in the Smith and Dan River
Basins. This new combination is 9.0 MGD (million gallons per day) and 430 ADMI
(American Dye Manufacturers Institute) color units. This request does not increase the
Mebane Bridge WWTP's permitted total maximum discharge of color to the Dan River.
To protect Eden's infrastructure investment, should a new large industry want to come to
Eden, I also request the permit modification include appropriate language to facilitate a
quick return to the plant's current flow and color limits by a letter request.
This request is being made in an effort to better assist local industries in very competitive
markets while Eden is not using a significant amount of its wastewater plant capacity.
As you are aware, the color of the Dan River is of considerable interest to the City of
Danville, Virginia. We have coordinated this request with Mr. Bang Dunkley, P.E.,
Director, Division of Water and Wastewater Treatment of the City of Danville, and the
City is supportive of our request. Attached is a letter from him confirming their support
and identifying sampling, analyses, and treatment adjustment issues with which we fully
agree.
I concur with and support Mr. Dunkley's comment that the limit imposed on Eden's
wastewater discharge may not be appropriate. I will request assistance from NC DWQ in
setting up a program to thoroughly review this limit.
191 Mebane Bridge Road • Eden, NC 27288-5346 • [phone] • Fax [phone]
JJP

With the assistance of Mr. Dunkley and the NC Division of Pollution Prevention and
Environmental Assistance, this permit modification request has been discussed with the
Virginia Department of Environmental Protection (VA DEP), Lynchburg Regional
Office, which issues the permits for the City of Danville. They have also been supportive
of this modification request, and would like at some point for there to be a formal
exchange between NC DENR and VA DEP to reach agreement on how to handle new
industrial wastewater discharges containing color into the Smith and Dan Rivers. Please
advise me or Bill Albright of DPPEA on when and how you would like this to take place.
Please let me know if you need any additional information, or if we can do anything to
expedite this request, as our industries are under considerable pressure. Thank you for
your assistance in this matter.
Sincerely,
Dennis Asbury
Director of Public Utilities
Attachment
cc: Brad Corcoran, Manager, City of Eden
Jerry Rowland, CEO, National Textiles
—Barry Dunkley, P.E. Director, Danville Division of Water & Wastewater
Steve Tedder, Regional Water Quality Supervisor, NCDENR, DWQ, WSRO
Abner Braddy, Environmental Specialist III, NCDENR, DWQ, WSRO
Bill Albright, Environmental Engineer II, NCDENR, PP&EA
Keyes McGee, Environmental Engineer H, NCDENR, PP&EA
Charles Van Zandt, Superintendent, City of Eden Wastewater Treatment Division
Page 2 of 2

DEn
* .i/
City of Eden
(Pu6Cic V 01ities Department
May 5, 2005
Point Source Branch
Division of Water Quality
NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
Gentlemen:
RE: PERMIT MODIFICATION
NPDES PERMIT NCO025071
MEBANE BRIDGE WWTP
ROCKINGHAM COUNTY
N
fr I(OdL
M AY 1 0 2005
R - WATER QUALITY
POINT T SOURCE BRANCH
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Please find enclosed the City of Eden's Check No. 46829 in the amount of $860.00 to cover the
modification fee for the subject NPDES permit. Also enclosed is a copy of Mr. Dennis Asbury's
April 6, 2005 letter to Mr. David Goodrich of your office requesting the modification.
Please direct any questions you may have to Mr. Asbury's attention at 336-627-1009, Ext. 304.
Sincerely, I
�5 1
Beverly Johnson)
Public Utilities Secretary
Enclosures
c: Dennis Asbury, Public Utilities Director
Charles Van Zandt, Wastewater Treatment Plant Superintendent
191 Mebane Bridge Road * Eden, NC 27288-5346 * [phone] * Fax [phone]