NC0021211_Permit Issuance_20130517

Pat McCrory
Governor
- 7
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P. E. John E. Skvarla, III
Director Secretary
May 17, 2013
Mr. Victor R. Quick, Utilities Director
City of Graham
P.O. Drawer 357
Graham, North Carolina 27253
Subject: Issuance of NPDES Permit NCO021211
Graham WWTP
Alamance County
Facility Class IV
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 October 15, 2007 (or as
subsequently amended).
Thank you for your comment letter on the draft NPDES permit. DeChlorination was added to the
components list on the Supplement to Cover and the Effluent Pollutant Scan years were changed
as requested. The City's submittal for a monitoring frequency reduction for fecal coliform, TSS,
NH3*-N. and BOD5 was thoroughly evaluated and sampling for all four parameters was reduced
from daily to two times per week.
The following changes have been incorporated into this permit renewal:
• The stream classification in the Supplement to Cover was revised from C NSW to WS-V
NSW in accordance with the Jordan Lake Wastewater Discharge Rule (15A NCAC 02B
.0270).
• Effluent sampling data for lead, copper, and zinc did not show reasonable potential to violate
Water Quality Standards. Monitoring for all three parameters has been removed from the
permit, however, the City is expected to continue monitoring these parameters as part of its
Pretreatment Long Term Monitoring Program (LTMP).
• The Total Nitrogen discharge allocation in Section A.(3) was added as a loading limitation in
Section A. (L) along with a footnote recognizing Session Law 2011-394, H.B. 119.
• In accordance with NPDES Permitting Guidance for the 2012 Statewide Mercury TMDL,
five years of effluent mercury data was reviewed. Annual average effluent mercury
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 812 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterouatity.ora
One N)Vatarally
Carolina
An Equal Opportunity 1 Affirmative Action Employer

Page 2 of 2
concentrations were less than the Water Quality Based Effluent limitation and the
Technology Based Effluent Limitation, therefore, no limit was required. Monthly monitoring
requirements have been removed and mercury monitoring shall continue as part of the
Effluent Pollutant Scans. As part of implementing the Statewide Mercury TMDL, a Mercury
Minimization Plan must be developed for your facility. See new Special Condition A. (7).
The requirements are posted on our website: http://portal.ncdenr.ore/web/wg/ps/npdes. You
will have 180 days from the effective date of this permit to develop the plan.
• Section A. (9.) Effluent Pollutant Scan has been modified and now specifies the three years
the facility is expected to perform its annual scans.
• Footnote #5 was amended under Section A.(1.) to include the following statement: Limit and
monitoring apply only if chlorine or chlorine derivatives are used for disinfection. The
Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance
with the permit. However, the Pennittee shall record and submit all values reported by a
North Carolina certified laboratory (including field certified), even if these values fall below
50 µg/L..
• The wording in Section A. (8.) on Chronic Toxicity Testing has been changed and should be
reviewed carefully.
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 Julie Grzyb by email
[e-mail]) or phone at [phone].
Si cerely,
nl harles Wakild P.E.
Enclosure: NPDES Permit N00021211
cc: NPDES Unit
Central Files
Winston-Salem Regional Office / Surface Water Protection Section
e-copy:
EPA Region IV, Ben Gosh
PERCS Unit
Aquatic Toxicity Unit
ESS/ Ecosystems Unit
Lisa Edwards, DWR, PWS, WSRO
Mr. Frankie Maness, Assistant City Manager' (Acting Manager), City of Graham,
[e-mail]

Permit No. NCO021211
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMTT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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, 2013.
This permit and authorization to discharge shall expire at midnight on ................................ May 31, 2016.
Signed this day ......................................May 17, 2013.
2harles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0021A1
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facilihj, 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 facilihj 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 MGD wastewater treatment facility consisting of the following
components:
• Mechanical bar screen
• Grit chambers
• Primary settling
• Extended aeration basin
• Final clarifiers
• Aerobic digesters
• Chlorination
• DeChlorination
• Sand filters
• Post aeration
• Lime stabilization unit
• Sludge storage
This facility is located at the Graham Wastewater Treatment Plant at 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 WS-V; NSW waters in the Cape Fear River Basin.
Page 12

x
USGS Quad #: C21SE
Lat. 360 02'44" Lonq.-790 22'06'
N
SCALE
1:24,000
(1" = 2000�
City of Graham — Graham WWTP
NCO021211
County:
Receiving Stream:
Stream Classification
River Basin:
Sub -Basin /HUC#:
Alamance
Haw River
WS-IV; NSW
Cape Fear
03-06-02/ 03030002
Page 1 3

Permit No. NCO021211
A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly,
Average .
Weekly
Average, ,
9
Daily,
Maximum
Measurement
FrequencySample
Sample
Type
Location
Flow
3.5 MGD
Continuous
Recording
Influent or Effluent
Total Monthly Flow
Monitor & Report (MG)
Monthly
Rec. or Calc.
Influent or Effluent
BOD, 5 day, 20°C 2
(April 1- October 31)
12.0 mg/L
18.0 mg/L
2/Week
Composite
Influent and Effluent
BOD, 5 day, 200C 2
(November 1- March 31)
24.0 mg/L
36.0 mg/L
2/Week
Composite
Influent and Effluent
Total Suspended Solids 2
30.0 mg/L
45.0 mg/L
2/Week
Composite
Influent and Effluent
NH3 as N
(April 1- October 31)
4.0 mg/L
12.0 mg/L
2/Week
Composite
Effluent
NH3 as N
(November 1- March 31)
8.0 mg/L
24.0 mg/L
2/Week
Composite
Effluent
Dissolved Oxygen 3
Daily
Grab
Upstream & Downstream 1
pH 4
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent, 1
Upstream & Downstream
Fecal Coliform
(geometric mean)
200 / 100 mL
400/100 mL
2/Week
Grab
Effluent
Total Residual Chlorine 5
28 ug/L
Daily
Grab
Effluent
Conductivity
Daily
Grab
Effluent
TKN6
Monitor & Report (mg/L)
Weekly
Composite
Effluent
NO3-N + NO2-N6
Monitor & Report (mg/L)
Weekly
Composite
Effluent
Total Nitrogen, TN
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TN Load',8
Monitor & Report (lb/mo)
56,315 Ib/yr (effective 1/1/2016) 9
Monthly
Annually
Calculated
Effluent
Total Phosphorus, TP
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TP Load'•8
Monitor & Report (lb/mo)
7,079 Ib/yr (effective 1/1/2010)
Monthly
Annually
Calculated
Effluent
Chronic Toxicity 10
1
Quarterly
Composite
Effluent
Effluent Pollutant Scan11
Monitor & Report
See Footnote
See Footnote
Effluent
All footnotes are listed on the following page.
Page 14

Permit No. NCO021211
Footnotes:
1. Upstream = at Highway 54. Downstream = at NCSR 2158. Stream samples shall be grab samples collected
three times per week during June, July, August and September and once per week during the remaining
months of the year. See section A .(2) for details regarding the provisional waiver of instream monitoring
requirements.
2. The monthly average effluent BOD5 and Total Suspended 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.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. TRC limit and monitoring requirement only apply if chlorine is used for disinfection. The Permittee shall
report all effluent TRC values reported by a NC -certified laboratory [including field -certified]. Effluent
values below 50 µg/L will be treated as zero for compliance purposes.
6. TKN is Total Kjeldahl Nitrogen, NO3-N and NOrN are Nitrate and Nitrite Nitrogen, respectively.
7. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See
Special Condition A.(5.), Calculation of Mass Loads
8. Compliance with mass limits shall be determined in accordance with Special Condition A.(4.), Annual Limits
for Total Nitrogen or Total Phosphorus.
9. Per the Jordan Lake Wastewater Discharge Rule (15A NCAC 02B .0270) as modified by North Carolina
Session Law 2011-394 (HB119), the annual mass Total Nitrogen limit shall be effective beginning with
calendar year 2016, unless the discharger has received by December 31, 2016, an authorization -to -construct
permit for construction, installation, or alteration of the treatment works for purposes of complying with this
limit, in which case the limit shall.be effective beginning with calendar year 2018.
10. Chronic Toxicity (Ceriodaphni4V7F limit at 14 % with testing in March, June, September and December. See
Special Condition A. (8).
11. See Condition A.(9.), Effluent Pollutant Scan.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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.
Page 15

Permit No. NCO021211
A.(3.) NUTRIENT ALLOCATIONS
(a.) The following table lists the Total Nitrogen (TN) and Total Phosphorus (TP) allocations assigned
to, acquired by, or transferred to the Permittee in accordance with the Jordan Lake nutrient
management rule (T15A NCAC 02B .0270) and the status of each as of permit issuance. For
compliance purposes, this table does not supersede any TN or TP limit established elsewhere in
this permit or in the NPDES permit of a compliance association of which the Permittee is a Co-
Permittee Member.
Total Nitrogen Allocation
ALLOCATION
ALLOCATION AMOUNT
TYPE -
SOURCE
DATE
STATUS.
-
Delivered (Ib/yr)
Discharge (Iblyrj
Base
Assigned by Rule
8/11/09
45,615
56,315
Active
(T15A NCAC 02B .0270)
TOTAL
1 45,615
1 56,315
Active
Footnote:
(1) Nitrogen Transport Factor = 81%
Total Phosphorus Allocation
ALLOCATION AMOUNT
ALLOCATION
TYPE
SOURCE
DATE
STATUS
Delivered (lb/yr)
Discharge (Iblyr)
Base
Assigned by Rule
8/11/09
5,026
7,079
Active
(T15A NCAC 02B .0270)
TOTAL
5,026
7,079
Active
Footnote:
(1) Phosphorus Transport Factor = 71%
(b.) Any addition, deletion, or modification of the listed allocations) (other than to correct
typographical errors) or any change in status of any of the listed allocations shall be considered a
major modification of this permit and shall be subject to the public review process afforded such
modifications under state and federal rules.
Page 16

Permit No. NCO021211
A.(4.) ANNUAL LIMITS FOR TOTAL NITROGEN OR TOTAL PHOSPHORUS
(a.) Total Nitrogen (TN) and Total Phosphorus (TP) allocations and load limits for NPDES
dischargers in the Jordan Lake watershed are annual limits and apply on a calendar year basis.
(b.) For any given calendar year, the Permittee shall be in compliance with the annual TN (or TP)
Load limit in this Permit if:
(i.) the Permittee's annual TN (or TP) Load is less than or equal to the effective limit, or
(ii.) the Permittee is a Co-Permittee Member of a compliance association.
(c.) The TN (or TP) Load limit in this Permit may be modified as the result of allowable changes in
the Permittee's allocations.
(i.) Allowable changes include those resulting from purchase of TN (or TP) allocation from an
authorized mitigation banker, the Ecosystem Enhancement Program, or other source
allowed under applicable regulations; purchase, sale, trade, or lease of allocation between
the Permittee and other dischargers; regionalization; and other transactions approved by
the Division.
(ii.) The Permittee may request a modification of the TN (or TP) Load limit in this Permit to
reflect allowable changes in its allocation(s).
(A)' Upon receipt of timely and proper application, the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Changes in TN (or TP) limits become effective on January 1 of the year following
permit modification. The Division must receive application no later than August 31
for changes proposed for the following calendar year.
(iii.) Any requests for modification should be sent to:
NCDENR/ DWQ/ NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
(d.) If the Permittee is a member and co-permittee of an approved compliance association on January
1 of a given year, its TN and TP discharges during that year are governed by that association's
group NPDES permit and the limits therein.
(i.) The Permittee shall be considered a Co-Permittee Member for any given calendar year in
which it is identified as such in Appendix A of the association's group NPDES permit.
(ii.) Association roster(s) and members' TN and TP allocations will be updated annually and in
accordance with state and federal program requirements.
(iii.) If the Permittee intends to join or leave a compliance association, the Division must be
notified of the proposed action in accordance with the procedures defined in the
association's NPDES permit.
(A) Upon receipt of timely and proper notification, the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Membership changes in a compliance association become effective on January 1 of the
year following modification of the association's permit.
(e.) The TN and TP monitoring and reporting requirements in this Permit remain in effect
throughout the term of the Permit and are not affected by the Permittee's membership in a
compliance association.
Page 17

Permit No. NCO021211
A.(5.) CALCULATION OF TOTAL NITROGEN OR TOTAL PHOSPHORUS LOADS
(a.) The Permittee shall calculate monthly and annual TN Loads as follows:
Monthly TN (or TP) Load (lb/mo) = 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 the 12 Monthly TN (or TP) Loads for the calendar
year
(b.) The Permittee 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
calendar year's results (lb/yr) with the December report for that year.
A.(6.) NITROGEN OPTIMIZATION
(a.) Not later than February 11, 2010, the Permittee shall:
(i.) evaluate its treatment facilities and operations,
(ii.) identify further opportunities to improve and optimize nitrogen reduction in the existing
facilities beyond those previously implemented pursuant to G.S.143-215.1B(d), and
(iii.) submit a report to the Division documenting its findings, proposing optimization measures,
and describing expected results.
(b.) No later than six months following the Division's written acceptance of the report, or as provided
in the acceptance, the Permittee shall implement the proposed measures.
(c.) Beginning one year following the Division's acceptance of the report and continuing through
2016, the Permittee shall submit a progress report to the Division documenting the status of the
proposed measures and the nitrogen reductions achieved at the facility during the previous
calendar year.
(d.) Reports shall be submitted to:
NCDENR/ DWQ/ NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
A.(7.) MERCURY MINIMIZATION PLAN (MMP)
The permittee shall develop and implement a Mercury Minimization Plan (MMP) during this permit
term. The MMP shall be developed within 180 days of the NPDES Permit Effective Date, and shall be
available for inspection on -site. A sample MMP was developed through a stakeholder review process
and has been placed on the Division website for guidance
(hgp:/ /portal.ncdenr.org/web/wolf swp/ps/npdes, under Model Mercury Minimization Plan). The
MMP should place emphasis on identification of mercury contributors and goals for reduction. Results
shall be summarized and submitted with the next permit renewal.
Page 18

Permit No. NCO021211
A.(8.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Cmodaphnia dubia at an effluent concentration of 14 % .
The permit holder shall perform at a minimum, MjfLrly 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.
These months signify the first month of each three month toxicity testing quarter assigned to the facility.
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 I niit, 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. If reporting pass/fail results using the
parameter code TGP3B, DWQ Form AT-1(original) is sent to the below address. If reporting Chronic Value
results using the parameter code THP3B, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: NC DENR / 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 ineasured and reported if chlorine is
employed for disinfection of the waste stream.
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 -opened and modified to
include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR and all AT
Forms submitted.
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.
Page 19

Permit No. NC0021211,
A. (9.) EFFLUENT POLLUTANT SCAN
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2012, 2013, and 2014. Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria. Samples should
be collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not
sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia (as N)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) ether
Chlorine (total residual, TRC)
1,1-dichloxoethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite
1,3-dichloropropylene
4-bromophenyl phenyl ether
Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chiysene
Hardness
1,1,2,2-tetrachloroethane
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 (EPA Method 1631E)
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
2,4,6-trichlorophenol
Indeno(1,2,3-cd)pyrene
Benzene
.Base -neutral compounds:
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
Reporting. Test results shall be reported on DWQ Form A MR PPA1 (or in a form approved by the
Director) by December 31St of each designated sampling year. The report shall be submitted to the
following address: NC DENR/ DWQ/ Central Files,1617 Mail. Service Center, Raleigh, North
Carolina 27699-1617.
Page 110

AFFIDAVIT OF INSERTION OF ADVERTISMENT
The Times -News Publishing Company
Burlington, NC
Alamance County
I, Debbie Shue, Legal Advertising Manager of the Times -News Publishing Co.,
Do certify that the advertisement of entitled:
Account#20307
Public Notice
North Carolina Environmental Management
Measuring 56 lines appeared in The Times -News, a newspaper published in Alamance
County, Burlington, NC, in issues of
March 17. 201
"26129 )/226 l 7 17
Legal Advertising Manager
Sworn to and subscribed before me this c�! day of QJ? , 2013
cS Unit
Nvice
�r
jh, NC
.r9.1617
\ r Intent to Issue
,ES Wastewater
Permit
.e Minh Carolina Fnvi.
unrre�tal fvlanagemew
Commission proposes t0
issue a NPDFS waste
water discharge permit to
the person(s) listed be-
low. Written comments
regarding the proposed
permit will be accepted
until 30 clays after the
publish date of this nonce.
The Director of the NC (1-
vision of Water Quality
(DW0) may hold a public
hearing should there be a
significant degree of pub-
lic interest. Please mail
Comments and/or infor
oration requests to DWQ
at the above address. in-
te►este:l persons may
visit the DWO at 612 N
Saiisi,u-y Streit, Raleigh,
NC to �ewew information
on f0u, Additional infor-
mation on NPDFS permits
and ut:s notice may he
found on our website:
http-//portal.ncdenr.org/w
e b/w q/s yr p/p s/n p d e s/c a l e
ndar, or by calling (919)
80''!-6390 the City of
Ciaham requested re-
newal of perniit
NC007' 211 for its WW1 P
in /llamanre County, this
,nutted discharge is
'ed municipal and in -
wastewater to
vet, Cape Fear
``1111111111.F
`%�ogg Little' ������
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doAngelia Ross Little
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My commission expires: January 20, 2015
f3

Fecal.Coliform
1� 3.209103 geo averac 2010-2012
< 100/100mL or 50 % of permit limit
200% of 400/100 mL = 800/100mL
2010 1 2011 0 2012
4 daily samples > 200% of permit limit
< 20 daily samples exceeded 200% of the 400/100 mL permit limit
3) no more than two weekly average limit violations in 2012 (one on record)
Reduce monitoring Frequency for fecal coliform to 2/week
BOD
1) 7/12*12 mg/L + 5/12*24 mg/L =17 mg/L weighted, annual monthly average
8.5 = 50% of wt. annual monthly average
4.526035 three-year average is < 50% of the weighted annual monthly average limit
200% of summer monthly avg. limit = 24 mg/L summer values > 24
2010 0 2011 0 2012 3
no more than 3 daily samples exceeded 200% of the monthly average summer limit
200% of winter monthly permit limit = 48 mg/L winter values > 48
2010 0 2011 0 2013 0
0 0 0
no daily samples exceeded 200% of monthly average winter limit
3) no more than two weekly average limit violations in 2012 (one on record)
Reduce Monitoring Frequency for BOD5 to 2/week
TSS
1) 30 mg/L monthly average permit limit
15 = 50% of monthly average permit limit
3.939386 three-year average is < 50% of the monthly average permit limit
200% of monthly average permit limit= 60 mg/L
2010 0 2011 0 2012 2
no more than 2 daily samples exceeded 200% of the monthly average limit
3) no more than two weekly average limit violations in 2012 (one on record)
Reduce Monitoring Frequency for TSS to 2/week
NH3-N
1) 7/12*4 mg/L + 5/12*8 mg/L = 5.67 mg/L weighted, annual monthly average
2.835 = 50% of wt. annual monthly average
1.10 three-year average is < 50% of the weighted annual monthly average limit
2) 200% of summer monthly avg. limit = 8 mg/L summer values > 8
2010 6 2011 3 2012 4
no more than 13 daily samples exceeded 200% of the monthly average summer limit
200% of winter monthly permit limit = 16 mg/L winter values > 16
2010 0 2011 0 2013 0
0 0 0
no daily samples exceeded 200% of monthly average winter limit
3) no more than two weekly average limit violations in 2012 (none shown)

Grzyb, Julie
From: Graznak, Jenny
Sent: Friday, April 12, 2013 2:31 PM
To: Grzyb, Julie
Subject: RE: City of Graham, Graham WWTP Draft permit (NC0021211) for your review
Hi Julie,
I have reviewed the draft permit for Graham. Only found one issue with the draft:
- The Supplement to Permit Cover Sheet does not include dechlorination as a facility component.
Other than that, I didn't see any issues and therefore, the WSRO concurs that the permit be issued. On a side note, I think the
City of Graham was planning to apply for reduced monitoring but I didn't see that addressed in the permit. Any info on that?
Thanks.
Jenny Graznak
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Grzyb, Julie
Sent: Thursday, March 14, 2013 10:54 AM
To: Basinger, Corey; Graznak, Jenny
Subject: FW: City of Graham, Graham WWTP Draft permit (NC0021211) for your review
Corey / Jenny,
Attached please find the Draft permit and fact sheet for the Graham WWTP for your review.
The receiving stream for this facility is the Haw River and the segment to which it discharges was reclassified from C; NSW to
WS-V; NSW with the adoption of the Jordan Lake Rules. The Public Notice period ends April 19, 2013.
Please let me know if you have any questions.
Julie Grzyb
Julie A. Grzyb, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
NPDES Complex Permitting, Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6389 (wk); 919/807-6495 (fax)
iulie.przvbCa*cdenr eov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed
to third parties.

Tity of (6ra4am
P. O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
April 5, 2013
Julie Grzyb
NCDENR/DWQ/NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Draft NPDES Permit
Permit NC0021211
City of Graham WWTP
Alamance County
Dear Ms. Grzyb:
The City of Graham received draft permit No. NC0021211 on March 18, 2013. According
to your letter, the City's comments are due to your office no later than April 19, 2013. Based on
our review, the City would offer the following comments regarding this draft permit. Thank you
in advance for your consideration of the City's request.
In a previous permit, the City of Graham received a chlorine limit effective July 1, 2008
and installed a de -chlorination facility prior to that date as part of compliance with this
requirement. The City request that De -Chlorination be added to the list of treatment
components listed as part of item 1 on the "Supplement to Permit Cover Sheet". Unless you
feel it is not necessary to this permit, the City would request inclusion of the appropriate
language under item 2 referencing Senate Bill 810, that indicates the water quality water supply
standards that do not apply in this segment of the Haw River.
Section A. (9) Effluent Pollutant Scan has been modified and now specifies the three
years the facility is expected to perform its annual scans. Upon the expiration of our previous
permit (May 31, 2011), the City was unsure of the exact requirements that would be associated
with this draft permit. City staff decided to continue annual monitoring as a safety measure
until the new permit was issued. The City conducted an Effluent Pollutant Scan in December
2012. We recently conducted sampling for an Effluent Pollutant Scan in March of 2013 and
have scheduled our next annual Effluent Pollutant Scan to be due June, 2014. The draft permit
requires the three Effluent Pollutant Scans for this permit cycle to be conducted in the years
2013, 2014, and 2015. The City would request that the required years of analysis be adjusted

to 2012, 2013, and 2014. According to my calculations, even with moving back one year, the
City would still meet the application renewal criteria that effluent testing data must be based
on at least three pollutant scans and must be no more than four and one-half years old.
Assuming this permit remains within our previous permit cycle, this permit will expire May 31,
2016 with the application for renewal being required by December, 2015.
In accordance with the Division of Water Quality guidance regarding the reduction of
monitoring frequencies in NPDES permits for exceptionally performing facilities, the City of
Graham is requesting reduced monitoring for BOD5, TSS, NHO, and fecal coliform bacteria.
The City previously e-mailed you this request on March 19, 2013 and I am enclosing the printed
version of our justification which includes the previously submitted spreadsheets with three
years of data for each of the four parameters along with a summary sheet. After review of the
last three years of data, the City meets the required approval criteria as outlined in section B of
the Divisions guidance document.
Approval Criteria
The facility has no civil penalty assessment for permit limit violations for each target parameter
during the previous three years.
Neither the permittee nor any of its employees have been convicted of criminal violations of
the CWA within the previous five years.
The facility is not currently under an SOC for target parameter effluent limit noncompliance.
The facility is not on EPA's Quarterly Noncompliance Report for target parameter limit
violations.
For BOD5, TSS, and NH3-N, the three year arithmetic mean of effluent data is less than fifty
percent of the monthly average permit limit.
For fecal coliform, the three year geometric mean is less that fifty percent of the monthly
average permit limit.
For BOD5, TSS, less than 15 daily samples over the 3-year review period were over 200% of the
monthly average limit.
Less than 20 daily sample results were over 200% of the weekly average limit for fecal coliform.
For the four target parameter, sampling results did not show more than two non -monthly
average limit violations during 2012.
Reduced effluent monitoring should not impair assessment of sensitive downstream uses, such
as endangered species.

The City of Graham operates a facility that has traditionally demonstrated an
outstanding NPDES compliance history. The effluent from the City's Wastewater Treatment
Plant discharges are typically excellent in both quality and consistency and therefore request
that the final permit be issued with reduced monitoring frequencies.
The City of Graham appreciates the opportunity provided to comment on this draft
permit and would request an electronic copy of the final permit prior to issuing. You may
submit this to [e-mail]. This will allow us the opportunity to review the final
permit and provide a response to any technical correction that may be necessary prior to actual
issuance of the permit. Thank you for your attention and consideration of these comments
related to draft permit #NC0021211. Should you have any questions, please contact me at 336-
570-6721 or via my e-mail listed above.
Sincerely,
�JW
Victor R. Quick
Utilities Director
Cc: Frankie Maness, City Manager
Cris Routh, W WTP Superintendent

GMb, Julie
From: Victor Quick [[e-mail]]
Sent: Tuesday, March 19, 2013 2:21 PM
To: Grzyb, Julie
Subject: NPDES Permit #NC0021211
Attachments: REDUCED MONITORING DATA.xIs
Would you please e-mail me a copy of the NPDES Draft Fact Sheet used in conjunction with issuance of our Draft Permit as I
prepare comments related to the draft permit received yesterday. Thanks. 5 d"w'-k- 3 -.1R - d,7 wz'%J-A.�-
Attached please find the spreadsheets I will be submitting for justification of reduced monitoring frequencies for exceptionally
performing facilities. The first tab is a detailed summary of effluent data and the additional tabs contain the 3 years of data for
each of the four parameters. I will be including this information as part of my comments associated with the draft permit.
The facility has no civil penalty assessment for permit limit violations for each target parameter during the previous three years.
Neither the permittee nor any of its employees have been convicted of criminal violations of the CWA within the previous five
years.
The facility is not currently under an SOC for target parameter effluent limit noncompliance.
The facility is not on EPA's Quarterly Noncompliance Report for target parameter limit violations.
For BOD5, TSS, and NH3-N, the three year arithmetic mean of effluent data is less than fifty percent of the monthly average
permit limit.
For fecal coliform, the three year geometric mean is less that fifty percent of the monthly average permit limit.
For BOD5i TSS, less than 15 daily samples over the 3-year review period were over 200% of the monthly average limit.
Less than 20 daily sample results were over 200% of the weekly average limit for fecal coliform.
For the four target parameter, sampling results did not show more than two non -monthly average limit violations during 2012.
Reduced effluent monitoring should not impair assessment of sensitive downstream uses, such as endangered species.
Thank you for your time in this matter and I look forward to working with you.
Victor R. Quick
UtiCities Director
City of Graham
P.O. Drawer 357
Graham NC 27253
[phone]
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DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO021211
Facility Information
Applicant/FacilityName:
GrahamWWTP
Applicant Address:
P.O. Drawer 357, Graham, North Carolina 27253
Facility Address:
1204 East Gilbreath St., Graham, North Carolina 27252
Permitted Flow
3.5 MGD
Type of Waste:
Domestic 94% and industrial (6%) with full pretreatment program
Facility/Permit Status:
Class IV /Active; Renewal
County:
Alamance County
Miscellaneous
Receiving Stream:
Haw River
Regional Office:
Winston-Salem WSRO
Stream Classification:
WS-V; NSW
State Grid / USGS Quad:
Mebane / C21 SE
303 d Listed?
No
Permit Writer:
Julie Grzyb
Subbasin/8-Digit HUC:
03-06-02
/03030002
Date:
March 4, 2013
Drainage Area (mi):
614
Lat. 36002' 44" N Long. 79° 22' 06" W
Summer 7Q10 (cfs)
34
Winter 7Q 10 cfs
85
Average Flow (cfs):
553
IWC (%):
14%
Stream Index:
16-(1)
BACKGROUND
The City Of Graham W WTP is a Class IV facility with a permitted flow of 3.5 MGD. The average
flow for the past three years (2010-2012) has been 1.24 MGD. The permit was originally issued on
May 29, 2006 with an expiration date of May 31, 2011. Several modifications were issued: one on
October 20, 2006 which reduced nutrient monitoring to weekly; one on July 9, 2010 which
included the Jordan Reservoir Nutrient Management Strategy Rules; and one on August 9, 2010
which included some technical revisions. The expired permit has been administratively continued
until the permit is renewed and issued. The Permittee submitted EPA Form 2A on November 29,
2010 in order to request renewal of the permit.
The City of Graham has four significant industrial users and a full pretreatment program with the
Division of Water Quality's Pretreatment Unit. The City will be required to continue to implement
this program in the new permit term.
STREAM CONDITIONS
This facility discharges to the Haw River in subbasin 03-06-02, in the Cape Fear River Basin. This
portion of the Haw River was reclassified from C NSW waters to WS-V NSW waters as part of the
Jordan Lake Wastewater Discharge Rule (15A NCAC 02B .0270). This segment of the Haw River
is not listed on the 2012 North Carolina 303(d) Impaired Waters List.
Note that on July 16, 2012 the NC Governor signed Senate Bill 810 which clarified that "nutrient
management strategies for B. Everett Jordan Reservoir and the Falls of the Neuse Reservoir
watersheds shall not be interpreted to apply surface water quality standards set out in 15A NCAC
2B .0218(3)(e) through (3)(h) to waters designated in the nutrient management rules as WS-V
except where: ............. are classified as WS-II, WS-III, or WS-IV." Therefore, water quality
Fact Sheet
NPDES NCO024881 Renewal
Page I

water supply standards outlined in 15A NCAC 2B .0218(3)(e) through (3)(h) do not apply in this
segment of the Haw River.
Instream monitoring is waived as long as this facility is a member of the Cape Fear River Basin
Association. If the facility ends its membership in the Association, instream monitoring
requirements as specified in this permit take effect immediately.
BOD5 and NH3-N
In 1989 the facility relocated its discharge point from Town Branch Creek to the Haw River. A
Waste Load Allocation was performed which determined limitations for BOD5 at 12 mg/L in the
summer and 24 mg/L in the winter. Limitations for NH3-N were determined to be 4 mg/L in the
summer and 8 mg/L in the winter. A Waste Load Allocation was performed on NH3-N for this
permit renewal and at current limits the receiving stream is protected from ammonia -nitrogen
toxicity. It is recommended that current limitations for BOD5 and NH3-N remain in the permit.
REASONABLE POTENTIAL ANALYSIS
Reasonable Potential Analyses were conducted for: As, Cd, CN, Cr, Cu, Pb, Mo, Ni, Ag, Se, and
Zn (see the results of the RPA and parameter recommendations attached). Effluent samples from
Jan. 2010 through Dec. 2012 showed no reasonable potential to violate WQS. Monitoring for Pb,
Cu, and Zn was removed from the permit, however, the City is required to continue sampling all
twelve metals as part of its Pretreatment Long Term Monitoring Program (LTMP).
TOXICITY TESTING:
The facility has passed all 20 of its toxicity tests performed since 2008. It is recommended that they
continue to perform whole effluent chronic toxicity tests, pass/fail at a 14% effluent concentration,
March, June, September and December.
COMPLIANCE SUMMARY
DMRs have been reviewed for the period January 2008 through December 2012. During the
review period, the following NOVs (notices of violation) have been issued: 12/19/2012 for pH,
DO, TSS, BOD, and Fecal Coliform; 7/7/2008 for NH3-N and BOD. The 2012 non-compliance
issues were due to a surge of caustic wastewaters and the WWTP had to be reseeded. The
permittee was not able to prove what industry caused the impact.
A Compliance Evaluation Inspection conducted on 8/29/2012 found the facility satisfactory. A
Pretreatment Compliance inspection performed on 10/31/2012 found the facility very reliable with
no compliance issues.
MERCURY MINIMIZATION PLAN (,MMP)
In accordance with the NPDES Permitting Guidance for Implementation of the 2012 Statewide
Mercury TMDL, the past five years of mercury sampling data were evaluated (2008-2012). All
five annual averages were less than the allowable Water Quality Based Limit and no samples
exceeded the Technology Based Effluent Limit of 47 ng/L. As a result, no permit limit is required.
Multiple samples did exceed 1 ng/L and as a WWTP with a permitted flow > 2 mgd, the facility
will be required to develop and implement a MMP and conduct mercury monitoring as part of its
Effluent Pollutant Scans.
PROPOSED CHANGES
• The stream classification in the Supplement to Cover page was revised to show that the Haw River
was reclassified from C; NSW waters to WS-V; NSW waters as part of the Jordan Lake
Wastewater Discharge Rule (15A NCAC 02B .0270).
Fact Sheet
NPDES NCO024881 Renewal
Page 2

• Pb, Cu, and Zn effluent sampling data did not show reasonable potential to violate water quality
standards. All three parameters have been removed from the permit but will continue to be
monitored as part of the City's Pretreatment LTMP.
• Hg is not showing potential to violate the WQBEL or the TBEL so the monitoring requirement was
removed from Section A.(1) Effluent Limitations and Monitoring Requirements. Since multiple
samples did exceed 1 ng/L the facility is required to develop and implement a MMP and conduct
mercury monitoring as part of the Effluent Pollutant Scans. MMP requirements have been added to
the permit under Section A.(7.)
• A Total Nitrogen limitation and footnote have been added on the TN mass load limitation in
Section A. (L) in order to recognize Session Law 2011-394, H.B. 119 as listed in Section A.Q.)
Nutrient Allocations.
• The Effluent Pollutant Scan in Section A.(4) has been modified to request the specific three years
the facility is expected to perform its annual scans.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 20, 2013 (estimate)
Permit Schedule to Issue: May 6, 2013 (estimate)
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Julie Grzyb at [phone].
NAME: - DATE:
COMMENTS
—� o — a? o l 3
WSRO - Regional comments were received on 4/12/2012. It was recommended that
Dechlorination be added to the "Supplement to Cover" page. WSRO concurred that the permit be
issued.
US EPA Region IV - No comments were received.
ADDENDUM TO FACT SHEET 4/29/2013
A comment letter was received from the City of Graham on April 9, 2013. The letter requested
that DeChlorination be added to components list on the "Supplement to Cover" page and that the
Effluent Pollutant Scan years be changed to 2012, 2013, 2014 since the City already performed the
annual scan in 2012 as required in the previous permit. These changes were made in the final
permit.
The City also requested monitoring frequency reductions for fecal coliform, TSS, BODS, and NH3-
N. All the necessary data was submitted and the permittee demonstrated consistent, long-term
treatment performance at levels far below effluent limitations. Sampling reductions were granted
for all four parameters and monitoring frequencies were reduced from daily to twice per week. See
the Effluent Analysis sheet and data review for all four parameters attached.
Fact Sheet
NPDES NCO024881 Renewal
Page 3

Graham WWTP REASONABLE POTENTIAL ANALYSIS
NCO021211
Qw(MGD)= 3.50
WWTP/WTP Class: class
1QIOS(cfs)= 27.96
IWC @ 1Q10S = 16.25%
7Q10S(cfs)= 34.00
IWC @7QIOS= 13.76%
7QIOW(cfs)= 85.00
IWC@7QIOW= 6.00%
30Q2 (cfs) = NO 30Q2 DATA
IWC @ 30Q2 = N/A
Avg. Stream Flow, QA (cfs) = 553.00
IWC @ QA = 0.97%
Receiving Stream: Haw River
Stream Class: WS-V
Outfall 001
Qw = 3.5 MGD
CHRONIC TEST CONCENTRATION =13.8%
PARAMETER
STANDARDS S CRITERIA (2)
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
(1)
�
Oa
F
z
NC WQS / Applied '/s FAV /
Max Fred
Chronic Standard Acute
n N Det. Cw Allowable Cw
Acute: NO WQS
Arsenic
C
50 FW(7QIOs)
u
0 0
N/A
e11<2
Chronic: 363.4
Arsenic
C
10 HH/WS(Qavg)
ug/L
0 0
N/A
----------------------------
Chronic: 1,030.9
Acute: 92.3
Cadmium
NC
2 FW(7QIOs) IS
ug/L
0 0
N/A
_ _ _ _
all <2
Chronic:---- 14.5
----------------
Acute: 6,289.2
No RP, Predicted Max <50%of Allowable Cw-No
Chromium
NC
50 FW(7QIOs) 1022
ug/L
21 2
3.1
Monitoring required
Chronic----- 363.4 —
-------------------------
No value> Allowable Cw
Acute: 44.9
No RIP, Predicted Max a 50% of Allowable Cw -
Copper(AL)
NC
7 FW(7QIOs) 7
ug/L
36 31
33
defer to LTMP
Chronic:---- 50.q------------------------------
No value> Allowable Cw
Acute: 135.4
Cyanide
NC
PW(7QIOs) 22
10
ug/L
0 0
N/A
all <5
_ _ _____ ___
Chronic: 36.3
________
Acute: 208.0
No RR Predicted Max <50%of Allowable Cw-No
Lead
NC
25 FW(7QIOs) 33.8
ug/L
36 3
16.5
Monitoring required
--Chronic---- 181.7-----------------------------
No value> Allowable Cw
Acute: NO WQS
No RP, Predicted Max <50%of Allowable Cw- No
Molybdenum
INC
2000 HH(7QIOs)
ug/L
20 11
20.5
Monitoring required
Chronic 14,534.9
No value> Allowable Cw
Acute: 1,606.2
No RP, Predicted Max <50%of Allowable Cw-No
Nickel
NC
88 FW(7QIOs) 261
ug/L
21 1
7.5
Monitoring required
Chronic---- 639.5 —
-------------------------
No value> Allowable Cw
Acute: 344.6
Selenium
NC
5 FW(7QIOs) 56
ug/L
0 0
N/A
_ _ —L— _____
all <10
____
Chronic: 36.3
2012 RPA-Graham WTP.xism, rps
Page 1 of 2 3/5/2013

Graham WWTP REASONABLE POTENTIAL ANALYSIS Outfall 001
Ncnn21211 Qw = 3.5 MGD
Acute: 7.569
all <5
Silver (AL)
NC
006 FW(7QIOs) 1.23
ug/L
0 0
N/A
_ -----------------------------
Acute 412.3
No RP, Predicted Max, 50%of Allowable Cw-No
Zinc (AL)
NC
50 FW(7Q I Os) 67
ug/L
36 36
154.E
_ _
Monitoring required
Chronic: 363.4
No value> Allowable Cw
2012 RPA-Graham W rP.xlsm, rpa
Page 2 of 2 3/5/2013

REASONABLE POTENTIAL ANALYSIS
e
Chromium
s
Copper (AL)
Date
Data
BDL=112DL
Results
r •
Date
Data
BDL=1/2DL
Results
1
Dec-12
<
5
2.5
Std Dev.
0.3586
1
1/1/2010
Std Dev.
4.4536
2
Nov-12
<
5
2.5
Mean
2.3571
2
1/13/2010
12
12
Mean
8.7778
3
OCl-12
<
5
2.5
C.V.
0.1521
3
1/18/2010
C.V.
0.5074
4
Sep42
<
5
2.5
n
21
4
2/18/2010
10
10
n
36
5
Aug-12
<
5
2.5
5
3/16/2010
3
3
6
Jul-12
<
5
2.5
Mull Factor =
1.25
6
4M212010
Mult Factor =
1.73
7
Jun-12
<
5
2.5
Max. Value
2.5 ug/L
7
4/7/2010
4
4
Max. Value
19.0 ug/L
8
May-12
<
5
2.5
Max. Pred Cw
3.1 ug/L
8
5/2512010
11
11
Max. Pred Cw
32.9 ug/L
9
Apr-12
<
5
2.5
9
5/31/2010
10
Mar-12
2
2
10
6/8/2010
14
14
11
Feb-12
2
2
11
7/5/2010
12
Jan-12
2
2
12
7/8/2010
19
19
13
13
8/6/2010
5
5
14
Nov-11
2
1
14
9/6/2010
15
15
9/14/2010
8
8
16
16
10F7/2010
6
6
17
Aug-11
<
5
2.5
17
11/9/2010
12
12
18
Jul-11
18
11/25/2010
19
Jun-11
19
11/26/2010
20
May-11
<
5
2.5
20
12/8/2010
9
9
21
21
12/24/2010
22
Mar-11
<
5
2.5
22
12/27/2010
23
Feb-11
<
5
2.5
23
12/26/2010
24
24
1/3/2011
25
25
1/17/2011
26
26
1/1812011
14
14
27
Oct-10
<
5
2.5
27
2/1012011
11
11
28
<
28
3/17/2011
2
1
29
Aug-10
<
5
2.5
29
4/5/2011
12
12
30
30
4/22/2011
31
Jun-10
<
5
2.5
31
5/19/2011
4
4
32
32
5/30/2011
33
33
6/7/2011
2
2
34
Mar-10
<
5
2.5
34
7/412011
35
35
7/12/2011
2
1
36
36
8/11/2011
16
16
37
37
915/2011
38
38
9/6/2011
15
15
39
39
10MV2011
5
5
40
40
11/17/2011
7
7
41
41
11/24/2011
42
42
11/25/2011
43
43
12/6/2011
12
12
44
44
12/23/2011
45
45
12/26/2011
46
46
12/27/2011
47
47
1/2/2012
48
48
1/12/2012
7
7
49
49
1/1612012
50
50
2116/2012
9
9
51
51
3/8/2012
9
9
52
52
4/5/2012
8
8
53
53
4/6/2012
54
54
5/17/2012
8
e
55
55
5/28/2012
56
56
6/21/2012
10
5
57
57
7/4/2012
56
58
7/12/2012
10
5
59
59
8/23/2012
10
5
60
60
9/3/2012
61
61
9/20/2012
13
13
62
62
10/4/2012
9
9
63
63
11/15/2012
15
15
64
64.
11/22/2012
65
65
11/23/2012
66
66
12/6/2012
10
10
67
67
12/2412012
68
68
12125/2012
59
69
12/26/2012
2012 RPA-Graham WTP.xlsm, data
- 1 - 3/11/2013

REASONABLE POTENTIAL ANALYSIS
12
• •
14
Lead
Molybdenum
Date
Data
BDL=1/2DL
Results
• •
Date Data
BDL=1/2DL
Results
1
1/1/2010
Std Dev.
1.9913
1
12/1/2012
5
2.5
Std Dev.!2.36352
1/13/2010
10
5
Mean
4.3694
2
11/1/2012
5
2.5
Mean
503
1/18/2010
C.V.
0.4557
3
10/1/2012
5
2.5
C.V.
56
4
2/16/2010
10
5
n
36
4
9/1/2012
5
2.5
n
20
5
3/16/2010
10
5
5
8/1/2012
9
9
6
4/2/2010
Mull Factor =
1.65
6
7/1/2012
5
2.5
Mult Factor =
2.05
7
41712010
10
5
Max. Value
10.0 uglL
7
6/1/2012
6
6
Max. Value
10.0 ug/L
8
5/25/2010
10
5
Max. Pred Cw
16.5 ug/L
8
5/1/2012
6
6
Max. Pred Cw
20.5 ug/L
9
5/31/2010
9
4/1/2012
6
6
10
6/8/2010
10
5
10
3/1/2012
6
6
11
7/5/2010
11
2/1/2012
4
4
12
7/8/2010
10
5
12
1/1/2012
7
7
13
8/5/2010
10
5
13
14
9/6/2010
14
11/1/2011
6
6
15
9/14/2010
10
5
15
16
10812010
10
5
16
17
11/9/2010
10
5
17
8/l/2011
10
10
18
11125/2010
18
19
11/20/2010
19
20
12/8/2010
0.5
0.25
20
5/1/2011
5
2.5
21
12/24/2010
21
22
12/27/2010
22
23
12/28/2010
23
2/1/2011
5.
2.5
24
1/3/2011
24
25
1/17/2011
25
26
1/18/2011
10
5
26
27
2110/2011
10
5
27
10/1/2010
5
2.5
28
3/17/2011
10
5
28
29
4/5/2011
10
5
29
8/1/2010
5
5
30
4/22/2011
30
31
5/19/2011
10
5
31
6/1/2010
6
6
32
5/30/2011
32
33
6/7/2011
10
5
33
34
7/4/2011
34
3/112010
5
2.5
35
7/12/2011
10
5
35
2/1/2010
36
8/11/2011
10
5
36
1/1/2010
37
9/5/2011
37
38
9/6/2011
10
5
38
39
10/1712011
10
10
39
40
11/17/2011
0.5
0.25
40
41
11/24/2011
41
42
11/25/2011
42
43
12/6/2011
0.5
0.25
43
44
12/23/2011
44
45
12/26/2011
45
46
12/27/2011
46
47
1/2/2012
47
48
1/12/2012
0.6
0.6
48
49
1/16/2012
49
50
2/16/2012
0.7
0.7
50
51
3/8/2012
0.5
0.25
51
52
4/5/2012
10
5
52
53
4/6/2012
53
54
5/17/2012
10
5
54
55
5128/2012
55
56
6/21/2012
10
5
56
57
7/4/2012
57
58
7/12/2012
10
5
58
59
8/23/2012
10
5
59
60
9/3/2012
60
61
9/20/2012
10
5
61
62
10/4/2012
10
5
62
63
11/15/2012
10
5
63
64
11/22/2012
64
65
11/23/2012
65
66
12/6/2012
10
5
66
67
12/24/2012
67
68
12/25/2012
68
69
12/26/2012
69
2012 RPA-Graham WTP.xlsm, data
- 1 - 3/11/2013

REASONABLE POTENTIAL ANALYSIS
15
18
Nickel
Zinc (AL)
Date
Data
BDL=1/2DL
Results
• •
Date Data
BDL=112DL
Results
1
12/1/2012
<
10.0
5
Std Dev.
1.2071
1
1/1/2010
Std Dev.
18.5353
2
11/1/2012
<
10.0
5
Mean
4.4286
2
1/13/2010 ;.
82
82
Mean
77.3889
3
10/1/2012
<
10.0
5
C.V.
0.2726
3
1/18/2010
C.V.
0.2395
4
9112012
<
10.0
5
n
21
4
2/1812010
80
80
n
36
5
8/12012
<
10.0
5
5
3/1612010
61
61
6
7/12012
<
10.0
5
Mult Factor =
1.49
6
4/2/2010
Mult Factor =
1.31
7
6/1/2012
<
10.0
5
Max. Value
5.0 ug/L
7
4f7/2010
70
70
Max. Value
118.0 ug/L
8
5/1/2012
<
10.0
5
Max. Pred Cw
7.5 ug/L
8
5/25/2010
81
81
Max. Pmd Cw
154.6 ug/L
9
411/2012
<
10.0
5
9
6/31/2010
10
3/12012
2.0
2
10
6/8/2010
96
96
11
2112012
2.0
2
11
7/6/2010
12
1112012
2.0
2
12
7182010
116
116
13
13
8/5/2010
79
79
14
11/112011
2.0
2
14
9/6/2010
15
15
9/14/2010
59
59
16
16
10/7/2010
42
42
17
8112011
<
10.0
5
17
11/9/2010
74
74
18
18
11/25/2010
19
19
1128/2010
20
5/1/2011
<
10.0
5
20
12/8/2010
48
48
21
21
12/24/2010
22
3/1/2011
<
10.0
5
22
12/27/2010
23
2112011
<
10.0
5
23
12128/2010
24
24
1132011
25
25
1/17/2011
26
26
1/18/2011
80
80
27
10/1/2010
<
10.0.
5
27
2/10/2011
67
67
28
28
3/17/2011
76
76
29
8/1/2010
<
10.0
5
29
4/5/2011
54
54
30
<
30
4/222011
31
6112010
<
10.0
5
31
5/19/2011
75
75
32
32
5/302011
33
33
6f712011
77
77
34
3/1/2010
<
10.0
5
34
7/4/2011
35
2/1/2010
<
35
7/12/2011
78
78
36
1112010
<
36
8/112011
85
85
37
37
9162011
38
38
9/6/2011
93
93
39
39
10/17/2011
94
94
40
40
11/17/2011
90
90
41
41
11/24/2011
42
42
11/25/2011
43
43
12/6/2011
54
54
44
44
1223/2011
45
45
12/26/2011
46
46
12/27/2011
47
47
1/2/2012
48
48
1/12/2012
95
95
49
49
1/162012
50
50
2/162012
111
111
51
51
3/8/2012
70
70
52
52
4/5/2012
86
B6
53
53
4/6/2012
54
54
5/172012
90
90
55
55
5/28/2012
56
56
6212012
118
118
57
57
7/4/2012
58
58
7/12/2012
48
48
59
59
8/23/2012
65
65
60
60
9/3/2012
61
61
920/2012
52
52
62
62
10/4/2012
74
74
63
63
11/152012
71
71
64
64
11/22/2012
65
65
11/23/2012
66
66
12/6/2012
95
95
67
67
12242012
68
68
1225/2012
69
69
12/26/2012
2012 RPA-Graham WTP.xlsm, data
1 - 3/112013

NPDES/A uifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART:
Date of Request 2/19/2013
PERMIT WRITERS -AFTER you get this form back
Check all that
municipal renewal
apply
It
frNotify PERCS if LTMP/STMP data we said should be
on DMRs is not really there, so we can get it for you
(or NOV POTW).
- Notify PERCS if you want us to keep a specific POC
in LTMP/STMP so you will have data for next permit
renewal.
- Email PERCS draft permit, fact sheet, RPA.
- Send PERCS paper copy of permit (w/o NPDES
boilerplate), cover letter, final fact sheet. Email RPA if
changes.
Re uestor
Julie Grz b
new industries
Facility Name
Graham W WTP
WWTIP expansion
Permit Number
Region
NCO021211
WSRO
Speculative limits
stream reclass.
WS-V
Basin
Cape Fear
outfall relocation
7Q10 change
other
other
check applicable PERCS staff:
Other Comments to PERCS:
Four SIU's identified in renewal application:
G&K Services, Luxfer Gas Cylinders,
Novaflex Hose, Inc. (40CFR 428 Subpart F) rubber manufacturing, and
Stericycle Inc.
Note: the stream classification has changed to WS-V in accordance with
Nutrient management strategies for Jordan Resv.and Falls; surface WQS set
y
BIRD, CPF, CTB, FRB, TAR - Sarah Morrison (807-6310
CHO, HIW, LUM, LTN, NES, NEW, ROA, YAD - Monti
Hassan 807-6314
PERCS PRETREATMENT STAFF COMPLETES THIS PART:
Status of Pretreatment Program (check all that apply)
XJ1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment Program
3) facility has SIUs and DWQ approved Pretreatment Program (list 'DEW if program still under development)
X 3a) Full Program with LTMP
3b) Modified Program with STMP
4) additional conditions regarding Pretreatment attached or listed below
Flow, MGD
Permitted
I Actual
Time period for Actual
1 STMP time frame:
Industrial
0.205
1 0.1793
Apr 07-Mar 08
Most recent:
Ell
Uncontrollable
n/a
1 1.1007
1 Apr 07-Mar 08
Next Cycle:
n
x
Parameter of
Concern (POC)
Check List
POC due to
NPDES/ Non-
Dlech Permit
Limit
Required by
EPA'
Required
by 503
Sludge**
POC due
to SIU•"
POTW POC
(Explain
below)—
STMP
Effluent
Freq
LTMP
Effluent
Freq
Q= Quarterly
M = Monthly
X
BOD
X
X
M
X
TSS
X
X
M
X
NH3
X
M
X
Arsenic
X
M
Cadmium
X
X
M
Chromium
X
M
Copper
X
X
M
X
Cyanide
X
M
Is all data on DMRs?
Lead
X
X
M
YES
X
Mercury
X
X
M
NO (attach data)
X
Molybdenum
X
M
Nickel
X
X
M
X
Silver
M
X
Selenium
X
M
Zinc
J
X
X
M
Is data in spreadsheet?
Total Nitrogen
M
YES email to writer
X
Phosphorus
X
X
M
NO
X
TKN X
'Always in the LTMP/STMP " Only in LTMP/STMP if sludge land app or composte (dif POCs for incinerators)
"' Only in LTMP/STMP while SIU still discharges to POTW •"' Only in LTMP/STMP when pollutant is still of concern to POTW
Comments to Permit Writer (ex., explanation of any POCs• Info you have on IU related Investigations Into NPDES Problems -• The
Industrial flow data included a textile SIU (Culp Weaving) that was permitted at .105 MGD(Avg discharge was .044 MGD) This facility closed
down in 2007. All named SIUs above were included in Industrial flow data.
NPDES Preveavnent request form for Graham WWrP 2013renewal.xlsx
Revised: July 24, 2007

Cape Fear River Basin
> AU Number Name
2012 North Carolina 303(d) List -Category 5
10-digit Watershed 0303000201
Description
Length or Area Units
Reedy Fork
Classification categor;
ICategory Rating Use Reason for Rating Parameter Year
> 16-11-14-2a South Buffalo Creek From source to McConnell Rd
15.4 FW Miles WS-V;NSW
5 Impaired
Aquatic Life
Fair Bioclassification
Ecological/biological Integrity FishCom
2012
5 Impaired
Aquatic Life
Fair Bioclassification
Ecological/biological Integrity Benthos
2008
5
• 16-11-14-2b
South Buffalo Creek
From McConnell Rd to US 70
4.7 FW Miles
WS-V;NSW 5
5
Impaired Aquatic Life
Poor Bioclassification
Ecological/biological Integrity FishCom
1998
> 16-11-14-2c
South Buffalo Creek
From US 70 to Buffalo Creek
4.8 FW Miles
WS-V;NSW 5
Cape Fear River Basin
10-digit Watershed
12-digit Subwatershed
0303000202
030300020204
Headwaters Haw River
Benaja Creek -Haw Rive
> 16-(1)cl
HAW RIVER
From SR 2426 to Troublesome Creek at US29 7.3 FW Miles
WS-V;NSW 5
5
Impaired
Aquatic Life
Standard Violation
Copper
2008
12-digit Subwatershed
030300020206
Giles Creek -Haw Rive
> 16-(1)c2
HAW RIVER
From Troublesome Creek at US29 to NC87 13.9 FW Miles
WS-V;NSW 5
5
Impaired
Aquatic Life
Standard Violation
Turbidity
2012
16-6-(3)
Troublesome Creek
From dam at Lake Reidsville to Haw River 1.8 FW Miles
WS-V;NSW 5
5
Impaired
Aquatic Life
Standard Violation
Low Dissolved Oxygen
2010
12-digit Subwatershed
030300020205
t ti e'f7 lesome C eel
> 16-7a
Little Troublesome
Creek
From source to Reidsville WWTP
3.5 FW Miles
WS-V;NSW 5
5
Impaired
Aquatic Life
Fair Bioclassification
Ecological/biological Integrity Benthos
2000
Friday, August 24, 2012 Approved by EPA August 10, 2012 Page 5 of 170

Cape Fear River Basin
> AU Number Name
2012 North Carolina 303(d) List -Category 5
10-digit Watershed 0303000202
Description
Headwaters Haw River
Length or Area Units Classification Category
Category Rating Use Reason for Rating Parameter Year
12-digit Subwatershed 030300020201
Mears Fork -Haw Rivei
> 16-(1)a HAW RIVER From source to SR 2109 7.8 FW Miles WS-V;NSW 5
5 Impaired Aquatic Life Fair Bioclassification Ecological/biological Integrity Benthos 2000
12-digit Subwatershed 030300020207 Town of Altamahaw-Haw Rive
> 16-(1)c2 HAW RIVER From Troublesome Creek at US29 to NC87 13.9 FW Miles WS-V;NSW 5
5 Impaired Aquatic Life Standard Violation Turbidity 2012
Cape Fear River Basin 10-digit Watershed 0303000203 Big Alamance Creek
12-digit Subwatershed - 030300020310
Lower Big Alamance Creel
> 16-19-(4.5)a Big Alamance Creek From Dam at Lake Macintosh to confluence with Stinking Quarter Creek 5.6 FW Miles WS-V;NSW 5
(Alamance Cr)(Lk
Macintoch)
5 Impaired Aquatic Life Fair Bioclassification Ecological/biological Integrity Benthos 2006
> 16-19-11 Little Alamance Creek From source to Big Alamance Creek 12.6 FW Miles WS-V;NSW 5
(Gant Lake, Mays
Lake)(Alamance County
5 Impaired Aquatic Life Poor Bioclassification Ecological/biological Integrity Benthos 2000
Cape Fear River Basin 10-digit Watershed 0303000204 Back Creek -Haw River
12-digit Subwatershed 030300020406 Quaker Creek -Quaker Creek Reservoi
> 16-18-(1.5)al Back Creek (Graham- From .3 mile upstream of NC Hwy 119 to dam at Graham -Mebane Res to 132.0 FW Acres WS-II;HQW,NSW,C 5
Mebane Reservoir) SR1917
5 Impaired Aquatic Life Standard Violation Turbidity 2012
Friday, August 24, 2012 Approved by EPA August 10, 2012 Page 6 of 170

3/4/13 WQS = 12
Facility Name: Graham W WTP
Total Mercury 1631E PQL = 0.5 ng/L
Date Modifier Data Entry
ng/L
Value
MERCURY WQBEL/TBEL EVALUATION V:2012-4
Annual Limit 47 ng/L with
Quarterly Monitoring
7Q10s = 34.000 cfs WQBEL = 87.21 ng/L
Permitted Flow= 3.500 MGD TBEL= 47 ng/L
1/13/2010
7.13
7.13
2/18/2010
6.42
6.42
3/9/2010
8.36
8.36
4/7/2010
2.88
2.88
5/25/2010
2.98
2.98
6/11/2010
1.7
1.7
7/8/2010
8.49
8.49
8/5/2010
2.3
2.3
9/14/2010
4.28
4.28
10/5/2010
2.81
2.81
11/9/2010
4.81
4.81
12/8/2010
1.78
1.78
4.5
ng/L- Annual Average for 2010
1/25/2011
3.15
3.15
2/10/2011
2.28
2.28
3/17/2011
2.82
2.82
4/7/2011
2.7
2.7
5/19/2011
8.82
8.82
6/7/2011
4.77
4.77
7/12/2011
3.1
3.1
8/11/2011
7.34
7.34
9/6/2011
3.67
3.67
10/17/2011
1.25
1.25
11/17/2011
1.94
1.94
12/6/2011 <
1
0.5
3.5
ng/L- Annual Average for 2011
1/12/2012
1.81
1.81
2/16/2012
1.88
1.88
3/8/2012
2.27
2.27
4/5/2012
3.39
3.39
5/17/2012
5.44
5.44
6/21/2012
1.73
1.73
7/12/2012
4.54
4.54
8/23/2012
2.6
2.6
9/20/2012
2.31
2.31
10/4/2012
1.8
1.8
11/15/2012
2.64
2.64
12/6/2012
1.1
1.1
2.6
ng/L- Annual Average for 2012
1/17/2008
4.25
4.25
2/14/2008
3.89
3.89
3/6/2008
7.54
7.54
4/15/2008
6.32
6.32

5/6/2008
7.02
7.02
6/6/2008
2.85
2.85
7/10/2008
2.61
2.61
8/12/2008
3.64
3.64
9/19/2008
2.25
2.25
10/7/2008
5.88
5.88
11/6/2008
3.67
3.67
12/2/2008
2.07
2.07 4.3 ng/L-Annual Average for 2008
1/8/2009
9.48
9.48
2/3/2009
4.11
4.11
3/12/2009
7.47
7.47
4/7/2009
2.97
2.97
5/8/2009
2.17
2.17
6/12/2009
1.93
1.93
7/14/2009
3.26
3.26
8/7/2009
4.24
4.24
9/11/2009
3.02
3.02
10/7/2009
3.47
3.47
11/3/2009
11.6
11.6
12/8/2009
5.69
5.69 5.0 ng/L- Annual Average for 2009
Annual averages do not exceed WQBEL or
TBEL so no permit limitation is required.
Monitoring for mercury will occur as part
of the Effluent Pollutant Scans. The POW
discharges > 2 MGD (permitted flow 3.5
MGD) and mercury was detected in
concentrations greater than 1 ng/L on
multiple occassions, therefore a MMP is
required.

EFFLUENT ANALYSIS
I1) 3.209103 geo averac 2010-2012
< 100/100mL or 50 % of permit limit
200% of 400/100 mL = 800/100mL
2010 1 2011 0 2012
4 daily samples > 200% of permit limit
< 20 daily samples exceeded 200% of the 400/100 mL permit limit
no more than two weekly average limit violations in 2012 (one on record)
Reduce monitoring Frequency for fecal coliform to 2/week
BOD
1) 7/12*12 mg/L + 5/12*24 mg/L = 17 mg/L weighted, annual monthly average
8.5 = 50% of wt. annual monthly average
4.526035 three-year average is < 50% of the weighted annual monthly average limit
2) 200% of summer monthly avg. limit = 24 mg/L summer values > 24
2010 0 2011 0 2012 3
no more than 3 daily samples exceeded 200% of the monthly average summer limit
200% of winter monthly permit limit = 48 mg/L winter values > 48
2010 0 2011 0 2013 0
0 0 0
no daily samples exceeded 200% of monthly average winter limit
3) no more than two weekly average limit violations in 2012 (one on record)
Reduce Monitoring Frequency for BOD5 to 2/week
TSS
1) 30 mg/L monthly average permit limit
15 = 50% of monthly average permit limit
3.939386 three-year average is < 50% of the monthly average permit limit
200% of monthly average permit limit= 60 mg/L
2010 0 2011 0 2012 2
no more than 2 daily samples exceeded 200% of the monthly average limit
no more than two weekly average limit violations in 2012 (one on record)
Reduce Monitoring Frequency for TSS to 2/week
NH3-N
1) 7/12*4 mg/L + 5/12*8 mg/L = 5.67 mg/L weighted, annual monthly average
2.835 = 50% of wt. annual monthly average
1.10 three-year average is < 50% of the weighted annual monthly average limit
2) 200% of summer monthly avg. limit = 8 mg/L summer values > 8
2010 6 2011 3 2012 4
no more than 13 daily samples exceeded 200% of the monthly average summer limit
200% of winter monthly permit limit = 16 mg/L winter values > 16
2010 0 2011 0 2013 0
0 0 0
no daily samples exceeded 200% of monthly average winter limit
3) no more than two weekly average limit violations in 2012 (none shown)

IWC Calculations
Facility: Graham WWTP
NC0021211
Prepared By: Julie Grzyb
Enter Design Flow (MGD): 3.5
Enter s7Q10 (cfs): 34
Enter w7Q10 (cfs): 85
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
34
s7Q10 (CFS)
34
DESIGN FLOW (MGD)
3.5
DESIGN FLOW (MGD)
3.5
DESIGN FLOW (CFS)
5.425
DESIGN FLOW (CFS)
5.425
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
13.76
IWC (%)
13.76
Allowable Conc. (ug/l)
124
Allowable Conc. (mg/1)
a -!
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
85
Monthly Average Limit:
2001100mi DESIGN FLOW (MGD)
3.5
(If DF >331; Monitor)
DESIGN FLOW (CFS)
5.425
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
7.27 Upstream Bkgd (mg/1)
0.22
IWC (%)
6.00
Allowable Conc. (mg/I) r--26:6—
Total Residual Chlorine 4 C �
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity N 4a
y
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only S%,P%.
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter)
eAA` 5. BAT for Major Municipals: 1 mg/I (year-round) e
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Mu
NPDES Server/Current Versions/WLA; TB 1/16/2009

am
Ow QJ11-tyof (6ra4atn
P.O. Drawer 357
am 201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
Mq
November 29, 2010
Mrs. Dina Sprinkle
NCDENR 1 DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
P" RE: Renewal for NPDES Permit No.NC0021211
City of Graham, Alamance County
Dear Mrs. Sprinkle:
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.
M
0"
P"
1. One original and two copies of this cover letter.
2. One signed original and two copies of the completed application.
3. Three copies of Authorized Representative delegation letter.
4. One signed original and two copies of the narrative description of the Sludge
Management Plan.
Be advised that only three 2nd Species Toxicity results are included. The fourth
2nd Species Toxicity test will be conducted the week of December 6-10, 2010 and the
results are to be submitted to this office when they become available (per Charles H.
Weaver, NPDES unit). Please contact me at 336.570.6721 if you have any questions or
need additional information.
5' y, A. & .4,. je
Victor R. Quick
Utilities Director
Cc: Chris Rollins, Manager, City of Graham
Cris Routh, Plant Superintendent, City of Graham WWTP

op 11�
Catoaf (6ra4atn
P.O. Drawer 357
am 201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
ran
September 14, 2006
MM Alan W. Klimek, P.E., Director
NCDENR, Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
MP Dear Mr. Klimek:
In compliance with permitting requirements all applications, reports, or
information submitted to the Director are to be signed by the City Manager or his duly
authorized representative. Additionally regulations state that if a duly authorized
representative is designated, it must be done in writing to the Director by the City
Manager.
By this letter, the City of Graham is notifying the Division of Water Quality that
this authority to sign as "Permittee" is given to the individual holding the position of
Utilities Director. The individual currently in this position is Victor R. Quick. In the
event the position becomes vacant, the City Manager will sign until the position is filled.
This authority is given for the following permits currently issued to the City of
rim Graham.
NPDES Permit # NC0045292 (Graham -Mebane Water Treatment Plant)
NPDES Permit # NC0021211 ( Graham Wastewater Treatment Plant)
Permit # NCG110021 (Wastewater Treatment Plant Stormwater)
Permit # WQ0003824 (Land Application)
�., Permit # WQCS00065 (Collection System)
If you have any questions, please call me at 336.570.6700 or write to my attention
to the address above.
Chris Rollins
City Manager
Cc: NPDES Point Source Unit
MR PERCS Unit
Stormwater and General Permits Unit
Aquifer Protection Section
Pq
0"

FACIUTY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
City of Graham, NC0021211
RENEWAL
CAPE FEAR
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES
All treatment works receiving discharges from significant industrial users or which 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. 1
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: G & K SERVICES
Mailing Address: P.O. BOX 718
GRAHAM NC 27253
Fri. 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 Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal pmduct(s): CLEANING UNIFORMS
Raw material(s): BLEACH FERRIC CHLORIDE CAUSTIC SURFACTANTS AND DETERGENTS
F.6. 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.
27,300 gpd ( continuous or X 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.
4,000 gpd (X continuous or intermittent)
F.7. PretreatmentStandards. 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?

Me
We
FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
City of Graham, NCO021211
RENEWAL
CAPE FEAR
F.S. 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.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. 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 ❑ Rai ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amou Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
I i
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
FA2 Remedistion Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) ❑ No
F.11 Waste Origin. Describe the site and type of facility at which the CERCLAIRCRA/or other remedial waste originates (or is excepted to orgniate in
the next five years).
F.14. Poflutants. 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.)
FA& Waste Treatment
a. Is this waste treated (or witl 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

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
Mailing Address: 235 RIVERBEND ROAD
GRAHAM NC 27253
Fri.
Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
MANUFACTURE GAS CYLINDERS
F.5,
Principal Product(s) and Raw Matertal(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): GAS CYLINDERS
Raw material(s): METALS CAUSTIC LUBRICANTS WATER AND POWDER PAINTS
F.6.
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.
33,100 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.
2,100 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.

F.3.
Significant Industrial User Info rmatlon. 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.5.
Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that aged or contribute to the SIU's
discharge.
Principal pmdud(s): HOSE RUBBER AND PLASTIC
Raw material(s): NATURAL AND SYNTHETIC RUBBER AND THERMO PLASTIC RESINS
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.
12,900 gpd ( continuous or X 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.
9,400 gpd ( continuous or X 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
RENEWAL
CAPE FEAR
F.8.
Problems at the TmIlmant Works Attributed to Waste Discharge by the SIU. Has the SIU mused or centdbuted to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

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: STERICYCLE INC
Mailing Address: P.O. BOX 310
HAW RIVER NC 27258
FA.
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 Matertal(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 matenal(s): MURIATIC ACID FERRIC CHLORIDE AND CAUSTIC SODA _
F.6.
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.
20,000 gpd ( continuous or X 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.
1,600 gpd ( continuous or X 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.R.
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.

City of Graham Wastewater Treatment Plant
Sludge Management Plan
NPDES Permit No. NCO021211
Updated on October 12, 2010
• 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 1,810,000 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,
ran 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
'an 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.
M"
76 or�_
MR -"o em —
rispian T. Routh
WWTP Superintendent
F" City of Graham
Victor R. Quick
Utilities Director
City of Graham

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FIGURE NO. 1-1
PLANT PROCESS SCHEMATIC
WASTEWATER TREATMENT PLANT
GRAHAM, N.C.
RNKBONER, PEMS & SMOUT. INC.
CONSUL77NO ENGINEERS
GR££NSBORO, N.C.
COO: OMI-1 / 91-14-01

I I 1 I I 1 I I I I I I I 1 I 1 1 I
CITY OF GRAHAM WWTP
SIMPLIFIED SCHEMATIC + WATER BALANCE
B.3
READ FLOW FROM TOP TO BOTTOM OF PAGE
INCLUDES BAR
2010 DAILY FLOW RATE AVERAGES
SCREEN, GRIT
COLLECTION,
INFLUENT
1.391 MGD
FLOW METER, WET
HEADWORKS
WELL + PUMPS
11
QTY ( 2 ) 296,200
PRIMARY
\
1.391 MGD ��
DIGESTER No.1
VOLUME=114,000 GALS
gals. EACH
CLARIFERS
QTY (2) 1.75 M
AERATION
I
I
\
2.212 MGD
DIGESTER No.2
VOLUME=196,000 GALS
EACH
BASINS
I
QTY (4) 325,000
SETTLING
I I
I
R.A.S. = 821,000 gpd 1
\
DIGESTER No.3
VOLUME=750,000 GALS
gals. EACH
TANKS
W.A.S. = 41,000 gpd
FEED RATE 35
SLUDGE STORAGE
\
CHLORINATION
1.350 MGD
VOLUME=750,000 GALS
LBS/DAY
UNIT
I
QTY (2)
`\
SAND FILTERS
SAND FILTER
TRUCK FILL ZONE
VOLUME=100,000 GALS
BYPASS OPTION
I
QTY ( 1 ) 270,000
FINAL
LAND APPLICATION
\
1.350 MGD
FARM
gals.
CLARIFER
11
PERMIT W00003824
EFFLUENT
1.36qMGD
SAMPLER
EFF.POINT
ADDITIONAL SYTEMS AVAILABLE ARE LIME
EFFLUENT
STABILIZATION, ROTARY DRUM SLUDGE
APPROX. 1,150 FT
.5
POINT
THICKENER, AND ALUM FEED.
FROM PLANT