NC0021211_Permit Issuance_20060529

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 29, 2006
Mr. Victor R. Quick
Utilities Director, City of Graham
P.O. Box 357
Graham, North Carolina 27253
Subject: Issuance of NPDES Permit
Permit No. NCO021211
City of 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).
Your comment letter from April 13, 2006 has been addressed and the following modifications
from the draft permit are included in the final permit:
• Total Residual Chlorine - The schedule of compliance was extended to 24 months.
• Priority Pollutant Scan- the intent of the special condition is to require testing on an
annual basis. The permit was not modified regarding the pollutant scan.
• Chronic Toxicity - The schedule included in the permit has not been changed. The City
of Graham has demonstrated compliance with toxicity analysis and has not provided
justification that would grant changing the schedule.
Lead - The limit for lead was eliminated from the permit and monitoring was modified to
monthly. The city has provided information to substantiate that the only detection for
lead in the past three years did not meet adequate QA/QC from the analytical
laboratory. The city has since changed laboratories.
• Nutrient monitoring - Nutrients and oxygen demanding wastes are pollutants of
increasing concern in the Cape Fear Basin. The Division has developed specific
permitting strategies for four sub -basins within the Cape Fear Basin to address
modeling and special studies. The permitting strategy for the Jordan Lake watershed
calls for additional nutrient monitoring and reporting to support the efforts of the
Modeling and TMDL Unit in developing special studies and TMDL projects. Dischargers
in the Jordan Lake watershed will monitor TN three times per week, report nitrogen
species, and report TN and TP as both concentration and mass loads. The permit also
includes a re -opener special condition. In the event that the Environmental
Management Commission adopts a nutrient management strategy or the EPA approves
a TMDL in the coming permit term, the condition allows the Division to re -open affected
permits to set nutrient limits and related conditions accordingly.
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Intemet: h2o.enr state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer- 501Y* Recycled110% Post Consumer Paper
AiieCarolina
ovaturailly
Customer Service
1-877-623-6748

Permit No. NC0021211
City of Graham
Page 2
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 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, please contact Teresa Rodriguez at telephone
number [phone], extension 553.
Sincerely,
�� :Alan W. Klim
Cc: NPDES Files j
Central Files
Fayetteville Regional Office — Surface Water Protection
Aquatic Toxicology Unit
EPA Region 4

Permit NCO021211
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
1204 East Gilbreath St.
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, 2006.
This permit and authorization to discharge shall expire at midnight on May 31, 2011.
Signed this day May 29, 2006.
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO021211
SUPPLEMENT To PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
The City of Graham is hereby authorized to:
1. Continue to operate an existing 3.5
consisting of the following components:
➢
Mechanical bar screen
➢
Grit chambers
➢
Primary clarifiers
➢
Extended aeration basin
➢
Final clarifiers
➢
Aerobic digesters
➢
Chlorination
➢
Sand filters
➢
Post aeration
➢
Lime stabilization unit
MGD wastewater treatment facility
➢ Sludge storage
This facility is located at the Graham Wastewater Treatment Plant on 1204
East Gilbreath St., Graham, 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.

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City of Graham NCO021211
Facility Location
State Grid/Ouad: C21SF/Mebane Latitude: 36' 02' 44" N not to scale
Longitude: 790 22' 06" W
Receiving Stream: Haw River Drainage Basin: Cape Fear River NPDES Permit No. NCO021211
Stream Class: C-NSW Sub -Basin: 03-06-02
North Alamance County

Permit NCO021211
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:
_FFL'UENT x
L yy }/, .' J?....�y1i�+�.=«7pa1h
1�•. l+it�S-(;f'� L7.Y... :ylR.T�F .i1.3 '4. i Y' .'GE'
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xC'1. RGA.�t3.�1�
Flow
3.5 MGD
Continuous
Recording
Influent or Effluent
Total Monthly Flow
Monthly
Recorded or calculated
Influent or Effluent
BOD, 5 day, gh (APO
ril 1 through October 31 2
12.0 mg/L
18.0 mg/L
Daily
Composite
Influent and Effluent
BOD, 5 day, 200C 2
November 1 through March 31
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
4.0 mglL
12.0 mg/L
Daily
Composite
Effluent
NH3 as N
November 1 through March 31
8.0 mg/L
24.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen 3
Daily
Grab
Effluent, 1
Upstream & Downstream
pH 4
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent,
Upstream & Downstream
Fecal Coliform
(geometric mean
200 / 100 ml.
400/100 ml
Daily
Grab
Effluent
Total Residual Chlorines
28 yg/L
Daily
Grab
Effluent
Conductivity
Daily
Grab
Effluent
TKN
3/Week
Composite
Effluent
NO3-N + NO2-N
Week
Composite
Effluent
Total Nitrogen
3/Week
Composite
Effluent
Total Nitrogen Load 6
Monitor & Report (lb/mo)
Monthly
Calculated
Effluent
Total Phosphorus 7
2.0 mg1L
I
I
3/Week
Composite
Effluent
Total Phosphorus Load 6
Monitor & Report (Ib/mo)
Monthly.
Calculated
Effluent
Total Lead
Monthly
Composite
Effluent
Total Mercury
Monthly
Grab
Effluent
Total,Copper
Monthly
Composite
Effluent
Total Zinc
Monthly
Composite
Effluent
Chronic Toxicity 8
Quarterly
Composite
Effluent
EuentPollutant Scan9
Annuals y
Grab/
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 BODS and Total Suspended Solids concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.

Permit NCO021211
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Effluent monitoring and limitation only apply if chlorine or a chlorine derivative is added to the waste stream during
treatment. The limit will take effect July 1, 2008.
6. TN or TP Load is the mass quantity of Total Nitrogen and Total Phosphorus discharged in a given period of time.
See Special Condition A. (5) Calculation of Mass Loads.
7. The quarterly average for total phosphorus shall be the average of composite samples collected weekly during each
calendar quarter.
8. Chronic Toxicity (Ceriodaphnia) limit at 14% with testing in March, June, September and December (see section A.
(3))•
9. See Condition A. (6).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO021211
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, auarterl 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: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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.

Permit NCO021211
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 Section 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-opene
d 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.
A (4). PERMIT RE -OPENER NUTRIENT CONTROLS
The Division may, upon written notification to the Permittee, re -open this Permit in order to incorporate
or modify effluent limitations, monitoring and reporting requirements, and other permit conditions when it
deems such action is necessary to implement nutrient management- requirements such as those established
through rule making or USEPA approval of TMDL(s).
A. (5) CALCULATION OF MASS LOADS
a. The permitte shall calculate monthly and annual TN (or TP) loads as follows:
Monthly TN (or TP) Loads = TN (or TP) x TMF x 8.34
Where:
TN (or TP) = the average Total Nitrogen (or Total Phosphorus) concentration (mg/L) of the
composite samples collected during the month.
TMF = the total monthly flow of wastewater discharged during the month (MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
ii. Annual TN (or TP) Load (lb/yr) = Sum of 12 monthly TN (or TP) Loads for calendar year.
b. The permitte shall report monthly total nitrogen and total phosphorus results (mg/L and lb/mo)
in the appropriate discharge monitoring report for each month and shall report each year's results
(lb/yr) with the December report for that year.

Permit NCO021211
A. (6) EFFLUENT POLLUTANT SCAN
The permittee shall perform an annual Effluent Pollutant Scan for all parameters
listed in the table below (in
accordance with 40 CFR Part 136). The annual effluent pollutant scan samples shall represent seasonal
(summer, winter, fall, spring) variations
over the 5-year permit cycle. Unless otherwise indicated, metals shall
be analyzed as "total recoverable." Additionally, the method detection level and the minimum level shall be
the most sensitive as provided by the appropriate analytical procedure.
Ammonia (as N)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine (total residual, TRC)
1,1-dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether .
Total Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Total Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1.1,2,2-ttrachloroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n-octyl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthracene
Beryllium
1,1,1-trichloroethane
1,2-dichlorobenzene
Cadmium
1,1,2-trichloroethane
1,3-dichlorobenzene
Chromium
Trichloroethylene
1,4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury
P-chloro-m-cresol
Dimethyl phthalate
Nickel
2-chlorophenol *
2,4-dinitrotoluene
Selenium
2,4-dichlorophenol
2,6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydrazine
Thallium
4,6-dinitro-o-cresol
Fluoranthene
Zinc
2,4-dinitrophenol
Fluorene
Cyanide
2-nitrophenol
Hexachlorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile organic compounds:
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroethane
Acrylonitrile
2,426-trichlorophenol
Indeno(1,2,3-cd)pyrene
Benzene
Base -neutral comtounds:-
Isophorone
Bromoform
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlorobenzene
1,1-dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy) methane
Test results shall be reported to the Division in DWQ Form- DMR-PPA1 or in a form approved by the
Director, within 90 days of sampling. A copy of the report shall be submitted to Central Files to the following
address: Division of Water Quality, Water Quality Section, 1617 Mail Service Center, Raleigh, North Carolina
27699-1617.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO21211
Facility Information
Applicant/Facility Name:
City of Graham / Graham WWTP
Applicant Address:
P.O. Box 357, Graham, North Carolina 27253
Facility Address:
1204 East Gilbreath St., Graham, NC 27253
Permitted Flow
3.5 MGD
Type of Waste:
Domestic (93 %) / Industrial (7 %)
Facility/Permit Status:
Class 4 / Renewal
County:
Alamance County
Miscellaneous
Receiving Stream:
Haw River
Regional Office:
Winston-Salem
Stream Classification:
C-NSW
State Grid / USGS Quad:
Mebane / C21SE
303(d) Listed?
No
Permit Writer:
Teresa Rodriguez
Subbasin:
03-06-02
Date:
3/13/06
Drainage Area (mi2):
614
Lat. 360 02' 44" N Long. 79° 22' 06" W
Sumner 7Q10 (cfs)
34
Winter 7Q10
85
Average Flow (cfs):
553
'WC (%):
14
SUMMARY
The City of Graham operates a 3.5 MGD wastewater treatment facility consisting of a
mechanical bar screen, grit chamber, primary settling tanks, extended aeration basin, final
clarifiers, aerobic digester, sand filter, chlorination, and post aeration.
Pre -Treatment — The town has an approved pre-treatment program. The program covers 3 non -
categorical SIUs and 2 CIUs. The permit requires the town to continue to operate its approved
pre-treatment program.
Basin Plan — This segment of the Haw River is supporting aquatic life because of a Good -Fair
benthic community rating, however the turbidity standard was exceeded 7 % at one sampling site
and 10 % at another.
Reasonable Potential Analysis — A reasonable potential analysis was done for cadmium,
chromium, copper, cyanide, lead, mercury, molybdenum, nickel, and zinc. Copper, lead and zinc
showed reasonable potential to exceed water quality standards. A limit of 34 µg/L will be
implemented for lead. Zinc and copper are action level standard parameters, so no limit will be
implemented.
Compliance review — In 2005 the facility had several violations of weekly averages for BOD,
Total Suspended Solids, Fecal Coliform and ammonia.
Fact Sheet
NPDFS NCO021211
Page I

SUMMARY OF PROPOSED CHANGES
• Total chlorine limit — A limit of 28 jtg/L was added to the permit based on the water
quality standard with a schedule of compliance of 18 months after issuance of the permit.
• Ammonia weekly average limit — A weekly average limit of 12 mg/L for the summer and
24 mg/L for the winter season were added to the permit. According to federal rules
permits should include both weekly average and daily maximum limits.
• Lead daily maximum limit - A limit of 34 µg/L was added to the permit based on the
reasonable potential analysis.
• Priority Pollutant Analysis — A special condition to analyze for priority pollutants was
added to the permit. This condition is been added to all municipal facilities above 1 MGD
to collect data necessary for permit renewal.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 15, 2006
Permit Scheduled to Issue: June 1, 2006
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Teresa Rodriguez at [phone] ext. 553.
NAME: DATE: Vllvino
REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
N PDES NCO02 l3I I
Page

REASONABLE POTENTIAL ANALYSIS
Graham WWTP
Outfall 001
NCO021211
Qw = 3.5 MGD
Time Period 2004-2005
Ow (MGD) 3.5
WWTP Class IV
7010S (cfs) 34
iWC (%) 0 7010S 13.76
7010W (cfs) 0
0 701OW WA
3002 (ds) 0
0 3002 WA
Avg. Stream Flow, OA (cfs) 553
0 OA 0.9715
Recldng Stream Haw River
Stream Class C
STANDARDS &
PARAMETER
TYPE
CRITERIA (2)
POL
units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
I11
trcwasr
16FAVI
n rat. MURWOr
Agmabb CW
axadr
Aarr
Acute:
WA
Arsenic
• NC
50
ugfL
0 0
WA
Acute:
WA
- -
Beryllium
C
6.5
uWL
0 0
WA
Acute:
15
Cadmium
NO
2
15
ugfL
8 1
2.4
— —
IL[mftd
Note: nd2
Chronic:
15
-
data set
Acute:
I.=
-
Ctmnium
NO
5o
1,022
uWL
8 1
4.2
— —
Note: n<12—
_
Limited data set
-
Acute:
7
-
Copper
NO
7
AL
7.3
uA
23 23
61.2
Acute:
22
;
Cyanide
NO
5
N
22
10
ugfL
8 1
5.0
9'
Note: na12
Chron�:
36
r `
Limited data set
Acute:
WA
Fluorlde
NO
1,800
UWL
0 0
WA
z,
Chrort�
13.081
� ' _
Acute:
34
Lead
NO
25
N
33.8
uyLJ
8 1
2297.1
Note: nd2—
a.
Limited data set
`
Acute:
WA
Mercury
NO
12
nWL
41 41
51.2820
Acute:
WA
Molybdenum
A
3,500
up+t.
8 8
45.6
Note: n<12
Chrort�
MVALItEI
'
Limited data set
Acute:
261
Nickel
NO
88
261
ugfL
8 1
31.5
— —
Note: n02
640
r
Limited data set
Acute:
WA
Phenols
A
1
N
U01L
0 0
WA
Acute:
56
-
Selenium
NO
5.0
56
uWL
0 0
WA
— -
_
Acute:
1
-
Silver
NO
0.06
AL
1.23
uyl.
0 0
WA
- --
__
— — — — --- — — -- ---
Chtortic:
0
-
Mute:
67
21nc
NO
50
AL
•67
uWL
23 23
477.5_
— — — — — _ _-- -
— — — - --
Chronic
869—
•Legend: •' Freshwater Discharge
C- CarcbrogeMc
NC a Non-carehWeft
A a Aesthe*
RPA Gotham 21211.)ds, rpa
3/10 2006

PERMIT NUMBER: NCO021211
FACILITY NAME: City of Graham - Graham WWTP
PERIOD ENDING MONTH: 12 - 2005 DMR 12 Month Calculated
PAGE 6 OF 7
CITY: Graham COUNTY: Alamance REGION: Winston-Salem
OUTFALL: 001 EFFLUENT
00010
00094
00300
00310
00400
00530
00600
00610
deg c
umhos/cm
mg/1
mg/1
su
mg/l
mg/l
mg/l
Temperature,
Conductivity
DO, Oxygen,
BOD, 5-Day (20
pH
Solids, Total
Nitrogen, Total
Nitrogen,
Water Deg.
Dissolved
Deg. C)
Suspended
(as N)
Ammonia Total
Centigrade
(as N)
24
30
8
1 - 05
10.947368
808.526316
9.731579
7.726316
6.8 - 7.2
8.526316
8
0.163158
24
30
8
2-05
10.6
824.25
9.785
6.125
6.8 - 7.3
1 5.35
6.03
0.0815
24
30
8
3-05
11.454545
751.772727
9.772727
6.781818
7 - 7.3
8.318182
9.11
0.106364
12
30
4
4-05
15.619048
758.714286
8.981905
5.709524
7.2 - 7.4
6.904762
3.55
0.248571
12
30
4
5-05
18.904762
1172.619048
8.638095
4.133333
7 - 7.4
5.380952
8.55
0.026667
12
30
4
6-05
22.727273
922.045455
7.786364
3.468182
6.9 - 7.3
4.863636
8.09
0.108182
12
30
4
7-05
25.5
984.1
7.435
2.6
6.9 - 7.1
2.55
0.097
12
30
4
8-05
25.347826
999.826087
7.408696
2.2
6.3 - 7.3
6.043478
20.05
0.102609
12
30
4
9-05
24.047619
1,105.47619
6.952381
10.038095
6.7 - 7.5
20.857143
16.19
7.864762 Violatio
10 - 05
12
30
4
20.428571
1,025.571429
7.942857
14.057143 Violati
6.9 - 7.6
18.952381
7.76
5.594286 Violatio
24
30
8
11 - 05
16.65
951.25
8.935
4.695
6.7 - 7.1
8.1
11.83
0.361
24
30
8
12-05
11.789474 1
738.473684 19.489474
17.421053
16.8
- 7.1 1
9.421053 1
11.76 10.958421

PERMIT NUMBER: NCO021211
FACILITY NAME: City of Graham - Graham WWTP
PERIOD ENDING MONTH: 12 - 2005 DMR 12 Month Calculated
PAGE 7 OF 7
CITY: Graham COUNTY: Alamance REGION: Winston-Salem
00665
01042
01092
31616
50050
50060
71900
TGP3B
mg/l
ug/1
ug/1
V100ml
mgd
mg/l
ug/l
pass/fail
Phosphorus,
Copper, Total
Zinc, Total (as
Coliform, Fecal
Flow, in
Chlorine, Total
Mercury, Total
P/F STATRE 7Day
Total (as P)
(as Cu)
Zny
MF, M-FC
Broth,99.5C
conduit or thru
treatment plant
Residual
(as Hg)
Chr Ceriodaphnia
3.5
1 - 05
1.4
10
82
16.872852
1.62871
0.311579
3.5
2-05
1.25
21
127
5.835617
1.673214
0.32
3.5
3 - 05
2.12
21
78
11.053592
1.92871
0.260455
6.115
1
3.5
4 - 05
0.871429
17
63
8.127531
1.697
0.370952
3.5
5 - 05
1.433333
24
79
20.388509
1.359677
0.214286
3.5
6 - 05
2.64
26
98
27.585152
1.292
0.172727
1
3.5
7 - 05
4.325
32
78
11.812117
1.27129
0.171
3.5
8 - 05
4.8
36
67
24.926004
1.240323
0.120435
3.5
9 - 05
1.214286
26
74
105.803697
1.16
0.129048
1
3.5
10-05
1.283333
9
97
369.752484
1.226452
0.248095
3.5
11 - 05
1.5625
17
115
31.05141
1.25
0.3065
3.5
12-05
1.585714
1 23
191
139.224661
11.665484
1 0.394737
1

PERMIT NUMBER: NCO021211 PERIOD ENDING MONTH: 12 - 2004 DMR 12 Month Calculated
FACILITY NAME: City of Graham - Graham WWTP
PAGE 6 OF 7
CITY: Graham COUNTY: Alamance REGION: Winston-Salem
OUTFALL: Q01 EFFLUENT
00010
00094
00300
00310
00400
00530
00600
00610
deg c
umhos/cm
mg/1
mg/1
su
mg/1
mg/l
mg/l
Temperature,
Water Deg.
Conductivity
DO, Oxygen,
Dissolved
BOD, 5-Day (20
Deg. C)
pH
Solids, Total
Suspended
Nitrogen, Total
(as N)
Nitrogen,
Ammonia Total
(as N)
Centigrade
24
30
8
1 - 04
10.2
1,013.6
10.31
5.285
6.6 - 7.1
7
14.18
0.2425
24
30
8
2-04
10.15
949.85
10.075
9.99
6.7 - 7.1
10.35
15.5
0.182
24
30
8
3-04
13.217391
920.086957
9.578261
4.373913
6.2 - 7.6
7.913043
9
0.058696
12
30
4
4-04
16.181818
876.619048
9.085714
4.52381
7.1 - 7.5
5.904762
8.1
0.2
12
30
4
5-04
21.3
905.45
8.295
5.75
6.9 - 7.8
6.1
7.9
0.0055
12
30
4
6-04
23.272727
903.181818
7.795455
6.227273
6.5 - 7.4
4.181818
7.7
0.206818
12
30
4
7 - 04
24.904762
870.090909
7.72381
9
7.1 - 7.4
3.571429
8.5
0.071905
12
30
4
8-04
24.136364
887.181818
7.595455
2.954545
7.2 - 7.4
4.318182
8.5
0.254545
12
30
4
9-04
22.619048
777.047619
7.971429
3.528571
7 - 7.4
3.333333
6.9
0.154286
12
30
4
10-04
19.47619
907:428571
8.242857
4.47619
6.8 - 7.2
4.190476
13.9
0.157619
24
30
8
11 - 04
16.45
914.55
8.805
4.265
6.8 - 7.1
5.3
15.5
0.0335
24
30
8
12-04
11.7 1
799 19.34
16.64
16.6 - 7.5
1 8.1
1 10
10.098

PERMIT NUMBER: NCO021211 PERIOD ENDING MONTH: 12 - 2004 DMR 12 Month Calculated
FACILITY NAME: City of Graham - Graham WWTP PAGE 7 OF 7
CITY: Graham COUNTY: Alamance REGION: Winston-Salem
00665
01042
01092
31616
50050
50060
71900
TGP3B
mg/l
ug/l
ug/1
V100ml
mgd
mg/l
ug/l
pass/fail
Phosphorus,
Total (as P)
Copper, Total
(as Cu)
Zinc, Total (as
Zn)
Coliform, Fecal
MF, M-FC
Flow, in
conduit or thru
Chlorine, Total
Residual
Mercury, Total
(as Hg)
P/F STATRE 7Day
Chr Ceriodaphnia
Broth,44.5C
treatment plant
3.5
1 - 04
1.7
21
84
3.406007
1.432258
0.298
3.5
2-04
2.425
29
120
9.985171
1.788621
0.3495
3.5
3-04
1.65
36
120
8.840027
1.623871
0.398261
1
3.5
4-04
1.92
22
94
7.358282
1.559333
3.5
5-04
2.78
32
250
39.849967
1.313871
0.308
9.95
3.5
6-04
1.128571
38
190
15.971716
1.426333
0.208636
3.86
1
3.5
7 - 04
1.566667
19
68
12.747908
1.441613
0.204286
3.5
8 - 04
1.625
22
66
21.006588
1.611613
0.231364
3.5
9-04
1.55
13
50
14.878234
1.812
0.414286
4.86
1
3.5
10 - 04
1.542857
21
44
19.051181
1.371613
0.422857
3.5
11 - 04
2.04
31
80
14.153707
1.616
0.3445
3.5
12 - 04
1.616667
16
65
4.669466
1.647742
0.3745
1
*..

MONITORING REPORT(MR) VIOLATIONS for:
ReportDate: 0310106
Page: 1 of
Permit:
ncU021211
MRs Between: 12-2004
and 12-2005
Region: %
Violation
Category: %
Program Category: NPDWES W
Facility Name: %
Param Name: %
County: %
Subbasin: %
Violation Action:
PERMIT: NCO021211
FACILITY: City of Graham - Graham WWTP
COUNTY: Alamance
REGION: Winston-Salem
Limit Violation
MONITORING OUTFALL
VIOLATION
UNIT OF
CALCULATED
REPORT
/ PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
VIOLATION TYPE
VIOLATION ACTION
09 - 2005
001
Effluent
BOD, 5-Day (20 Deg. C)
09/26/05
5 X week
mgll
18
27.8
Weekly Average Exceeded
Proceed to NOV
10 - 2005
001
Effluent
BOD, 5-Day (20 Deg. C)
10101/05
5 X week
mg/I
18
27.86
Weekly Average Exceeded
Proceed to NOV
10 - 2005
001
Effluent
BOD, 5-Day (20 Deg. C)
10/08/05
5 X week
mg/I
18
38.06
Weekly Average Exceeded
Proceed to NOV
10 - 2005
001
Effluent
BOD, 5-Day (20 Deg. C)
10/31/05
5 X week
mg/I
12
14.06
Monthly Average Exceeded
Proceed to NOV
09 - 2005
001
Effluent
Colifonn, Fecal MF, M-FC
09/26/05
5 X week
0/100ml
400
8.723
Weekly Geometric Mean
proceed to NOV
Broth,44.5C
Exceeded
10
001
Effluent
Coliform, Fecal MF, M-FC
10/01/05
5 X week
#/100ml
400
8,723.32
Weekly Geometric Mean
Proceed to NOV
-2005
Broth,44.5C
Exceeded
10 2005
001
Effluent
Colifonn, Fecal MF, M-FC
10/08/05
5 X week
#/100ml
400
42.645.87
Weekly Geometric Mean
Proceed to NOV
-
Broth,44.5C
Exceeded
10 2005
001
Effluent
Coliform, Fecal MF, M-FC
10/31/05
5 X week
#/100ml
200
369.75
Monthly Geometric Mean
Proceed to NOV
-
Broth,44.5C
Exceeded
12 - 2005
001
Effluent
Coliform, Feral MF, M-FC
12/03/05
5 X week
#/100ml
400
424.53
Weekly Geometric Mean
Proceed to NOV
Broth,44.5C
Exceeded
09 - 2005
001
Effluent
DO, Oxygen, Dissolved
09130/05
5 X week
mg/I
5
4.7
Daily Minimum Not Reached
Proceed to NOV
09 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
09/26/05
5 X week
mg/I
12
21
Weekly Average Exceeded
Proceed to NOV
09 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
09/30/05
5 X week
mg/I
4
7.86
Monthly Average Exceeded
I
Proceed to NOV i
10 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
10/01/05
5 X week
mg/I
12
21
Weekly Average Exceeded
Proceed to NOV
10 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
10/08/05
5 X week
mgll
12
15.34
Weekly Average Exceeded
Proceed to NOV
10 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
10/31/05
5 X week
mgll
4
5.59
Monthly Average Exceeded
Proceed to NOV
09 -2005
001
Effluent
Phosphorus, Total (as P)
09/30105
Weekly
mg/I
2
2.43
Quarterly Average Exceeded
Proceed to NOV
09 - 2005
001
Effluent
Solids, Total Suspended
09/26/05
5 X week
mg/I
45
65.2
Weekly Average Exceeded
Proceed to NOV

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 03/10/05 Page: 2 of 3
Permit: nc0021211 MRs Between: 12-2004 and 12-2005
Region: %
Violation Category: /
Program Category: NPDES `PAV
Facility Name: % Param Name: %
County:%
Subbasin: %
Violation Action: %
PERMIT: NCO021211
FACILITY: City of Graham - Graham WWTP
COUNTY: Alamance
REGION:
Winston-Salem
Limit Violation
MONITORING
OUTFALL
VIOLATION
UNIT OF
CALCULATED
\
REPORT
/PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
VIOLATION TYPE
VIOLATION ACTION
10 - 2005
001
Effluent
Solids, Total Suspended
10/01/05
5 X week
mgA
45 65.2
Weekly Average Exceeded
Proceed to NOV
\\\
/
10 - 2005
001
Effluent
Solids, Total Suspended
10/08/05
5 X week
mg/I
45 52.2
Weekly Average Exceeded
Proceed to NOV
Monitoring Violation
MONITORING
OUTFALL
VIOLATION
UNIT OF
CALCULATED
REPORT
/PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
VIOLATION TYPE
VIOLATION ACTION
01 - 2005
001
Effluent
SOD, 5-Day (20 Deg. C)
01/08/05
5 X week
mgA
Frequency Violation
None
09 - 2005
001
Effluent
BOD, 5-Day (20 Deg. C)
09/10/05
5 X week
mg/I
Frequency Violation
None
01 - 2005
001
Effluent
Chlorine, Total Residual
01/08/05
5 X week
mgA
Frequency Violation
None
09 -2005
001
Effluent
Chlorine, Total Residual
09/10/05
5 X week
mg/I
Frequency Violation
None
01 - 2005
001
Effluent
Coliform, Fecal ME, M-FC
01/08/05
5 X week
#/tooml
Frequency Violation
None
Bmth,44.5C
09 -2005
001
Effluent
Coliform, Fecal ME, M-FC
09/10/05
5 X week
#/loom]
Frequency Violation
None
Broth,44.5C
01-2005
001
Effluent
Conductivity
01/08/05
5Xweek
umhos/cm
Frequency Violation
None
09-2005
001
Effluent
Conductivity
09/10/05
5Xweek
umhos/cm
Frequency Violation
None
01 - 2005
001
Effluent
DO, Oxygen, Dissolved
01/08/05
5 X week
mgA
Frequency Vlolation
None
09-2005
001
Effluent
DO, Oxygen, Dissolved
09/10/05
5 Xweek
mgA
Frequency Violation
None
01 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
01/08/05
5 X week
mg/I
Frequency Violation
None
09 - 2005
001
Effluent
Nitrogen, Ammonia Total (as N)
09/10/05
5 X week
mg/I
Frequency Violation
None
07-2005
001
Effluent
Nitrogen, Total (as N)
07/31/05
Monthly
mgA
Frequency Violation
None
01 - 2005
001
Effluent
Solids, Total Suspended
01/08/05
5 X week
mg/I
Frequency \flotation
None

MONITORING REPORT(MR) VIOLATIONS for:
ReportDate: 03/10/06 Page: 3 of 3
Permit: nc0021211
MRs Between: 12-2004
and 12-2005
Region: %
Violation Category: %
Program Category: NPDES WW
Facility Name: %
Param Name: %
County: %
Subbasib: %
Violation Action: %
PERMIT: NCO021211
FACILITY: City of Graham - Graham WWTP
COUNTY: Alamance
REGION: Winston-Salem
Monitoring Violation
MONITORING OUTFALL
VIOLATION
UNIT OF
CALCULATED
REPORT /PPI LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
VIOLATION TYPE VIOLATION ACTION
09 - 2005 001 Effluent
Solids, Total Suspended
09/10/05
5 X week
mg/I
Frequency Violation None
01 - 2005 001 Effluent
Temperature, Water Deg.
01/08/05
5 X week
deg c
Frequency Violation None
Centigrade
09 - 2005 001 Effluent
Temperature, Water Deg.
09/10/05
5 X week
deg c
Frequency Violation None
Centigrade
01 - 2005 001 Effluent
pH
01/08/05
5 X week
su
Frequency Violation None
09 - 2005 001 Effluent
pH
09/10/05
5 X week
su
Frequency Violation None

a
Re: NCO021211
Subject: Re: NCO021211
From: [e-mail]
Date: Tue, 23 May 2006 08:40:02 -0400
To: Teresa Rodriguez <[e-mail]
thanks for sending - am ok with the changes.
of 1 5/25/2006 8:10 AM

AFFIDAVIT OF PUBLICATION
State of North Carolina
County of Durham
Jennifer Lloyd being duly sworn says that she is the Principal Clerk of
The Durham Herald Co., Inc., publishers of The Herald -Sun a newspaper
published in And of general circulation in said County, and that a notice of
which the annexed is a True copy, was published in said newspaper one
time on the 21", day of March, 2006.
Sworn to and subscribed before me this 21A day of March, 2006.
Notary Public
My Commission Expires I Tj �C
Durham County, North Carolina
`,k�niu1ir1
�,%� ON
q(4,JOE
I�
Zi
b
A NI
the proposes
aye after the
permit and other suppoi
used to determine: co
t p rhlt are available- ui
t of the coat of repro
tlor requests for Infamu
Water Ouaij at the at,
pint Source ranch at (9
0. Please nCh de the
achedY in. any common
2 NY e DM
lists rya Street, eet, F
wean the Fours of 8:0
aw information on file.
m, NPDES pannR NCO
ging to the Haw RNer
Of
Cape Feor River Basin. Som
Basin -
water g0elity limited, which r
cations in this Portion If the
sin.
H-S; March 21, 2006
iR
A HR I, 10D6
OI"L QF V%"„ L:-R QUALITY
SUB ET OFFICE

Cfity of ( a4am
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
Teresa Rodriguez
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh NC 27699-1617
Subject: Permit Renewal
No. NCO021211
Dear Ms. Rodriguez
APA 2 1 20Oo �-
April 13, 2006
The City of Graham has received and reviewed our draft permit renew-
al. The City desires to make the following concerns/ comments to you for
review before issuing the final product.
1. Total Residue Chlorine limit. The City requests that the 28 microgram
limit for chlorine become effective 24 months from the permit date
issuance. The additional time is requested for budgetary, engineering,
and construction purposes.
2. Priority Pollutant Scan. The draft permit spells out the seasonal
representation of the requirements with an annual analysis. I believe
the intent is for four samples over the five year permit cycle. Please
clarify in the final version the number of required samples to be
performed during this five year period.
3. Chronic Toxicity. The permit spells out March, June, September, and
December as the required months for sampling. If possible, the City
would like to change this to a quarterly requirement with no specific
month named. As an alternative, the second month of each quarter
which would be February, May, August, and November would be
preferred. The City desires this change to allow additional time with
either sampling or laboratory problems encountered, to still complete
the requirement in the quarter. Our commercial lab has indicated that
the proposed changes would be acceptable to them.
4. Lead, weekly testing with limit. The City of Graham believes that the
Reasonable Potential Analysis used to recommend the weekly testing
and 34 ug/I limits should be performed again without using the May
21, 2004 data. The lead result was 130 micrograms on our effluent

per Pace Analytical Services, Inc. This sample was collected as part of
our headworks analysis, based on flow thru rates. The influent result
was 64 micrograms per liter thereby making the effluent result
somewhat suspicious. Excluding that lone number, the City has 218
analyses of effluent lead performed since January 1993. The highest
result of the other 217 samples is 25 ug/L on 7/6/1993. We have not
had an effluent lead result higher than < 10 ug/L since 1/1/2000. In
fact, the highest influent lead result for the period is less than half
that result at 64 micrograms per liter. The May, 2004 sample
analyses were performed at Pace Lab's Asheville location and are the
only results we received from there. Pace Lab's Asheville location was
inspected by the QA/QC committee of the Upper Cape Fear River
Basin Association. The committee became very concerned about the
accuracy of results of Haw River sampling events. Numerous errors
were detected by the committee and the UCFRBA ended the contract.
Additionally, other metal results from that sample appear to be higher
than normal for the City of Graham. I am attaching lead data results
for the period of 1993-2005. Therefore the City of Graham requests
that lead be removed from this permit.
The City of Graham's comments and requests are made to improve the
final NPDES Permit. If you need any additional information or data to make
these important changes for the City, please call me at 336.570.6721.
Sincerely,
David W. Lawson, ORC, City of Graham
CC: Chris Rollins, City Manager, City of Graham
Victor Quick, Utilities Director, City of Graham
Scott Pickard, Pretreatment Coordinator, City of Graham
Attachments: Lead Data Summary 1993-1999
Lead Data Summary 2000-2005
Letter dated March 30, 2004 to Pace

It
k
YEAR
1993
1994
1995
1996
1997
1998
1999
CITY OF GRAHAM
WASTEWATER TREATMENT PLANT
EFFLUENT LEAD RESULTS
1993 THRU 1999
HIGHEST
LOWEST
NUMBER OF
EFFLUENT
EFFLUENT
SAMPLES
RESULT
RESULT
58
20.1 ug/L
6.25 ug/L
52
23.4 ug/L
3.4 ug/L
52
24.1 ug/L
10.0 ug/L
12
6.3 ug/L
1.8 ug/L
4
7.7 ug/L
2.4 ug/L
4
13.0 ug/L
2.1 ug/L
4
21.0 ug/L
6.6 ug/L
186
Prepared by David Lawson 04/13/2006
Page 1

SAMPLES
9nnn
CITY OF GRAHAM
WASTEWATER TREATMENT PLANT
LEAD DATA FROM JANUARY 2000
STORET CODE 01051
INF. RESULT EFF. RESULT MDL METHOD
ug/L ug/L ug/L USED
LABORATORY
USED
MARCH
11.0
7.4
0.2
EPA200.8
BURLINGTON RESEARCH
MAY
23.0
6.7
0.2
EPA200.8
BURLINGTON RESEARCH
AUGUST
45.0
4.9
0.2
EPA200.8
BURLINGTON RESEARCH
DECEMBER
20.0
5.8
0.2
EPA200.8
BURLINGTON RESEARCH
2001
MARCH
10.0
2.5
0.2
EPA200.8
SIMILABS
JUNE
30.0
2.6
0.2
EPA200.8
SIMILABS
SEPTEMBER
7.9
2.5
0.2
EPA200.8
SIMILABS
NOVEMBER
11.0
1.9
0.2
EPA200.8
SIMILABS
2002
MARCH
22.0
8.4
0.2
EPA200.8
SIMILABS
APRIL
58.0
3.9
0.5
EPA200.8
SIMILABS
MAY
41.0
2.7
0.5
EPA200.8
SIMILABS
JUNE
20.0
3.5
0.5
EPA200.8
SIMILABS
JULY
19.0
2.3
2.0
EPA200.8
SIMILABS
AUGUST
64.0
2.4
0.5
EPA200.8
SIMILABS
SEPTEMBER
31.0
3.7
2.0
EPA200.8
SIMILABS
OCTOBER
21.0
<10
10.0
EPA200.7
SIMILABS
NOVEMBER
29.0
<10
10.0
EPA200.7
SIMILABS
DECEMBER
30.0
<10
10.0
EPA200.7
SIMILABS
2003
JANUARY
30.0
<10
10.0
EPA200.7
SIMILABS
FEBRUARY
<10
<10
10.0
EPA200.7
SIMILABS
MARCH
18.0
<10
10.0
EPA200.7
SIMILABS
JUNE
24.0
<10
10.0
EPA200.7
SIMILABS
JULY
18.0
<10
10.0
EPA200.7
SIMILABS
OCTOBER
33.0
<10
10.0
EPA200.7
SIMILABS
2004
JANUARY
18.0
<5
5.0
EPA200.7
PACE
MAY
64.0
130.0
5.0
EPA200.7
PACE
AUGUST
41.0
<10
10.0
EPA200.7
MERITECH
NOVEMBER
19.0
<10
10.0
EPA200.7
MERITECH
2005
MARCH
25.0
<10
10.0
EPA200.7
MERITECH
MAY
10.0
<10
10.0
EPA200.7
MERITECH
JULY
15.0
<10
10.0
EPA200.7
MERITECH
NOVEMBER
29.0
<10
10.0
EPA200.7
MERITECH
Prepared by David Lawson 03/28/2006 Page 1

March 30,2004
Mr. Jeff Graham
General Manager
Pace Analytical Services, Inc
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Dear Mr. Graham:
The Upper Cape Fear River Basin Association is -concerned about the changes that have
resulted from the. PACE buyout of SimaLabs in Burlington. These
concerns are outlined
with the hope that they can be resolved My and efficiently.-
• At the January 7b2004 meeting in Burlington, PACE lead the UCFRBA' to
believe that they could handle our work, i.e. they have three shifts -working around
the clock to provide high quality data quickly. However, the Yadkin Basin River
Basin Association left PACE three years ago because the quality of work was
very poor and it would appear that many of these, same problems still exist.
• The -January 22-23 2004 audit of the PACE Ashville Lab added to the level of
our concern because of the followina issues.
o All problems found were just 'exceptions'.
'0 The lack of senior lab personal and a low pay level making it difficult to
retain quality people-
o No one is checking to see that the data meets all the State and EPA
Method QA/QC ten requirements;of blanks,`cvc.'s every
curves, running
samples, etc.
o- Write-ups from the two. previous State inspections were each seven pages
long.
o The conflictina, views between Charlie Billings and Barry John]Son on
whether analysts use SOPs.
Io The lack of response time from the Asheville lab. Phone calls are not
returned and emails are not acknowledged.
o The idea that our data was going to be treated special All clients should
be treated* with ' the same commitment to quality.
0 In some nutrient -analyses, PACE is incorrectly correctly using- multiple curves run
ZIP
on different days to pick good data points to* meet.QA/QC. -

o No notes were taken by PACE personal at the meeting about the problems
we found giving the impression that they were not serious about the
problems.
• The March 02004 January data review confirmed our concerns. Many of the
issues discussed at the Ashville lab audit in January were not addressed.
o TILT data was higher then ammonia data and_multiple.curves were still
being -used in the. nutrient data. This data may have to be invalidated.
o Metals samples were being over diluted.
o Rounding errors and tppos: weiz-to iiirl.
o Final numbers -.on the benchsheets didn't match the final spreadsheet.
o Samples dates were incorrect on run sheet.
o It is March 26 b and we still have not heard any feedback on our Jan
uary
data which was reviewed. on March 4t'.
The bottom line is that PACE NC does not appear to conduct their business at, the high
quality level we expect. There seems to be a mentality of `just get the nunibers ' out' to
meet deadlines and. regulations and -not a focus on the quality of the work being done.
We have serious concerns about continuing :business with PACE. We. would like you to
address each of these concerns in writing --and at our Board Meeting on April 7h in
Mebane, if you can.
Please call me, [phone], if you have any questions.
Sincerely, _
Stephen Shoaf,
Upper Cape Fear River Basin Association, Chairman
Cc: John Sledge, Pace :Analytical
Barry Johnson, PACE Analytical
Charlie Billings, PACE Analytical
Lauren Elmore, DWQ
QA/QC Subcommittee

o No notes were taken by PACE personal at the .meeting about the problems
we found giving the impression that they were not serious about :the -
problems.
• The March 4a' 2404 January data review confirmed our concerns. Man of
issues -discussed at the Ashville lab audit in January were not addressed. the
o TKN data was higher then ammonia data and multiple.curves were still
being ,used .in the nutrient data.: This data may have to be invalidated.
o -Metals sabiples were being ove�'dffuted. .
-o Rounding errors 'and typos weiz found.
o Final numbers :on the benchsheets didn't match the final spreadsheet-
0 Samples dates Were incorrect. -on run sheet.
o It is March 26 b and we still have-not heard any: feedback on our Jan
-data which -was reviewed. on March 4t'. �Y
The bottom line is that'PACE NC does not appear to -conduct their -business at the high
quality level we expect. There seems .to be a rrientalitYof `just et the-nui ibers'-
g out' to
meet deadlines .and regulations - and .not a focus .on the quality of .the work being -done.
We have serous concerns about conti]gO4.-business with PACE.. W.e woulflike you to
address each of these concerns in writing `and -at our Board..Meetin .. on April .7''. in
Mebane, if you can.
Please call me,. [phone], if .you have any questions.
Sincerely,
-Stephen Shoaf,
:Upper Cape Fear River Basin Association, Chairman
: Cc: John :Sledge} PaceAnalytical
Barry Johnson, PACE -Analytical
Charlie Billings, PACE knalytical
Lauren.Elmore.) DWQ
QA/QC Subcommittee

ED ST,tTFS
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
m .W REGION 4
i r ATLANTA FEDERAL CENTER
;Fro 10 61 FORSYTH STREET
l,( PROSEO ATLANTA, GEORGIA 30303-8960
MAR 2 9 2006
Ms. Teresa Rodriguez
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUB7: Draft NPDES Permit
City of Graham WWTP - NPDES No. NCO021211
Dear Ms. Rodriguez:
D
APO 4 �
I)FNR - WATER QUALITY
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit 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 prior to issuance, or if
significant comments objecting to the draft permit are received. Otherwise, please send us one
copy of the final permit when issued.
If you have any questions, please call me at [phone].
Sincerely,
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Pdnted with Vegetable 08 Based Inks on Recycled Paper (Minimum 30 % Posiconsumer)

cc: Charles Weaver, NPDES Unit
Central Files
WSRO
SOC PRIORITY PROJECT: Yes
If Yes, SOC No.
To: Permits and Engineering Unit.
Surface Water Protection Section
Attention: Teresa Rodriauez
Date: November 3, 2005
NPDES STAFF REPORT AND RECOMMENDATION
Alamance County
Permit No. NC0021211
PART I - GENERAL
1. Facility and Address:
City of Graham WWTP
1204 East Gilbreath Street
Burlington, NC 27215
2. Date of Investigation: October 26, 2005
No X
3. Report Prepared by: Jenny Freeman
4. Persons Contacted and Telephone Number: David Lawson, ORC
Phone [phone]
5. Directions to Site: From I-40, take NC-54 East. Turn right
onto Woody Drive. Turn left onto E. Gilbreath Street. The
entrance will be on the left.
6. Discharge Point(s), List for all discharge points:
Latitude: 36 02' 44" Longitude:79 22' 06"
U.S.G.S. Quad No. C21SE U.S.G.S. Quad Name Mebane
7. Site size and expansion area consistent with application?
X Yes No If No, explain:
8. Topography (relationship to flood plain included):
Located adjacent to a tributary that has flooded part of
plant on occasion. The plant is approximately 1500 feet

from Haw River.
9. Location of nearest dwelling: >1000 feet
10. Receiving stream,or affected surface waters: Haw River
a. Classification: C-NSW
b. River Basin and Subbasin No.: 03-06-02
C. Describe receiving stream features and pertinent
downstream uses: Residential/Commercial
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT'WORKS
1.
2.
a. Volume of Wastewater to be permitted: 3.5 MGD
b. What is the current permitted capacity of the Waste
Water Treatment facility? 3.5 MGD
C. Actual treatment capacity of the current facility?
3.5 MGD
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years. N/A
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities: Bar screen, grit chamber, primary
clarifiers, aeration basins, nitrification, final
clarifiers, tertiary sand filters, chlorination, post
aeration, and sludge digesters and storage.
f. Please provide a description of proposed wastewater
treatment facilities. N/A
g. Possible toxic impacts to surface waters: N/A
h. Pretreatment Program (POTWs only): N/A
in development approved X
should be required not needed
Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM
Permit No. WQ0003824
Residuals Contractor: None, land application site is
dedicated city -owned land. City is responsible for
land application.

NPDES Permit Staff Report
Telephone No. [phone]
b. Residuals stabilization: PSRP X PFRP
Other
C. Landfill:
d. Other disposal/utilization scheme:
3. Treatment plant classification (attach completed rating
sheet) . Class IV
4. SIC Code(s): 4952
Primary: 01 (Domestic) Secondary: 02 (Industry)
Main Treatment Unit Code: 1 1 1 X 3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?
N/A
2. Special monitoring or limitations (including toxicity)
requests: N/A
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate) N/A
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation: N/A
Connection to Regional Sewer System: N/A
Subsurface: N/A
Other disposal options: N/A
5. Other Special Items:

NPDES Permit Staff Report
PART IV - EVALUATION AND RECOMMENDATIONS
The City of Graham has applied for renewal of NPDES Permit No.
NC0021211, which covers the Graham WWTP. During the last
inspection on November 22, 2004, no major problems were noted
with operation and/or maintenance.
WSRO recommends reissuance of this permit in accordance with
Division policy.
Regional staff
Regional Supervisor
(I /OY:
Date
Date

NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form
INPDES OR NONDISCHARGE PERMITTING UNIT COMPLETES THIS PART:
Date of Request 2/9/2006
Facility
City of Graham
Permit #
NCO021211
Region
W S
Requestor
Teresa Rodriguez
Pretreatment A-F Towns- Dana Folley (ext. 523)
Contact G-M Towns- Jon Risgaard (ext. 580)
N-Z Towns- Deborah Gore (ext. 593)
MENTS TO PRETREATMENT UNIT:
PRETREATMENT UNIT COMPLETES THIS PART:
Status of Pretreatment Program (circle all that apply)
3) the facility has (or is developing) a Pretreatment Program
3a) is Full Program with LTMP
Flow
Permitted MGD Actual MGD STMP time frame:
Industrial
0.3868 0.2004 most recent
Domestic
next cycle
Pollutant
L
Check List
POC due to
(s)
NPDES/Non-
STMP
LTMP
T
Discharge
Required
Required by
Frequency at
Frequency at
MP
Permit Limit
by EPA'
503 Sludge"
POC due to SIU"
Sitespecific POC (Provide Explanation)""
effluent
effluent
BOD
X
Q
TSS
X
Q
NH3
X
Q
Arsenic
X
Q
Cadmium
X
Q
Chromium
X
Q
Copper
X
Q
Cyanide
Q
Lead -
X
Q
Mercury
X
Q
Molybdenum
X
Q
Nickel
X
Q
Silver
Q
Selenium
X
Q
4.zinc-
X
Q
Total Phosphorus
X
Q
'Always in the LTMP all LTMP/STMP effluent data
"Only in the LTMP if the POTW land applies sludge
Only in LTMP while the SlU is connected to the POTW on DMRs?
"' Only in LTMP when the
pollutant is a specific concern to the POTW (ex -Chlorides for a POTW who accepts Textile waste) Yes
O= Ouartedy
M=Monthly
NO
(attach data)
Comments:
Monitorng frequecy increases to 1/month the year before the HWA available in spreadsheet?
is due. Next HWA is due 9/2008. Have requested electronic Yes
No
copy of data from PT coordinator.
version 10/8/03
NPDES_Pretreatment.request.form21211.xls
Revised: August 4, 2000

r
PERMIT
OWNER
FACILITY
COUNTY
CASE#
AssessDato
PENA T
PAD
CASE_
NCO0212 1
Cityo raham
GrahamWA
amance
- 5
00
8 0
NCONCO0212 1
Gi o ra am
raham P
amance
0
8 0
02
it o Graham
Graham P
amance
LV-20 0-0 5
0
$ 1,31 .00
1,064.00
O
City of Graham
I Graham WWTP
jAlamance
I LV-20 - 0
1
4.00
689.00
5
NCO021211
I Cityof raham
I Graham WWTP
jAlamance
I LV-20 -00
2
$ 1,064-00
. 0
5 2
Facility is compliant. Some older [early 2000] phosphorus violations.
Would not recommend any specific permit actions.
;ED

Tity of (6ra4am
P. O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
November 22, 2005
Mrs. Carolyn Bryant
NCDENR 1 DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Renewal for NPDES Permit No.NC0021211
City of Graham, Alamance County
Dear Mrs. Bryant:
The City of Graham request renewal for NPDES permit No. NCO021211 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. One signed original and two copies of the narrative description of the Sludge
Management Plan.
Please contact me at 336.570.6721 if you have any questions or need additional
information.
Sincerely,
n
Victor R. Quick
Utilities Director
Cc: Chris Rollins, Manager, City of Graham
David Lawson, Supervisor, City of Graham WWTP

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
City of Graham, NCO021211
RENEWAL
CAPE FEAR
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES
All treatmentworks receiving discharges from significant Industrial users orwhich receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.I. Pretreatment program. Does the treatment works have, or is subject ot, an approved pretreatment program?
® Yes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs. /3 )
b. Number of CIUs.
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: CULP WEAVING
Mailing Address: P.O. BOX 117
GRAHAM, NC 27253
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
WOVEN TEXTILE WASTE, TASLIN WEAVING OCPSF 414 (PIPE 03 ONLY)
F.B. Principal Product(s) and Raw Materlal(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): YARN. CLOTH THREADS
Raw material(s): POLYPROPYLENE (ON PIPE No 03). COTTON
F.S. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
71,800 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged Into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
62,000 gpd (X continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
40 CFR 414 SUBPART C (OCPSF)

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
City of Graham, NCO021211
RENEWAL
CAPE FEAR
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SILL Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.S. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes ® No (go to F.12)
F.10. Waste transport Method by which RCRA waste is received (check all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediatlon Waste. Does the treatment works currently (a has It been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) 9 No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLAIRCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
FAAL Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
F.16. Waste Treatment
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
If yes, describe the treatment (provide information about the removal efficiency):
b. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
END OF PART F.
REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST COMPLETE

t
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: G & K SERVICES
Malting Address: P.O. BOX 718
GRAHAM NC 27253
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
INDUSTRIAL. LAUNDERING
F.S. Principal Product(s) and Raw Materlal(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): CLEANING UNIFORMS
Raw material(s): BLEACH, FERRIC CHLORIDE, CAUSTIC, SURFACTANTS, AND DETERGENTS
F.S. Flow Rate.
a. Process wastewater flow rate. Indicate the average dally volume of process wastewater discharge Into the collection system in gallons per
day (gpd) and whether the discharge Is continuous or Intermittent.
50,000 gpd ( continuous or X Intermittent)
b. Non -process wastewater flow rate. Indicate the average dally volume of non -process wastewater flow discharged into the collection system
In gallons per day (gpd) and whether the discharge is continuous or Intermittent.
4,000 gpd (X continuous or Intermittent)
F.T. Protreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
City of Graham, NCO021211 RENEWAL CAPE FEAR
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, Interference) at the treatment works In the past three years?
❑ Yes ® No If yes, describe each episode.

' -A IIMIN fs1
F.3.
Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: LUXFER GAS CYLINDERS
Malting Address: 235 RIVERBEND ROAD
GRAHAM, NC 27253
F.4.
Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
MANUFACTURE GAS CYLINDERS
F.S.
Principal Product(s) and Raw Mat3erial(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): ALUMINUM GAS CYLINDERS
Raw material(s): ALUMINUM CAUSTIC LUBRICANTS WATER AND POWDER PAINTS
F.S.
Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge Into the collection system In gallons per
day (gpd) and whether the discharge is continuous or Intermittent.
30,000 gpd (X continuous or Intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged Into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
3.700 gpd (X continuous or Intermittent)
F.7.
Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
City of Graham, NCO021211
RENEWAL
CAPE FEAR
F.8.
Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, Interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

v ' , rOMN
F.3. Significant Industrial User information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: NOVAFLEX HOSE, INC.
Mailing Address: P.O. BOX 1838
BURLINGTON NC 27216 -1838
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
RUBBER AND PLASTIC HOSE AND MOLDED PARTS
F.S. Principal Product(s) and Raw Naterial(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): HOSE RUBBER AND PLASTIC
Raw matedal(s): NATURAL AND SYNTHETIC RUBBER AND THERMO PLASTIC RESINS
F.6. Flow Rats.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
1,700 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
9,000 gpd (X continuous or Intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
40CFR 428 SUBPART F (RUBBER MANUFACTURING)
FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
City of Graham, NCO021211 I RENEWAL I CAPE FEAR
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, Interference) at the treatment works In the past three years?
❑ Yes ® No If yes, describe each episode.

I
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�A
F.3. Signiftcant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: STERICYCLE, INC.
Mailing Address: P.O. BOX 310
HAW RIVER, NC 27258
F.4. Industrial Processes. Describe all the Industrial processes that affect or contribute to the SIU's discharge.
MEDICAL. WASTE INCINERATION
F.S. Principal Product(s) and Raw Matberlat(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): ASH FROM MEDICAL. WASTE
Raw material(s): MURIATIC ACID, FERRIC CHLORIDE, AND CAUSTIC SODA
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daiy volume of process wastewater discharge into the collection system In gallons per
day (gpd) and whether the discharge Is continuous or Intermittent.
24.000 gpd (X continuous or Intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
In gallons per day (gpd) and whether the discharge Is continuous or Intermittent.
1.615 gpd (X continuous or Intermittent)
F.7. Pretreatment Standards. indicate whether the SIU Is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
City of Graham, NCO021211 RENEWAL CAPE FEAR
F.a. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works In the past three years?
❑ Yes ® No if yes, describe each episode.

v It -0 A0*�
City of Graham Wastewater Treatment Plant
Sludge Management Plan
NPDES Permit No. NCO021211
Updated on November 17, 2005
• Wastewater Treatment Plant sludge is aerobically digested, stabilized, and then
surface applied to a City owned land application site.
• Aerobic digestion takes place in the Extended Aeration Basin, Primary and
Secondary digesters, Digester No. 3, and then Held in a Sludge Storage Unit.
Total volume of all sludge holding tanks is 1,975,000 gallons. The digested
sludge is either 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) or by proving 503B sludge
compliance by passing S.O.U.R test and Fecal Coliform Analysis. Additionally,
two lime stabilization tanks (combined volume of 100,000 gallons) are utilized for
these processes. 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.
• r
David W. Lawson Victor R. Quick
WWfP Supervisor Utilities Director
City of Graham City of Graham

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FIGURE NO. 1-1
PLANT PROCESS SCHEMATIC
WASTEWATER TREATMENT PLANT
GRAHAM, N.C.
RNKBEIN£R. PEMS & SMOUT, INC.
CONSULTING ENGINEERS
GREENSBORO, N.C.
CM 0MI-1 / 11-14--01

CITY OF GRAHAM WWTP
SIMPLIFIED SCHEMATIC + WATER BALANCE
B.3
READ FLOW FROM TOP TO BOTTOM OF PAGE
INCLUDES BAR
2005 DAILY FLOW RATE AVERAGES
SCREEN, GRIT
COLLECTION,
INFLUENT
1.51 MGD
FLOW METER, WET
HEADWORKS
WELL + PUMPS
QTY (2 ) 296,200
PRIMARY
1.51 MGD
DIGESTER No.1
VOLUME=114,000 GALS
gals. EACH
CLARIFERS
I
QTY (2) 1.75 M
AERATION
2.26 MGD I
DIGESTER No.2
VOLUME=196,000 GALS
EACH
BASINS
I
I I
IR.A.S. = 750,000 qpd 1
QTY (4 ) 325,000
SETTLING
DIGESTER No.3
VOLUME=750,000 GALS
gals. EACH
TANKS
W.A.S._ 35,000 d _ _ _ _ _ _
FEED RATE 35
SLUDGE STORAGE
CHLORINATION
1.475 MGD
VOLUME=750,000 GALS
LBS/DAY
UNIT
SAND FILTER
QTY (2)
SAND FILTERS
TRUCK FILL ZONE
VOLUME=100,000 GALS
BYPASS OPTION
QTY ( 1 ) 270,000
FINAL
LAND APPLICATION
1.475 MGD
FARM
gals.
CLARIFER
PERMIT WQ0003824
EFFLUENT
1.475 MGD
SAMPLER
EFF.POINT
11
1
ADDITIONAL SYTEMS AVAILABLE ARE LIME
EFFLUENT
STABILIZATION, ROTARY DRUM SLUDGE
APPROX. 1,150 FT
POINT
1.475 MGD
THICKENER, AND ALUM FEED.
FROM PLANT