NC0024881_Permit Issuance_19961223

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Kelly Almond, City Manager
City of Reidsville
230 West Morehead Street
Reidsville, North Carolina 27320
Dear Mr. Almond:
AI LT.K*A
[DFEE HNFi
December 23, 1996
Subject: Adjudication Settlement
Permit No. NC0024881
City of Reidsville WWTP
Rockingham County
This letter is to provide formal written documentation that your previously -issued NPDES
permit which had been contested is now in full effect. The NPDES Committee of the
Environmental Management Commission acted on December 11, 1996 to allow the withdrawal
of your petition versus the Division as you requested (you have previously been sent a copy of
the Final Agency Decision). As such, this brings the matter of the contested case to a close and
the applicable and active permit should be the one issued to the City of Reidsville in October
1995.
I appreciate your working with members of my staff during this process. If you have any
questions or concerns, please contact Mr. Dave Goodrich at telephone number [phone],
extension 517.
Sincerely,
Preston Howard, Jr., P.E.
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
Permits and Engineering Unit
Anita Quigless, Attorney General's Office
Bobby Blowe, Construction Grants and Loans
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

e-
STATE OF NORTH CAROLINA
COUNTY OF ROCKINGHAM
CITY OF REIDSVILLE,
A MUNICIPAL CORPORATION
PETITIONER,
V.
N. C. DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES,
DIVISION OF ENVIRONMENTAL
MANAGEMENT,
RESPONDENT.
BEFORE THE
NPDES COMMITTEE OF THE
ENVIRONMENTAL MANAGEMENT
COMMISSION
95 EHR 1335
PI : P • SOL
kwo-on-o-MI Wa we). 3 WJ
THIS MATTER came before the NPDES Committee of the Environmental Management
Commission for final agency decision pursuant to N.C.G.S. § 150B-36 at its regularly scheduled
meeting in Raleigh, North Carolina on December 11, 1996. After the recommended decision and
official record were received by the NPDES Committee, the City of Reidsville, petitioner herein,
on December 5, 1996, delivered its letter giving notice of withdrawal of its petition for a
contested case.
The recommended decision and official record were received by the agency on November
11, 1996. The parties were provided the opportunity to file exceptions and objections to the
recommended decision and the contested case was to be heard during the February 12, 1997
meeting of the NPDES Committee. At the administrative hearing, the City of Reidsville was
represented by J. Michael Thomas, Esquire of Reidsville, North Carolina and the Department of

7
Environment, Health and Natural Resources was represented by Assistant Attorney General
Anita L. Quigless. Neither party deemed it necessary to have counsel present during the
Committee's consideration of the request to withdraw the petition for contested case and the City
of Reidsville waived its appearance.
At its December 11, 1996 meeting, the NPDES Committee considered the December 3,
1996 letter by the City of Reidsville requesting withdrawal of the contested case 'petition and
stating it was prepared to accept the conditions and limits established in the NPDES Permit
issued in October, 1995 and also a memorandum by the Director of the Division of Water
Quality recommending the acceptance of the withdrawal and reinstatement of the NPDES Permit
issued in October, 1995.
After considering the record and submissions by the parties, the NPDES Committee,
upon duly made motion and vote, rendered its final decision allowing the withdrawal of the
petition in the contested case by the City of Reidsville.
Based upon careful consideration of the record and submissions of the parties, the
NPDES Committee makes the following:
1. The City of Reidsville initiated the contested case and challenged the terms and
conditions of the NPDES Permit issued in October, 1995 for the City's wastewater treatment
plant discharge. The subject of the adjudication was the basis for the establishment of effluent
limits for a proposed relocated wastewater discharge to the Haw River.

3
2. By letter dated December 3, 1996, the City of Reidsville requested withdrawal of its
petition for contested case which was pending before the NPDES Committee of the
Environmental Management Commission.
3. Judicial and administrative efficiency are furthered by encouraging settlements, including
withdrawals, which eliminate the case in controversy.
Based upon the foregoing Findings of Fact, the NPDES Committee makes the following:
1. The NPDES Committee has jurisdiction over the subject matter and the parties in this
contested case.
2. The Legislature's delegation of quasi-judicial authority to DEHNR and the NPDES
Committee of the Environmental Management Commission includes the authority to deal with
motions of the parties, including here the letter requesting withdrawal of the petition for
contested case which initiated the case in controversy.
3. By withdrawing the petition for contested case, the petitioner drops and abandons, with
prejudice, its challenge to the NPDES Permit and is bound by the terms and conditions of the
permit.
4. By withdrawing the petition for contested case, the situation reverts to the status quo
ante, with petitioner being subject to the NPDES Permit as issued in October, 1995.
7. It is appropriate for the NPDES Committee to accept and allow the withdrawal of the
petition for the contested case.
THEREFORE it is Ordered and the Final Decision of the NPDES Committee that the
request to withdraw the petition for the contested case is accepted and allowed. Furthermore, the

c
r
4
City of Reidsville is subject to NPDES Permit issued in October 1995 and its terms and
conditions.
REASONS n SONS WHY RECOMMENDED DECISION NOT ADOPTED
By allowing the petitioner's request to withdraw the petition for contested case, the State's
policy encouraging settlement of disputes through informal procedures is furthered and serves to
promote judicial efficiency by eliminating superfluous process.
This the 1 Ith day of December, 1996.
Daniel V. Besse, Chairman
NPDES Committee of the
Environmental Management Commission

t
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing ORDER and
FINAL DECISION on the parties listed below by the methods indicated:
Mr. D. Kelly Almond, Manager
City of Reidsville
230 West Morehead Street
Reidsville, North Carolina 27320
J. Michael Thomas, Esquire
P.O. Box 2104
Reidsville, North Carolina 27233-2104
Anita L. Quigless, Esquire
Assistant Attorney General
P. 0. Box 629
Raleigh, North Carolina 27602-0629
CERTIFIED MAIL
RETURN RECEIPT
U. S. MAIL
HAND DELIVERY
Mr. Larry Coble U. S. MAIL
Regional Supervisor
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, North Carolina 27107
Mr. Beecher R. Gray U. S. MAIL
Office of Administrative Hearings
P. 0. Drawer 27447
Raleigh, North Carolina 27611-744
This the 13th day of December, 1996.
MICHAEL F. EASLEY
Attorney General
Francis W. Crawley
Special Deputy Attorney General
NC Department of Justice
P. 0. Box 629
Raleigh, North Carolina 27602-0629
[phone]

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
Office of the Director
December 11,1996
To: NPDES Committee
From: A. Preston Howard, Jr., P.E.
Subject: City of Reidsville vs. DEHNR (95 EHR 1335)
NPDES Permit No. NCO024881
Rockingham County
The City of Reidsville adjudicated the NPDES permit issued in October 1995 for the City's
wastewater treatment plant discharge. The subject of the adjudication was the basis for the
establishment of limits for a proposed relocated discharge to the Haw River from Little
Troublesome Creek. The Division has been working with the City since the filing of the
petition in an attempt to reach a satisfactory resolution. However, no resolution was able to
be reached prior to the case being heard before an Administrative Law Judge (ALJ) with the
Office of Administrative Hearings in April 1996. The ALJ rendered a recommended
decision that the Environmental Management Commission remand the permit back to the
Division to perform the modeling analysis in accordance with the Division's standard
modeling protocol. The permit issued in 1995 was, in fact, developed using the Division's
standard procedures for modeling. Therefore, the staff are of the opinion that the
recommended decision did not and would not change the permit conditions that were
contested. -
Subsequent to the ALJ's recommended decision, the City submitted a letter withdrawing
the contested case petition on December 3,1996. The letter further states that the City of
Reidsville is prepared to accept the conditions and limits established in the permit issued in
October 1995.
The Division recommends that the NPDES Committee accept the City's withdrawal and
direct the Division to reinstate the permit with the conditions and limitations set forth in the
initial permit issued in 1995.
cc: Steve W. Tedder
Frank Crawley, Special Deputy Attorney General
Steve Mauney, Winston-Salem Regional Office
Central File

2-0 -1996 11:30AM FROM CITY OF REIDSVILLE TO 19197156229 P.02
CI v Of Reidsville 230 West Morehead Street, Reidsville. North Carolina 27320 • [phone]
OFFICE OF THE CITY MANAGER
December 03, 1996
Mr. A. Preston Howard, Jr., P.E.
NCDEHNR
P.O. Box 29535
Ral:igh, North Carolina 27626-0535
1 Dear Mr. Howard:
In reference to DRAFT NPDES Discharge Permit No. NC0024881, the City of Riedsville wishes
to withdraw its' request for modification of the proposed discharge limits for CBOD5 and
Ammonia, and end the adjudication process. Reidsville is prepared to accept the conditions and
discharge limits as stated in the DRAFT Permit dated October 27, 1995. Please forward to my
office, a final copy of the permit for the required signatures. It is my understanding that once the
City's representative has signed the permit, all conditions of the permit become effective.
As a pan of the adjudication process, the final implementation of EMC WQ SOC No. 93-01 Ad I
was delayed until the permit issues were resolved. A copy of SOC 93-01 was signed by Mayor
Clark Turner on June 13, 1996 and submitted to Steve Mauney of the Winston-Salem Regional
Office. Please take the necessary actions to implement the Special Order as signed by Mayor
Turner.
As a requirement of the Special Order, the City of Reidsville must begin construction of the Haw
River Outfall project by February 1, 1997. This is a very tight time schedule. As you know,
finalization of the permit is required prior to the issuance of an Authorization to Construct. Please
expedite the processing of the permit and special order in any way possible.
If 1, or any of my staff, can be of any further assistance in these matters, please let me know.
Sincerely,
D. Kelly Alm# d
Manager
City of Reidsville
® Paper Reeyeled
TnT01 P R-D

State of North Carolina
Department of Environment,
Health and Natural Resources `LT.VAAIT
�
Division of Water Quality
James B. Hunt, Jr., Governor L
Jonathan B. Howes, Secretary p E H N F i
A. Preston Howard, Jr., P.E., Director
November 6, 1996
D. Kelly Almond
City Manager
230 W. Morehead St.
Reidsville, NC 27320
Subject: Request for Information
Level B Model Development
City of Reidsville WWTP
Rockingham County
Dear Mr. Almond:
In response to your request, dated October 8, 1996, we are hereby forwarding the
below listed items pertaining to the development and implementation of the Division of
Water Quality's (DWQ) desktop (Level B) model for the assimilation of oxygen demanding
wastes, as it was applied to the proposed Haw River outfall for the Reidsville wastewater
treatment plant:
1. The general guidance document describing the equations, processes, inputs and
outputs for the Level B model entitled, "Desktop Modeling Procedure (Level B)
for Determining NPDES Permit Effluent Limitations on Oxygen Consuming
Waste".
2. The model outputs, stream DO profile, and inputs from the specific Level B model
used to help determine the effluent limits in the draft NPDES permit for discharge
to the Haw River at the proposed site at Highway 150.
3. The section of our modeling unit's Standard Operating Procedures manual
pertaining to the Level B model entitled, "Level B Stream Modeling Procedures".
4. Supplemental instream data from the Division's files for the Haw River from the
immediate area of the proposed discharge site, including: instream data from the
Division's ambient monitoring station at Highway 29 near Benaja and an analysis
showing the average dissolved oxygen saturation for the 75th percentile
temperature at that site; and results of two instream SOD analyses from sites at
Highway 29 and Hwy 150.
Items 1 and 2 may be familiar. Item 1 was faxed to David Love of Aware
Environmental on February 2, 1996, and Item 2 was faxed to your office after your
January 3 meeting with DWQ staff.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

At your nearest possible convenience we would like to schedule a meeting for you and
any interested members of your operator's staff and/or your consultants to meet with my
staff to thoroughly discuss the enclosed information and conduct hands-on modeling
exercises, if needed. Please do not hesitate to contact me if there is any further information
we can provide to assist your evaluation.
Sincer ly
Steve W. Tedder, Chief
Water Quality Section
cc: Central Files
Jason Doll - Instream Assessment
Coleen Sullins - Permits & Engineering
Dave Goodrich - Permits & Engineering
r

Page 1
Note for Jason Doll
From:
Steve Tedder
Date:
Wed, Nov 6, 1996 8:37 AM
Subject:
RE: REIDSVILLE
To:
Don Safrit
Cc:
Coleen Sullins; Jason Doll
WE HAVE TO GET THE RESPONSE TO THEIR LETTER OUT TODAY.
I TALKED TO KELLY ALMOND THIS MORNING. HE SAYS THAT IF THEY CAN
SEE HOW WE RUN THE MODEL, THE INPUTS USING THE BEST AVALIABLE
DATA AND IF WE DO IT JUST AS WE DO WITH OTHERS WHEN WE USE THE
LEVEL B, AND IT COMES OUT 5/2, THEN THEY WILL GET ON WITH THE SHOW.
LET BE SURE THE INFORMATION WE SEND IS UNDERSTANDABLE. WHEN
THEY GET IT I AGREED TO MEET WITH THEM ONE MORE TIME AND GO THRU
IT AND HOPEFULLY WE CAN GET THIS RESOLVED.
From: Steve Tedder on Mon, Nov 4, 1996 2:35 PM
Subject: RE: REIDSVILLE
To: Don Safrit
ANYTIME TOMORROW MORNING
From: Don Safrit on Mon, Nov 4, 1996 2:20 PM
Subject: RE: REIDSVILLE
To: Steve Tedder
What's a good time for you? I'll try to get Coleen and Jason together so we can discuss.
Thanks, Don
From: Steve Tedder on Mon, Nov 4, 1996 2:03 PM
Subject: RE: REIDSVILLE
To: Don Safrit
I KNOW YOUR FOLKS HAVE MET ON THIS A COUPLE OF TIMES. WE NEED TO
MEET ASAP AND DISCUSS FUTURE DIRECTIONS AS WELL AS THE OAH
DECISION.
From: Jason Doll on Mon, Oct 28, 1996 3:54 PM
Subject: RE: REIDSVILLE
To: Steve Tedder
Cc: Carla Sanderson; Coleen Sullins; Dave Goodrich; Ruth Swanek
Steve,
We (Coleen, Dave, Carla and I) met with our attorney (Anita Quigless) last Friday to begin to
hammer out a strategy for presenting this to the NPDES committee and to resolve our
response to Kelly Almond's information request. There is still some level of concern from
Anita, and amongst us, that the items requested by Mr. Almond encompass the central points
of contention in this case, that is still proceeding, and we want to insure that our response in

TAR-PAMLICO RIVER BASIN
SUB
MAP
STREAM NAME
BASIN
-----
INDEX NUMBER
------------
NUMBER
------
CLASS
-----
-----------
LOG CREEK
TAR07
29-34-46-1
F32NE6
SA NSW
LONE TREE CREEK
TAR07
29-60-5
F34NE6
SA
LONE TREE CREEK
TAR07
29-69
F35NW1
SA
LONG BRANCH
TARO1
28-31-2
C26SW5
B NSW
LONG BRANCH
TAR02
28-35
D27SW1
WS-IV NSW
LONG BRANCH
TAR04
28-79-2-1
B25SE3
C NSW
LONG BRANCH
TAR04
28-79-16
B26SE5
C NSW
LONG BRANCH
TAR04
28-79-32-5
D29NW2
WS-IV NSW
LONG CREEK
TARO1
28-17-3
C25NW4
C NSW
LONG CREEK
TAR07
29-28-13-(1)
F32SW1
C NSW
LONG CREEK
TAR07
29-28-13-(2)
F32SW1
SA NSW
LONG CREEK
TAR07
29-33-3-2
F32SE7
SA NSW
LONG CREEK
TAR07
29-40
F33NW7
SA NSW
LONG CREEK
TAR07
29-41-6
F32SE6
SA
LONG CREEK
TAR07
29-42-1-1
F33NW4
SA
LONG SHOAL RIVER
TAR07
29-73-(1)
E35NW9
C SW
LONG SHOAL RIVER
TAR07
29-73-(2)
E35NW9
SA
LOT CANAL
TAR07
29-6-2-1-2-3-2
F30NE9
C SW NSW
LOWER DOWERY CREEK
TAR07
29-34-31
E32SE4
SC NSW
LOWER SPRING CREEK
TAR07
29-33-11
F32SW6
SA NSW
LOWES DITCH
TAR07
29-34-8
E32SE3
SC NSW
LYNCH CREEK
TARO1
28-21-(0.3)
B25SW9
C NSW
LYNCH CREEK
TARO1
28-21-(0.7)
C25NW3
WS-IV NSW
MALLARD CREEK
TAR07
29-13-(1)
F31NW3
C NSW
MALLARD CREEK
TAR07
29-13-(2)
F31NW3
SC NSW
MALLARD CREEK
TAR07
29-33-3-4
F32SE4
SA NSW
MAPLE BRANCH
TAR04
28-29-20.5
C26NE2
C NSW
MAPLE BRANCH
TAR04
28-79-22-8
B26SE8
C NSW
MAPLE BRANCH
TAR06
28-103-15
E30SE1
C SW NSW
MAPLE BRANCH
TAR07
29-6-2-1-7
E30SE7
C SW NSW
MAPLE SWAMP
TAR02
28-66
D27NW6
WS-IV NSW
MAPLE SWAMP
TAR04
28-79-31-(0.3)
C28SE4
C NSW
MAPLE SWAMP
TAR04
28-79-31-(0.7)
C28SE5
WS-IV NSW
MARIE CREEK
TAR07
29-36-2
F32NE9
SA NSW
MARSH BRANCH
TAR02
28-62
D27NW8
WS-IV NSW CA
MARSH ROCK CREEK
TAR07
29-39
F33NW7
SA NSW
MARSH SWAMP
TAR04
28-79-30-1
B27NE9
C SW NSW
MARSH SWAMP
TAR04
28-79-32-2
C29SW8
WS-IV NSW
MARTIN CREEK
TAR02
28-78-1-3
B25SW9
C NSW
MARTIN GUT
TAR07
29-9-2
F31NW4
SC NSW
MARTIN SWAMP
TAR04
28-79-30-1-0.5-1
B27SE3
C SW NSW
MARY ANNS POND
TAR07
29-89
G35SW1
SA
MATTHEWS CREEK
TAR04
28-79-2
B25SE2
C NSW
MCGEES CREEK
TARO1
28-16-2-(1)
C25SW1
C NSW
MCGEES CREEK
TARO1
28-16-2-(2)
C25NW7
WS-IV NSW
MEADOW BRANCH
TAR06
28-103-8-1
E30NW2
C SW NSW
MEETING HOUSE BRANCH
TAR05
28-97-1
E29SE4
C NSW
MIDDLE CREEK
TAR01
28-15
C24SE3
C NSW
MIDDLE CREEK
TAR07
29-44-5-4
F33SW3
SA
MIDDLE CREEK
TAR07
29-59
F34SE2
SA
MIDDLE SHOAL CREEK
TAR07
29-44-4
F33NW9
SA
MIDDLE TOWN CREEK
TAR07
29-66
F34NE3
SA
MIDGETTE CREEK
TAR07
29-42-1-2
F33NW8
SA
MILL BRANCH
TAR04
28-79-13
B26SE1
C NSW
10

Page 2
no way comprimises our position. In that interest we are all conducting a careful review of
the materials previously submitted to Reidsville and the trial record to determine the
appropriate response. We are meeting again this Thursday morning and should have a clear
idea of the best response after that meeting. I will keep you posted.
Thanks, Jason
From: Steve Tedder on Mon, Oct 28, 1996 3:17 PM
Subject: REIDSVILLE
To: Ruth Swanek
Cc: Jason Doll
WHAT IS YOUR TIMETABLE ON THE RESPONSE TO THE LETTER FROM
REIDSVILLE? KELLY ALMOND HAS CALLED AND I NEED TO GIVE HIM SOME
TIMETABLE.. I BELIEVE JASON SAID YOU WERE MEETING WITH THE
PERMITTING FOLKS LAST FRIDAY ON THIS>??????

TAR-PAMLICO RIVER BASIN
SUB
MAP
STREAM NAME
BASIN
-----
INDEX NUMBER
NUMBER
------
CLASS
-----
-----------
KENNEDY CREEK
TAR07
------------
28-104
E30SE5
C NSW
KENYON BAY
TAR07
29-34-37
F32NE1
SC NSW
KEY BRANCH
TAR02
28-76.5
D28NW6
WS-IV NSW
KING CREEK #
TAR05
28-88
E28NE8
WS-IV NSW
KINGS CREEK
TAR01
28-19
C25NW6
WS-IV NSW
KITTEN CREEK
TAR03
28-86-1-(1)
E28NE4
C NSW
KITTEN CREEK
TAR03
28-86-1-(2)
E28NE2
WS-IV NSW
KITTY CREEK
TAR07
29-70-3
E35SW7
SC HQW
KNIGHT CANAL
TAR03
28-87-3-1
D29SW1
C NSW
KNIGHTS CREEK
TAR07
29-34-10
E32SE6
SC NSW
KNOLL CREEK
TAR07
29-81
G35NE7
SA
KNOLL HOUSE CREEK
TAR07
29-82
G35NW9
SA
LAKE CANAL
TAR07
29-34-3-2
E32NE6
C SW NSW
LAKE MARGUERITE
TARO1
28-17-2-(1)
B25SW1
B NSW
LAKE MATTAMUSKEET
TAR07
29-57-1-1
F34NW1
SC
LAKE ROYALE #
TARO1
28-31-(1)
D26NW2
B NSW
LAKE SAGAMORE
TARO1
28-31-(1)
D26NW2
B NSW
LANDS POND
TARO1
28-30-2
D25NE5
C NSW
LANE SWAMP
TAR02
28-78-5
C27SE3
C NSW
LARGO LAKE
TAR04
29-79-22-2
B26SW4
C NSW
LASSITERS CREEK
TAR02
28-68-4
C27SE7
C NSW
LATHAM CREEK
TAR06
28-103-14-2
E30NE7
C SW NSW
LAUREL CREEK
TAR07
29-52-7
F34SW1
SA ORW
LAWRENCE RUN
TAR05
28-88-1
E29NW7
WS-IV NSW
LEE CREEK
TAR07
29-33-2-12
F32SW9
SA NSW
LEES BRANCH
TAR04
28-79-22-2
B26SW4
C NSW
LEWIS CANAL
TAR03
28-87-1.4
D29SW7
C NSW
LEWIS GUT
TAR07
29-12-3
F31NW6
C NSW
LIGHTHOUSE CREEK
TAR07
29-41-7
F33SW4
SA
LIGHTWOOD SNAG BAY
TAR07
29-44-3
F33NW8
SA
LINIAR BAY
TAR07
29-34-47
F32NE4
SA NSW
LITTLE BUFFALO CREEK
TARO1
28-18-1-(1)
C25NW3
C NSW
LITTLE BUFFALO CREEK
TARO1
28-18-1-(2)
C25NW3
WS-IV NSW
LITTLE CLARK CREEK
TAR07
29-35-6-4-1
F32SE6
SA NSW
LITTLE COKEY SWAMP
TAR03
28-83-3-1
D27NE5
C NSW
LITTLE CREEK
TARO1
28-17-2-5
B25SW7
C NSW
LITTLE CREEK
TAR07
29-9-1-8
F31NW7
C NSW
LITTLE CREEK
TAR07
29-28-9-(1)
F31SE6
C NSW
LITTLE CREEK
TAR07
29-28-9-(2)
F31SE6
SA NSW
LITTLE CREEK
TAR07
29-34-35-8
F32NW3
SC NSW
LITTLE EASE CREEK
TAR07
29-29-7
F32NW5
SA NSW
LITTLE FISHING CREEK
TAR04
28-79-25
B26NE9
C NSW
LITTLE GOOSE CREEK
TAR07
29-11-(1)
F31NW3
C NSW
LITTLE GOOSE CREEK
TAR07
29-11-(2)
F31NW3
SC NSW
LITTLE GUT
TAR07
29-34-44
F32NE5
SA NSW
LITTLE HAMMOCK CREEK
TAR07
29-42-1-3
F33NW8
SA
LITTLE KERNEL TREE BR
TAR07
29-33-2-4
F32SW8
SC NSW
LITTLE PEACHTREE CREEK
TAR02
28-68-1.5
C26SW9
C NSW
LITTLE RUIN CREEK
TARO1
28-17-2-6
B25SW7
C NSW
LITTLE SAPONY CREEK
TAR02
28-55-6-(0.3)
D26NE3
C NSW
LITTLE SAPONY CREEK
TAR02
28-55-6-(0.6)
D26NE6
WS-IV NSW
LITTLE SHOCCO CREEK
TAR04
28-79-22-6
B26SW7
C NSW
LITTLE SWASH OPENING
TAR07
29-84
G35NW9
SA
LITTLE TURKEY CREEK
TARO1
28-33-2
D26NW6
C NSW
E

'Igg3
City of Reidsville 230 West Morehead Street, Reidsville, North Carolina 27320 • [phone]
�t95,�LLE. rypR�
b�O p
F e
v a
1873
October 8, 1996
to , 9%
EOCT 14 1
Mr. Steve W. Tedder, Chief
Water Quality Section
NCDEHNR
P. O. Box 29535
Raleigh, NC 27626-0535
Dear Mr. Tedder:
OFFICE OF THE CITY MANAGER
As a follow-up to a recent conversation I had with Mr. Jeff Morse of the Environmental
Management Commission, I am forwarding this request for further information regarding the Level
B Model used to develop the specific limits included in the Draft Permit issued to the City of
Reidsville.
Please provide us with the following information: d„.W
A functional copy of the Level B Model l;oftware or the mathematical formula used
to develop the model.
Instructions sufficient in detail to correctly utilize the Model.
A complete hard copy print-out of the original dated Level B Model input and output
utilized by NCDEHNR to develop the limits included in the Draft Permit, along with
any internal memos or reports developed pursuant to that procedure.
Your consideration in offering to furnish this additional information is appreciated. If you
have any questions or require clarification of this request, please feel free to contact me.
Sincerely,
D. Kelly Almond
City Manager
DKA:asb
Recycled
Paper

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2

a
STATE OF NORTH CAROLINA
COUNTY OF ROCKINGHAM
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
Oct �,.. ' 1. „ 95 EHR 1335
1 � � �',�
CITY OF REIDSVILLE t ,11..c ')
A MUNICIPAL CORPORATION, ADMIN f SYR T' it
Petitioner ..) y
V. )
RECOMMENDED DECISION
DEPARTMENT OF ENVIRONMENT, )
HEALTH AND NATURAL RESOURCES, )
ACTING THROUGH DIVISION OF )
ENVIRONMENTAL MANAGEMENT, )
Respondent )
•THIS MATTER was heard before the Honorable Beecher R. Gray, Administrative
Law Judge, on April 11 and 12, 1996, in Wentworth, North Carolina,
Petitioner filed a Petition for a contested case hearing on November 21, 1995,
requesting a hearing pursuant to N. C. Gen. Stat. § 150-23 to contest the BOD5 and NH;-N
effluent parameters set out in National Pollutant Discharge Elimination Systems (NPDES)
Discharge Permit No. NC0024881.
APPEARANCES
For Petitioner: J. Michael Thomas
Post Office Box 2104
Reidsville, NC 27323-2104
[phone]
Attorney for Petitioner
For Respondent: Anita LeVeaux - Quigless
Assistant Attorney General
N. C. Department of Justice
Post Office Box 629
Raleigh, NC 27602-0629

-2-
ISSUE
Whether the BOD5 (CBOD5) and NH3-N limits set forth in the State NPDES
Discharge Permit No. NCO024881 effective December 1, 1995, are arbitrarily and
capriciously restrictive and therefore imposed by Respondent in violation of Petitioner's
rights?
The undersigned makes the following:
FINDINGS OF FACT
1. The petitioner City of Reidsville, a municipal corporation of Rockingham
County with a population of approximately 14,000, 'is the operator of a public wastewater
treatment plant holding an NPDES permit issued by the respondent agency Division of
Environmental Management, acting upon regulatory authority delegated to the State of North
Carolina and the issuing agency by the United States Environmental Protection Agency.
Petitioner currently discharges under an NPDES permit into Little Troublesome Creek, a
tributary of the Haw River which in turn is a tributary and subbasin of the Cape Fear River.
2. On October 27, 1995, the Respondent issued a draft NPDES permit permitting
the Petitioner to discharge into the Haw River at a new discharge point located adjacent to
the N.C. Highway 150 bridge in southeastern Rockingham County. The draft permit was
based upon the Petitioner's application for a discharge point relocated directly to Haw River.
3. Petitioner's wastewater treatment pfant was recently enlarged and improved
pursuant to a judicial order of consent with the State of North Carolina, in order to deal with
continuing problems in meeting certain effluent parameters and eliminating chronic toxicity
from the effluent. The plant's designed wastewater treatment capacity is for a wastewater
flow of 7.5 million gallons per day (MGD). The Petitioner's discharge into Little
Troublesome Creek currently accounts for approximately 98 percent of the stream flow
below the plant; this is the petitioner's curgent "in -stream concentration" of effluent at point
of discharge. The planned relocated discharge into Haw River would reduce the in -stream
concentration of the Petitioner's effluent at point of discharge from 98 percent to 61 percent.

4. The significance of the high in -stream concentration of effluent lies in its effect
on the dissolved oxygen (DO) in the receiving stream at point of discharge. The DO is a
scientific measure often used as an indicator of the receiving water's ability to support
aquatic life. A receiving water's ability to assimilate polluting effluent without negatively
affecting the DO in the stream and, therefore, the stream's ability to support aquatic life, is
referred to as the receiving stream's "assimilative capacity."
5. The DO in the receiving stream is protected through two key effluent
parameters or pollution limits, namely, (1) the carbonaceous biological oxygen demand
(CBODS) parameter, and (2) the ammonium nitrogen (NH3-N) parameter. The current high
in -stream concentration of the Petitioner's discharge into Little Troublesome Creek has • ,
resulted in the Petitioner currently having restrictive (summer) parameters of CBOD, at 4.0
mg/1 and NH3-N at 2.0 mg/l. These CBODS and NH3-N parameters effectively reduce the
Petitioner's treatment plant capacity (to receive and treat wastewater) to 2.8 MGD, instead of
7.5 MGD, because the Petitioner must treat its wastewater effluent to a higher degree than is
typically the case since its discharge makes up most of the receiving stream below the plant.
6. Because the Petitioner's wastewater treatment plant currently intakes a high
degree of industrial waste, its has no additional capacity for treatment of additional
commercial or industrial users without violating its current parameters. The Petitioner plans
to construct the new discharge point at Haw River by running a pipe from its wastewater
treatment plant approximately 5.5 miles to the N.C. Highway 150 bridge location, at a
projected cost of $5.8 million dollars. The Petitioner has already expended approximately
$352,000.00 in engineering and acquisitions costs- preparatory to permitting and construction
of the discharge line.
7. In processing the Petitioner's application for a new NPDES permit for the
proposed Haw. River discharge point, the Respondent agency through its Water Quality
Section considered inter alia the Petitioner's environmental assessment (EA) prepared for the
Petitioner by its consulting engineer. The EA indicated that the proposed discharge
relocation to Haw River would provide increased dilution of the Petitioner's effluent that
would minimize the Petitioner's chronic toxicity problem. The EA, prepared by the
Petitioner's consulting engineer, noted the current Little Troublesome Creek discharge
parameters and did not propose increasing the CBODS, NH3-N, or other permit effluent

-4-
parameters at the Haw River discharge location. The Petitioner, however, expected the DO -
related parameters to be increased because of a presumed increased assimilative capacity at
the proposed Haw River discharge location.
8. On October 27, 1995, the Respondent issued the draft NPDES permit for die
Petitioner's proposed relocated Haw River discharge. The draft permit modified or
eliminated effluent parameters at the new proposed discharge site for toxicity and metals
consistent with the new discharge location's increased dilution of effluent. The draft permit
maintained the CBOD, and NH3N parameters at the same levels for the proposed Haw River
discharge as currently required at the Little Troublesome Creek discharge. In a cover letter
therefor to Petitioner's City Manager D. Kelly Almond, written over the name of the
Respondent agency's director A. Preston Howard, Jr., and signed for the director by David
A. Goodrich, environmental engineering supervisor -of the permits and engineering unit of
Respondent's Water Quality Section, the Respondent summarized its bases for maintaining
the restrictive CBOD, and NH3N limits:
The limits for BOD, (CBOD,) and NH3-N were determined based on the
hydrologic characteristics for the receiving stream and instream dissolved oxygen
levels in the upper Haw River. In the area of the proposed discharge relocation, the
Haw River is characterized by very low slopes which cause slow velocities and low
reaeration rates in the receiving stream. This condition can severely limit assimilative
capacity, especially in the case of larger discharges. In addition, due to the high
industrial wastewater percentage at the City's treatment plant, the wastewater is more
resilient than 100% domestic wastewater. The resiliency of the wastewater for the
City of Reidsville was determined through the Division's BOD ultimate test. All of
these factors contributed to the determination of the limits for oxygen consuming
waste and the recommendation that the City of Reidsville retain their existing limits
for CBOD, and NH,-N.
9. The draft NPDES parameters for CBOD, and NH,-N were in fact determined
though an in-house modeling protocol known as the "Level B model." The Level B model is
a "desktop" model used by the Respondent to test the effects of proposed discharges by
NPDES permit applicants and makes use of data maintained by the State previously collected
by state and federal agencies from the river basins throughout North Carolina. Use of the
Level B model permits the Respondent to handle the large number of NPDES permits
expeditiously and relatively inexpensively, without having to collect in -stream and field data

-5-
over a long period of time from the affected receiving stream as required to conduct the
more elaborate, field -calibrated approach known as "Level C" modeling.
10. The Level B modeling is performed according to a protocol adopted by the
Respondent and entitled "Desktop Modeling Procedure (Level B) for Determining NPDES
Permit Effluent Limitations on Oxygen Consuming Waste." The Level B protocol provides
in pertinent part, "In the absence of actual stream data for model calibration, a Level B
(desktop) modeling analysis can be performed. Level B modeling incorporates the use of
empirical model input equations and DEM procedures to establish model input parameter *41
values." The modeling is done based on four major input categories, namely, (1) model
hydraulics considerations including streamflow, runoff, stream velocity, channel width and
depth, and stream bed gradient, (2) model reaction rates including CBOD decay (kd), NBOD
decay (k.), and reaeration (kJ, (3) model design temperature based upon the -season and
physical location of the stream within the State, and (4) background and boundary conditions,
i.e. headwaters and tributaries. q
11. The Level B model thus provides for and is premised on the absence of actual
water quality data collected in -stream at the point of discharge and relies instead on default
values previously compiled and applicable to the proposed discharge location. The default
values are used in a series of equations to predict the effect of the permittee's discharge on
the DO in the receiving stream and produce wasteload allocations expressed in terms of
CBOD (BOD,) and NBOD (NH3--N) parameters.
12. The Level B model for Petitioner's Haw River discharge NPDES permit was
performed by Jason Doll, an environmental modeler employed by the Respondent's instream
assessment unit. In performing the Level B model for the subject permit application, Doll
used the results of ultimate CBOD testing from a sample made at the Petitioner's wastewater
treatment plant in June 1993. This was the "BOD ultimate" information referred to in the
Respondent's October 327, 1995 letter covering the draft NPDES permit.
13. "BOD ultimate " or "ultimate CBOD",refers to the oxygen demand
(consumption of oxygen) over a long period of time - in the case of the Reidsville sampling,
a period of 140 days. "BOD," refers to the same thing, but over a set period of five days.
The ratio of ultimate BOD/BOD, is used as a coefficient in the Level B modeling to
determine waste load allocations - i.e, the contested CBOD, and NH3-N parameters. An

I M.
equally significant input parameter in the modeling is the decay rate (kj, meaning the rate at
which the BOD is oxidized.
14. Because the Level B modeling employs mathematical formulae, the input
parameters used thin are co-dependent - that is, if all but one coefficient is known, the
u� t equation will dictate that remaining coefficient's value. Doll used the actual ultimate
OFF
�BODBODS ratio derived from the June 1993 Reidsville sampling and adefault-value decay
0-11- `�
rate (kd) of 0.22. Use of these coefficients, one an actual datum from the Reidsville plane
and the other a default value, produced waste load parameters of 5 mg/l BOD, and 2 mg/I
NH,--N, respectively, which were the effluent parameters set forth in the draft NPDES
permit.
15. Robert M. Stein, an expert in the field of water quality analysis, reviewed the
Respondent's Level B modeling. Stein did not duplicate the Level B modeling but simulated
it through the use of a computer software program called QUAL2E, a sophisticated
environmental modeling program. The results of Stein's review of the Respondent's 00�0/1
modeling was summarized in his written report as follows:
Determination of Allowable Waste Load Allocation Given Section Kinetics and
Waste Loading
To determine the maximum allowable CBOD which does not violate the 5
mg/l in -stream DO standard, the QUALM model was run at CBOD values
ranging from a low of 20 mg/l to the 40.5 mg/l used by the Section. The
NBOD loading, the hydraulic and kinetic parameters, and the background
conditions in the river were kept constant at the values used in the Level B
model.
The minimum in -stream DO predicted by the model for each CBOD value is
presented graphically in Figure 4. A CBOD of 25 mg/l represents the
maximum assimilative capacity of the model area based upon the QUALM
results.
Evaluation of Section Kinetic Cod9cients and CBOD/BOD. Ratio
The oxygen load of an oxygen -consuming organic wastewater can be
represented with a first -order decay equation which when integrated from time
zero to infinity is expressed as:
where Lt is the amount of first -stage BOD remaining in the water at time t, L

is the ultimate BOD, and kd is the reaction rate coefficient. By selecting
values for any two of the three variables in this equation Lt,L,kd) the value of
the third variable is fixed by the mathematical relationship.
Inspection of the Level B model input reveals that the combination of
e �Je CBOD/BOD5 ratio of 8.1 is not consistent with a BOD decay coefficient (kd)
� c aCp of 0.22 when the BOD, is taken to be 5 mg/l. The 8.1 CBOD/BOD5 ration is
S based upon long-term BOD testing which indicates that the Reidsville effluent
��� continues to exert oxygen demand long after the twenty to thirty day period
typical of municipal wastewater. For comparison, the Section guidance
document for the Level B model recommends a CBOD/BOD, ration of 1.5 to
3 in the absence of waste -specific data. The kd value of 0.22 is typical of
readily degradable municipal waste; however, it is not compatible with the
high CBOD/BOD5 ratio assumed by the Section. The ratio and the coefficient
are inversely related. For the CBOD/BOD, ratio to be higher than normal, the
decay coefficient must be lower than normal given a specific value of BOD5.
Determination of Allowable CBOD with Alternate Kinetic Coefficient and
CBOD/BOD, Ratio
Using the mathematical relationship outlined above, alternate values for kd and
for the CBOD/BOD, ratio were calculated. First, the resulting BOD, was
calculated using a CBOD value of 25 mg/1, a kd of 0.22, (conditions the
model indicates the river will support) and the derived relationship:
y5=L(I-ek )
where ys is BOD, L is CBOD, and kd is the BOD decay rate coefficient. The
resulting BOD, is 16.7 mg/l. Using this kinetic relationship, the QUALM
model predicts that the river is capable of assimilating a Reidsville WWTP
effluent BOD5, in excess of 16 mg/l.
The second alternative was to keep the CBOD and BOD, values assumed in
the Level B model input ratio and to calculate the resulting kd value using"the
referenced equation. With a CBOD of 40.5 mg/l and BOD5 at 5 mg/l, the kd
value becomes to 0.03 (rounded to two decimal places).
To determine the effect of the calculated decay rate coefficient on the river
DO, the QUALM model was re -run with kd=0.03 and with the CBOD
varying from 40 mg/l to 140 mg/l. A plot of the minimum in -stream DO
concentration versus the CBOD for this model configuration is presented as
Figure 6.
Using the revised kd of 0.03, the QUALM model indicates that a CBOD in
excess of 120 mg/t can be supported by the river. With a CBOD/BOD5 ratio
of 8.1, the resulting allowable BOD5 becomes approximately 15 mg/I.

16. In Stein's expert opinion, the Haw River at the proposed discharge location
has a higher assimilative capacity than predicted by the Respondent's modeling. Further.
Stein concluded, and the foregoing excerpt from his report provides the technical basis for
such conclusion, that the key problem with the Respondent's modeling was the failure to
develop an accurate degradation rate (k) as dictated by the June 1993 sampling; instead, the
Respondent's modeler used a default value decay rate. This violated the Respondent's own
Level B protocol, which requires the use of default data only where actual data is lacking.
Where the Respondent had the June 1993 sampling (actual data), it had the means to
mathematically calculate the actual decay rate (kd); instead, the modeler coupled the ultimate
CBODBOD5 ratio with a default -value decay rate, which is not correct under the
Respondent's own Level B protocol.
CONCLUSIONS OF LAW
1. All parties are properly before the Office of Administrative Hearings, all
parties received due notice of the contested case hearing herein, and the Office of
Administrative Hearings has jurisdiction over the parties and the subject matter.
2. All parties have been correctly designated, and there is no question as to
misjoinder or nonjoinder.
3. Respondent acted arbitrarily and capriciously, and in violation of Petitioner's
rights, in establishing the BODS (CBOD5) and NH3-N limits set forth in the State NPDES
Discharge Permit No. NCO024881 effective December 1, 1995, because in establishing said
limits the Respondent violated its own modeling protocol, entitled "Desktop Modeling
t� (LeelB)for mgNProcedure Permit Effluent Limitations on Oxygen
Consuming Waste," uniformly applicable to NPDES permitting decisions. See Kent
County, Maryland v. U. S. Environmental Protection Agency, 963 F.2d 391 (D.C. Cir. 1992)
(Where U. S. Environmental Protection Agency placed landfill operator's site on National
Priorities ("Superfund") List (the NPL), and the action was challenged as violating the
standard precluding agency acts "arbitrary, capricious, an abuse of discretion, or otherwise
not in accordance with law" pursuant to 5 U.S.C. § 706(2)(A), held the agency acted
arbitrarily and capriciously when it used only unfiltered samples and not filtered samples as

sea
well, as required by its own internal policy, to test the groundwater at the site to determine
the landfill's "toxicity/persistence" score.) Accord, Anne Arundel County, Maryland v. U. S.
Environmental Protection Agency, 963 F.2d 412 (D.C. Cir. 1992). See National Gypsum
Company v. U. S. Environmental Protection Agency, 968 F.2d 40 (D.C. Cir. 1992) (Where
petitioner's dump site was placed on the NPL, and where EPA could not offer a satisfactory
explanation for its inference that compounds other than boron oxide existed at the site, nor
could offer substantial evidence that the highly toxic boron compounds were present there, all
based on a test of groundwater revealing traces of boron but not disclosing the chemical form
of boron contained in the groundwater sample, held the agency's decision to assign a
toxicity/persistence score placing it on the NPL was based on unsupported assumptions and
not reasonable or scientifically based inferences and therefore was arbitrary and capricious.)
See State of Ohio v. U. S. Environmental Protection Agency, 784 F.2d 224 (6th Cir. 1986)
(Where EPA established Clean Air Act emission limits for the smokestacks of two electric
utility plants based on a computer model used by EPA to forecast pollution from such
plants, held the agency acted arbitrarily in using the computer model without adequately
validating, monitoring, or testing its reliability or its trustworthiness in forecasting pollution
in the plants' vicinity; more specifically, given the model's demonstrated sensitivity to site -
specific characteristics, EPA's failure to validate the model at the two smokestack sites in
accordance with its own guidelines was arbitrary and capricious.) See City of Stoughton,
Wis. v. U. S. Environmental Protection Agency, 858 F.2d 747 (D.C. Cir. 1988) (Where EPA
placed city and corporate landfills on the NPL, held EPA did not act arbitrarily or
capriciously in relying on information submitted by the city showing the presence of
chloroform, when another test negatived that finding, since there was no showing that the
data relied on by EPA was invalid; the court noted the petitioner -City of Stoughton correctly
stated the applicable standard for review, namely, that the use of invalid data is, in itself, an
arbitrary and capricious action, and that failure on the part of EPA to follow its own
regulation is an arbitrary and capricious action.)
Based upon the foregoing Findings of Fact and Conclusions of Law, the undersigned
makes the following:

-10—
RECOMMENDED DECISION
e, The North Carolina Environmental Management Commission should remand the subject
��o draft NPDES permit to the Division of Environmental Management for re -modeling in strict
1
mac` compliance with the Division's protocol entitled "Desktop Modeling Procedure (Level B) for
Determining NPDES Permit Effluent Limitations on Oxygen Consuming Waste.
It is hereby ordered that the agency serve a copy of the final decision on the Office of
Administrative Hearings, P. O. Drawer 27447, Raleigh, NC 27611-7447, in accordance with N.
C. Gen. Stat. § 150B-36(b).
NOTICE
The agency making the final decision in the contested case is required to give each party
an opportunity to file exceptions to this recommended decision and to present written arguments
to those in the agency who will make the final decision. N. C. Gen. Stat. § 150B-36(a).
The agency is required by N. C. Gen. Stat. § 150B-36(a) to serve a copy of the final
decision on all parties and to furnish a copy to the parties' attorney of record and to the Office of
Administrative Hearings. The agency that will make the final decision in this contested case is
the North Carolina Environmental Management Commission.
This the l day of 0 C 1'096'k 11996.
Hon. Beecher R. G
Administrative Law

•
-11-
A copy of the foregoing was mailed to:
J. Michael Thomas
Attorney at 'Law
P.O. Box 2104
Reidsville NC 27323-2104
Attorney for Petitioner
Anita LeVeaux Quigless
Assistant Attorney General
N.C. Department of Justice
P.O. Box 629
Raleigh NC 27602-0629
Attorney for Respondent
This the 1 day of October, 1996. _
Office of Administrative ]Tea!'ngs
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447
919/733-2698

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
1 �r ee, ,1
August 30, 1996
Mr. D. Kelly Almond, City Manager
City of Reidsville j �Ck,,Ck,�-
230 West Morehead Street
Reidsville, NC 27320-3855
Dear Mr. Almond:
ID H NFZ
s a� V-"G 4 -/Gv Wit f �J
� 11 v►rs� how-FG� -z-
SUBJECT: City of Reidsville
Approval of the
Plans and Specifications
Haw River Effluent Outfall
Project No. CS370384-04
The review for completeness and adequacy of the project construction plans and
specifications has been concluded by the Construction Grants & Loans Section of the
North Carolina Division of Water Quality. The Construction Inspection Unit's
Biddability/Constructibility comments, including all the minor comments, have been
satisfactorily resolved and incorporated into the plans and specifications.
Therefore, said plan documents are hereby approved with the stipulation that
contracts shall not be awarded until the NPDES permit adjudication process, currently in
progress, has been satisfactorily resolved, the City has obtained a permit for discharge to
the Haw River, and an Authorization to Construct has been issued.
Construction Grants & Loans Section �Aw� FAX [phone]
P.O. Box 29579, Raleigh, North Carolina 27626-0579 �� An Equal Opportunity/Affirmative Action Employer
Voice 919-733-6900 7T ON - - 50% recycles/10% post -consumer paper
w

2
Eli,�ble
Eligibility for Revolving Loan Funding has been determined as follows:
Modifications and additions to the City of Reidsville's 7.5 MGD Wastewater
Treatment Plant with no increase in capacity to include installation of variable frequency
drives for two of the existing raw wastewater pumps (Pumps 2 and 3) in the influent
pump station; partial demolition of the existing concrete post -aeration basin; construction
of a 15 MGD effluent pumping station with four (4) vertical turbine pumps, pump control
building, and high-water alarm system; effluent sampler relocation; replacement of three
(3) existing positive displacement blowers in the Sludge Digester Building; and
construction of approximately 32,000 linear feet of 30-inch effluent force main
discharging to the Haw River.
Non -Eli , ible
Owner's protective liability insurance [Additive Bid Items VII A(i), VII B(i),
VII C(i)].
Funding for this project is limited to the proposed loan amount of $5,800,000.00
established and approved by the Environmental Management Commission. In the event
that received bids exceed this established amount and local funds are not adequate to
award contract(s), it will be necessary to consider all alternatives including redesign,
readvertising, and rebidding.
Neither the State or Federal Government, nor any of its departments, agencies or
employees is or will be a party to the invitation to bids, addenda, any resulting contracts
or contract negotiations/changes.
If the Recipient does not maintain the court sanctioned schedules which extended
the compliance date for complying with the final effluent limits established in the NPDES
Permit, then project costs incurred will not be eligible for Revolving Loan payments.
Your project is subject to the one-year performance certification requirements. By
this, you are required on the date one year after the completion of construction and initial
operation of the subject treatment facilities, to certify, based on your consultant engineer's
advisement, whether or not such treatment works meet the design performance,
specifications and the permit conditions and effluent limitations.

In accordance with the Federal Regulations, the Recipient is required to assure
compliance with the OSHA safety regulations on the subject project. In complying with
this regulatory responsibility, the Recipient should, by letter, invite the Bureau Chief,
Education and Training Bureau, North Carolina OSHA Division, 319 Chapanoke Rd.,
Raleigh, North Carolina 27603 (telephone [phone]), to participate in the
Preconstruction Conference to assure that proper emphasis is given on understanding and
adhering to the OSHA regulations.
It is the responsibility of the Recipient and the Consultant Engineer to insure that
the project plan documents are in compliance with Amended N. C. G. S. 133-3 (ratified
July 13, 1993). The administrative review and approval of these plans and specifications,
and any subsequent addenda or change order, does not imply approval of a restrictive
specification for bidding purposes; nor is it an authorization for noncompetitive
procurement actions.
Any addenda to be issued for subject project plans and specifications must be
submitted by the Recipient such that adequate time is allowed for review/approval action
by the State, and for subsequent bidder action prior to receipt of bids.
It is mandatory for project facilities to be constructed in accordance with the North
Carolina Sedimentation Pollution Control Act, and, when applicable, the North Carolina
Dam Safety Act. In addition, the specifications must clearly state what the contractors'
responsibilities shall be in complying with these Acts.
Prior to entering into any contract(s) for construction, the recipient must have
obtained all applicable project Permits from the State, including an Authorization to
Construct and/or Non -Discharge Permit.
Do not advertise for bids on the construction of this project until receipt of a proper
Wage Rate Decision from EPA that will not expire before bids can be received and a
tentative contract award made. Contact the Project Management Unit (919/715-6217) for
Wage Rate Decisions required in bid documents prior to advertising.
While rejection of all bids is possible, such action may be taken only with prior
State concurrence, and only for good cause.
Positive efforts shall be made by Recipients and Consultants to utilize small
business, minority -owned business, and women -owned business sources of supplies and
services. Such efforts should allow these sources the maximum feasible opportunity to

4
Positive efforts shall be made by Recipients and Consultants to utilize small
business, minority -owned business, and women -owned business sources of supplies and
services. Such efforts should allow these sources the maximum feasible opportunity to
compete for subagreements and contracts to be performed utilizing Federal loan funds.
The Recipient shall comply with the provisions of 40 CFR, Part 7, Subpart C -
Discrimination Prohibited on the Basis of Handicap.
Attached is one (1) copy of the Project Review and Cost Summary (Approval to
Award) which is to be completed within 21 days after bids have been received, and
submitted to the State for review. It must be accompanied by documents including a
detailed cost breakdown showing units, unit cost, and value of the eligible work. Upon
review and approval of this information, the State will authorize the Recipient to make
the proposed award.
Do not proceed with construction until the Authorization -to -Award package and the
EEO and MBE documentation/certification have been reviewed, and you are in receipt of
our approval, if a Federal loan is desired for project construction.
Two (2) copies of any change order must be promptly submitted by the Recipient to
the State. If additional information is requested by the State, a response is required within
two (2) weeks, or the change order will be returned without further or final action.
One (1) set of the final approved plans and specifications will be forwarded to you.
One (1) set of plans and specifications identical to the approved set must be available at
the project site at all times.
Upon completion of the project construction, the Recipient shall submit a letter
confirming that the project has been constructed in accordance with the plans and
specifications approved by the State. "As -built" plans will need to be submitted with any
changes color -coded on the plans if the above confirmation cannot be made.

If there are any questions concerning this matter, please do not hesitate to contact
Mr. Cecil G. Madden, Jr., P. E. at [phone].
Sincerely,
John R. Blowe, P.E., Chief
Construction Grants & Loans Section
Attachment
RPT/pe
cc: Finkbeiner, Pettis & Strout w/a
David Barnwell (OSHA)
Winston Salem Regional Office
Joe Martin
Tom Fahnestock
Allen Wahab
Robert Teulings
Don Evans
Valerie Lancaster
Colleen Sullins
DMU
SRF

Organization: DEM Water Quality To:
[e-mail] Date: Mon, 8 Jul 1996 7:50:34 EST
Subject: Forwarded: Reidsville needs Reply -to:
[e-mail] Priority normal
PLEASE GET ME THE SKINNY ON THIS. IF ATC CLOSES AND THEIR WASTE FLOW
IS ELIMINATED FROM THE SYSTEM, COULD REIDSVILLE ACCEPT ENOUGH REDUCTION
IN FLOW TO REDUCE THEIR IWC TO A LEVEL THAT WOULD RESOLVE THE TOX
ISSUE??
Date: Sun, 07 Jul 96 21:27:07 EST From: "linda rimer"
<[e-mail]> To:
[e-mail] Cc:
[e-mail], Gina [e-mail],
[e-mail], [e-mail]
Subject: Reidsville needs
In my mail this weekend was a letter to the Governor from the
mayor of Reidsville (which had been sent to the Secretary by Wayne
McDevitt and Ann Lichtner to advice on how to respond). It
seems that Brown and Williamson tobacco co has purchased American
Tobacco company and the ATC plant in Reidsville will be closed. Not
only will Reidsville lose 1000 jobs but also 23% of our tax base - and
a large use of their water and sewer system. Rockingham County
is listed as distressed. Reidsville is trying to relocate
their wastewater treatment discharge point from the Little
Troublesome Creek to the Haw River. that this
is necessary "only to be incompliance with the toxicity parameter"
- whatever that means!. Anyway, they are asking the governor
for help - (1) to identify any additional funding for the Haw River
Outfall Project - e.g. economic develop grants? and (2) help
working their way "through the regulatory processs in getting an
acceptable permit to discharge at the Haw River location". He
indicates that that they are going through some kind of
adjudicatory process on the proposed NPDES permit. Why am I
emailing you about this on Sunday evening?! I can hear someone
respect a lot "saying" to themselves - "Linda - get a life!"
However, I am sending this so you will have it first thing tomorrow.
the letter to the governor is dated may 22. The note to the Secretary
is dated June 20. Tomorrow is July 8. 1 will send a copy of
the letter to you tomorrow - but we will need to look into the
situation as soon as possible. Hope everybody had a great july 4!
-2-

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03-06-09
.03-06-1
unw un Y.S.LLPLI.I Ialam LL smu.
:■
Exhibit 1. Use Support Map for Cape Fear Basin #1
03-06-02
Cape Fear. # 1
Supporting
14
0 Supporting - threatened
i - 03-06-05 LJ Partially Supporting
z Not Supporting
03-06-12 I
Cape Fear River Basin #1
— W 7 Use Support Map for
Cape Fear Basin #1
k ` 03-06-11
N.C. Department of Environment,
Health, and Natural Resources
� n
Division of Environmental Management
'� Water Quality Section

Exhibit 2. Factors Affecting In -Stream Dissolved Oxygen
Haw River Discharge Permit Contested Case Hearing
• Amount of flow in river:
river flow relative to amount of wastewater discharge
• Background or initial conditions of river:
dissolved oxygen, temperature, existing waste load
• Amount and characteristics of wastewater discharge:
BOD, ammonia, dissolved oxygen, temperature, waste degradation rates
• Physical characteristics of river and streambed:
slope and type of river bottom plus velocity of water affect reaeration rate
WASTEWATER
DISCHARGE
INITIAL
CONDITIONS
OXYGEN REPLACEMENT FROM
NATURAL REAERATION
FLOW
\ �► RESULTING
� WATER
DISSOLVED OXYGEN OUALITY
DEPLETION AS ORGANISMS
UTILIZE OXYGEN TO
DEGRADE BOD AND AMMONIA

Exhibit 3. Biochemical Oxygen Demand (BOD)
Haw River Discharge Permit Contested Case Hearing
Calculated value of dissolved oxygen consumed by bacterial respiration and
chemical reactions in the course of waste decomposition. Expressed in mass of
oxygen per unit volume of water, typically milligrams per liter.
Time = 0
Add wastewater to laboratory bottle, dilute with distilled water as necessary.
Measure dissolved oxygen. Seal bottle.
O
O
O
O
O
O
O
O
O
Time = t
Measure dissolved oxygen.
9
A
W
Let Bottle Volume =1 liter and
DO = 9 milligrams (number of
bubbles)
DO = 3 milligrams
BOD at time t is equal to the difference in the dissolved oxygen divided by the volume of the
bottle.
BODt = 9 mg - 3 mg / lliter
6 mg / liter

Exhibit 4. BOD Relationships
Haw River Discharge Permit Contested Case Hearing
L

Exhibit 5. Governing Equation for Degradation of BOD
Haw River Discharge Permit Contested Case Hearing
Lt = L(1-ekdt)
Where:
Lt = BOD at time t
L = Ultimate BOD
kd = decay rate coefficient
t = amount of time
For any time t, setting the value of any two of the three variables Lt, L, or kd will
determine the value of the third variable.
In the DEM desktop or level B model, the value for kd was selected independently
of the values used for L and Lt.

cov�jear
0•
EXHIBIT 6. CBOD vs TIME
HAW RI ER DISCHARGE PERMIT CONTESTED CASE HEARING
40.0
35.0
soao 0000c000000aaCM oaeeooeooc ea axee00000AN ooaaoa000m xaooeoaaeooec 4"aoeaoa000> X*
Ale
30.000 ao-Y
6° iiiiiiiii,lil r
s
• I
25.0- r _Vo
E 20.0 4 '
o6 Ih
e 5flt -
h0 rloo
10.0
f
f
•
5.0 �
0.0
0 20 40 60 80 100 120 S�,w..i�40
_ TIME (days)
DEM CBOO ""'"'°" 'kd=0.20 kd=0.038

Exhibit 7 Water Quality Model Results
Haw River Discharge Permit Contested Case Hearing
A comparison of DEM Level B and Reidsville QUALM water quality model results for varying input parameters.
Input Parameter
Case 1
Case 2
Case 3
DEM Level B
QUAL2E with DEM
QUAL2E with
guidance defaults
CBOD/BOD5 ratio
and Kd decay rate
from June 1993
sample
CBOD/BOD5 ratio
8
2
7.4
kd
0.22
0.22
0.056
CBOD
40.5 in r 1
25.0
88.8
Model prediction of resulting
3.89 mg/l
5.06 mg/l
5.05 mg/1
minimum DO
.
Allowable BOD5 to maintain DO
< 5.0 mg/l
12.5 mg/1
stream standard

Exhibit 8. Revision 1 to QUAL2E Model Results
Haw River Discharge Permit Contested Case Hearing
A comparison of QUALM water quality model results for varying inital conditions of dissolved
oxygen.
Input Parameter
Case 3
Case 4.
QUAL2E with
QUAL2E with
CBOD/3OD5 ration
reduced DO as initial
and kd decay rate
condition
from June 1993
sample
CBOD/BODS ratio:
. 7.4
7.4
air kd:
0.056
0.056
CBOD
88.8
88.8 m
Inital DO, % of saturation
90%
85.7%1
Model prediction of resulting
5.05 mg/l
5.02 mg/1
minimum DO
Allowable BOD5 to maintain DO
12.0 mg/1
12.0 mg/1
stream standard
.
Notes: 1. Mean percent of saturation of dissolved oxygen from
Ambient Monitoring System Station "Haw River at US 29A
near Benaja, NC", Storet No B0050000, June 1985 to June
1995.
Yl- %\�
ke -Q k-a V-
Vb#\IQ

Exhibit 9. Revision 2 to QUAL2E Model Results
Haw River Discharge Permit Contested Case Hearing
A comparison of QUALM water quality model results for varying inital conditions of sediment
oxygen demand.
Input Parameter
Case 3
Case 5.
QUAL2E with
QUAL2E with
CBOD/BOD5 ration
sediment oxygen
and kd decay rate
demand
from June 1993
sample
CBOD/3OD5 ratio:
7.4
7.4
kd:
0.056
0.056
CBOD
88.8
74.0 mgq
Sediment Oxygen Demand Rate
0
0.05 ft2-dl
Model prediction of resulting
5.05 mg/l
5.15 mg/l
minimum DO
Allowable BOD5 to maintain DO
12.0 mg/l
10.0 mg/l
stream standard
Notes: 1. Average of order of magnitude values for sandy stream
bottom, from Wastewater Engineering, Treatment, Disposal,
Reuse, 3rd Ed. Medcalf & Eddy, Inc. McGraw-Hill, Inc. 1991.

Exhibit 10. Revision 3 to QUAL2E Model Results
Haw River Discharge Permit Contested Case Hearing
A comparison of QUALM water quality model results for varying inital conditions of dissolved
oxygen and sediment oxygen demand.
Input Parameter
Case 3
Case 5.
QUAL2E with
QUAL2E with
CB0D/BOD5 ration
reduced DO as initial
and kd decay rate
condition and with
from June 1993
sediment oxygen
sample
demand
CBOD/BOD5 ratio:
7.4
7.4
kd:
0.056
0.056
CBOD
88.8
51.8 m
Initial DO, % of saturation
90%
85.7%1
Sediment Oxygen Demand Rate
0
0.05 fl -&
Model prediction of resulting
5.05 mg/l
5.10 mg/1
minimum DO
Allowable BOD5 to maintain DO
12.0 mg/1
7.0 mg/l
stream standard
Notes: 1. Mean percent of saturation of dissolved oxygen from
Ambient Monitoring System Station "Haw River at US 29A
near Benaja, NC", Storet No B0050000, June 1985 to June
1995.
2 Average of order of magnitude values for sandy stream
bottom, from Wastewater Engineering, Treatment, Disposal,
Reuse, 3rd Ed. Medcalf & Eddy, Inc. McGraw-Hill, Inc. 1991.

gAv i
0� :tp, / I
SELECTED PARAMETERS
Haw River Dischargers
PARAMETER*
Glen Raven
Mills WWTP
Cone Mills WWTP
North Buffalo
WWTP
T.Z. Osborne WWTP I
teidsville
WWTP
Flow, MGD
0.090
1.25
1.25
16.00
20.00
30.00
40.00
7.50
BOD5 mg/l
lb/day
56.0**
10/20+
5/10
(CBOD) 8/16
(CBOD)11/22
4/8
4/8
(CBOD) 4/8
41.9
100
Sp
) 3 3 q
1835/3670**
2000**
%1-334 2668**
3 l
NH3-N mg/1
lb/day
No limit
2/4
2/4
4/8
3/6
2/4
2/4
2/4
500/1000
500/1000
667/1 �34
Issue Date
'
09/01/95
Initial Date
3 years after
issue
04/01/96
01/01/96
Upon expansion
to 30 MGD
Upon expansion
to 40 MGD
Draft
Expiration Date
08/31/00
3 Years
01/31/01
01/31/01
12/31; 02
11/30/00
*Monthly average values
**Equivalent Value
'Summer/Winter

SELECTED PARAMETERS
Haw River Dischargers
PARAMETERS
Burlington East
WWTP
Burlington South
WWTP
Graham
WWTP
Flow, MGD
12.0
12.0
3.5
BOD mg/l
12/24+
9/18
12/24
NH3-N mg/l
4/8
3/6
4/8
Effective Date
04/01/96
---------
---------
Expiration Date
1/31/01
1/31/01
1/31/01
{Summer/Winter

A TARE Environmental Inc.
9305 JMonroe Road
Charlotte, NC 28270
Fax Cover Sheet
DATE: March 21, 1996 TIME: 11:40 AM
TO: C.D. Malone FAX: [phone]
Hydro Management Services, Inc
FROM: David Love PHONE: [phone]
AWARE Environmental Inc. FAX: [phone]
RE: Long-term BOD Study, Reidsville WVVTP
AEI Job No. N323-01
Number of pages including cover sheet: 4
Message
Have performed review of DEM BOD lab data sheets, note that results from 6/16/93
sample are for total BOD adjusted for seed demand. We calculated intermediate and final
NBOD and subsequent CBOD values using an assumed total nitrogen value of 17 mg/1
and exponential "best fit" estimates of intermediate TILT and NOx values. Ultimate
CBOD value is approximately 33.8 mg/l and is reached at approximately 80 days. With
BOD5 at 4.57 mg/l, CBOD to BOD5 ratio is 7.4. Comparison plot of total BOD and
CBOD is attached as Figure 1.
We continued evaluation by calculating a k value to produce a predicted CBOD that
matched the DEM results. Calculations yielded a k value of 0.03 8. Recall that k value
used in DEM model was 0.22. Figure 2 displays actual CBOD results plus predicted
CBOD results with k values of 0.038 and 0.22.
HAL CBOD data through Day 30 has been entered into NCASI forecasting routine to
predict ultimate CBOD and k values. Results were much higher than expected, exceeding
DEM results. We will update as more data becomes available. Figure 3 is a plot of DEM
and HAL CBOD results. HAL numbers are consistently lower than DEM.
We expect day 35 nitrogen data from HAL on Friday morning (3/22/96) and will update
plots accordingly. Thank you for your patience, please call if you have any questions or
need additional information.
Hard Copy to Follow [ ] [✓]
Yes No

60
50
40
co
E 30
O
m
20
10
0
Figure 1. Total BOD and CBOD vs. Time
DEM Long-term BOD Analysis, 6/16/93 Sample from Reidsville WWTP
• 00
r�•
•go
00
i
40
0 20 40 60 80 100 120 140
Time (days)
DEM Total BOD
• • DEM CBOD

40
35
30
25
c
CD
E 20
In
O
m
/,
MF72
10
5
0-V
0
Figure 2. CBOD vs. Time
Comparison of predicted and actual CBOD for varying decay rates.
•
r
•
i
00
i�
o�
20 40 60 80 100 120 140
Time (days)
DEM CBOD
-CBOD k = 0.038
"° -CBOD k = 0.22

40
35
30
25
ed
E 20
0
0
m
15
10
5
0-P
0
Figure 3. DEM and HAL CBOD vs. Time
• w • w • • • • r■ � � � w ■ w ■ w r■
• on
so
•
•
lop
on
i
it
20 40 60 80 100 120 140
Time (days)
• ■' DEM CBOD
�HAL CBOD

State of North Carolina IT
Department of Environment,
Health and Natural Resources 4• •
Division of Environmental Management .Jr
i
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E H N F1
A. Preston Howard, Jr., P.E., Director
March 18, 1996
Mr. Kelly Almond, City Manager
City of Reidsville
230 West Morehead Street
Reidsville, North Carolina 27320
Subject: Adjudication Settlement Proposal
Permit No. NCO024881
City of Reidsville WWI?
Rockingham County
Dear Mr. Almond:
Thank you for the opportunity to meet with you and C.D. Malone on February 29, 1996 to discuss potential
solutions to the matter of the permit adjudication for the above -referenced permit. To summarize the meeting, both
parties recognized that the Haw River, although larger than Little Troublesome Creek, has limited assimilative capacity.
You and Mr. Malone shared information prepared by AWARE Environmental regarding the assumptions of the stream
model used to help determine permit limits for five-day biochemical oxygen demand (BOD5) and ammonia (NH3).
During this discussion. you contended that the long-term BOD test used to set the ultimate carbonaceous
biochemical oxygen demand (CBOD) in the Division's model of this proposed discharge to the Haw River was collected
during an unrepresentative discharge period. Specifically, one major industrial contributor was experiencing difficulties
at their pretreatment plant and another was not discharging at normal operating flows. Based on this information, the
Division reviewed its files to determine if other long-term BOD tests have been made on the Reidsville W WTP effluent
in the past. Two other tests have been completed which documented CBOD:BOD5 ratios of 3.9:1 (collected prior to the
wastewater treatment plant upgrade) and 7.1:1. You also shared with us the fact that Reidsville is in the process of
making another analysis of the ultimate BOD in their wastewater.
The Division is willing to consider the results of past tests, the test currently being run by the City of Reidsville
and another test (run by the Division) in a reassessment of the CBOD:BOD5 ratio used in the model. Specifically, the
Division will agree to average the results of four tests completed after the plant expansion to use in another model run.
The Division will agree to the placement of the resultant limits in the permit without modifying other assumptions made
in the initial modeling.
I would also like to put forward two other proposals for your consideration. First, the City of Reidsville could
agree to accept the permit with the understanding that a field study would be completed by the city which would be used
to calibrate a QUAL2E model. The Division and the City of Reidsville would agree to accept the results of the modeling
effort as the limits necessary to protect the stream. We would be glad to discuss the requirements of such a study with
you. Finally, the city could choose to "trade" some of their allowable discharge of nitrogenous biochemical oxygen
demand (in the form of NH3) for a higher BODS limit. Specifically, after determining the appropriate CBOD:BOD5
ratio, the Division would agree to increase the limit for BOD5 proportionally to the decrease in NBOD. This final option
would be based upon the completion of the long-term BOD tests by Reidsville and the Division.
If this agreement is acceptable to you, please sign the attached withdrawal form and return it to the Office of
Administrative Hearings. If you have any questions concerning these proposals, please contact Mr. Dave Goodrich at
telephone number [phone], extension 517 or me at extension 500.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
Permits and Engineering Unit
Anita Quigless, Attorney General's Office
Bobby Blowe, Construction Grants and Loans
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10 % postconsumer paper

!/. /yam/ /(-,X-
Pr
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CITY OF REIDSVILLE
i
L WEL B MODEL REVIEW
CITY USED QUALM
NCDEM USED LEVEL B
• City calibrated and compared LEVEL B to QUALM for upper reaches of Haw River -
Excellent comparison.
• CBOD/BODS Ratio of 8.1 used
• Reaction Rate Coefficient, km of 0.22 used
These data arc inconsistent. A high CBODBODS Ratio of 8.1 would indicate a much louver
reaction rate coefficient than kd = 0.22
Employing the relationship Lt/L = e-'a'
Where
Lt = BODY, L = CBOD, t = time
kd = reaction rate coefficient
By selecting values for any two of the three variables (Lt, L, kd), the value of the third variable is
determined by the relationship.
Thus using
And
CBOD = 25 mA the maximum allowable value, which would not violate the 5.0 mg/l D.O.
Std (as per QUALM Figure 4)
kd = 0.22 (as, per LEVEL B) then the calculated BOD5 = 16.7 mg/1, resulting in a
CBODBOD5 Ratio = 25/16.7 =1.5
Z0'd 69tO 99L OT6 'OUI sons 36W oJP44
Wdee:oe 966T-Lz-ze

ATTACHMENT 1. DISSOLVED OXYGEN DATA FROM NORTH BUFFALO CREEK
I I
7.2 7.0 6.2
611/93
6/2/93
6.4 5.2
6/3/93
7.0 7.0 5.91
614/93
.Yr. . . . . .
7.0 6.8 36.3
617/93
5.3
7.6
6/8/93
6.9 6.6 6.2
6/9/93
6.7 7.2
6/10/93
8.5 5.8 . .... ...
6.(
6111/93
8.0
6/14/93
6.0
7.9 S. ----- ----
6115/93
7.3- 6.6 8.3
6/16/93
7.9, 5.9
6/17/93
7.2 5. 8.2
6118/93
7.2 5.5
4-9..
1
6121/93
. . . . . . . . . . . . . . .
4.9
6122193
7 2
6/23/93
7.0 5.3
4.-
6/24/93
7.3
6125/93
7.1 5.7
6128/93
7.2 6.3 4.
6129/93
7.2 6.6: 6.8
f%
6/30/93
7.0 6.0
7/1/93
6.3 so 5.3
7/2193
6.6 5 . 3'
7/5193
- 5
4.9 .7
7/6/93
6.3
7/7/93
6.0 4.9
7/8/93
5.3 5.0
7/9/93 6.
:T-7
7/12193 -------.0 5.
10
7/13/93 .........
.
7/ 14193.:.
MI.; Z,
..
?/15/93
.........
...... . . . . . . . . . . .
.... .
5.2
7/16/93
......
6.0
5.
7/20/93
5.0
7/21/93.,
7
7/22/93
50
7/23193
5.9 5.0
7/26193
6.2 5.2
6.4 5.3
7/27/93
7/28/93
6---o
7/ 29/93
7/30/93
# of measuments
84------- 84 35 35
9 22 33 7
a -c 5 ma/I
--TRc2a
4.9
5.0
5.0
5.3
8.2
5.81
35
SEP 421 1993'
*VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINTICENTRAL FILES

WT OF REIDSVRdLE
WASrEWATER TREATMENT PLANT
At Current Flow levels:
98.5% BOD Removal Rate
Industrial Flow = 1.18 MGD
Domestic Flow = I. XM
Total = 2.87 MGD
whenFlow increases to 7.5 MGD
Assume BOD Removal Rate of 98% (to be conservative)
Effluent BOD Luau = 10 mg/l
Influent BOD 98 % Reduction Effluent BOD 10 mg/l
x WWJILP
X 10 500 nWl BOD Influent
(1-0-98)
Influent NHS-N = 8.5 mg/1
Equivalent Nitrogen Oxygen Demand
8.5 x 4.5, mga 02.- s 38 mg/l NBOD
mg/INM-N
500 mg/1 BOD - *38 mg/1 NBOD = 462 mg/1 BOD remaining,
462 mg/l x 8.34 x 7.5 MGD = 28.898 lb/day Max Influent BOD
Total Oxygen Demand (BOD + NBOD)
500 mg/1 x 8.34 x 7.5 MOD = 31,275 lb/day
G0*d 69VO 99L OT6 'Oul SOAS 16W 0JPRH
WdTO:t?O 966T-a--ZO

date
UPSTREAM CONE
25 yds. above outfali
temp DO % sat tunp
DOWNSTR.
Summit Ave.
DO % sat
EFF
BOD5
lbs/day
GREENSBORO UPST
at Influent Conduit ,
temp BOD5 DO % sat
5/4/95
16.6
7.7
79.0
17.1
7.7
79.9
61
14.5
2.9
5.4
53.0
5/9/95
20.8
8.0
89A
19.9
7.3
80.2
62
17.9
2.2
40.1
5116195
23.1
6.4
74.8
23.1
6.4
74.8
64
20.9
2.3
34.7
5/23/95
24.2
6.5
77.5
23.5
6.7
78.9
58
20.1
1.5
32.0
6/5/96
24.0
6.4
76.1
24.0
6.4
76.1
19
20.7
1.7
6.9
77.0
6/6/95
24.0
6.8
80.8
24.0
7.1
84A
17
21.0
4.0
6.9
77A
6/20/95
24.0
6.3
74.9
24.0
6.6
78A
18
20.6
2.1
5.4
'60.1
6/22195
25.0
7.0
84.7
25.0
6.8
82.3
20
23.6
2.4
5.9
69.6
6/26195
25.0
6.7
81.1
24.0
7.0
83.2
26
23.1
2.7
5.7
66.6
6/27/95
25.0
6.2
75.1
24.0
6.7
79.6
11
24.0
2.4
Y
58.2
6/29/95
24.0
6.3
74.9
24.0
6.3
74.9
49
22A
3.4
6.3
72.6
7/5/95
26.0
7.3
90.0
26.0
7.2
88.8
15
24.8
1.7
5.4
65.1
7/6/95
26.0
7.0
86.3
26.0
7.0
86.3
30
25.8
2.2
5.9
72.5
7/7/95
26.5
6.7
83.4
27.0
6.6
82.9
34
23.6
3.5
6.2
73.1
7/10/95
25.0
7.0
84.7
27.0
7.0
87.9
48
23.5
1.5
5.6
65.9
7/11 /95
25.0
7.4
89.6
26.0
7.0
86.3
31
24.6
1.4
5.5
66.1
7/13/95
25.0
6.7
81.1
26.0
6.7
82.6
35
24.7
1.3
5.8
69.8
7/17/95
26.0
6.6
81 A
26.5
6.7
83.4
44
24.5
3.2
6.2
74.4
7/18/95
26.0
7.0
86.3
27.5
6.7
84.9
30
25.6
1.8
5.5
67.3
7/20/95
25.0
7.0
84.7
26.5
7.0
87.1
33
25A
1.6
6.4
78.0
7/24/95
24.5
7.2
86.4
26.0
6.8
83.8
60
27.1
2.0
':...
57.9
7/25/95
25.0
6.3
76.3
26.0
6.2
76.4
39
26.4
4.6
48.4
7/27/95
27.5
6.6
83.6
27.0
6.6
82.9
46
26.7
3.8
,::::.
51.2
7/31 /95
26.0
6.9
85.1
27.0
6.8
85A
40
27.2
2.7
5.4
68.0
8/1 /95
25.5
6.6
80.6
27.5
6.4
81.1
45
26.8
2.4
5.3
66.3
8/3/95
25.0
7.1
85.9
27.0
6.7
84.1
45
26.3
1.9
,� :.
52.1
8/7/95
24.0
6.3
74.9
26.5
6.8
84.6
38
25.6
. 1.2
5.9
72.2
8/8/95
25.0
6.4
77.5
27.0
6.6
82.9
39
23.5
1.2
6.0
70.6
8/9/95
24.0
6.8
80.8
25.5
6.5
79A
44
22.7
1.2
6.5
75.4
8114/95
26.0
6.7
82.6
27.0
6.6
82.9
44
26.6
1.8
, fi :. s
58.6
8/15/95
26.0
6.4
78.9
26.0
6.5
80.1
45
27.7
1.8::
52.1
8/17/95
27.0
7.0
87.9
27.0
7.0
87.9
37
27.0
2.3
F-I
56.58/21/95
27.0
6.6
82.9
27.0
7.1
89.1
55
24.2
1.654.9
8/22/95
27.0
6.7
84.1
27.0
6.7 '
84.1
46
25.3
1.7
t .
48.7
8/24/95
26.0
6.2
76.4
27.0
7.0
87.9
67
24.8
1.7
5.0
60.3
8/29/95
26.5
6.8
84.6
27.0
6.8
85A
38
23.2
2.0
:. = ...
49.2
8/30/95
25.5
6.4
78.2
26.0
6.6
81 A
44
24.3
1.4
r4-5
53.8
8/31 /95
24.0
6.6
78A
25.0
6.9
83.5
47
24.7
2.1
:: S"
42.1

• 90 * d _U101
Available Aembon Capacity
41
450 UP x 24 Hr/day x 3.0 lb 02/HP-Fh* = 32,,400 lb/day Available
3.0 lbsO2/BP-Hr taken fmm Design fla calm HOUS.
Since
32,400 lb/day Available > 31.275 lb/day Needed
Effluent BOD limit of 10 =Vl and NR3-N of 4 mg/I is feasible.
90 od 69170 99L 0T6 eoui S3AS '46W OJOH
WCOO: Vo 966T-2z—m

Coro olschar+ge
10
9
8
7
-�•
6
..
5
O
�
4
3
2
1
0
DO PROALE
North Buffalo Creek
0 1 2 3 4 5 6
STREAM MLE
Jun '94 Jul '94 Aug '94

I
� CIO
Cityof Reidsville 230 West Morehead Street, Reidsville, North Carolina 27320 • [phone]
.3, 1996
Mr. Steve Tedder
NCDEHNR
Post Office Box 27687
Raleigh, NC 29535
Dear Mr. Tedder:
OFFICE OF THE CITY MANAGER
1�� yy�yJi[AiN � ky J
FEB 15 1996
WATET *0t_1A.11TY
The City of Reidsville discharges its treated wastewater into Little Troublesome Creek.
During low stream flood conditions, the discharge from our plant represents approximately ninety-
eight (98) percent of the stream flow. Being such a large portion of the stream has resulted in both
toxicity and metals problems. To resolve these problems, we decided through discussions with your
staff and the Winston-Salem Regional Office, to relocate our discharge line downstream to the Haw
River, and therein lies our predicament.
The NPDES Permit issued in draft fort, established limitations for the proposed Haw River
discharge point. The proposed limits for both BOD and Ammonia -Nitrogen remained at the same
level as in Little Troublesome Creek. These liinits place the City in a very difficult position. The
relocation of the discharge line is anticipated to cost in excess of 5.5 million dollars, yet we will not
be able to add additional customers to defray these costs, since we have currently allocated all of
our available BOD loading to existing users. If we could not add additional customers, the entire
cost of relocation of the line would have to be home by the existing customers. Our current sewer
rates are very high. Adding an additional 5.5 million dollars of indebtedness onto our current sewer
users will have a crippling effect.
In discussions with the Winston-Salem Regional Office, we understand that it would be
possible to gain additional BOD loading by evaluating (through the Headworks Analysis) the plant
capacity on a design basis, rather than basing the plant capacity on the NPDES Permit effluent
standard. We appreciate this consideration and intend to pursue this approach. If we are successful,
this would resolve part of our concerns.
v
®Recycled
Paper

f -
Mr. Steve Tedder
Page 2
February 13, 1996
In reviewing our proposed NPDES Permit limits, we have by necessity, become educated
to the process and procedure for establishing stream limitations. Your star provided us with the
actual model and input data employed. Our star and the consultants we retained to review the
model have questions regarding the input data. We believe that if more typical input parameters
were employed, higher BOD limits would be predicted by the model. We desire and are seeking
higher limits for both BOD and Ammonia -Nitrogen to provide us with a measure of safety in our
day-to-day plant operations. We have already experienced one excursion of the--5.0 mg/1BOD
limitation at our current hydraulic loading.
Because of our concerns with the model and having no remaining available BOD capacity,
the City elected to adjudicate the NPDES Permit limitations proposed for the Haw River. This has
caused another dilemma, in that, "Authorization to Construct" the new discharge line has been
withheld, pending resolution of the adjudicatory hearing. This could delay resolution of this
situation for an additional seventeen months or more, and require another Schedule of Compliance.
Further, it could jeopardize our priority standing in obtaining the money through the State
Revolving Loan Program.
The City of Reidsville is soliciting your assistance and input in resolving this matter. I
would be happy to meet at any time or location convenient to you. I anxiously await your reply.
If you should desire further input on this question or further clarification, please feel free to contact
C. D. Malone, President of Hydro -Management Services, (1-800-722-0469), who operates our
Wastewater Treatment Plant. Mr. Malone can discuss the particulars of this request with you.
Sincerely,
- __'.44 UA4.1�1
D. Kelly Almond
City Manager
DKA:asb

2/13/96 / 7:23 PM I2elaarill8 AM Te%RM rncra Pane 1 of 2 nanPG
This information is based on the Pretreatment Annual Report submitted by the Ci of Reidsville for the January through December 1994 Period.
Next Pretreatment Annual Report is due March 1, 1996 for the year of 1995.
Average and Maximum Q and BOD are averages of the 2 six month periods and the units are MGD and mg/L.
Average and Maximum Wday BOD are based on Average and Maximum Q
and BOD.
* Schlegel data is per Nadine Blackwell and
is 1995 data.
SlU
Daily Max
Monthly Avg
Avg Q 1-6/94
Q 1-6/94
Avg Q
Avg BOD 1-6/95
Avg BOD 1-6/951
Avg BOD
Avg Wday BOD
Beta Systems pipe 2
No Limit
No Limit
0.0012
-Avg
0.0018
0.0015
12.03
56.53
34.28
, 0.43
Boehme Filatex
187 Wday
No Limit
0.1172
0.1134
0.1153
111.6
104.5
108.05
103.90
Brown & Williamson
2000 Wday
1330 Wday
0.1343
0.1766
0.1555
496
436
466
604.15
Chace Precision p 2
313 Wday
No Limit
0.0344
0.0404
0.0374
19.18
32.01
25.595
7.98
Equity Group
1804 Wday
No Limit
0.1064
0.1528
0.1296
675
938
806.5
871.72
Reynolds Metals p 2
642 Wday
No Limit
0.0697
0.0753
0.0725
172.9
135.6
154.25
93.27
Schlegel Rubber p2
313 Wday
No Limit
0.0141
0.04
0.0271
178
155
166.5
37.56
Tamco Metal
No Limit
No Limit
0.004
0.004
0.004
75.45
74
74.725
2.49
Unifi
4253 Wday
3545 Wday
0.6265
0.4516
0.5391
86.65
1241
105.325
473.51
Slu
Daily Max
Monthly Avg
Max Q 1-6/941
Max Q 1-6/941
Max Q
Max BOD 1-6/95
Max BOD 1-6/95
Max BOD
Max Wday BOD
Beta Systems pipe 2
No Limit
No Limit
0.0025
0.002
0.0023
28.6
74.7
51.65
0.97
Boehme Filatex
187 Wday
No Limit
0.18
0.21
0.195
522
430
476
774.12
Brown & Williamson
2000 Wday
1330 Wday
0.197
0.192
0.1945
920
840
880
1427.47
Chace Precision p 2
313 Wday
No Limit
0.0512
0.0576
0.0544.
25.2
47
36.1
16.38
Equity Group
1804 Wday
No Limit
0.192
0.188
0.19
1263
1840
1551.51
2458.51
Reynolds Metals p 2 _
642 Wday
No Limit
0.093
0.0991
0.09611
435
433
434
347.66
Schlegel Rubber p2
313 Wday
No Limit
0.031
0.088
0.0595
340
260
300
148.87
Tamco Metal
No Limit
No Limit
0.004
0.004
0.004
85.9
74
79.95
2.67
Unifi
4253 Wday
3545 Wday
1.09721
0.08651
0.5919
163
200
181.5
895.89
No Reidsville SIU were Significantly Non -Compliant for BOD during 1994.
NOV for pretreatment permit limits were issued to Boehme, B & W, and Equity Group during 1994.
Pretreatment Units are:
Beta Systems pipe 2
Chem Precip
Reynolds Metals
DAF, Chem Preci
Boehme Filatex
Equiliz, Mixing
Schlegel Rubber
O&G Sep
Brown & Williamson
Screening
Tamco Metal
Chem Preci
Chace Precision
Chem Precip
Unifi
Aeration,2ndry Clr,Chem Add
Equity Group
E uil, Chem Preci

2/13/96 / 7:23 PM Raidsville BCD Toadinew Page 2 of 2 pages.
SIU
Daily Max
Monthly Avg
Avg Wday BOD
Beta Systems
No Limit
No Limit
0.43
Boehme Filatq
187 Wday
No Limit
103.90
Brown ,& Willi
2000 Wday
1330 Wday
604.15
Chace Precisi
313 Wday
No Limit
7.98
Equity 'Group
1604 Wday
No Limit
871.72
Reynolds Met
642 Wday
No Limit
93.27
Schlegel Rub
313 Wday
No Limit
37.56
Tamco Metal
No Limit
No Limit
2.49
Uniti
4253 Wday
3545 Wday
473.51
SIU
Daily Max
Monthly Av
Max Wday BOD
Beta Systems
No Limit
No Limit
0.97
_
Boehme Filate
187 Wday
No Limit
774.12
Brown & Willi! 2000 Wday
1330 Wday
1427.47
Chace Precis!
313 Wday
No Limit
16.38
—
i
Equity Group
1 1804 Wday
No Limit
2458.51
Reynolds Mete,
642 Wday
No Limit
347.66
Schlegel RuU
313 #/day
No Limit
148.87
Tamco Metal
No Limit
No Limit
---2.67
Unifi
4253 Wday
3545 Wday
895.89

Aiii INC.
February 9, 1996
Mr. C.D. Malone
President
Hydro Management Services, Inc.
P.O. Box 1279, 2511 Neudork Road, Suite G
Clemmons, North Carolina 27012
RE: Haw River Water Quality Model
AEI Project Number N323-01
Dear Mr. Malone:
As outlined in our proposal dated January 16, 1996, AWARE Environmental Inc. (AEI) has
evaluated proposed limits on City of Reidsville wastewater discharges. Effluent limits of 5
mg/l of 5-day biological oxygen demand (BOD5) and 2 mg/1 of ammonia (NH3) have been
incorporated into the Reidsville discharge permit by the North Carolina Division of
Environmental Management (DEW. Results of water quality modeling performed by the
DEM Water Quality Section (Section) have been offered to justify these limits. An outline of
the model evaluation approach used by AEI and the results of further modeling are presented
below.
Description of Water Quality Models and Stud& Area
Water quality modeling performed by the Section involved the use of a Section -developed
"desktop" model, also referred to as the Level B model, to simulate the effect of oxygen
consuming wastes on in -stream dissolved oxygen (DO) levels. Oxygen -consuming wastes are
described in terms of carbonaceous biological oxygen demand (CBOD) and nitrogenous
biological oxygen demand (NBOD). Each of these waste loads is entered into the model at its
ultimate value. Hydraulic and kinetic model parameters for the model are based upon
commonly used empirical relationships. The Level B model is intended for preliminary
evaluations performed without verifying field data. Section documentation for the Level B
model is provided as Attachment A.
9305 MONROE ROAD • SUITE J • CHARLOTTE, N.C. 28270-1490 • TELEPHONE [phone] • FAX [phone]

As the Section's Level B model has not been released for public use, AEI chose the QUAL2E
Enhanced Stream Water Quality Model (Version 3.12, February 1995). This model,
developed under the auspices of the USEPA Center for Exposure Assessment Monitoring, is
widely used in the United States and by the DEM for stream studies and waste load
allocations.
Although the QUAL2E model offers the potential for greater technical sophistication, its use
here is limited to the Level B input. The QUAL2E results should not be interpreted as more
or less correct than the Level B results. None of the model results presented here have been
verified through comparison with field data.
The model area, as established by the Section, consisted of a 10.3 mile stretch of the Haw
River, beginning at the NC Highway 150 bridge and extending downstream to near the town
of Altamahaw. The portion of the river under study was divided into seven reaches to allow
for varying physical characteristics. The purpose of the modeling effort was to simulate the
effect of the proposed Reidsville WWTP outfall relocation from Little Troublesome Creek to
the Haw River. The portion of the river included in the model and the surrounding area are
pictured in Figure 1.
Establish QUAL2E Input Data ile
The first step in evaluating the Level B model results was to establish a QUAL2E input data
file which produced output similar to that of the Level B model. QUAL2E coefficients were
developed for hydraulic conditions to match within each reach the flow volume, velocity, and
depth numbers provided by the Section. Likewise, QUAL2E kinetic coefficients were
matched with Level B values to describe the stream reaeration rate (k ), the BOD decay rate
(kd), the ammonia decay rate (kN), and the temperature correction factors for each of these
coefficients (0). Water quality parameters of flow, temperature, CBOD, NBOD, and DO
were entered for the Reidsville WWTP effluent, for the background conditions in the river,
and for the tributary flows. A summary of the Level B and QUAL2E inputs is presented in
Table 1.
2

The Reidsville WWTP effluent is characterized in the Level B model input as having a CBOD
of 40.5 mg/1 and a NBOD of 9.0 mg/l. These numbers, referred to as the waste load
allocation, are derived from the proposed permit limits of 5 mg/ BODS and 2 mg/l NH3 using
multipliers of 8.1 and 4.5 for CBODBODs and NBOD/NH3 respectively. The BOD
multiplier is based upon a long-term BOD study performed on Reidsville WWTP effluent.
The ammonia multiplier is based upon the stotiometric requirements for oxidation of ammonia
to nitric acid and water.
Results of the QUALM simulation for DO and BODs, using the Level B input, are compared
with Level B results in Figure 2 and Figure 3 respectively.
As configured by the Section, the Level B model predicts a violation of the 5.0 mg/1 DO
standard producing a DO of 3.89 mg/1 approximately 4.8 miles downstream from the NC
Hwy. 150 bridge. This prediction is confirmed by the QUALM model when configured with
the Section's kinetic parameters and CBOD value.
Determination of Allowable Waste Load Allocation Given Section Kinetics and Waste Loading
To determine the maximum allowable CBOD which does not violate the 5 mg/l in -stream DO
standard, the QUALM model was run at CBOD values ranging from a low of 20 mg/l to the
40.5 mg/1 used by the Section. The NBOD loading, the hydraulic and kinetic parameters, and
the background conditions in the river were kept constant at the values used in the Level B
model.
The minimum in -stream DO predicted by the model for each CBOD value is presented
graphically in Figure 4. A CBOD of 25 mg/l represents the maximum assimilative capacity
of the model area based upon the QUALM results.
Evaluation of Section Kinett'c Coefficients and_ ODIBQQy atio
The oxygen load of an oxygen -consuming organic wastewater can be represented with a first -
order decay equation which when integrated from time zero to infinity is expressed as:
3

LVL=e d
where I.ti is the amount of first -stage BOD remaining in the water at time t; L is the ultimate
BOD, and kd is the reaction rate coefficient'. By selecting values for any two of the three
variables in this equation (Lt, L, kd) the value of the third variable is fixed by the mathematical
relationship.
Inspection of the Level B model input reveals that the combination of CBODBODS ratio of
8.1 is not consistent with a BOD decay coefficient (kd) of 0.22 when the BODS is taken to be
5 mg/l. The 8.1 CBODBOD5 ratio is based upon long-term BOD testing which indicates that
the Reidsville effluent continues to exert oxygen demand long after the "twenty to thirty day
period typical of municipal wastewater. For comparison, the Section guidance document for
the Level B model recommends a CBOD/BODS ratio of 1.5 to 3 in the absence of waste -
specific data. The kd value of 0.22 is typical of readily degradable municipal waste; however,
it is not compatible with the high CBOD/BODS ratio assumed by the Section. The ratio and
the coefficient are inversely related. For the CBODBOD5 ratio to be higher than normal, the
decay coefficient must be lower than normal given a specific value of BODS.
Determination of Allowable CBOD with Alternate Kinetic Coefficient and CB D/BOD5 Ratio
Using the mathematical relationship outlined above, alternate values for kd and for the
CBOD/BODS ratio were calculated. First, the resulting BODS was calculated using a CBOD
value of 25 mg/l, a kd of 0.22, .(conditions the model indicates the river will support) and the
derived relationship:
y5 = L(1-e a )
where y5 is BODS, L is CBOD, and kd is the BOD decay rate coefficient. The resulting GODS
is 16.7 mg/l. Using this kinetic relationship, the QUALM model predicts that the river is
capable of assimilating a Reidsville WWTP effluent BOD, in excess of 16 mg/l.
Wastewater Engineering, Treatment, Disposal, Reuse, 3rd Ed. Mecalf & Eddy, Inc. McGraw-Hill, Inc. 1991,
p. 73.
4

The second alternative was to keep the CBOD and BOD, values assumed in the Level B model
input ratio and to calculate the resulting 4 value using the referenced equation. With a
CBOD of 40.5 mg/l and BOD5 at 5 mg/l, the kd value becomes to 0.03 (rounded to two
decimal places).
To determine the effect of the calculated decay rate coefficient on the river DO, the QUAL2E
model was re -run with 4 = 0.03 and with the CBOD varying from 40 mg/l to 140 mg/l. A
plot of the minimum in -stream DO concentration versus the CBOD for this model
configuration is presented as Figure 6.
Using the revised kd of 0.03, the QUALM model indicates that a CBOD in excess of 120
mg/l can be supported by the river. With a CBOD/BOD5 ratio of 8.1, the resulting allowable
BOD5 becomes approximately 15 mg/l.
Conclusions
Use of the QUALM model with the Level B input as modified above indicates that
assimilative capacity exists for the Reidsville VWVTP to discharge to the Haw River up to 7.5
MGD at 15 mg/l BOD5 and 2 mg/l NH3. Using the existing input data, the Level B model
does not offer sufficient justification for the proposed BOD5 limit of 5 mg/l.
The following qualifications should be noted with regard to the model results:
No comparison of Level B or QUALM model results with actual field conditions
has been made;
• The model input assumes an initial river DO at ninety percent of saturation prior to
the wastewater discharge; this condition is questionable.
• No attempt was made to include BOD settling within the stream or BOD demand
from the streambed (SOD). The basin -wide plan mentions that SOD is a problem
in the upper reaches of the Haw River.
5

• The COB/BODS ratio used by the Section is extremely high while the resulting
calculated 4 value is extremely low. Actual conditions are likely to be more
moderate and may affect the resulting assimilative capacity.
Recommendatr'ons
AEI recommends that the following activities be performed as a part of the model evaluation:
• Review model results with regard to available field data. The DEM collects water
quality data at a number of stations in the Haw River and Cape Fear River basins.
The available information, managed by the USEPA in the STORET database, can
be used to confirm background conditions in the area. AEI has acquired STORET
data for five (5) monitoring stations in die -Reidsville area.
• Review the long-term BOD data. The CBOD value used by the Section in the
model reflects a slowly degrading, high demand waste not typical of municipal
effluent.
AWARE Environmental Inc. appreciates this opportunity to assist Hydro Management
Services, Inc. AEI is prepared to continue with the water quality modeling evaluation as
recommended above pending your approval. If you have any questions or require additional
information, please feel free to call.
Sincerely,
AWARE Environmental Inc.
Robert M. Stein, P.E.
President
Attachments
19999

Table 1. Model Input
Haw River Water Quality Evaluation
Parameggr Level B
Haw River
7Q 10 7.4 ft3/s 7.4 ft3/s
DO 7.3 mg/1 7.3 mg/I
Temperature 78.8 °F . 78.8 OF
CBOD 2.0 mg/I 2.0 mg/I
NBOD 1.0 mg/I
NH3 ---- 0.22 mg/I
Reidsville WWTP
Flow
19.0 ft3ls
19.0 ft3/s
DO
6.0 mg/I
6.0 mg/l
Temperature *
77.0 OF
CBOD
40.5 mg/I
40.5 mg/1
NBOD
9.0 mg/I
----
NH3
2.0 mg/I
Tributaries
Flow
Reach dependent
Reach dependent
(0.2 to 0.4 ft3/s)
(0.2 to 0.4 ft%)
DO
7.3 mg/l
7.3 mg/1
Temperature
78.8 °F
78.8 OF
CBOD
2.0 mg/I
2.0 mg/1
NBOD
1.0 mg/1
NH3
0.22 mg/1
* Waste temperature not specified in Level B input.

LEGEND
Population Center
OState Route
0 Town. Small City
US Highway
County Boundary
Major Street/Road
State Route
US Highway
Haw River -- -
Scale 1:135.000 (at center)
es
Figure 1. Location Map
Reference: DeLORME MAPPING Street Atlas USA, Version 2.0 for Windows

a
7
6
a 6
E
CD
04
O
0
3
2
1
Figure 2. Dissolved Oxygen vs River Mile Using Level B Input Parameters
�3ft
w
0.0 2.0 4.o 6.0 8.0 10.0 12.0
River Mile from Hwy 150
� QUAUE
LEVEL B
--DO = s mgn

30.00
25.00
20.00
c
E
15.00
0
m
10.00
5.00
0.00 4-
0.0
Figure 3. CBQD vs River Mile Using Level B Input Parameters
2.0 4.0 6.0 8.0 10.0 12.0
River Mile from Hwy 150 (mi)
--QUAL2E
'" " LEVEL B

6.00
5.50
5.00
F
cm
E
c
n)
cm
0 4.50
0
4.00
3.50
3.00
15
Figure 4. Minimum Dissolved Oxygen vs CBOD Loading Using kd= 0.22
20
25 30 35
CBOD (mgA)
40
45
EQUAL 2E DO
--DO = 5 mg/1

8
7
6
ado 5
E
2
1
0
Figure 5. Dissolved Oxygen vs River Mile Using CBOD = 25 mg/l & kd = 0.22
0.0 2.0 4.0 6.0 8.0
River Mile from Hwy 150
w
10.0 12.0
---DO = 5 moA
—QUAUE Do

6.5
6
4.5
4
Figure 6. Minimum Dissolved Oxygen vs CBOD Loading Using kd = 0.03
20 40 60 80 100 120 140 160
CBOD (mg/1)
�QUAUE DO
--DO = 5.0 mg/l

8
7
6
E
c
m
O 4
V
0
. 3
2
1
Figure 7. Dissolved Oxygen vs River Mile Using CBOD =120 mg/l & kd= 0.03
w
2.0 4.0 6.0 8.0 10.0 12.0
River Mile from Hwy 150
---DO = 5 mg/l,
�QUAUE DO

Page 1
Note for Jason Doll
From: Tom Poe
Date: Fri, Feb 9, 1996 12:05 PM
Subject: RE: Reidsville WWTP
To: Bo McMinn; Coleen Sullins; Jason Doll
Cc: Dave Goodrich
Of course an under loaded plant needs more BOD. Standard HWA are based on current
flows and actual average treatment effeciency. If any POTW has additional unused capacity
in place they may submit "Design" Headworks based on total hydraulic & design treatment
capacity. They may then issue pretreatment permit limits based on the design HWA. CD
Malone and Nadine Blackwell know this and can work with Bo and I to update Headworks.
In general, if any town is consistantly meeting NPDES limits, Sludge criteria, and the WQ
std in receiving stream we in pretreatment will do everything we can to help them work out
the allocations to satisfy all of their current users and accomodate controlled growth. We
have some flexibility in reviewing and approving pretreatment permit limits, because there is
no explicit prohibition against a "numerical" over allocation in the .0900 regs.
Bo is out today. I talked with Steve Mauney WSRO and Nadine Blackwell to let them know
we could work with them, to re-evaluate their HWA based on design treatment capacity so
they could have some more "concrete" numbers to use to plan on the amount of growth and
increased industrial loading DEM-pretreatment would allow. As always, these would be
contigent upon continued compliance with NPDES, Sludge, WQ std, & Tox. Revision,
submission, and even approval of Design HWA could be done as early as monday, 2/12/96,
by phone/fax. Nadine said she would talk with CD and call us back.
From: Coleen Sullins on Thu, Feb 8, 199617:26
Subject: RE: Reidsville WWTP
To: Bo McMinn
Cc: Dave Goodrich; Jason Doll; Tom Poe
Bo - to further clarify the issues, I need to relate my conversation with Steve Mauney. Steve
said that the current headworks analysis had established the load that could be effectively
treated by the WWTP. They have allocated the load that was calculated based on the
headworks to their industrial users. Per the town, they are able to treat the wastewater
without fully using their treatment plant. They have a very low F/M ratio, therefore, they
think that they could use more BOD loading and achieve better treatment overall. The region
is inclined to agree with them that this is a possibility. Steve said that he suspected that they
may have a "weak" influent and wondered the possibility of allowing them to take on more
load into the plant.
Per Jason's note, my understanding is that they would be willing to drop their adjudication if
they have some ability to take on some additional load into the system. Since I have not ever
been involved in a headworks analysis and do not have sufficient knowledge of the rules, I
can not respond as to our ability to revise the headworks numbers. However, I do know that
if they are suffering from a weak influent, additional BOD loading may help them achieve
better levels of treatment (including, possibly, tox) - which would result in a higher level of
protection of water quality, our end point in this whole thing. We need to proceed forward

Piedmont Triad Regional Water Authority. GS 162A-7 & 153A-285 Review
Document and Final Environmental Impact Statement, Randleman Lake, Randolph
and Guilford Counties, NC.
Piedmont Triad Regional Water Authority. Water Quality and Quantity Studies to
Support Randleman Lake Environmental Impact Statement. December 1990.
NC DEM. Water Quality Analysis and Model Lower Cape Fear River. June 1984.
NC DEM. Water Quality Evaluation. Upper Deep River. Cape Fear Basin. 1983.
February 1985.
NC DEM. A Water Quality Analysis of the Proposed Expansion of the Durham -
Farrington Road WWTP and Its Impact on New Hope Creek. May 1989.
Hydroscience. Water Quality Model of the Lower Cape Fear River. June 1990.
NC DEM. Rocky River Subbasin Nutrient Budget (Chatham County). May 1991.
NC DEM. A Wasteload Allocation Analysis for the Proposed Expansion of the
Mason Farm WWTP, Chapel Hill, NC. July 1991.
NC DEM. Review of Deep River/Carbonton Dam Water Quality Investigations
1992/1993. June 1994.
NC DEM. A Water Quality Analysis of the Cape Fear River from Buckhorn Dam to
Lock & Dam #3 using QUAL2EU. 1995.
NC DEM. A Water Quality Analysis of the Cape Fear River from Lock & Dam #3 to
Lock & Dam #1 using QUAL2EU. 1995.
NC DEM. A Water Quality Analysis of the Haw River from Reedy Fork to
Sawpahaw Dam using QUAL2EU. 1995.
NC DEM. A Wasteload Allocation Analysis for the Proposed Expansion of the
Greensboro T.Z. Osborne WWTP using QUAL2E,1995.
NC DEM. Analysis of Nutrient Loading in the Deep River Basin. 1995.
45

Page 2
with developing an answer to this question as quickly as possible, as the case is already
scheduled (March, I think). Please let me know if we need to sit down and discuss. Thanks
Coleen
From: Jason Doll on Thu, Feb 8, 1996 4:14 PM
Subject: Reidsville WWTP
To: Bo McMinn
Cc: Coleen Sullins; Tom Poe
As you are probably aware, the City is adjudicating the permit we have issued them for there
relocated 7.5 MGD discharge to the Haw River at Hwy 150 in Rockingham Co.. The chief
issues of contention are the limits assigned for BODS and NH3N of 5 mg/1 and 2 mg/l,
respectively. The City has represented recently that the chief reason they feel the need to
contest these limits is that they have effectively capped the headworks loading to the plant to
such a degreee as to render the facility incapable of issuing new permits for pretreatment
customers. This puts them in an allegedly untenable position because they have a fairly large
debt burden that needs to be serviced from the expansion to 7.5 MGD and the pending outfall
relocation.
Currently the plant is about half loaded hydraulically and only using about half of its aeration
capacity, according to David Russell (WSRO). So the million dollar question is why does a
plant that currently appears to be about half loaded not have any remaining alloaction in their
headworks loading for BOD. Could you take a look at the facility's pretreatment permits and
advise me as to whether or not they have overallocated any of their clients significantly, so
we can determine if that is the problem? If this issue really is their concern, we may be able
to address it in the next month and head off the adjudication, if its just the bluff they are
fronting with, I would like to call it before we go to court. Please keep me posted.
Thanks, Jason
PS Be advised that since these issues appear to be surfacing as major ramifications in this
case, I advised Anita (attoney from AG's office) that she should include you on the witness
list for the adjudication. Welcome aboard!

ROBERT C. WILLIAMS, COMMISSIONER
PUBLIC WORKS COMMISSION
WILLIAM H. OWEN. COMMISSIONER
W. LYNDO TIPPETT. COMMISSIONER
OF THE CITY OF FAYETTEVILLE
MILT WOFFORD, COMMISSIONER
STEVEN K. BLANCHARD. GENERAL MANAGER
ELECTRIC IS WATER UTILITIES
Environmental Section
August 26, 1994
Central Files
Division of Environmental Management
North Carolina Department of Environment,
Health, and Natural Resources
Post Office Box 29535
Raleigh, North Carolina 27626-0535
508 PERSON STREET
P.O. BOX 1089
FAYETTEVILLE. NORTH CAROLINA 283024089
TELEPHONE (AREA CODE 910)9834401
FAX(AREA CODE 910)483 1429
SUBJECT: Submittal Of Annual Pollutant Analysis
Rockfish Creek Water Reclamation Facility
(NPDES No. NC0050105)
To Whom It May Concern:
m
n
v
Attached please find two (2) copies of the Annual Pollutant
Analysis for the Public Works Commission's Rockfish Creek Water
Reclamation Facility. The APA was conducted on composite and grab
samples collected from Wednesday, July 13, 1994 through Thursday,
July 14, 1994.
The original report was sent to the Public Works Commission,
by Burlington Research, on August 17, 1994. We have not, to date,
received the original report, therefore we are submitting signed
facsimile copies with the July 1994 NPDES Monthly Report. As soon
as the original reports are received, we will forward clean copies
to the Central File Office.
We apologize for any inconvenience that this may cause your
office. If you should have any questions concerning this report,
please feel free to contact me at [phone].
Sincerely Yours,
PUBLIC WORKS /COMMISSION
Theresa G. Pereira
Environmental Compliance Supervisor
attachment
cc: Mick Noland
Don Register
Dickie Vinent
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ATTACHMENT 1. DISSOLVED OXYGEN DATA FROM NORTH BUFFALO CREEK,
Date Ups.
of Cone Summit Ave. Ups. of Gboro Ds. of Gtoro Rankin Mill Rd
4/1/93
9.0 8.8
4/2/93
8.8 9.2
4/5/93
9.5 8.8
4/6/93
9.6 9.2
4/7/93
9.0 8.8
4093
102 8.4 7.1
7.0 6.8
4/9/93
4112/93
4113/93
7.4 7.2
9.7 7.2
6.5 7.8
4114/93
9.9 7.2
4/15/93
9.3 7.3
4/16/93
7.7 7.8
4/19/93
4/20/93
9.2 6.0
8.2 6.5
5.2 5.3
4/21/93
7.4 5.4
4/22/93
8.3 7.0
4/23/93
7.9 6.5
4/26/93
4/27/93
6.8 6.2
8.2 6.9
5.8 4.9
4/28193
8.6
4/29/93
8.3 5.3
4/30/93
8.6 6.3
5/3/93
5/4/93
11.0 7.2
X M
515193
7.5 6.7
516/93
7.9 5.7
5/7/93
7.0 5.8
5110/913
7.3, 6.0
5.9
4.9 - ------ --
5111/93
9.2
5112/93
5/13/93
8.8
5/14/93
6117/93
8.0
5.81
5/18/93
6.2 5.6
5.3
5/19/93
6.3 5.9
5/20/93
7.0 6.2
5/21140030
6.6
5/24/93
7.0 5.3
6.4
6.4 8.2
5/25/93
8.0
5/26/93
6.9 6.4
5/27/93
7.9 5.7
6/28/93
7.3 5.9
i-
5/31/931
.........
S E P 1993
*VIOLATIONS OF THE D.O. STANDARD ARE SHADED AND SHOWN IN BOLD PRINT.
k.,L111TSAL 'IFILES

1
CITY OF RE)SVILLE
l '
i
IM-MATE AM IEsr REs M
1. Inconsistencies in the Nitrogen data between Day 0 and Day 5.
2. The Total Nitrogen decreases from Day 0 to Day 5.
3. Oxygen Uptake continued through Day 140. Seems unusual.
4. Noted on sheets that a large industrial contributor was off hinc on sample date.
5. Plant was in upset condition (See Supervisors Log Book).
i
6. Commenced another Ultimate ROD Test, which shows some significant differences.
d0'd 69d0 99L OT6 •Oul s3AS 46W oJPAH
WdTO:Vo 966T-2Z-ZO

dots
UPSTR. CONE
25 yds. above outtall
tamp DO % sat tow
DOWNSM EFF
Summit Ave. BODE
DO % sot §Yda
GREENSBORO UPST
at Influent Conduct
Boos Do % set
Sr"
14.6
8.7
85.6
15.0
8.8
87.3
30
17.0
2.8
49.7
5110/94
19.4
7.4
80.4
20.0
7.8
85.8
47
18.0
3.8
49.7
5/17/94
21.0
6.0
67.3
20.8
6.8
76.0
55
20.0
5.7
39.6
5/26/94
22.0
7.4
84.7
23.0
7.9
92-1
17
22.0
2.3
28.6
5/31 /94
25.0
6.6
79.9
24.0
7.5
89.1
46
22.0
7.1
24.0
6/7/94
24.0
5.8
68.9
24.0
5.8
68.9
40
24.0
4.3
20.2
6/9/94
23.0
5.3
61.8
23.0
5.3
61.8
30
23.0
5.5
30.3
6/10/94
23.0
5.4
63.0
23.0
5.8
65.3
48
22.0
3.2
,..
29.7
6/13/94
25.0
5.9
71 A
25.0
6.4
77.5
30
23.0
2.5
29.2
6/14/94
26.0
5.3
65.3
26.0
6.0
74.0
28
24.0
4.1
27.3
6/16/94
28.0
5.8
74.1
28.0
5.0
63.9
105
26.0
7.0
24.7
6/21 /94
29.0
8.0
104.0
27.0
6.9
74:1
79
26.0
6.9
32.1
MOM
26.0
5.3
65.3
26.0
6.0
74.0
109
26.0
3.9
f
30.8
6/24/94
25.0
5.6
67.8
26.0
6.0
74.0
114
24.0
4.8
57.0
6128/94
23.0
5.6
65.3
23.0
5.4
83.0
86
23.0
4.9
38.5
SM/94
24.0
8.2
73.7
24.0
5.4
64.2
75
22.0
4.6
48.1
7/1 /94
24.0
8.6
78.4
24.0
5.6
66.5
115
23.0
5.3
5.0
58.3
7/5/94
24.4
6.0
71.8
25.0
6.3
76.3
175
25.0
5.7
33.9
7/7/94
24.0
7.2
85.6
24.6
6.9
82.9
111
26.0
5.1
r.
25.9
7/8/94
26.4
6.3
78.2
26.8
6.9
86.3
125
27.0
6.1
26.4
7/12/94
25.1
6.2
75.2
25.4
7.0
85.4
106
25.0
4.0
-29.1
7/14/94
25.2
6.7
81.4
25.4
7.8
95.1
64
26.0
-6.4
25.9
7/15/94
25.8
6.3
77.4
25.9
7.9
97.2
76
26.0
5.8
30.8
7/19/94
27.0
7.8
97.9
27.2
9.0
113.4
71
26.0
4.3
30.8
7/21 /94
27.0
7.7
96.7
26.0
8.7
107.3
107
24.0
3.1
48.7
7/22/94
26.3
8.0
99.2
26.3
8.7
107.8
133
26.0
3.9
39.5
7/26/94
26.6
10.3 128.4
26.5
9.6
119.4
82
26.0
2.4
5.6
69.0
7/28/94
23.8
11.1
131.4
25.2
10.6
128.8
88
24.0
3.1
7.8
92.7
7129/94
23.0
10.3 120.1
23.0
10.3
120.1
91
23.0
4.9
8.5
99.1
8/2194
25.0
9.6
116.2
25.0
9.9
119.8
107
125.0
2.9
6.9
83.5
8/4/94
26.0
10.0 123.3
26.0
10.0
123.3
98
25.0
2.4
6.5
78.7
8/5/94
26.0
10.9 134.4
26.0
10.1
124.5
79
25.0
2.7
5.2
62.9
8/9/94
23.0
12.2 142.3
23.5
10.2
120.1
102
22.0
8.9
FBI
18.3.
8111 /94
26.0
10.6 130.7
26.0
10.7
131.9
78
24.0
4.9
39.2
8/12/94
26.0
9.7
119.6
26.0
10.2
125.8
90
24.0
3.0
.`
32.1
8/16/94
24.0
10.0 118.8
24.0
9.8
116.5
105
23.0
2.7
'. `
47.8
8/18/94
24.0
10.4 123.6
25.0
11.2
135.6
. 105
23.0
5.4
. io
52.5
8/19/94
24.5
10.0 119.9
25.0
10.9
132.0
122
25.0
2.2
::..
47.2
8/23/94
24.0
12.0 142.6
24.0
11.4
135.5
63
23.0
1.8
5.6
65.3
8/25/94
24.0
7.6
90.3
24.0
6.9
82.0
120
23.0
2.8
5.9
68.8
8/26/94
24.0
7.9
93.9
24.0
7.7
91.5
97
23.0
3.9
49.0
8/30/94
24.0
8.2
97.4
24.0
8.3
98.6
107
.24.0
3.0
7.4
87.9
9/1/94
24.0
7.3
86.7
25.0
7.3
88.4
134
24.5
120.3
2.2
6.2
74.4
9094
23.0
7.6
88.6
24.0
7.6
90.3
98
22.3
3.3
6.7
77.1
9/6/94
24.0
7.0
83.2
24.0
7.6
90.3
95
1.0
6.4
70.8
9/8/94
23.0
7.7
89.8
24.0
7.0
83.2
112
21.2
2.0
7.4
83.4
9/9/94
23.0
7.6
88.6
24.0
6.6
78.4
88
21.0
1.9
5.7
64.0
9/13/94
24.0
7.0
83.2
25.0
6.6
79.9
123
20.7
1.2
5.4
60.2
9/15/94
24.0
7.2
85.6
25.0
6.7
81.1
83
21.3
1.8
6.0
67.7
9/16/94
24.0
7.6
90.3
25.0
7.3
88.4
85
22.0
1.9
5.6
64.1
9/20/94
22.0
10.9 124.7
23.0
8.6
100.3
92
18.0
1.1
7.5
79.2
9/22/94
23.0
7.9
92.1
23.0
7.5
87.5
95
18.7
4.3
:'`'##
49.3
9/23/94
23.5
7.7
90.6
23.5
6.8
80.0
63
17.9
2.8
.`
49.6
9/27/94
24.0
7.3
86.7
24.0
6.9
82.0
119
20.1
1.9
5.1
56.2
9/29/94
22.0
8.6
98.4
22.0
7.8
89.2
77
18.7
3.6
5.5
59.0
9/30/94
21.5
9.6
108.8
21.5
8.8
99.7
43
17.5
1.9
5.7
59.6

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DIVISION OF ENVIRONMENTAL MANAGEMENT
December 15, 1995
MEMORANDUM
TO: Coleen Sullins
FROM: Jason Doll %�
THROUGH: Carla Sanderso
Ruth Swanek 2jC,S
SUBJECT: Items Under Adjudication
Petition for Administrative Hearing
City of Reidsville WWTP
Rockingham County
The Instream Assessment Unit IAU) has reviewed the petition filed with the Office of
Administrative Hearings on behalf of the City of Reidsville, and we have the following
comments:
The petition gives the chief issue of contention as the CBOD5 and NH3N limits
assigned to the 7.5 MGD discharge once it is relocated to the Haw River mainstem. The
limits assigned to the relocated outfall are necessary to protect water quality in the affected
area of the Haw River. The Haw River headwaters in this area are characterized by low
slopes and slow stream velocities which cause low rearation rates and, in turn, severely
limit assimilative capacity. Although we have not applied a field calibrated water quality
model as yet in this case, we have evaluated the water quality impacts of this discharge
using our empirical desktop (Level-B) model. It should be noted that the chief difference
between the Level-B model and a field calibrated model is that, instead of relying on
recently collected field data from the area in question, the Level-B model relies on a set of
assumptions that fit it to typical North Carolina streams on the basis of the state's
geographic regions and their hydrologic properties. In this case actual field data have
shown that most of the assumptions in the Level-B model work in favor of the permittee.
In other words, there is a strong potential that the Level-B model is overestimating the
assimilative capacity for this area of the Haw River. Even with the assumptions working in
Reidsville's favor, the model predicts a DO sag point about 5 miles downstream of the new
outfall site with a minimum instream DO of 3.9 mg/l. So preliminary modeling indicates
that capacity is so limited in this area of the upper Haw that advanced tertiary limits may not
be truly adequate to protect DO levels instream during critical conditions. A field calibrated
model, based on a more thorough assessment of the actual conditions of the affected area,
could very well produce even more dire predictions with regard to water quality.
The petition also contends that the assigned CBOD5 and NH3N limits are "below
DEM's own minnnum levels". DEM regularly assigns advanced tertiary treatment limits
for BODS and NH3N at 5 mg/1 and 2 mg/l, respectively, and assigns corresponding
CBOD5 limits at 4 mg/l. The difference in BOD5 and CBOD5 concentrations is due to the
fact that BOD5 accounts for oxygen demand from nitrogen, so BOD5 values are higher than
CBOD5 in a given effluent sample. In fact, U.S.EPA guidelines in the Code of Federal
Regulations use a CBOD5:BOD5 ratio of 25:30 (or 5:6) when defining secondary
treatment. Taking this ratio into account, the limits assigned in the Reidsville permit for the
Haw River discharge are no more stringent than the standard advanced tertiary treatment

limits given above. The same limits have been assigned to, and are consistently met by,
numerous dischargers of varying size and waste stream composition across North
Carolina. Additionally, the limits are no more stringent than those the Reidsville WWTP
currently meets consistently at the Little Troublesome Creek outfall site. Thus far, available
file records and various DEM staff personal accounts and meeting notes indicate that it has
been clearly communicated to the pennittee on several occasions that, upon relocation,
limits for oxygen demanding wastes would be no less stringent for the Haw River
discharge.
The petition goes on to state the limits are so stringent as to "effectively negate the
beneficial effect of... (the) Haw River Outfall project". This contention is very surprising,
given that documents submitted by, ;or on behalf of, the City during the approval process
for this project stated clearly that the sole benefit sought from the relocation was relief in the
Facility's chronic WET test limit. The current Reidsville WWTP WET test limit is P/F at
90% for the Little Troublesome Creek discharge, but the limit would be P/F at 61% for the
7.5 MGD discharge to the Haw River. Along these lines, it should also be noted that the
facility has reported, not only failing WET test results, but chronic values below the 61 %
level that would fail to comply at the proposed Haw River site, for 7 of their last 9 valid
toxicity tests since May of this year. If WET test performance continues at these levels, the
stated sole benefit of the outfall location would be effectively negated.
Thank you for the opportunity to comment on this petition. Please let me know if you
need further information or if you have any questions or comments pertaining to this
matter.
cc: Steve Mauney - Winston-Salem Regional Office
Central Files

,fc: WWO
Division of Environmental Management 1-,cb
November 27, 1995
MEMORANDUM
To: Ruth Swanek, Supervisor
Instream Assessment Unit
From: Coleen Xuin`s,P.E., Supervisor
Permits and Engineering Unit
Subject: Reidsville
Permit No. NCO024881
Rockingham County
In accordance with Water Quality Section procedures, please review the attached petition
filed with the Office of Administrative Hearings. Please evaluate the objections raised by
the permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
1 - Petition states that the permit contains unreasonably low effluent limits for CBOD5
and NH3-N into the Haw River and that the parameters are below DEM's "own
minimum levels" and effectively negate the beneficial effect of DEM's approved Haw
River Outfall project.
Miscellaneous Comments:
If you have any comments, please contact Susan Wilson or myself at [phone].
cc: Office of the Attorney General - Kathy Cooper
Dave Goodrich
Water Quality Section

w J. MICHAEL THOMAS i
ATTORNEY AT LAW
227 WEST MOREHEAD STREET • THE WACHOVIA BUILDING • P O BOX 2104
REIDSVILLE, NORTH CAROLINA 27323.2104
[phone]
Ms. Dean Farrar
Chief Hearings Clerk
Office of Administrative Hearings
P. O. Drawer 27447
Raleigh, NC 27611-7447
November 20, 1995 '
s
WATER QUALITY
SECTION
S
Re: City of Reidsville v. Department of Environment, Health and
Natural Resources, acting through Division of Environmental
Management
Dear Ms. Farrar:
Enclosed please find the original and two copies of the petition :fora contested case >:
hearing in the above matter. Please file this petition and mail a copy marked filed to me at the
above address in the stamped self-addressed envelope provided. As certified in the petition, a
copy has this date been served on the subject state agency.
The original. petition and cover letter have been mailed this date to your office per Rule
.0101 of the Rules of the Office of Administrative Hearings, Hearing Division.
Thank you in advance for your assistance in this matter.
Yours very truly,
J. MICHAEL THOMAS
ATTORNEY AT LAW
JMT/tc/4596. ltr
Enclosures as stated.
cc: D. Kelly Almond
City Manager
Jerry W. Rothrock
Director of Public Works
A. Preston Howard, Jr., P.E.
Division of Environmental Management

PLEASE PR_ CLEARLY OR TYPE
STATE OF NORTII CAROLINA
COUNTY OF (I) ROCKINGHAM
IN TILE OFFICE OF
ADillx*l
STR,ITI1 E IlE•1RINGS
(2) CITY OF REIDSVIL
LE, )
a Municipal Corporation }
Petitioner,
(Your Name)
PETITION'
DEPARTMENT OF`RWIRONMENT, HEALTH } � FOR A
(3) AND NATURAL, RESOURCES actin through CONTESTED CASE IIEARING
DIVISION OF ENVIRONMENTAL MANAGEMENT
Respondent. )
(The State Agency or Board about which you are
complaining) )
I hereby ask for a contested case hearing as provided for by G.S. 1 S08-23 because the:
(4) DIVISION OF ENVIRONMENTAL, MANAGEMENT
(name of agency) has:
(Briefly state facts showing how you believe you have been harmed by the state agency or board.)
issued State—NPDES Permit No. NCO024881 con :aining unreasonabl lo
arameto-rs for dischac-re of CBOD5 and NH3—N into Haw River- said parameter
ecti
are below DEM's own minimum levels and effs
effect of our ve) neate the beeretitioner's DEM-a roved Haw River Outfall ro. neficial
(Jrnore space is needed, use additional sheers and attach) eet.
(5) (Check all that apply) Because of these facts, the agency has:
deprived me of property;
ordered me to pay a fine or civil penalty; X acted erroneausl�;
otherwise substantially prejudiced my failed to use proper procedure;
rights: and based on these facts the agency arbitrarily or capriciously; or
has exceeded its authority or jurisdiction; y -�—failed to act as required by la«• or rule.
(b) Date: November 20 199 (7) Your telephone number: (910)�L42-3320 (8) Print your address: P- 0- Box 2104 / Reidsville, NC 27323-2104 _.
(9) Print your name: J- Michael Thomas, Attorney at Law — Reidsville City Attorney
(10) Your signature:
NX. State Bar No. 12574
You must mail or deliver a COPY to the State Agency named on line (3) of this form. Please indicate belch.
CERTIFICATE OF SERI-ICE
I certify that this Petition has been served on the State Agency named below by depositing a copy of it with the L '
n.ed States
Postal Service with sufficient postage OR by delivering it to the named agency.
.
Served on:
(11) A. Preston Howard, Jr., P.E-
(name) (12) Division of Environmental Management
(13) P- 0. Box 29535 (agency)
/ Raleigh, NC 27626-0535
(address)
(14) This the 20th day of November 19 95
,
(15)
When you have completed this form
Uative Heyou gh. 1it;ST mail or deliver the ORIGINAL and one COPN'
arings, P.O. Drawer 27447, RaleiNC 2761 t_�, to the Office nter

Reidsville Model Runs
INPUTS
DEFAULT
NH3N
Tem /DO
SOD 1
SOD 2
Kd 1
AMB+Kd 1
AMB+Kd2
AMB+Kd3
Kd3+NH3N
Kd2+SOD2
BODS m /l
5.0
5.0
5.0
5.0
6.0
5.0
5.0
5.0
5.0
6.0
6.0
NH3N m /I
2.0
i .0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
1.0
2.0
Multiplier
8.1
8.1
8.1
8.1
8.1
8.1
8.1
8.1
8.1
8.1
8.1
CBOD m /)
40.5
40.6
40.5
40.5
40.5
40.5
40.5
40.5
40.5
48.6
48.6
Design Temp. (dog. C
26'
26'
24
26'
26'
26'
24
24
24
24
24
Headwater DO m /I
7.3'
7.3'
6.9
7.3'
7.3'
7.3'
6.9
6.9
6.9
6.9
6.9
SOD r/m/da 20 C
no input
no input
no input
1.83
1.19
no input
1.83
1.83
1.83
1.83
1.19
Kd 20 C
0.22'
0.22'
0.22'
0.22'
0.22'
0.02
0.02
0.05
0.04
0.04
0.05
RESULTS
DO Sag m /l
3.89
4.35
4.3
1.87
2.68
6.34
4.95
4.51
4.65
4.95
5.03
Sag Point mi.
4.8
4.8
4.8
4.8
4.8
2.2
4.8
6.4
6.4
6.4
4.8
INPUTS
DEFAULT
NH3N
Tem /DO
SOD 1
SOD 2
Kd 1
AMB+Kd 1
AMB+Kd2
AMB+Kd3
Kd3+NH3N
Kd2+SOD2
BODS (mall)
5.0
5.0
5.0
6.0
5.0
5.0
5.0
5.0
5.0
7.0
7.0
NH3N m /l
2.0
1.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
1.0
2.0
Multiplier
7.1
7.1
7.1
7.1
7.1
7.1
7.1
7.1
7.1
7.1
7.1
CBOO m /1
35.5
35.5
35.5
35.6
35.5
35.5
35.5
35.5
35.5
49.7
49.7
Design Temp. (deg. C
26'
26'
24
26'
26'
26'
24
24
24
24
24
Headwater DO m /)
7.3'
7.3'
6.9
7.3'
7.3'
7.3'
6.9
6.9
6.9
6.9
6.9
SOD r/m/da 20 C
no input
no input
no input
1.83
1.19
no input
1.83
1.83
1.83
1.83
1.19
Kd 0 20 c
0.22'
0.22'
0.22'
0.22'
0.22'
0.02
0.02
0.05
0.04
0.04
0.05
RESULTS
DO Sag m /l
4.24
4.7
4.63
2.22
2.92
6.37
4.99
4.6
4.73
4.93
5.01
Sag Point mi.
4.8
4.7
4.7
4.8
4.8
2.0
4.8
6.4
6.4
6.4
4.8
INPUTS
DEFAULT
NH3N
Temp/DO
SOD 1
SOD 2
Kd 1
AMB+Kd 1
AMB+Kd2
AMB+Kd3
Kd3+NH3N
Kd2+SOD2
BOD5 (m /l)
5.0
5.5
_
5.0
5.0
8.0
_
NH3N m /I
2.0
1.0
2.0
2.0
1.0
Multiplier
5.8
5.8
_
5.8
5.8
5.8
CBOO m /I
29.0
31.9
_
29_0
29.0 -
46.4
Y
Design Temp. (deg. C
26'
26'
v
24
24
24
Headwater DO m n
7.3'
7.3'
6.9
6.9
6.9
_
SOD r/m/da 20 C
no input
no input
1.83
1.83
1.83
Kd @ 20 C
0.22'
0.22'
0.05
0.04
0.04
RESULTS
DO Sag m /I
4.69
4.95
4.72
4.82
4.98
Sag Point mi.
4.5
4.6
6.4
6.4
6.4
_ ._
' denotes Level-B model default values
Page 1

Cityof Reidsville 230 West Morehead Street, Reidsville, North Carolina 27320 • [phone]
August 19, 1995
Mr. David A. Goodrich
NCDEHNR/DEM
NPDES Permits Group
P.O. Box #29535
Raleigh, North Carolina 27626-0535
Dear W. Goodrich:
OFFICE OF THE CITY MANAGER
This letter is to acknowledge receipt of the DRAFT Permit prepared by your office. The
DRAFT permit has been reviewed and the following items are submitted for your consideration.
The general context of the DRAFT Permit is complete and in agreement with the
information submitted in the Permit Application submitted by the City of Reidsville. The inclusion
of alterna - limits based on the 7Q10 of the Proposed Haw River discharge outfall seems a logical
and effective way to handle the simultaneous permit applications that were necessary.
We were pleased to see that most of the proposed Haw River discharge metals limits
reflected the increased assimilation capacity of the larger receiving waters of the Haw River. We
are concerned that the conventional pollutant parameter limits for BOD5, NH3-N, and Total
Phosphorus were left at the more restrictive limits based on the 7Q 10 of Little Troublesome
Creek. Information supplied to us by the Cities of Burlington and Graham indicate that their
permits are less restrictive than the limits issued to the City of Reidsville. Given the increased
dilution factor and assimilation ability of the Haw River, the City of Reidsville requests that the
discharge limits on the conventional parameters be increased to the values listed below.
®Recycled
Paper

Summer Limits, April 1- October 31
TSS: 30.0 mg/l monthly average, 45.0 mg/l weekly average
BOD5: 12.0 mg/1 monthly average 18.0 mg/1 weekly average
NH3-N: 4.0 mg/l monthly average
PO4: - 4.0 mg/l monthly average (* * * *)
Winter limits November 01 to March 31:
TSS ;._ - - 30.0 mg/l monthly average, 45.0 mg/l weekly average
BOD5: 24.0 mg/l monthly average, 36 mg/l weekly average
NH3-N: 8.0 mg/l 01 r
CIO c
4.0 mg/l monthly average (****) -rr'v ;s
*--( Based on a quarterly average of weekly samples) -a x
�,d
Your consideration of these suggested limits is greatly appreciated. If you have any further r x
questions or require further information, please give me- a call. -'4"
SiOeerely, w.
D. Kelly Almond
Manager
City of Reidsville
cc: C.D. Malone
Jerry Rothrock
Donald Waddell
file
file: a:lpermit.wpd

Upper Haw River Watershed Vicinity Map
G,
L
REIDSVILLE WWTP ~ `,
5.0 MGD/7.5 MGD
Uf,i}sa .�.-.t v^h • Existing ��= 16o L
,� ti
n,o US 15a r -TMr Proposed o = �. {
°. Haw GLEN RAVEN MILLS
CV, .
0.09 MGD/0.12 MGD
k t C
A, 7 cis
Legend
r' MONARCH HOSIER K Xt�r : �� Le 9
0.050 MGp \
Ci BBCIy i„ ,.,.,.,��.� —t�5 a x0 NPDES Discharger
BURLINGTON (EAST WWTP) Stream/River
12.0 MGD
'SCa
N. BUFFALO CK WWTP 33.6 cR Haw River _s Haw 7D2�0 a
o N
16.0 MGD
Road
w T. Z. OSBORNE WWTP 20.0 MGD �. •MS MGD WWTP County Boundary
:Bt rlingtllt# S
Ci[yrrom
�(FY.i15bi7rtJ -
CONE MILLS 4r_ `* Am P 1 ° GRAHAM WWTP
1.25 MGD Y P Cx a 3.5 MGD
OA �
BURLINGTON (SOUTH WWTP) 7DID= Si��-
12.0 MGD - o
jQ10 = 3.o c{s Cryflb
5 0 5 10 15 Miles D E H N R
April 10, 1996

FINDING OF NO SIGNIFICANT IMPACT
AND ENVIRONMENTAL ASSESSMENT
RELOCATE THE EFFLUENT DISCHARGE AND MAKE MINOR CHANGES
TO THE EXISTING WASTEWATER TREATMENT PLANT
REIDSVILLE, NORTH CAROLINA
AGENCY: NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
CONTACT: JOHN R. BLOWE, P.E., CHIEF
CONSTRUCTION GRANTS AND LOANS SECTION
DIVISION OF ENVIRONMENTAL MANAGEMENT
512 N. SALISBURY STREET
RALEIGH, NORTH CAROLINA 27626-0535
JUNE 271995

FINDING OF NO SIGNIFICANT IMPACT (FNSI)
Title VI of the amended Clean Water Act requires the review and approval of
environmental information prior to the construction of publicly -owned wastewater
treatment facilities financed by the State Revolving Fund (SRF). The proposed project
has been evaluated for compliance with the North Carolina Environmental Policy Act and
determined to be a major agency action which will affect the environment.
Project Applicant: Reidsville, North Carolina
Project Number: CS370384-04
Project Description: The proposed project consists of relocating the effluent
discharge from Little Troublesome Creek to the Haw River.
Improvements will also be made to wastewater pumps and
sludge processing facilities.
Total Project Cost: $528342000
Revolving Loan Amount: $5,8342000
Mitigative measures will be implemented to avoid significant adverse environmental
impacts, and an environmental impact statement (EIS) will not be required. The decision
was based on information in the facilities plan, a public hearing document, and reviews
by governmental agencies. An environmental assessment supporting this action is
attached. This FNSI completes the environmental review record, which is available for
inspection at the State Clearinghouse.
No administrative action will be taken on the proposed project for at least thirty working
days after notification that the FNSI has been published in the North Carolina
Environmental Bulletin.
Sincerely,
A. Preston Howard, ., ., Director
Division of Environmental Management

ENVIRONMENTAL ASSESSMENT
A. Proposed Facilities and Actions
Figure 1 identifies the site of the existing treatment plant and the route of the effluent
force main.
Transport Facilities. The proposed transport facilities consist of constructing a 15 mgd
PUMP station and installing 33,000 L.F. of 30-inch force main to relocate the effluent
discharge from Little Troublesome Creek to the Haw River. The mechanical aerator will
be removed from the existing post -aeration basin to convert the facility to a wet well for
the planned pump station and effluent force main.
Treatment Facilities. Two influent pumps will be retrofitted to provide variable speed
capability. Also, the aerobic digester blower capacity will be increased, and additional
diffusers will be installed to increase oxygen transfer in the digester. A Class B sludge
will be generated and land applied. Appropriate auxiliary power will be added to the
treatment facilities.
B. Existing Environment
Topography and Soils. The city of Reidsville is located in Rockingham County, which
is part of North Carolina's Piedmont physiographic region. The area consists of gently
rolling hills and low ridges adjacent to streams. There are several soil associations in the
planning area. Dominant soils are gently sloping to very steep and are poorly drained to
very well drained soils underlain by plastic, impermeable, clayey subsoils.
Surface Water. Reidsville is located in the Cape Fear River Basin. Effluent from the
existing 7.5 mgd treatment plant is currently discharged into Little Troublesome Creek, a
Class C NSW stream. Little Troublesome Creek, a tributary to the Haw River, is a small
stream with the effluent comprising approximately 95 percent of the total flow during
7Q 10 conditions.
Water Supply_. Lake Reidsville is the source of potable water for the city of Reidsville.
C. Existing Wastewater Facilities
The city of Reidsville operates a 7.5 mgd wastewater plant which was originally
constructed in 1950 as a trickling filter and upgraded and expanded to an extended
aeration facility in 1977. The plant was expanded from 5.0 to 7.5 mgd in 1989, and is
currently operated as an extended aeration system with tertiary filtration. Treatment plant

operations consist of screening, grit removal, aeration, final settling, filtration,
disinfection, and dechlorination. Sludge is thickened, aerobically digested, and land
applied. All of the domestic users within the city's boundaries are provided centralized
collection and treatment service. An evaluation of the collection system indicates that
infiltration and inflow are non -excessive.
D. Need for Proposed Facilities and Actions
Reidsville has experienced chronic toxicity problems, and the city is currently operating
the wastewater treatment plant under a Special Order by Consent (SOC). Moreover, the
city completed the expansion of the existing 7.5 mgd facility in 1989, but the amount of
wastewater that can be treated is limited to 5.0 mgd until the facility can demonstrate
consistent compliance with the chronic toxicity requirements. The improvements
facilitated compliance with all of the NPDES parameters except chronic toxicity.
Approximately one-half of the existing flow comes from industrial plants. Additionally,
the effluent discharge into Little Troublesome Creek is approximately 95 percent of the
7Q 10, and any significant increase in the industrial flow could further exacerbate
compliance to an existing, chronic toxicity problem. Effluent limitations for the existing
discharge into Little Troublesome Creek are as follows:
PARAMETER
MONTHLY AVERAGE
Flow, mgd
7.5
CBOD5, mg/l
(Summer)
(Winter)
4.0
8.0
TSS, mg/1
30.0
NH3 - N, mg/1
(Summer)
(Winter)
2.0
4.0
Total Phosphorus, mg/1
2.0
Fecal Coliform, #/100 ml
200.0
Residual Chlorine, Mg/l
(Daily
Maximum)
17.0
Chronic Toxicity, Ceriodaphnia
Pass/Fail at 90%
The city's treatment plant must also meet monitoring requirements and/or discharge
limitations for conductivity, chromium, nickel, fluoride, MBAS, cyanide, cadmium, lead,
copper, zinc, aluminum, manganese, antimony, silver, chloroform, mercury, and
dissolved oxygen.
2

Speculative effluent limitations have not been finalized for the discharge into the Haw
River, but it is anticipated that NPDES permit requirements will not be more stringent
than the current limits for the discharge into Little Troublesome Creek. For example, the
instream waste concentration for the existing discharge is 90 percent. The projected
instream waste concentration for the proposed discharge into the Haw River is 61 percent
for 7.5 mgd.
E. Alternatives Analvsis
The city of Reidsville needs to make improvements to the existing wastewater treatment
facilities to comply with the SOC and to accommodate future growth. Accordingly, an
updated facilities plan was prepared, and several alternatives were evaluated. The "no -
action" alternative was determined not to be practical due to the possible imposition of
civil penalties for violating the conditions of the SOC and not meeting other regulatory
requirements. Additionally, the city operates a plant which is designed to process a flow
of 7.5 mgd. However, the plant is limited to processing 5.0 mgd until compliance is
achieved for the toxicity test of pass/fail at 90 percent. An optimum plant operation
would not accomplish the desired results of consistently complying with all of the
NPDES parameters. A land application system was investigated and rejected due to the
high cost to implement. This alternative would require approximately 4,400 acres of
land, and the abandonment of existing treatment facilities which were upgraded and
expanded in 1989. The final alternative consisted of examining different discharge
locations with more flow than Little Troublesome Creek. This approach would facilitate
the discharge of an effluent to a stream with less stringent toxicity requirements. The
Haw River is the closest stream that could be a viable option. A major advantage of the
Haw River is that the stream has a 7Q 10 of 18.98 cfs, whereas Little Troublesome Creek
has a 7Q 10 value of 7.82 cfs. Several transport routes and various discharge points were
examined. The most cost-effective alternative is to transport the effluent via pump station
and force main to a point beyond the confluence of Little Troublesome Creek and the
Haw River. It is the selected plan. Additionally, the city of Reidsville has implemented
a toxicity reduction evaluation to correct the chronic toxicity problems. This effort, when
combined with the proposed relocation of the effluent discharge from Little Troublesome
Creek to the Haw River, should also assure compliance with the SOC and facilitate
meeting NPDES requirements.
F.. Environmental Consequences, Mitigative Measures
All of the proposed improvements to the treatment plant will take place at the existing
site, and modifications will be within previously cleared areas. The 6.25 mile force main
will traverse a wetland, woodland, road rights -of -way, and previously cleared areas. The
3

first 6,200 feet of pipe from the treatment plant will parallel Little Troublesome Creek,
and this part of the construction will require the clearing of approximately 4.3 acres of
forestland and about 0.6 acre of a wetland. The remaining sections of the force main will
be located either within previously cleared areas or along road rights -of -way.
Approximately 0.1 acre of woods will be cleared for the installation of the discharge pipe
and headwall at the Haw River. The Department of Cultural Resources is not aware of
any properties of architectural, historic, or archaeological significance which would be
affected by the project. The U. S. Fish and Wildlife Service indicated that there were no
federally -listed endangered or threatened species in the project area. Nationwide Permit
No. 12 has been issued by the U.S. Army Corps of Engineers to install the proposed force
main. North Carolina's Wildlife Resources Commission evaluated the proposed project
and determined that the following mitigative measures were necessary to avoid or
minimize adverse environmental impacts:
1) Strict adherence to an approved sedimentation and erosion control plan.
2) Require chronic toxicity testing on a monthly basis for an interim period through
December 1996.
3) Plant two-inch diameter trees and saplings along Little Troublesome Creek for a
segment of the force main which will be located closest to the stream. Tree
planting activities will be conducted in consultation with the Division of Forest
Resources and/or the Wildlife Resources Commission.
4) Wetland topsoil will be stockpiled separately from the topsoil for the remaining
parts of the project.
5) The wetland area will be planted with rye grass and annual small grains or annual
lespedeza after the ground disturbing activities.
6) Non -wetland areas to be disturbed will be seeded with a sericea or orchard grass.
7) The maximum maintenance width for the wetland corridor will be ten feet.
8) The force main corridor will be mowed once every one to three years, and the
mowing will take place between August and March.
All project activities will take place in accordance with applicable rules, regulations, and
permit conditions.
rM
W

G. Public Participation. Sources Consulted
A public hearing was held January 112 1995 on the proposed improvements to
Reidsville's wastewater treatment facilities. The hearing covered the problems of the
existing facilities, the need to construct the proposed improvements, and the cost to
implement the selected alternative. No opposition to the proposed project has been
expressed. A customer using 5,000 gallons of water currently pays $23.97 per month for
sewer service. The proposed project will result in a typical customer paying
approximately $34.04 per month. This is a significant increase in the user fee, but the
proposed project is the most cost-effective alternative which can be implemented to
comply with the SOC and facilitate future growth.
Sources consulted about this project for information or concurrence included:
1) City of Reidsville
2) North Carolina Department of Environment, Health, and Natural Resources
-Wildlife Resources Commission
-Parks and Recreation
-Air Quality Section
-Groundwater Section
-Environmental Health
-Water Quality Planning
-Waste Reduction
-Winston-Salem Regional Office
-Legislative and Intergovernmental Affairs
3) North Carolina Department of Cultural Resources
4) North Carolina State Clearinghouse
5) U.S. Fish and Wildlife Service
�I

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GREENSBOAO, NORTH CAAOUNA ep-cdiD °'' REIDSVILLE. N.C. �;
at'sa.

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 31, 1995
puld
45
MEMORANDUM 44,TO: Rob Brown
Construction Grants & Loans
FROM: Jason Doll
THROUGH: Carla Sanderson
Ruth Swanek 2C
SUBJECT: Speculative Limits for Reidsville WWTP
NCO024881
Rockingham County
Per your request of May 26,1995, the Instream Assessment Unit has reviewed the
wasteload files for the City of Reidsville WWTP, and we can confirm the speculative limits
communicated to the City for the relocation of the WWTP discharge to the Haw River at the
U.S. Highway 150 bridge.
The area of the Haw River in question generally offers little assimilative capacity due
to low flows and high sediment oxygen demand. In addition, the upper Haw River
mainstem and its tributaries are typically slow moving and swamp -like, which also limits
assimilative capacity, so new and expanding discharges, when allowed, are required to
meet advanced tertiary treatment limits for oxygen -consuming wastes. Limits for the
relocated discharge will be assigned as follows for wasteflows of 5.0 and 7.5 MGD:
Parameter
Units
Limits (30 day avg.)
CBOD5 (Sum/Win)
mg/l
4/8
NH3N (Sum/Win)
mg/l
2/4
DO (minimum)
1119/1
6.0
TS S
mg/l
30
Fecal Coliform
/100 ml
200
Residual Chlorine
ug/l
28
pH
S U
6.0-9.0
Total Phosphorus
m9/1
2.0
Total Nitrogen
mg/l
monitor (monthly)
Chronic Toxicity @ 5.0 MGD*
P/F @ %
51.0
Chronic Toxicity @ 7.5 MGD*
P/F @ %
61.0
Metals**
**
*Toxicity Testing: Chronic / Ceriodaphnia - no observable inhibition of
reproduction or significant mortality at the percentage indicated; Quarterly Test.
**A complete evaluation of limits and monitoring requirements for metals and other
toxicants will have to be addressed at the time of formal NPDES application.

Given the limited assimilative capacity at this location in the Haw River, the limits
listed above are unchanged from the limits applied to the Little Troublesome Creek
discharge with regard to conventional pollutants. The only limits to change will be the
chronic toxicity test concentration and specific toxicant (metals) limits, which are based on
the degree of dilution in the receiving stream.
It is our understanding that the City of Reidsville has undertaken substantive efforts to
address the historical problems with effluent toxicity at the WWTP. Review of recent data
has shown a marked improvement in reported test results, with the facility consistently
passing at test concentrations above the limits that would be assigned to the Haw River
discharge. The City should continue to aggressively pursue toxicity reduction efforts in
order to ensure that the outfall relocation is a successful endeavor.
If you have any further questions or require any additional information in this matter,
please let me know.
cc: CentrAl Files
Dave Goodrich

State of North Carolina
Department of Environment,
Health and Natural Resources 4 • •
Division of Environmental Management r
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E H N F1
A. Preston Howard, Jr., P.E., Director
October 27, 1995
Mr. D. Kelly Almond, Manager
City of Reidsville
230 West Morehead Street
Reidsville, North Carolina 27320
Subject: NPDES / Reidsville WWTP
NPDES Permit No. NCO024881
Rockingham County
Dear W. Almond:
In accordance with your application for modification of the current discharge permit, we are
forwarding herewith the subject State - NPDES 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 US Environmental Protection Agency dated December 6, 1983. In response to your letter
received September 22, 1995 regarding the draft permit, the following comments are offered for your
information.
The City of Reidsville has been informed by the Division since 1992 that existing limits for BOD5
and NH3-N would have to be met upon relocation to the Haw River. This was emphasized again by letter
dated January 6, 1993 to the City's consultant. Specifically, the Division stated that although the limits for
toxicity and chemical specific parameters would change with relocation, the BOD5 (CBOD5) and NH3-N
limits would not.
The limits for BOD5 (CBOD5) and NH3-N were determined based on the hydrologic
characteristics of the receiving stream and instream dissolved oxygen levels in the upper Haw River. In
the area of the proposed discharge relocation, the Haw River is characterized by very low slopes which
cause slow velocities and low reaeration rates in the receiving stream. This condition can severely limit
assimilative capacity, especially in the case of larger discharges. In addition, due to the high industrial
wastewater percentage at the City's treatment plant, the wastewater is more resilient than 100% domestic
wastewater. The resiliency of the wastewater for the City of Reidsville was determined through the
Division's BOD ultimate test. All of these factors contributed to the determination of the limits for oxygen
consuming waste and the recommendation that the City of Reidsville retain their existing limits for CBOD5
and NH3-N.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicative hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such demand is
made, this decision shall be final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please take notice this permit is not transferable. Part II, E.4. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Environmental Management
or permits required by the Division of Land Resources, 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 Susan Wilson at telephone
number [phone], extension 555.
S4 Signed By
®avid k Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Winston-Salem Regional Office
Mr. Roosevelt Childress, EPA
Permits and Engineering Unit
Facility Assessment Unit
Aquatic Toxicology and Survey Unit

Permit No. NCO024881
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Mangement Commission,
and the Federal Water Pollution Control Act, as amended,
City of Reidsville
is hereby authorized to discharge wastewater from a facility located at
Reidsville Wastewater Treatment Plant
on Broad Street
Rockingham County
to receiving waters designated as Little Troublesome Creek in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, and III hereof.
The permit shall become effective December 1, 1995.
This permit and the authorization to discharge shall expire at midnight on November 30, 2000.
Signed this day October 27, 1995. 0[ Sind By
GoodTich
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Mangement Commission

-
c
t
Permit No. NCO024881
SUPPLEMENT TO PERMIT COVER SHEET
City of Reidsville
is hereby authorized to:
1. Continue to operate a 7.5 MGD wastewater treatment facility consisting of influent screening,
preaeration, grit removal, biological treatment using activated sludge, alum or polymer
treatment, final clarification, chlorine disinfection, tertiary sand filtration, chlorine contact
chambers, dechlorination, parshall flume, post aeration, aerobic digester, and storage basins
located at Reidsville Wastewater Treatment Plant, on Broad Street, Rockingham County (See
Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into Little
Troublesome Creek which is classified C-NSW waters in the Cape Fear River Basin, and,
3. After receiving an Authorization to Construct from the Division of Environmental
Management,
4. Discharge from said treatment works at the location specified on the attached map into the
Haw River which -is classified C-NSW waters in the Cape Fear River Basin.

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it 11
DISCHARGE PAT (RELOCATIONS o C
IN '
CITY OF REIDSVIL.LE
c^ i WASTEWATER TREATMENT PLANT :
• � ��� �•� ^ � - NC(}O248 81
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edited, and published by the Geological Survey -
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)

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31)
Permit No. NCO024881
During the period beginning on the effective date of the permit and lasting until relocation to the Haw River, the Permittee is authorized to
discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow t
CBOD, 5-Day, 20°C"
Total Suspended Residue"
NH3 as N
Dissolved Oxygen'
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Conductivity
Total Phosphorus
Total Nitrogen (NO2 + NO3 + TKN)
Chronic Toxicity ""*
Discharge
Limitations
Monitoring
Measurement
Beguirements
Sample_ *Sample
Monthly.
Avg.
Weekly Avg. Daily Max.
Frequency .
lype Location
7.5 t
MGD
Continuous
Recording
I or E
4.0
mg/l
6.0 mg/I
Daily
Composite
1,E
30.0
mg/I
45.0 mg/I
Daily
Composite
1,E
2.0
mg/I
Daily
Composite
E
6.0
mg/I
Daily
Grab
E,U,D
200.0
/100 ml
400.0 /100 ml
Daily
Grab
E,U,D
17.0 µg/l
Daily
Grab
E
Daily
Grab
E,U,D
Daily
Grab
E,U,D
2.0
m g / I
Weekly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
t THE FACILITY HAS BEEN EXPANDED TO 7.5 MGD, BUT THE FLOW SHALL BE LIMITED TO 5.0 MGD UNTIL RELOCATION TO
THE HAW RIVER.
* Sample locations: E - Effluent, I - Influent, U - Upstream on Little Troublesome Creek at US Hwy. 29 Business, D - Downstream on Little
Troublesome Creek at NCSR 2600.
Upstream and downstream samples shall be grab samples. Instream samples shall be grab samples and shall be conducted 3 times per week
during the months of June, July, August, and September and once per week during the remainder of the year.
* * The monthly average effluent CBOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85
% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mgA.
**** Compliance shall be based on a quarterly average of weekly samples.
***** Chronic Toxicity (Ceriodaphnia) P/F at 90%; January, April, July, and October; See Part III, Condition G.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam other than trace amounts.
(CONTINUED)

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31)
Permit No. NCO024881
During the period beginning on the effective date of the permit and lasting until relocation to the Haw River, the Permittee is authorized to
discharge from outfall(s) serial number 001.
Such discharges shall be limited and monitored by the permittee as specified below:
r
Effluent Characteristics Discharge Limitations Monitoring
Requirements
Measurement
Sample
'Sample
Monthly,
Avg. Weekly Avg, Daily Max, Frequency
Ivoe
Location
Cadmium
2.0 µ g / l Weekly
Composite
E
Cyanide
5.0 µ g / l Weekly
Grab
E
Lead
25.0 µ g/ I Weekly
Composite
E
Fluoride
1.8 m g / I Weekly
Composite
E
MBAS
0.5 m g / l Weekly
Composite
E
Mercury
0.012 µ g / I Weekly
Composite
E
Copper
o n t h
Composite
E
Zinc
2/Mo h
Composite
E
Silver
2/Month
Composite
E
Other parameters of concern shall be monitored through the facility's Long Term Monitoring Plan.

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NCO024881
During the period beginning on the effective date of the permit and lasting until relocation to the Haw River, the Permittee is authorized to
discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge
Limitations
Monitoring
Requirements
Measurement
Sample-_ *Sample
Monthly.
Avg.
Weekly Avg. Daily Max. Freguepc_v -_
Type Location
Flow t
7.5 t
MGD
Continuous
Recording
I or E
CBOD, 5-Day, 200C"*
8.0
mg/l
12.0 mg/I Daily
Composite
1,E
Total Suspended Residue"
30.0
mg/l
45.0 mg/l Daily
Composite
1,E
NH3 as N
4.0
m g/ 1
Daily
Composite
E
Dissolved Oxygen"*"
6.0
mg/1
Daily
Grab
E,U,D
Fecal Coliform (geometric mean)
200.0
/100 ml
400.0 /100 ml Daily
Grab
E,U,D
Total Residual Chlorine
17.0 µ g / I Daily
Grab
E
Temperature
Daily
Grab
E,U,D
Conductivity
Daily
Grab
E,U,D
Total Phosphorus """'
2.0
mg/I
Weekly
Composite
E
Total Nitrogen (NO2 + NO3 + TKN)
Monthly
Composite
E
Chronic Toxicity ""*""
Quarterly
Composite
E
t THE FACILITY HAS BEEN. EXPANDED TO 7.5 MGD, BUT THE FLOW SHALL BE LIMITED TO 5.0 MGD UNTIL RELOCATION TO
THE HAW RIVER.
* Sample locations: E - Effluent, I - Influent, U - Upstream on Little Troublesome Creek at US Hwy. 29 Business, D - Downstream on Little
Troublesome Creek at NCSR 2600.
Upstream and downstream samples shall be grab samples. Instream samples shall be grab samples and shall be conducted 3 times per week
during the months of June, July, August, and September and once per week during the remainder of the year.
** The monthly average effluent CBOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85
% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
**** Compliance shall be based on a quarterly average of weekly samples.
***** Chronic Toxicity (Ceriodaphnia) P/F at 90%; January, April, July, and October; See Part III, Condition G.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam other than trace amounts.
(CONTINUED)

�f
•
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NCO024881
During the period beginning on the effective date of the permit and lasting until relocation to the Haw River, the Permittee is authorized to
discharge from outfall(s) serial number 001.
Such discharges shall be limited and monitored by the permittee as specified below:
_
Effluent Characteristics Discharge Limitations
(Monitoring
Measurement
Requirements
*Sample
Sample
Monthly.
Avg. Weekly Avg. Daily Max.
Frequency_
Type
Location
Cadmium
2.0 µ g/ l
Weekly
Composite
E
Cyanide
5.0 N g/I
Weekly
Grab
E
Lead
25.0 p g/l
Weekly
Composite
E
Fluoride
1.8 m g / I
Weekly
Composite
E
MBAS
0.5 m g / I
Weekly
Composite
E
Mercury
0.012 µ g / I
Weekly
Composite
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
Silver
2/Month
Composite
E
Other parameters of concern shall be monitored through the facility's Long Term Monitoring Plan.

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 31)
Permit No. NCO024881
During the period beginning upon relocation to the Haw River and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow
C80D, 5-Day, 200C**
Total Suspended Residue"
NH3 as N
Dissolved Oxygen***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Conductivity
Total Phosphorus ****
Total Nitrogen (NO2 + NO3 + TKN)
Chronic Toxicity *****
Discharge,
Limitations
Monitoring
Requirements
Measurement
Sample -
Monthly.
Avg.
Weekly Avg. Daily Max.
Fre uency
Type--
Location
7.5
MGD
Continuous
Recording
I or E
4.0
m g/ I
6.0 m g/ I
Daily
Composite
I, E
30.0
mg/I
45.0 mg/l
Daily
Composite
1,E
2.0
mg/I
Daily
Composite
E
6.0
mg/l
Daily
Grab
E,U,D
200.0
/100 ml
400.0 /100 ml
Daily
Grab
E,U,D
28.0 µg/l
Daily
Grab
E
Daily
Grab
E,U,D
Daily
Grab
E,U,D
2.0
m g / I
Weekly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
* Sample locations: E - Effluent, I - Influent, U - Upstream at US Hwy. 29, D - Downstream at NCSR 2620 on the Haw River.
Upstream and downstream samples shall be grab samples. Instream samples shall be grab samples and shall be conducted 3 times per week
during the months of June, July, August, and September and once per week during the remainder of the year.
** The monthly average effluent CBOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85
% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
**** Compliance shall be based on a quarterly average of weekly samples.
***** Chronic Toxicity (Ceriodaphnia) P/F at 61%; January, April, July, and October; See Part III, Condition H.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam other than trace amounts.
(CONTINUED)

IL
A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31) Permit No. NCO024881
During the period beginning upon relocation to the Haw River and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) sepal number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Measurement Sample *Sample
Monthly., Avg. Weekly Avg. Daily Max. Frequency Ivpe Location
Cadmium
3.3
µ g / I
Weekly
Composite
E
Cyanide
8.2
µ g / I
Weekly
Grab
E
Lead
41.0
µ g / I
Weekly
Composite
E
MggS
0.8
m g / I
Weekly
Composite
E
Mercury
0.019
µ g / I
Weekly
Composite
E
Copper
2/Month
Composite
E
Zinc
2/Month'
Composite
E
Silver
2/Month
Composite
E
Other parameters of concern shall be monitored through the facility's Long Term Monitoring Plan,

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NC0024881
During the period beginning upon relocation to the Haw River and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Measurement Sample "Sample
Monthly. Avg. Weekly AVg. Daily Max, Frequency Type Location
Flow 7.5 MGD Continuous Recording I or E
CBOD, 5-Day, 200C** 8.0 mg/I 12.0 mg/l Daily Composite 1,E
Total Suspended Residue" 30.0 mg/l 45.0 mg/l Daily Composite 1,E
NH3 as N 4.0 mg/I Daily Composite E
Dissolved Oxygen"" 6.0 mg/l Daily Grab E,U,D
Fecal Coliform (geometric mean) 200.0 /100 ml 400.0 /100 ml Daily Grab E,U,D
Total Residual Chlorine 28.0 µg/I Daily Grab E
Temperature Daily Grab E,U,D
Conductivity Daily Grab E,U,D
Total Phosphorus *"" 2.0 mg/I Weekly Composite E
Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite E
Chronic Toxicity ***** Quarterly Composite E
* Sample locations: E - Effluent, I - Influent, U - Upstream at US Hwy. 29, D - Downstream at NCSR 2620 on the Haw River.
Upstream and downstream samples shall be grab samples. Instream samples shall be grab samples and shall be conducted 3 times per week
during the months of June, July, August, and September and once per week during the remainder of the year.
Additional metals shall be monitored in the facility's Long Term Monitoring Plan.
** The monthly average effluent CBOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85
% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
**** Compliance shall be based on a quarterly average of weekly samples.
***** Chronic Toxicity (Ceriodaphnia) P/F at 61%; January, April, July, and October; See Part III, Condition H.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam other than trace amounts.
(CONTINUED)

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November l - March 31)
w '
Permit No. NCO024881
During the period beginning upon relocation to the Haw River and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001.
Such discharges shall be limited and monitored by the permittee as specified below:
,
Effluent Characteristics
Discharge Limitations Monitoring
Measurement
Requirements
5amp1r 'Sample
Monthly. Avg. Weekly Avg. Daily Max, Frgquency
Tye Location
Cadmium
3.3 µ g / I Weekly
Composite
E
Cyanide
8.2 µ g / I Weekly
Grab
E
Lead
41.0 µ g / I Weekly
Composite
E
MBAS
0.8 m g / l Weekly
Composite
E
Mercury
0.019 µ g / I Weekly
Composite
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
Silver
2/Month
Composite
E
Other parameters of concern shall be monitored through the facility's Long Term Monitoring Plan.

12. Record Keeping
The permittee shall retain for a mi imum of three years records of monitoring activities
and results, along with support information including general records, water quality
records, and records of industrial impact on the POTW;
13. Funding and Financial Report
The permittee shall maintain adequate funding and staffing levels to accomplish the
objectives of its approved pretreatment program;
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local
limits modifications, POTW monitoring of their Significant Industrial Users (SIUs),
and Monitoring Plan modifications, shall be considered a permit modification and shall
be governed by 15 NCAC 2H .0114 and 15A NCAC 2H .0907.
C. Construction
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until
Final Plans and Specifications have been submitted to the Division of Environmental
Management and written approval and Authorization to Construct has been issued.
The permittee shall, upon written notice from the Director of the Division of Environmental
Management, conduct groundwater monitoring as may be required to determine the
compliance of this NPDES permitted facility with the current groundwater standards.
I 7 A
All POTWs must provide adequate notice to the Director of the following:
1. Any new introduction of pollutants into the POTW from an indirect discharger which
would be subject to section 301 or 306 of CWA if it were directly discharging those
pollutants; and
2. Any substantial change in the volume or character of pollutants being introduced into
that POTW by a source introducing pollutants into the POTW at the time of issuance of
the permit.
3. For purposes of this
quality and quantity
impact of the change
POTW.
paragraph, adequate notice shall include information on (1) the
of effluent introduced into the POTW, and (2) any anticipated
on the quantity or quality of effluent to be discharged from the

F. Reguirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the
most environmentally sound alternative of the reasonably cost effective alternatives. If the
facility is in substantial non-compliance with the terms and conditions of the NPDES permit
or governing rules, regulations or laws, the permittee shall submit a report in such form and
detail as required by the Division evaluating these alternatives and a plan of action within
sixty (60) days of notification by the Division.

'PA . 1 0
NPDES No. NC0024881
G. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures
outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina
Chronic Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction
or significant mortality is 90 % (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform quarterly monitoring using this procedure to
establish compliance with the permit condition. The first test will be performed after thirty
days from the effective date of this permit during the months of January, April, July,
October. Effluent sampling for this testing shall be performed at the NPDES permitted
final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed,
using the parameter code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to
the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then
monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing, this monthly test requirement will revert to quarterly in the months specified
above.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Environmental Management indicate potential impacts to the receiving
stream, this permit may be re -opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate retesting(within 30 days of initial
monitoring event). Failure to submit suitable test results will constitute noncompliance
with monitoring requirements.

1
Part III NPDES No. NCO024881
H. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures
outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina
Chronic Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction
or significant mortality is 61 % (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform quarterly monitoring using this procedure to
establish compliance with the permit condition. The first test will be performed after thirty
days from the effective date of this permit during the months of January, April, July,
October. Effluent sampling for this testing shall be performed at the NPDES permitted
final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed,
using the parameter code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to
the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then
monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing, this monthly test requirement will revert to quarterly in the months specified
above.
Should any test data from this monitoring requirement or tests performed by the.North
Carolina Division of Environmental Management indicate potential impacts to the receiving
stream, this permit may be re -opened and modified to include. alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate retesting(within 30 days of initial
monitoring event). Failure to submit suitable test results will constitute noncompliance
with monitoring requirements.

NPDES No. NCO024881
I. NUTRIENT CONDITION FOR PERMITS WITH PHOSPHORUS LIMITS.
This permit may be modified, or revoked and reissued to change the effluent limitation on
nutrients for this discharge depending upon the following:
1. The findings of a study by the Division of Environmental Management determine
nutrient control is necessary.
2. Local actions do not successfully reduce the nutrient loading on the receiving waters.
3. The onset of problem conditions in the receiving waters.

P'- J"'to S",eS
� � C
s �
MO -A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, N.E.
ATLANTA. GEORGIA 30365
lOr��
�psOrl i'
I
M
SEP 2 8 1995
REF: 4WM-WPEB
Mr. Steve Tedder, Chief
Water Quality Section
Division of Environmental Management
NC Dept. of Environment, Health,
and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27626-0535
RE: NPDES Overview
Reidsville WWTP
NPDES Permit No. MC0024881
Dear Mr. Tedder:
�TJs4 �.st*+n K;
" tin.EY
0CT 2 9Z
WATT ^:rFp sry
V �iLij Wig
In accordance with the EPA/DEM MOA we have completed our
review of the above referenced draft permit and have the
following comments:
The toxic limits and monitoring requirements are acceptable
with the exception of aluminum. A review of water quality data
from the STORET database indicates the average aluminum concen-
tration between 1992 and 1994, at a station on Little Troublesome
Creek downstream of the discharge point, is 944.41 µg/l. The
average effluent concentration from the Reidsville WWTP over the
past two years is 202 µg/l. Although NCDEM does not have a water
quality standard for aluminum, it should be noted that the
federal 304(a) freshwater chronic water quality criteria is
87.0 µg/l. Based on our analysis, we recommend that the effluent
aluminum monitoring requirement of two composite samples per
month be retained as part of the routine metals monitoring
requirements versus being relegated to the Long Term Monitoring
Plan.
Printed on Recycled Paper

.. � • t\tti
i
l
f
2
If you have any comments or questions, please contact Darryl
Williams (Permits) or Thomas McGill (Water Quality) of my staff
at 404/347-3012, ext. 2949 or 404/347-3012, ext. 2960,
respectively.
We request we be afforded an additional review opportunity
only if significant changes are made prior to issuance, or if
significant objections to the permit modification are received.
Otherwise, please send us a copy of the final permit when issued.
Sincerely
Roger O. Pfaff, P.E.
Acting Chief
Water Permits and Enforcement Branch
Water Management Division

PERMIT NO.: NCO024881
PERMITTEE NAME:
FACILITY NAME:
City of Reidsville
Reidsville WWTP
Facility Status: Existing
Permit Status: Modification
Major Minor
Pipe No.: 001
Design Capacity: _7.5 MGD
Domestic (% of Flow): 63 }'o
Industrial (% of Flow): g- 9e
Comments: pac, ?Tcoa9
GmaSt To (m/Z/kS
RECEIVING STREAIV'
Class: C-NSW
Sub -Basin: 03-06-01
Reference USGS Quad: (please attach)
County: Rockingham
Regional Office: Winston-Salem Regional Office
Previous Exp. Date:
1/31/96 Treatment Plant Class: IV
Classification changes within three miles:
Changes to WS-IV NSW downstream approximately 4 miles at the
Haw River
Requested by: SusanWilsoty, Date: 6/16/95
Prepared by: f3lz (% Date:
Reviewed by: Date: / C S
Modeler
I Date Rec.
I #
J Gt>
(n vi
95
Drainage Area (mil ) /f,O Avg. Streamflow (cfs):
7Q10 (cfs) 7. L/ Winter 7Q10 (cfs) 30Q2 (cfs) 3t/
Toxicity Limits: IWC (o I % Acut Chronic
Instream Monitoring: Ulan reloou4izri -/v /{oo 6voI-
.vo
Parameters Temp., 4o <�cal Gono(.
Upstream �aT Location �ti or B)r-A__dJ
Downstream Ves Location Ak-62 ?&;70
Recommended Limits:
-
Monthly Average
Summer
Winter Daily Max.
= Wasteflow (MGD):
7.5*
7.5*
Baw(mg/1): 0860s
4.0
8.0
- NH3N (mg/1):
2.0
4.0
DO (mg/1):
6.0
6.0
_ TSS (mg/1):
30
30
Fecal Col. (1100 ml):
200
200
pH (Si):
6.0-9.0
6.0-9.0
Residual Chlorine (µg/l):
28
TP (mg/l):
2.0
2.0
- TN (mg/1):
monitor
monitor
Cadmium (ug/1):
3.3
- Copper (ug/1):
monitor
Lead (ug/1):
41
Zinc (ug/1):
monitor
Cyanide (ug/1):
8.2
MBAS (mg/1):
0.8
Mercury (ug l):
0.019
Silver (ug/1):
monitor
*Flow limit may increse to 7.5 MGD upon relocation to Haw
River, provided that facility continues to report improved WET test
results.
Comments:

FOR AQ=NCV USE
--1
STANDARD FORM A —MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a awrlptlon of each weaJor industrial facility discharging to the RwNc{pil system, Heine a fepwo" s4cuon IV for each f"Ittty ~rip.
tion. indicate the 4 digit Standard Industrial Classification (SIC) Code for the tewMtry, the wtalor prodwct or cow wute", tha how (in the%.•
sand gallons per day). and the characteristics of the waste,wateer discharged from the Inikatrlat faculty Into the municiplif system. Consult : ]ble
III for standard measures of products or raw materials. ($ee Instructions)
t• MtaJor Contributing facility .
(see Instructions) Golden Belt Manufacturing Company
Nam.• --
Number& Street
City
County
State
Zip code
2. Primary Standard Industrial
CNalfiaateon Code (see
Instructionsl
3. Prindpal Product or Raw
Material (sere Instructions)
Product
Raw Material
4. Flow Indicate the volume of water
. descharged into the munlCepal Sys-
tem In thousand gallons par day
and whether this descnargs is Inter.
mitten! or continuous.
S. Pretmatmont Prodded Indicate it
pretreatment es provided prior to
entering the municipal system
a. Caamtertstics of Wastewater
(see instructions)
40ib
40te;
"Id
401e ��
4011
402
4osa
403b
441 North Scales Street _
Reidsville _
Rockingham _
North Carolina
27 320
Z754, 3497
Units (toe
Quantity Table III)
Printing & Laminating of �a. 7.5 Million/Day
Foil to Paper
Paper, Foil, GraVure Inks ,w «JK
Adhesiveg. Tolvene, IPA
404a 3. 0 thousand gallons per day
404b ❑ Intermittent (Int)r)Continuous (con)
405 roves ❑No
I
Only Grd H2O remeediation
Parameter
Name TPA Tol xiene
DH
Parameter
00400
Number
Value
0: 001 10.005
7.78
'Isopropyl Accetate
IV-1 Me aecfion captain* 1 page.
G P 0 465.70E

r
1
FOR Aa=NCV USE
STANDARD FORM A —MUNICIPAL
SECTION 17. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a dwribtlon of each mWor IndustNal facility disc"arging to the fmnk ill 11IMO n. irslre a n0arate Sagan IV for *aft factttw dwf10,
Van. Indicate the 4 dtglt Standard Industrial Classification (SIC) Cod* for t1w itAkistry. the males Moduct or raw ulatffW, "M flow (in thrw••
sand gallons b*r day). and the Chsract*rasticl of the wastewater discharged from the Industrial facility Into the mUnicipaf syste n. Consult : 3ble
III for standard measures of products or raw materials. (s*e Inttruc3lons)
�• & ioe Centrlbutlnt Facility
(sae Instructions)
Name � 401i { am g Metal Finishing
Numbers. Street
City
County
State
210 Code
2. Primary Standard Industrial
Claalfication Code (see
Instructions)
3. Principal Product or Raw
Material (see Instructions)
Product
Raw Material
4. Flow Indicate the volume of water
discharged into the municipal sys-
tern in thousand gallons oar ay
and whether this discharge Is Inter-
mittent W continuous.
S. Preteeatment Provided Indicate if
pretreatment Is Drovload briar to
entering the municloal system
t. Characteristics of wastewater
(ail instructions)
401b
401c
4014
4010
401 f
402
4031
4031:
4041
4041
405
)
639 Tamco Road
Reidsville
Rockingham
North Carolina
27320
3471
Units (Self
Quantity Table III)
Nuts, Jaws, Band,-Misc. tea. 10 Aw Batches/da.
Metal Parts
apr Nx
3 thousand gNloru per day
intermittent (/nt) 0 continuous (can)
Yes ❑No
Pa•ameter
Name H 00
Silver
Cadmium
Chromium
Nickel
Zinc
Parameter
Number
00400
00556
01077
01027
01034
01067
Value
7.5
1.0
.01
.005
.05
0.10
0.1
IV-1 Me afghan eonselns 1 page.
G F 0 865.70E

FOR AGt dCV lift: I
-i
STANDARD FORM A —MUNICIPAL
SECTION 19. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of arch WWor Industrial faCllity discharging to the wounickw systm% Matto a separate Sdctlon IV for MCA faculty d"esep
tion. Indicate the 4 digit Standard Industrial Classification (SIC) Coda for the ftAustry. the moot tarodlfct of fail► watefist, the flow tin the%.
sand Gallons par day). and the characteristics of the wastewater discharged from the Mdustrlal facility Into the municipal system. Consult : able
111 for standard measures of product$ Or few materials. (see InstruCtions)
t• W{or Contributing facility
(am instructions) American Tobacco Company
Name 1 401 s 1 — --
Numbers: street
city
County
state
Zip Code
2. Primary Standard Industrial
04641ftcation Code (see
instructions)
3. Prindpal Product or Raw
material (see instructions)
Product
Raw Wtaterfal
4. flow Indicate the volume of water
discharged into the municipal sys.
•tom In thousand gallons per day
and wMthr this discharge Is inter-
mittent or continuous.
S. Pretreatment Provided Indicate if
pretreatment is provided prior to
entering the mtunicloal system
�. Ca►aractetlstics of Wastewater
tare Instructions)
40111641
4016
401C
"Id
4010
401 f
402
403a
403t
404a
404!
405
1
301 North Scales Street
Reidsville
Rockingham
North Carolina
2111
Units (lee
Quantity Table It I
C'.igart,tte Making am 162 Nft Million/Day
- Tohacc� aipr Nn
402 thousand "llons per day
13 Intermittent (Intl continuous(com
Vas]No
Parameter
Name TSS
PH
00
Paternal or
Number
00310
00530
00400
00556
.
Varue
50
1 159
6.7
30
IV•1 This section contains 1 page.

I
FOR AaENCV USE !
STANDARD FORM A —MUNICIPAL
SECTION 17. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each mWor Industrial facility discharging to the tnurAck M iyawh, weft* a separete Samoa IV for each taclItty dley[top
tion. Indicate the 4 digit Standard Industrial Clasttflcatton (SIC) Code tot the MiUitry, the 1004' ModWCt Of fear swafettal, toe flow (in thh--
sand gallons per day), and the characteristics of tht wastewater dls"Illld frOM the il+dutttlal faCMlty into the nwniCtpsi system- Consult : able
lit for standard rnessums of products Or taw Materials- 4see Instruction$)
t• aWor Contributing facility .
(see instructions)
Name 1 4018 1 .J ni fi - Tnr _ _---
Numbers. Street
City
County
State
Zip Code
2. Primary Standard Industrial
Classification Code (yet
Instructions)
3. Principal Product or Raw
aAateriai (see instructions)
Product
Raw Material
4, flow Indicate the volume of water
discharged into the municipal Sys-
tem In thousand gallons per day
and whether this discharge Is Inter-
mittent or continuous.
S. Pretreatment Provided Indicate if
pretrestmenl is provided prior to
entering the municipal system
6. Cwsracterlstics of wastewater
(see instructions)
401b
40tc
40td
4016
401 f
402
4031
403t
4041
4041
40s
i
300 Vance Street, P.O. Box 1437 _
RPidsvi11 _
Rockingham
North Carolina
Units (See
Quantity Table Ill)
nye am La 000 4eft 1h • .Yarn/d
ape Nx
i
1, 565 thousand getion . per day
O Intermittent (Intl 6continuous(con)
® Yes ONO
Parameter
Name BOD T S S
pH
0 &G
Cr
Cu
Zn
Psranhet er
Number
00310 00530
00400
00556
01034
01042
01092
Value
73
75
7.2
20.5
0.03
0.11
0.18
IV-1 "is section contains l psEe.
cFo 965-70t

r
l
FOIL AGE14CV use !
STANDARD FORM A —MUNICIPAL
SECTION 8. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a descriptlon of each a 1410f industNat facility discharging to Ma WAIRie10411 ayst&T4 WINN a NOaraN SeettOh IV for MCA 4801tty desert+p•
tion. Indicate the 4 digit Standard Industrial Classification (SIC) Code for the 641AUStry, the rwaior Orodssct Of eaer 001WW. tan Mow (in thh.-
sand gallons per day). and the characterlitics of the wastewater discharged from file IwduttfUl fSCMity into the municipal system. COnsutl : 3bte
III for standard measures of pfoduCtx Or faw materials. (see Instw040416)
10 "Wor Contributing Facility
(sae Instructions)
Herne 4010 RnhmP—Fi 1 a t ex ; Tnr.,,
Humberit Street
City
County
State
21p Code
2. Primary Standard Industrial
Classification Code (see
Instructions)
3. ►rindpal product or flaw
Mlateriat (sae Instructions)
Product
Raw Material
4. Flow indicate the volume of water
discharged into the municipal sys-
tem, in thousand gallons per day
and whether In$$ discharge Is Inter-
mittent of continuous.
S. Pretreatment Provided Indicate if
pretreatment is provided prior to
entering the municipal sysle-
4. CRatectertstics of Wastewater
(aM Instructions)
401 b
401 c
4014
4010
4011
402
403a
403b
464a
404b
1 405
1
Watlington Road
Route # 10 , Box 1
Reidsville
Rockinkham • .�
2815
units (tee
Quantity Table If i
Fini ghingMmmiral a for 4m _ 50,000 am 1. bs. /Day
textile-- an PA t"�l Y
i ndtts i eg MOW Mx
151 thousand gallons per day
13 intermittent (Intl MConanuous(con)
o Yes bNo
pafametaf
Hann
&G
Cr
Cu
Zn
parameter
Humber
00310
00530
00400
00556
01034
01042
01092
Value
195
50
7.4
14.4
0
0.05
0.16
IV-1 ntia aecflon confalna page.
GPO 465.70(

I
FOR AGC«CV USE
STANDARD FORM A —MUNICIPAL
SECTION IV. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each "of Industrial facility d"char ing to the tnunWw system. !Awns a separate Section 1V for each facility des 1W
lion. Indicate the 4 digit Standard Industrial Clatsiflcstion (SIC) Code for ttw IA/uttry. Vw moor product or saw awatartal. tea flow tin the%.-
sand gallons per day). and the characteristics of the wastewater discharged from the industrial fecUlty Into the MunklpN System. Consult : 301e
III for standard measures of products Or raw materials. (see Instructions)
%• silo► Contributiws facility •
(see Instructions)
14o1a Beta Systems
wm. •__
Numbers. Street
City
County
State
21p Code
2. Primary Standard Industrial
C14641ficetion Code (see
instructions)
3. Principal Product or Raw
Material (see instructions)
Product
Raw Material
4. flow Indicate the volume of water
discharged into the municipal Sys.
tern In thousand gallons per day
and whether this d46Ch8rge Is Inter-
mittent or Continuous.
S. Pretreatment Provided Indicate it
Pretreatment Is provided prlor to
entering the rnuniCloaf system
4. Cuaractsrlstics of Wastewater
(see instructions)
401b
40tc
401 d
401e
401 f
402
403a
403!
Division of Velcon Filters, Inc. _
i209 Freeway Drive
RAIdSV11]P
Rockingham
North Carolina
27320
35619 37289 3795
Units (see
Quantity Table 111
Metal Fabrication and �s 18 �sise Tanks/Day
Finishing
sex
404a 3 thouand gallon: tsar day
4046 Intermittent (Intl QContinuous(con)
405 Yes QNo
l
parameter
Name
H
0 &G
Cr
Cu
Zn
parsmet er
Number
01042
01092
Value
67
112
6.5
17
0.17
0.07
0.07
IV-1
GPO 465.70(
This section contains 1 page.

Post AacNCV USE
STANDARD FORM A —MUNICIPAL
SECTION 17. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each w4or industrial facility discharging to the "WrAc*al systeet" mine a "VMS" Section IV for each faculty owrip
lion. Indicate the 4 digit Standard Industrial Classification (SIC) Code for the Inrustry, the moor Product or tow (ovate". the flow tin ihi+•.-
sand gallons per day), and the characteristics of the wastewater discharged from the Wkistriat faculty Into the munklpa(system. Consult = able
lie tar standard measures of products or raw materials. (see Instructions)
t• "Woe Centributins Facility
(a" Instructions)
Name 14018 Fq t� i tv Meat Corporation
Number& Street
City
County
State
zip Code
2. Primary Standard industrlal
Csaulfication Code (se
Instructions)
]. Prindpst Product or Raw
1Natariat (see Instructions)
Product
(taw Material
4. Flow Indicate the volume Of water
discharged Into the municipal sys-
tem In thousand gatiom per day
and whether this discharge is Inter-
mittent or continuous.
S. Pretreatment Provided Indicate if
pretreatment is provided pnoi to
entering the municipal system
t. Cker6 Plants of wastewater
(w instructions)
. a
4016
40le
"id
4010
401 f
402
403a
403b
404a
404b
40s
I
Byers Drive at NC-87 _
Reidsville
Rnrkingham ,
Nnrt-h C:arnl ins
,)2-Agn
209
Units (See
Quantity Table ill
Fnnrl Prnr"Pa�i n g 4M 360,000 Nag Lb. /Day
156 thousand gallons per day
Intermittent (int) (NContinuous(con)
M Ves C)e o
Parameter
Name TSS
H
0 &G
xamet or
Numbcr
nnii o
00530
00400
00556
Value
720
600
7.4
95
GPO $65.701
IV-1
Me section contains I pate.

Dolt AGENCV USE
—s
STANDARD FORM A —MUNICIPAL
SECTION IF. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each "of Industrial facility discharging to ten nw"WAtltal sv tem. rstng a *DPW*" Section IV for eyeh facutty deftrep•
tion. Indicate the 4 digit Standard Industrial Classification (SIC) Code for the hM/ustry, VW wlajOr product or few watertal. the how ten thou.*
sand gallons per day). and the characteristics of the wastewater dise"C ed from ten In"trul faculty Into the municipal system. Consult :able
III for standard m"sures of products or raw material$. (see Instructions)
t• Mslor Centrtbutiag Facility
(ae Instructions) -
Nan" sots rha^p prPni si nn Metal _ Tnr. .
Number& Street
City
County
State
Zip Code
2. Primary Standard industrial
Classification Code (see
instructions)
3. Prinolpal Product or Raw
Material (see Instructions)
Product
Raw Material
4. View Indicate the volume or water
. desCharged into the municipal syS-
tem In thousand gallons pet day
and whether this discharge b Inter-
mitteni of continuous.
S. Pntteatenent Provided Indicate it
Oretrastment is provided prior to
entering the municipal system
4. Characteristics of wastewater
taw instructions)
401b
401t
4old
4010
401 f
402
4031
4031:
404'
404i
405
I
1704 Barnes Street
Reidsville _
Rockingham
North Carolina
27320
3499
units (fee
QuMttty Table 111
I
Metal Bonding Plating ilea. 15.7 milli Mss Items/Mo.
SIX
30 thousand gallons per day .
O intermittent (Intl Otcontinuous(con)
IRVes Otto
Parameter
Name
Cu
Zn
parameter
Number
00310
00530
00400
00556
01034
010
01092
Value
43
20
1 6.5
1 10
1 0.02
1 .30
1 0.09
IV-1 "i• section contains I pete.
GPO 465.7CC

a
STANDARD FORM A —MUNICIPAL
SECTION 17. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
FOR AGCNCV USE
--1
I
Submit a description of each "or Industrial facility dlsChargirq to the Tlthlt ifiN 111YOW . tlatnll Al tlaparala SecUoh IV for each factttty desrrrp-
tion. Indicate, the 4 digit Standard Industrial Classification (SIC) Code for t1w IrAk stry. the Moor product of raw Mew , tM flow On thfk.-
and gallons per day). and the characteristics of the wastewater dischafted from the sr4ustrlal faculty Into the mtunlcipal system. Consult We
III for standard matsufet of product% of raw materials. (see InstrudionQ
t• Moor Contributing Facility
(wa Instructions)
Name 4018
Reidsville Container Division
Numbers, Street
City
County
State
Zip Code
2. Primary Standard Industrial
Classification Code (see
Instructions)
3. Prindpst Product or Raw
huterial (see instructions)
Product
Raw Material
4. Flow Indicate the volume of water
dr$ChaMed into the municipal Sys -
tam In thousand gallons per day
and whether this discharge Is Inter -
mittens of continuous.
S. Pretreatm+eni Provided Indicate if
pretreatment Is provided prior to
entering the municipal system
a. Cteracteristkil of wastewater
(see instructions)
401 b
401 C
401 d
4014
401 f
402
403a
4034:
4041
404t
40S
(
1900 Ba nos Street
Reidsville
Rockingham ._
North Carolina
27320
3411
Units (tee
Quantity Table l l l
Aluminum Cans ftft 3,343*.000 Ms. Cans/Day
NS/ M>K
144 thousand getions per day
❑ Intermittent (Intl M Continuous (con)
V es Q NO
Parameter
Name BOD TSS
pH
0&G
Cr
Cu
Zn
Parameter
Number
nnmo
00530
00400
00556
01034
01042
01092
Value
255
144
8.0
86
000
1 0.16 1
0.37
IV-1 This tecfion contaima I pate.
cF0 465.70t

1
ROIL AaCNCV USE
y
STANDARD FORM A —MUNICIPAL
SECTION 17. INDUSTRIAL WASTE CONTRIBUTION TO MUNICIPAL SYSTEM
Submit a description of each Major industrial facility
discharging to the nwrjc Dal sya wl. tding a sspme" Section IV for Meh taelttty desef40'
tion. Indicate the 4 digit Standard industrial Classification (SIC) Code tot the industry. the MOW Nodwct Or faer wlatetlal, the flow On sht%-'
sand gallons par day). and the Char actorltticl of the wastewater dtsehwgad from the Imilkstrist facalty into the munict"f system. Consult : ]ble
III for standard Measures of products or raw materials.
(see Instructions)
1, DIWor Contributing Facility
'
(sae instructions)
Schlegel Corporation
Name
4018
•— —
. Number&. Street
46/e
226 Watlingt on In ustr_ ia) Dri ygm- _
Reidsville
city
401C
—• -
County
sold
Rockingham ..—
North Carolina
state
4010
27320
Zip Code
401 f
3 0 6 9
2. Primary Standard Industrial
402
Classification Code (sae
Instructions)
units
Quantity Table lli
3. Prindpal Product or Raw
Material (sae instructions)
Extruded Rubber Molding
�
2, 0 0 0
nn.%LYr
Product
402a
--
Raw Material
402b
4, Flow indiCate the volume of water
discharged onto the municipal sys-
tam In thousand gallons par day
and ~her this discharge fs inter-
mittent or Continuous.
S. PretteatMent Proelded Indicate it
pretreatment is provided prior to
anterrng the municipal system
4. CaarSCUIPlstlCt of Wastawatar
(ace tnstructrons)
404a 125 thousand gallons par day
4046 Q intermittent (Intl 0 Continuous (con)
405 (Xves ONO
l
Paramater
Name
Poran"t or
Number
00310
00530
00556
value
300
600
1 100
(V-1 nis section contain& 1 page.
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nAx

FACT SHEET FOR WASTELOAD ALLOCATION
Request # ---
8265 & 8311
Facility Name:
City of Reidsville W WTP
NPDES No.:
NCO024881
Type of Waste:
63% Domestic, 37% Industrial
Facility Status:
Existing
Permit Status:
Renewal & Modification (outfall relocation to Haw River)
Receiving Stream:
Little Troublesome Creek & Haw Rivei#
Stream Classification:
C-NSW
Subbasin:
03-06-01
County:
Rockingham Stream Characteristic:
Haw River
Regional Office:
Winston-Salem USGS #
per Robert Mason
Requestor:
Susan Wilson Date.
1/5/93
Date of Request:
6/16/95 Drainage Area (mi2):
160
Topo Quad:
B20SW Summer 7Q10 (cfs):
7.4
Winter 7Q10 (cfs):
30Q2 (cfs):
34
Average Flow (cfs):
144
IWC @ 7.5 mgd(%):
61%
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
Current permit has language stipulating that no expansion above 5.0 MGD may occur until WET
test compliance is achieved. Facility has reported chronic values that would pass at the Haw River
site for 18 of the last 21 WET tests, with 10 passing at >90%. Permit language should be changed
to allow flow expansion upon relocation provided that facility continues to show improved WET
test results. Toxicant analysis shows that limits for Cr and Ni can be removed from permit, ands-
that Fluoride limit can be removed upon relocation. Monitoring for Mn, Aland Sb can also be L=
removed. All parameters will continue to be monitored quarterly through LTMP. Permitfor ' ' -
relocated outfall will also have advanced tertiary treatment limits for conventional pollutants as with
Little Troublesome Creek discharge.
and additional comments from Reviewers:
Reviewed by
Instream Assessment
kegional Supervisor:
Permits & Engineerin
nkNr� �61ArJ��
RETURN TO TECHNICAL SUPPORT BY:
r,, ?' G 1095

2'
Existing Limier
CONVENTIONAL PARAMETERS
Monthly Average
Summer Winter Daily Max.
Wasteflow (MGD):
7.5* 7.5*
CBOD5 (mg/1):
4.0 8.0
NH3N (mg/1):
2.0 4.0
DO (mg/1):
6.0 6.0
TS S (mg/1):
30 30
Fecal Col. (/100 ml):
200 200
pH (SU):
6.0-9.0 6.0-9.0
Residual Chlorine (µgill):
17
Oil & Grease (mg/1):
TP (mg/l):
2.0 2.0
TN (mg/1):
monitor monitor
*Permit stipulates no expansion above 5.0 MGD until WET test compliance is achieved.
FoY L : Tvcubl� �rw-L and
Recommended Limits:
HaW s�iYe+(
Monthly Average
Summer Winter Daily Max. WQ or EL
Wasteflow (MGD):
7.5*
7.5*
BOD5 (mg/1):
4.0
8.0
NH3N (mg/1):
2.0
4.0
DO (mg/1):
6.0
6.0
TSS (mg/1):
30
30
Fecal Col. (/100 ml):
200
200
pH (SU):
6.0-9.0
6.0-9.0
Residual Chlorine (µg/1):
17 (Little
Residual Chlorine (µgill):
28 (Haw
TP (mg/1): 2.0 2.0
TN (mg/1): monitor monitor
*Flow limit may increse to 7.5 MGD upon relocation to Haw
continues to report improved WET test results.
Limits Changgs Due To:
Change in 7Q10 data
Change in stream classification
Relocation of discharge X
Change in wasteflow
Other (onsite toxicity study, interaction, etc.)
Instream data
New regulations/standards/procedures
New facility information
WQ
WQ
WQ
EL
EL
EL
Troublesome Cr.)
River)
WQ
River, provided that facility
Residual Chlorine
(explanation of any modifications to past modeling analysis including new flows, rates, field data,
interacting discharges)
(See page 4 for miscellaneous and special conditions, if applicable)

3
%jr-
TOXICS/METALS
Type of Toxicity Test: Chronic (Ceriodaphnia), 24 hr. P)F @ IWC
Existing Limit: P/F @ 90%
Recommended Limit: P/F @ 61 %
Monitoring Schedule: Jan., Apr., Jul., Oct.
L. Troublesome Haw River
Daily Max. Daily Max.
Aluminum (ug/1):
monitor
Antimony (ug/1):
monitor
Cadmium (ug/1):
2.0
Chromium (ug/1):
50
Copper (ug/1):
monitor
Nickel (ug/1):
50
Lead (ug/1):
25
Zinc (ug/1):
monitor
Cyanide (ug/1):
5.0
Flouride (mg/1):
1.8
Chloroform (ug/1):
monitor
Manganese (ug/1):
monitor
MBAS (mg/1):
0.5
Mercury (ug/1):
0.012
Silver (ug/1):
monitor
Recommended Limits
L. Troublesome
Haw River
Daily Max.
Daily Max.
Antimony (ug/1):
**
**
Cadmium (ug/1):
2.()
3.3
Chromium (ug/1):
**
**
Copper (ug/1):
monitor
monitor
Nickel (ug/1):
**
**
Lead (ug/1):
25
41
Zinc (ug/l):
monitor
monitor
Cyanide (ug/1):
5.0
8.2
Flouride (mg/1):
1.8
**
Chloroform (ug/1):
**
**
MBAS (mg/1):
0.5
0.8
Mercury (ug/1):
0.012
0.019
Silver (ug/1):
monitor
monitor
** Parameters will
continue to be monitored quarterly in LTMP.
Limits Changes Due To: Parameters Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge X Flouride
Change in wasteflow
New pretreatment information X Sb, Cr, Ni, Chloroform
Failing toxicity test
Other (onsite toxicity study, interaction, etc.)

Page 1
Note for Carla Sanderson
From: Carla Sanderson�j�
Date: Tue, Mar 14, 1995 1:22 PM
Subject: RE: Reidsville
To: Susan Wilson
Anything on the %Dom and %Ind?
From: Susan Wilson on Tue, Mar 14, 1995 1:19 PM
Subject: RE: Reidsville
To: Carla Sanderson
this is just a renewal that they sent in way early
From: Carla Sanderson on Tue, Mar 14, 1995 1:17 PM
Subject: Reidsville
To: Susan Wilson
Susan - this WLA got sent down without indication of %Domestic or %Industrial. Is there
any indication of this on the application? Also, will this be permitted in the basin schedule (to
issue Feb'96) or will this one get an earlier permit (usually only do these earlier than basin
schedule when expansion is requested).

Facility Name 61 Ku'cAS u i le W W779 Permit # 1106-2 yY'1 i Pipe # WL
CHRONIC TOXICITY PASS/FAII. PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is (9 / % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The fast test will be
performed after thirty days from the effective date of this permit during the months of
.Tan L, Or;' Effluent sampling for this testing shall be performed at the NPDES
permitt6d final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 7 N cfs
Permitted Flow -7. S MGD
IWC Gt %
Basin & Sub -basin -O
Receiving Stream a 3^ Rlu�r
County
Recommended by:
QCL P/F Version 9191

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Facility Name aF aiol6y d le- W L,07 9 Permit # 1J6062YY'f1 Pipe # �L
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is (o / % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
quarter monitoring using this procedure to establish compliance with the permit condition. The fast test will be
performed after thirty days from the effective date of this permit during the months of
Tan,. 40r.. Jul.. O,t . Effluent sampling for this testing shall be performed at the NPDES
pennitt&d finaleffluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 7 y cfs
Permitted Flow -7. 6 MGD
IWC GI %
Basin & Sub -basin Receiving Stream a 3� Rit/e�_ri
County
��
l./
a+dr/,.
QCL P/F Version 9191

Pegs ,
Note for Carta Sanderson
From: Carla Sanderson & /U+L"�
Date: Tue, Mar 14, 1995 1:22 PM
Subject: RE: Reidsville
To: Susan Wilson
Anything on the %Dom and %Ind?
From: Susan Wilson on Tue, Mar 14, 1995 1:19 PM
Subject: RE: Reidsville
To: Carla Sanderson
this is just a renewal that they sent in way early
From: Carla Sanderson on Tue, Mar 14, 1995 1:17 PM
Subject: Reidsville
To: Susan Wilson
Susan - this WLA got sent down without indication of %Domestic or %Industrial. Is there
any indication of this on the application? Also, will this be permitted in the basin schedule (to
issue Feb'96) or will this one get an earlier permit (usually only do these earlier than basin
schedule when expansion is requested).

.u- � � � `� •- n . ice,_ if • .-
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic tonicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is qO % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
Quarterly monitoring using this procedure to establish compliance with the permit condition. The fast test will be
performed after thirty days from the effective date of this permit during the months of
Tn. Ads W. nd . Effluent sampling for this testing shall be performed at the NPDES
p ttrmr ed hn6l efflu nt discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 0. ;;�
cfs
Pemritted Flow S. D
MGD
[WC 97
%
Basin & Sub -basin
Receiving Stream �/ :i l�
-roud/e3amo rr.
County
Recommended by:
Dare
QCL P/F Version 9191

X Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
No parameters are water quality limited, but this discharge may affect future allocations.
INSTREAM MONITORING REQUIREMENTS
0pw
Upstream Location: Hwy 29 bridge (Business Rte. or By -Pass, which ever is more accessible3�.
Downstream Location: NCSR 2620 bridge
Parameters: Temperature, Dissolved Oxygen, Fecal Coliform, Conductivity
Special instream monitoring locations or monitoring frequencies:
5 h vtG� i Yl L v�Ovb(r SB n`� V ' y4 n� t,,,s.fmw id he vk 2.t x ✓
o MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adequacy of Existing Treatment
Has the facility demonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes _ No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Wasteload sent to EPA? (Major) Y (Y or N)
(If yes, then attach updated evaluation of facility, including toxics analysis, modeling analysis if
modeled at renewal, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.

TOXICS/METALS
Type of Toxicity Test: Chronic (Ceriodaphnia), 24 hr. P/F @ IWC
Existing Limit: P/F @ 90%
Recommended Limit: P/F @ 61 %
Monitoring Schedule: Jan., Apr., Jul., Oct.
Existing Limits
L. Troublesome Haw River
Daily Max. Daily Max.
Aluminum (ug/1):
monitor
Antimony (ug/1):
monitor
Cadmium (ug/1):
2.0
Chromium (ug/1):
50
Copper (ug/1):
monitor
Nickel (ug/1):
50
Lead (ug/1):
25
Zinc (ug/1):
monitor
Cyanide (ug/1):
5.0
Flouride (mg/1):
1.8
Chloroform (ug/1):
monitor
Manganese (ug/1):
monitor
MBAS (mg/1):
0.5
Mercury (ug/1):
0.012
Silver (ug/1):
monitor
Recommended Limits
L. Troublesome
Haw River
Daily Max.
Daily Max.
Antimony (ug/1):
**
**
Cadmium (ug/1):
2.()
3.3
Chromium (ug/1):
**
**
Copper (ug/1):
monitor
monitor
Nickel (ug/1):
**
**
Lead (ug/1):
25
41
Zinc (ug/1):
monitor
monitor
Cyanide (ug/1):
5.0
8.2
Flouride (mg/1):
1.8
**
Chloroform (ugh):
**
**
MBAS (mg/1):
0.5
0.8
Mercury (ug/1):
0.012
0.019
Silver (ug/1):
monitor
monitor
** Parameters will continue to be monitored
quarterly in LTMP.
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge X Flouride
Change in wasteflow
New pretreatment information X Sb, Cr, Ni, Chloroform
Failing toxicity test
Other (onsite toxicity study, interaction, etc.)

CONVENTIONAL PARAMETERS
Existine Limi
Monthly Average
Summer Winter
Daily Max.
Wasteflow (MGD):
7.5* 7.5*
CBOD5 (mg/1):
4.0 8.0
NH3N (mg/1):
2.0 4.0
DO (mg/1):
6.0 6.0
TSS (mg/1):
30 30
Fecal Col. (/100 ml):
200 200
pH (SU):
6.0-9.0 6.0-9.0
Residual Chlorine (µgp):
17
Oil & Grease (mg/l):
TP (mg/1):
2.0 2.0
TN (mg/1):
monitor monitor
*Pemut stipulates no expansion above 5.0 MGD until WET test compliance is achieved.
Recommended Limits:
FovL.Tvoulob:�nyy c and
Haw +Fl;uer
Monthly Average
Summer Winter
Daily Max. WQ or EL
Wasteflow (MGD):
7.5* 7.5*
BOD5 (mg/1):
4.0 8.0
WQ
NH3N (mg/1):
2.0 4.0
WQ
DO (mgp):
6.0 6.0
WQ
TSS (mg/1):
30 30
EL
Fecal Col. (/100 ml):
200 200
EL
pH (SU):
6.0-9.0 6.0-9.0
EL
Residual Chlorine (µg/1):
17 (Little Troublesome Cr.)
Residual Chlorine (µg/1):
28 (Haw River)
TP (mg/1):
2.0 2.0
WQ
TN (mg/1):
monitor monitor
*Flow limit may increse to
7.5 MGD upon relocation to Haw River, provided that facility
continues to report improved WET test results.
Limits Changes Due To: Parameter(s) Affected
Change in 7Q10 data
Change in stream classification
Relocation of discharge X Residual Chlorine
Change in wasteflow
Other (onsite toxicity study, interaction, etc.)
Instream data
New regulations/standards/procedures
New facility information
(explanation of any modifications to past modeling analysis including new flows, rates, field data,
interacting discharges)
(See page 4 for miscellaneous and special conditions, if applicable)

Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WASTELOAD ALLOCATION
Request # 8265 & 8311
City of Reidsville WWTP
NC0024881
63% Domestic, 37% Industrial
Existing
Renewal &Modification (outfall relocation to Haw River),
Little Troublesome Creek &Haw River
C-NSW
03-06-01
Rockingham Stream Characteristic: Haw'River
Winston-Salem USGS # per Robert Mason
Susan Wilson Date: 1/5/93
6/16195 Drainage Area (mi2): 160 5.(0
B20SW Summer 7010 (cfs): 7.4 b. 7-
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
t • � T¢ou.(%ssewE
t . z Gctw
5, O
9m%
Current permit has language stipulating that no expansion above 5.0 MGD may occur until WET
test compliance is achieved. Facility has reported chronic values that would pass at the Haw River
site for 18 of the last 21 WET tests, with 10 passing at >90%. Permit language should be changed
to allow flow expansion upon relocation provided that facility continues to show improved WET.,
test results. Toxicant analysis shows that limits for Cr and Ni can be removed from permit, and - �
that Fluoride limit can be removed upon relocation. Monitoring for Mn, Al and Sb can also be - -
removed. All parameters will continue to be monitored quarterly through LTMP. Permit for
relocated outfall will also have advanced tertiary treatment limits for conventional pollutants as with
Little Troublesome Creek discharge.
0
an
d additional comments from Reviewers:
Reviewed by
Instream Assessment: Date:
- Regional Supervisor: Date: —3 -S 7
Permits & Engine ering: Date: $ 5
RETURN TO TECHNICAL SUPPORT BY:
l095

waters.
H- POLLUTANT ANALYSIS COND
1'1'ION
The PerMittee shall conduct a test for discharge shall be evaluated as Pollutants annually at the effluent from
completed annuallyws' 1) A pollutant analysis ofm the treatment plant.
using EPA a
P�'geables (i e. approved methods for the followin the effluent must be
• , volatile organic compounds
( Annual� ganochlorine pesticides and PCBomp ): (b) acid extractables• c g analytic fractions: (a
Pollutant Anal s (e) herbicides; and ' () base/neutral extractables; memo, to be provided to Monitoring (ApAM) Requirement R metals and other inorganics.
sampling discharges affected by this mom o Ong Form A and accompan -
P g and �alysis requirements and lists chemicals Y�g
This monitorin r emicals to be includedrequirement, describes the
Requirementitor g requirement is to be referred to as the "Annual nnual Pollutant Analysis anal
Analysis Monitorin s.
(2) Other significant levels of or Organic g
For the g • c chemicals must be identified an .
base/neutral Purpose of �plementln
extractable, and acids ez�u�eble f the largest i0 GC d approximately quash fled.
unidentified peaks occur) for chemical fractions (or fewer than peaks in the Purgeable
Reporting Forrn A should be ident' als other than those specified than 10, if less than 10
Reporting Form A instructions. Thisified and approximatel d °n the APA Requirement
the "10 significant part (item 2) of the ApAY1Quantified as stated in the ApAM
Peaks
a")• stated
is to be referred
to as
I. ENGINEERING ALTERNATIVE
S ANALYSIS CONDITION
The Puttee shall continuous) evaluate
environmentall Y irate all wastewater disposal alternatives
y sound alternative of the reasonably cost effective and
substantial non-compliance with the to Pursue the most
regulations or laws, the the N alternatives, If the facility is in
terms and conditions of the NPDES
Division evaluating Perminati shall submit a report in such formPernnt or goVemin
the Division• g these alternatives and a plan of action and detail as r uued rules,
within sixty (60) days of notification the
by

Part III
Permit No. NCO024881
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 90% (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. The first test will be performed after thirty days from the effective date
of this permit during the months of January, April, July and October. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
pemtit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
G. NUTRIENT CONDITION FOR PERMITS WITH PHOSPHORUS LIMITS
This permit may be modified, or revoked and reissued to change the effluent limitation on nutrients
for this discharge depending upon the following:
1. The findings of a study by the Division of Environmental Management determine nutrient
control is necessary.
2. Local actions do not successfully reduce the nutrient loading on the receiving waters.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1 - March 31) Permit No. NCO024881
During the period beginning upon the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall serial number 001. (Continued)
Effluent Characteristics
Pollutant Analysis*****
Conductivity
Chromium
Nickel
Fluoride
M BAS
Cyanide
Cadmium
Lead
Copper
Zinc
Aluminum
Manganese
Antimony
Silver
Chloroform
Mercury
Discharge Limitations
Monitoring
Requirements
Units (specify)
Measurement
SamRle
*Sample
Monthly Avg. Weekly Avg. Daily Max
Frequent
Type
Location
Annually
E
*
Grab
U,D
. 50.0 µg/I
Weekly
Composite
E
50.0 µg/l
Weekly
Composite
E
1.8 mg/l
Weekly
Composite
E
0.5 mg/I
Weekly
Composite
E
5.0 µ g / I
Weekly
Grab
E
2.0 µ g / I
Weekly
Composite
E
25.0 µ g / I
Weekly
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Morith
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Grab
E
0.012 µ g / 1
Weekly
Composite
E,U,D

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS WINTER (November 1- March 31)
Permit No. NCO024881
During the period beginning upon the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall serial number 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations Monitoring
Requirements
Measurement
Saml2le
*Sample
Monthly Avg. Weekly Avg. Daily Max Frequency
Type
Location
Flow
7.50 MGD Continuous
Recording
I or E
CBOD, 5 day, 200C **
8.0 m g/, I 12.0 m g/I Daily
Composite
E,I
Total Suspended Residue **
30.0 mg/l 45.0 mg/I Daily
Composite
E,I
NH3 as N
4.0 mg/l Daily
Composite
E
Dissolved Oxygen***
Daily
Grab
E,U,D
Fecal Coliform (geometric mean)
200.0 /100 ml 400.0 /100 ml Daily
Grab
E,U,D
Total Residual Chlorine
17.0 µg/I Daily
Grab
E
Temperature
Daily
Grab
E,U,D
Total Nitrogen (NO2 + NO3 + TKN)
Monthly
Composite
E
Total Phosphorus******
2.0 mg/l Weekly
Composite
E
Chronic Toxicity""
Quarterly
Composite
E
THE FACILITY HAS BEEN EXPANDED TO 7.5 MGD, BUT THE FLOW SHALL BE LIMITED TO 5.0 MGD UNTIL THE FACILITY
DEMONSTRATES THAT IT CAN CONSISTENTLY MEET THE CHRONIC TOXICITY REQUIREMENT FOR 5.0 MGD.
* Sample locations: E - Effluent, I - Influent, U - Upstream on Little Troublesome Creek at US Highway 29 Business, D - Downstream at the
following locations:
(1) Little Troublesome Creek at NCSR 2600
(2) Little Troublesome Creek at NCSR 2598
(3) Haw River at Highway 150
(4) Haw River at NCSR 2620
Upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week during June, July, August
and September and once per week during the remaining months of the year. Monitoring for Mercury shall be done at a minimum of once per
quarter.
** The monthly average effluent CBOD and Total Suspended Residue concentrations shall not exceed 15% of the respective influent values
(85% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90%; January, April, July and October; See Part III, Condition F.
* * * * * See Part III, Condition H.
****** Compliance shall be based upon a quarterly average of weekly samples.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1 - October 31)
Permit No. NCO024881 '
During the period beginning upon the effective date of the permit and lasting until expiration,
the Permittee is authorized to discharge from
.. outfall serial number 001. (Continued)
Effluent Characteristics Discharge LimitationD
Monitoring
Requirements
Units (specify)
Measurement
saml2le
*Sample
Monthly Avg. Weekly Avg.
Daily Max
Frequency
Type
Location
Pollutant Analysis*****
Annually
E
Conductivity
*
Grab
U,D
Chromium
50.0 µg/I
Weekly
Composite
E
Nickel
50.0 µg/l
Weekly
Composite
E
Fluoride
1.8 mg/l
Weekly
Composite
E
MBAS
0.5 mg/I
Weekly
Composite
E
Cyanide
5.0 µ g / I
Weekly
Grab
E
Cadmium
2.0 µ g / I
Weekly
Composite
E
Lead
25.0 µ g / I
Weekly
Composite
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
Aluminum
2/Mon'th
Composite
E
Manganese
2/Month
Composite
E
Antimony
2/Month
Composite
E
Silver
2/Month
Composite
E
Chloroform
2/Month
Grab
E
Mercury
0.012 µ g / I
Weekly
Composite
E,U,D

ii
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31) Permit No. NCO024881
During the period beginning upon the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Measurement Sample *Sample
Monthly Avg. Weekly Avg.. Daily ax Frequency Type Location
Flow 7.50 MGD Continuous Recording I or E
CBOD, 5 day, 200C** 4.0 mg/I 6.0 mg/I Daily Composite E,i
Total Suspended Residue" 30.0 mg/I 45.0 mg/I Daily Composite E,I
NH3 as N 2.0 mg/I Daily Composite E
Dissolved Oxygen"' Daily Grab E,U,D
Fecal Coliform (geometric mean) 200:0 /100 ml 400.0 /100 ml Daily Grab E,U,D
Total Residual Chlorine 17.0 µg/I Daily Grab E
Temperature Daily Grab E,U,D
Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite E
Total Phosphorus****** 2.0 mg/I Weekly Composite E
Chronic Toxicity**** Quarterly Composite E
THE FACILITY HAS BEEN EXPANDED TO 7.5 MGD, BUT THE FLOW SHALL BE LIMITED TO 5.0 MGD UNTIL THE FACILITY
DEMONSTRATES THAT IT CAN CONSISTENTLY MEET THE CHRONIC TOXICITY REQUIREMENT FOR 5.0 MGD.
* Sample locations: E - Effluent, I - Influent, U - Upstream on Little Troublesome Creek at US Highway 29 Business, D - Downstream at the
following locations:
(1) Little Troublesome Creek at NCSR 2600
(2) Little Troublesome Creek at NCSR 2598
(3) Haw River at Highway 150
(4) Haw River at NCSR 2620
Upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week during June, July, August
.and September and once per week during the remaining months of the year. Monitoring for Mercury shall be done at a minimum of once per
quarter.
** The monthly average effluent CBOD and Total Suspended Residue concentrations shall not exceed 15% of the respective influent values
(85% removal).
*** The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90%; January, April, July and October; See Part III, Condition F.
* * * * * See Part III, Condition H.
****** Compliance -shall be based upon a quarterly average of weekly samples.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts. :,�

State of North Carolina
Department of Environment,
Health and Natural Resources • •
Division of Environmental Management
James B. Hunt, Jr., Governor 10
Jonathan B. Howes, Secretary 1"A A. Preston Howard, Jr., P.E., Director
January 31, 1995
Mr. D. Kelly Almond
City of Reidsville
230 West Morehead St.
Reidsville, NC 27320
Subject: NPDES No. NCO024881
Reidsville WWTP
Permit correction
Rockingham County
Dear Mr. Almond:
The Division has reviewed the subject permit correction sent to you on December 8,
1994; and discovered' that the effluent pages sent to you were in error. Specifically, you were
inadvertently sent limits pages referencing the physical expansion of the plant which has
already occurred. Susan Robson of our office spoke with you on January 4, 1995 regarding this
error. Enclosed please find the correct effluent limits pages, which contain both the corrected
Phosphorus limits language and flow limitations language. These pages should be inserted into
your permit and all of the old limits pages discarded. Please note that flows still must be
limited to 5.0 MGD even though you have expanded until consistent compliance with whole -
effluent toxicity requirements are achieved. 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 December 6,
1983.
If any parts, measurement frequencies or sampling requirements contained in this
permit modification are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. This request must be
in the form of a written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447,
Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final
and binding.
Please take notice that this permit is not transferable. Part II, E.4. addresses the
requirements to be followed in case of change in ownership or control of this discharge. This
permit does not affect the legal requirement to obtain other permits which may be required by
the Division of Environmental Management or permits required by the Division of Land
Resources, 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 Susan Robson
at telephone number 919/733-5083.
cc: Mr. Jim Patrick, EPA
Winston-Salem Regional Office
Compliance -Jeanne Phillips, ISB
Central Files
Si cerely,
?-'**-A. Preston Howard, Jr., P.E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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FWKBEWER, PES 6 STRCW, INC.
.w. 201 FACILITIES
1; -�, CONSULTWG ENGINEERS o.DA.. PLAN UPDATE
- \ CREENSBORO, NORTH CARObWA DMA REIDSVILLE. N.C.
_ Dlfs

NPDES WASTE LOAD ALLOCATION _
PERMIT NO.: NCO024881
I U91 9005 ISO 0I
FACILITY NAME:
City of Reidsville
Reidsville WWTP
Facility Status: Existing
Permit Status: Renewal
Major `I Minor
Pipe No.: 001
Design Capacity: 7.5 MGD
Domestic (% of Flow):
Industrial (% of Flow): J3
Comments: ms. 1S apiq Me ¢o ,CA,hI — r4a a6 ir,orj '/c _
RECEIVING STREAM: Little Troublesome Creek
Class: C-NSW
Sub -Basin: 03-06-01
Reference USGS Quad: B 20 SW (please attach)
County: Rockingham
Regional Office: Winston-Salem Regional Office
Previous Exp. Date: 1/31/96 Treatment Plant Class: IV
Classification changes within three miles:
Changes to WS-I3I NSW downstream approximately 4 miles at the
Haw River to`nt N5w
Requested by: Susan Wilson
Prepared by: QW
Reviewed by: \
,:RoD, (S)/ /(O
�� � Z'
Date: 3/14/95
Date: Q/g /r-7.S
Date: 2S
JP//D
9S
Modeler
Date Rec.
#
.?"v
3 I4 9S
8 Z' S
,
Drainage Area (mil ) 6. (. Avg. Streamflow (cfs): S. 5
7Q10 (cfs) p, 2 Winter 7Q10 (cfs) /, 0 30Q2 (cfs) /, Z
Toxicity Limits: IWC q0 % Acut hromc
Instream Monitoring: Moo/,���inq s1s anc/ Parom.crS mould be,
Parametersrer1Y47n'nr�6 Oxwi'lj far 1_*tc ireub1e6&'nc, Cr
Upstream 7 Location
Downstream Location
Recommended Limits:
Monthly Average
Summer
Winter Daily Max.
Wasteflow (MGD):
7.5*
7.5*
BOD5 (mg/1):
4.0
8.0
NH3N (mg/1):
2.0
4.0
DO (mg/1):
6.0
6.0
TSS (mg/1):
30
30
Fecal Col. (/100 ml):
200
200
pH (Si):
6.0-9.0
6.0-9.0
Residual Chlorine (µ A):
17
TP (mg/1):
2.0
2.0
TN (mg/1):
monitor
monitor
Cadmium (ug/1):
2.0
Copper (ug/1):
monitor
Lead (ug/l):
25
Zinc (ug/1):
monitor
Cyanide (ug/1):
5.0
Flouride (mg/l):
1.8
MBAS (mg/1):
0.5
Mercury (ug/1):
0.012
Silver (ugft
monitor
*Flow limit may increse
to 7.5 MGD upon relocation to Haw
River, provided that facility continues to report improved WET test
results.
Comments:
M

•
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated. Discharge
to surface waters is the only alternative available for this
7.5 mgd discharge.
Spray Irrigation:
Connection to Regional Sewer System:
Subsurface:
Other disposal options:
5. Other Special Items:
PART IV - EVALUATION AND RECOMMTNDATIONS
It is recommended that the permit be modified to reflect a
discharge into the Haw River. Recent months have shown an
improvement in effluent toxicity. The City has requested an
amendment to their SOC for the relocation of the discharge to the
Haw River. Relocation to the Haw River would eliminate the
present discharge into the zero 7Q10 flow of Little Troublesome
Creek.
Signature of report preparer
ter Quality 6
gional Supervisor
D t
NPDLS Permit Staff Report
Version 10/92
Page 4

h. Pretreatment Program (POTWs only):
in development approved X
should be required not needed
2.� Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM
Permit No. W 0002376.
Residuals Contractor .
Telephone No.
b. Residuals stabilization: PSRP PFRP
Other
c . Landf ill:
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating
sheet). IV Attached
4. SIC Code(s): 4952
Primary Q2 Secondary 21
Main Treatment Unit Code: Q A §- m 3-
PART III - OTHER PERTINENT INFORKILTION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?
The proposed relocation of the discharge may involve some
grant monies.
2. Special monitoring or limitations (including toxicity)
requests: Monitoring and limitations should reflect current
guidelines.
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate) SOC 93-01 Ad I is being processed by DEN.
SOC Ad I Date ProRosed
Submission of Plans and Specifications
Begin Construction March 1, 1996
Complete Construction March 1. 1997
Original SOC requires toxicity compliance by Dec. 31, 1995.
NPDES Permit Staff Report
Version 10/92
Page 3

9. Location of nearest dwelling: There are some houses within
1000 feet of the WWTP.
10. Receiving stream or affected surface waters: Proposed:
Haw River
a. Classification C-NSW
b. River Basin and Subbasin No.: 030601
C. Describe receiving stream features and pertinent
downstream uses: The stream flows through rural
wetland areas. Just upstream of the proposed discharge
point, two mobile home parks discharge to the stream.
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 7.5 MGD (Ultimate
Design Capacity)
b. What is the current permitted capacity of the Waste
Water Treatment facility? 5.0 mgd (Upon consistent
compliance with WET flow limit will be increased to 7.5
mgd).
C. Actual treatment capacity of the current facility
(current design capacity)? 7.5 mgd
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two
years. NA
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities; Influent screening, preaeration, grit
removal, biological treatment using activated sludge,
alum or polymer treatment, final clarification,
disinfection using chlorine, tertiary sand filtration,
chlorine contact chambers, dechlorination using sodium
meta-bisulfite, flow measurement (Parshall Flume),
final aeration. Waste sludge solids are thickened,
aerobically digested, thickened again by decanting from
storage basins, then land applied by private hauler.
f. Please provide a description of proposed wastewater
treatment facilities. Effluent pump station and 33,000
feet of effluent discharge pipe.
g. Possible toxic impacts to surface waters: The facility
has had problems meeting the WET requirements; recent
months have shown an improvement.
NPDES Permit staff Report
Version 10/92
Page 2

cc: Permits and Engineering
Technical Support Branch
County Health Dept.
Central Files
WSRO
SOC PRIORITY PROJECT: Yes X No_
If Yes, SOC No. 93-01 Ad I (Requested)
To: Permits and Engineering unit
Water Quality Section
Attention: Susan Wilson
Date: June 26, 1995
NPDES STAFF REPORT AND RECOMMENDATION
County Rockingham
Permit No. NC0024881
PART I - GENERAL INFORMATION
1. Facility and Address:
Facility Address: Mailing Address
Reidsville WWTP City of Reidsville
407 Broad Street 230 West Morehead Street
Reidsville, N.C. 27320 Reidsville N.C. 27320
2. Date of Investigation: October 1995
3. Report Prepared by: David Russell, Environmental Specialist
4. Persons Contacted and Telephone Number: Donald Waddell (Oct.
194 during land application inspection) [phone]
5. Directions to Site: From Winston-Salem travel Hwy 158E to
Reidsville, Go. south on Bus. 29, left on Lawndale, left on
Seales St., right on Broad St. The WWTP is at the end of
Broad Street.
6. Discharge Points(s), List for all discharge points:
Existing: Latitude: 360 16' 02" Longitude: 790 36' 14"
Existing: U.S.G.S. Quad No. B20SE U.S.G.S.
Quad Name Williamsburg
7. Site size and expansion area consistent with application?
X Yes No If No, explain:
40+/-acres
8. Topography (relationship to flood plain included): Most of
the facility is on relatively high ground adjacent to the
upper reaches of the creek. Part of the plant is on the
edge of the flood plain.

+41
Jp� 5cA `0"
Cu r/'cn i �vd6J� l�o Q5oh<f G
7QID: 0.2c�s
In)7D ID c I tJ a;'S
.2 �Fs
a
3
sow 43
pcldfv;lles j'lonned ON�1 K�eCa
Qa = 5, o irl GL (eFl��;<� 7.5(
�A= i�o M• 1
C4 = 14q
%glp,7.J�fs Lvs.O'
cfis �7.5 °
3baa

�* HAW RIVER AT US 29A NEAR BENAJA, NC
Page 2 of 2
Summer Summaa (April -October):
nhePrvntinnc Observs > Det Median Maximum Minimum
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/1):
Ammonia -Nitrogen (mg/1):
Nitrate/Nitrite-Nitrogen (mg/1):
Conductivity (µMho):
Chlorophyll a (Corr) (µg/1):
Total Suspended Residue (mg/1):
11
11
7.6
9.8
6.2
11
11
6.7
7.3
6.5
11
11
0.07
0.12
0.04
11
10
0.06
0.09
0.01
11
11
0.22
0.36
0.05
11
11
78
92
63
NIS
11
11
9
25
2
Summer Summary (June -September):
Ohcervatinns Observs > Det Median Maximum Minimum
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/1):
Ammonia -Nitrogen (mg/1):
Nitrate/Nitrite-Nitrogen (mg/1):
Conductivity (µMho):
Chlorophyll a (Corr) (µg/1):
Total Suspended Residue (mg/1):
■
Yearly Summary:
Dissolved Oxygen
Year Obs Obs>Det Median Max Min
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
8.3
12 -
6.2 .
1993
7
7
8.8
12.6
7
Conductivity
1988
NIS
1989
NIS
1990
NIS
1991
1
NIS
1992
10
10
72.5
92
61
1993
7
7
63
87
31
Total Suspended Residue
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
5.5
25
2
1993
7
7
9
17
4
PE
Year Ohs Obs>Det Median Max Min
1988
NIS
1989
NIS
1990
NIS
1991
1
NIS
1992
10
10
6.7
73
6.5
1993
7
1 7 1
7
1 7.1
6.7
Total Phosphorus
MIN:
Ammonia -Nitrogen
off ..I
ffUM
ITV
••
��
il.
if•
li

AVERAGE
MAXIMUM
MINIMUM
UNIT
.023
.0733
3.30
.150
.8000
9.90
.100
.2000
.25
MG/L
UG/L
MG/L
GKEX88/MP
03/13/95
COMPLIANCE EVALUATION ANALYSIS REPORT
PAGE 1
PERMIT--NC0024881
'PIPE--001
REPORT PERIOD:
9202-9301
LOC --- E
FACILITY--REIDSVILLE
WWTP,
CITY OF
DESIGN FLOW--
7.5000
CLASS--4
LOCATION--REIDSVILLE
REGION/COUNTY--04 ROCKINGHAM
50050
00310
00530
00610
31616
50060
00300
TGP3B
MONTH
Q/MGD
BOD
RES/TSS
NH3-N
FEC COLI
CHLORINE
DO
CERI7DPF
LIMIT F
5.0000 F
10.00
F 30.0 F
4.00
F 1000.0
NOL
F 6.00
NOL
92/02
3.3365
8.33
20.0
1.57
5.4
.394
10.29
2
92/03
3.0325
10.80F 21.2
1.88
6.7
.240
9.63
2
LIMIT F
5.0000 F
5.00
F 30.0 F
2.00
F 1000.0
NOL
F 6.00
NOL
92/04
3.3836
5.40F 10.5
.24
1.5
.294
8.94
2
92/05
3.0293
4.13
4.2
.20
1.7
.309
8.79
2
92/06
3.2370-'
.r
3.71
5.7
.12
1.4
.307
7.98
2
.r
92/07
2.9535
2.40
5.1
.20
1.7
.296
7.54
2
92/08
3.1651
1.88
2.7
.10
1.2
.305
7.88
2
92/09
2.9173
1.96
2.9
.16
1.3
.298
7.92
2
92/10
2.5919
2.11
3.4
.15
1.0
.327
8.74
2
LIMIT F
5.0000 F
10.00
F 30.0 F
4.00
F 1000.0
NOL
F 6.00
NOL
92/11
2.7723
3.15
8.1
.38
1.2
.356
8.96
2
92/12
2.3077
4.95
9.0
.43
1.7
.345
9.91
,r s .

93/01 15.52 7.2-6.8 .10.800 1.6800 .7000 1.095 .0000 .0000

•
Chemical Monitoring Summary Report
Pate 1 of 2
HAW RIVER AT US 29A NEAR BENAJA, NC
Station Number: 0209331280
STORET Number. B0050000
Water Quality Class: WS-III Sw
Regional Office: Winston-Salem
Topographic Map: B20SW
County: Rockingham
Subbasin: 030601
Drainage Area (sq mi):
Average Flow (cfs):
Summer 7Q10 (cfs):
Winter 7Q10 (cfs):
30Q2 (cfs):
Gage: No Gage
® Stream
❑ Estuary
❑ Lake
❑ Fish Tissue
❑ Fish Community
❑ Benthic
STORET NC State Beginning Ending
Parameter Name Units rryk C ritPr;nn 1.I;n AAPA kA ., Te. n_:• mtP Moto
Dissolved Oxygen
mg/1
00300
4
6.2
8.4
12.6
17
17
0 -
3/3/92
7/22/93
pH
SU
00400
6-9
6.5
6.8
7.3
17
17
0
3/3/92
7/22/93
Conductivity
µMho
00094
N/C
31
72
92
17
17
0
3/3/92
7/22/93
Chlorophyll a (Corr)
I µg/1
32209
N/C
NIS
Fecal Coliform, MF
#/100 ml
31616
200
10
109.56
1800
16
16
3
3/3/92
7/22/93
Total Phosphorus
mg/l
00665
N/C
0.03
0.07
0.15
17
17
0
3/3/92
7/22/93
Ammonia -Nitrogen
mg/1
00610
N/C
0.01
0.05
0.09
17
16
0
3/3/92
7/22/93
Nitrate/Nitrite-N
mg/1
00630
10
0.05
0.22
0.36
17
17
0
3/3/92
7/22/93
Total Nitrogen
mg/l
00600
N/C
N/S
Turbidity
NTU
00076
50
11
17
100
17
17
1
3/3/92
7/22/93
Hardness
mg/1
00900
100
14
30
51
17
17
0
3/3/92
7/22/93
Total Residue
mg/1
00500
N/C
71
88
140
17
17
0
3/3/92
7/22/93
Total Suspended Res
mg/1
00530
N/C
2
6
25
17
17
0
3/3/92
7/22/93
Aluminum
µg/1
01105
N/C
100
560
7600
17
17
0
3/3/92
7/22/93
Arsenic
µg/1
01002
50
10
17
0
3/3/92
7/22/93
Cadmium
µg/1
01027
2
2
1
17
0
3/3/92
7/22/93
Chromium
µg/1
01034
50
25
17
0
3/3/92
7/22/93
Copper (AL)
µg/1
01042
7
2
3
7
17
12
0
3/3/92
7/22/93
Iron (AL)
µg/1
01045
1000
960
1800
4400
17
17
16
3/3/92
7/22/93
Lead
99/1
01051
25
10
10
29
17
2
1
3/3/92
7/22/93
Mercury
µg/1
71900
0.012
0.2
17
0
3/3/92
7/22/93
Manganese
µg/l
01055
200
36
170
310
15
15
7
3/3/92
7/22/93
Nickel
µg/l
01067
25
10 1
17
0
3/3/92,
7/22193
Zinc (AL)
µg/1
01092
50
10
10
16
17
2
0
3/3/92
7/22/93
Abbreviations: n=number of observations; > Det=number of observations greater than the detection limit; > Crit=number of
observations greater than the criterion; N/S=No sample; N/C=No Criteria; AI, —Action Level
Notes: Median values are calculated using the detection level for samples classified as below detection. The Median value for
Fecal Coliform is actually the Geometric Mean value. Data includes only surface samples. Samples recorded at less than
detection are considered at the detection level for this summary.
Station Comments:

TOXICANT ANALYSIS
GCA de/
jSUrrpb
16f1j AW& c 0
61noo I Cs l'J
Lp fl a+ (5
rear TIC
P \
y
C,�Arl-e
er
Glf fbIr- G,,
mrf obscrva : `(5 A /L
fYlo lf-o r ('n NpOr"�
�z(n c,
7/21 /95
Faciffly Name
Reisdville WWTP
NPDES #
NC0024881
rhv MGD
7.5
7010s Cfs
IWC %
RecWng Stream
„_.._.._.._.._.._..7_4....................
._.._.._.._..__61:10 _.._..___.._..
Haw River
Stream Class
C-NSW
FINAL RESULTS
MBAS
Max. Pred Cw
1.892
Allowable Cw
0.8
max Dbsu"ed
0.�4
Flouride
Max. Pred Cw
2.556
Allowable Cw
2.9
Cyanide
Max. Pred Cw
6
Allowable Cw
8.2
Cadmium
Max. Pred Cw
5.5
Allowable Cw
3.3
Chromium
Max. Pred Cw
34.2
Allowable Cw
81.8
Nickel
Max. Pred Cw
17.6
Allowable Cw
144.0
Lead
Max. Prod Cw
50.6
Allowable Cw
40.9
Mercury
Max. Pred Cw
0.39
Allowable Cw
0.0
Ma e J
0.3
Silver
Max. Prod Cw
0
Allowable Cw
0.1
Arsenic
Max. Prod Cw
0
Allowable Cw
81.8
Selenium
Max. Pred Cw
0
Allowable Cw
8.2
Antimony
Max. Pred Cw
246
Allowable Cw
7037.2
(,i;11,%t- ne,-de�W
Mo,,K 4sar ucd >- al/o,sad le -
Ai, 1111/f needy
Lime nr�dcGl /
/naX IOfea�,�>�cd � Gyl/ocJal�/c.
,lJo lim,t lgwdj
/naX arodicA-- < A/�otza,6�,
fjo lim rl- /leede.d /
r✓l a� ,p«ciic,�ed �
( mA 4ecda %G//a�aO/e
the y ob 6e -va
lV�,en•,'vr in �/1�0�5 /
A1n.K o�6Chie,d 7rn/�oat��J��
No�- enov jA dafa
G�n-�,'4oe, L7?y1fM1 4.4r,17
AoOF .6"LAIA 0"i
MAJ V PAGE'

,.,ti
.
.,
,,
.
-�� . - _.
t
.,
�,

Facility Name % v aT ions u ��� l.� l t) Permit # ^ICoo.,yjejj , Pipe # W I
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is & I% (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
. Effluent sampling for this testing shall be performed at the NPDES
pelrmittAd final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 I q cfs
Permitted Flow -7. S MGD
IWC 61 %
Basin & Sub -basin --O
Receiving Stream
County
Recommended by:
QCL PIF Version 9191

CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is q& % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
ayaLtedy monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
. Effluent sampling for this testing shall be performed at the NPDES
permitted finil efflu nt discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 b0 dL cfs
Permitted Flow . a MGD
1WC 9? %
Basin & Sub -basin 06-
Receiving Stream /.;&%roLAh1ecsad2G Lf:
County
Recommended by:
QCL P/F Version 9191

%0-
_X_ Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving waxer will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
•o
No parameters are water quality limited, but this discharge may affect future allocations.
INSTREAM MONITORING REQUIREMENTS
Upstream Location: Hwy 29 bridge (Business Rte. or By -Pass, which ever is more accessible),
Downstream Location: NCSR 2620 bridge
Parameters: Temperature, Dissolved Oxygen, Fecal Coliform, Conductivity
Syecial instream monitoring locations or monitoring frequencies: I
i i y15 Gt Vi'� Vhftu�t -m rr,(. ; r2I'k P� tJ 0 iq YK
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Has the facility demonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
�107NWIJVITIRURI • • • I • •
Wasteload sent to EPA? (Major) Y_ (Y or N)
(If yes, then attach updated evaluation of facility, including toxics analysis, modeling analysis if
modeled at renewal, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.

6
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.- ....[O
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�.z7-l�j'
�r(Jv..
�-,.r�;�...
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no

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slp /vorr�
Sp c-�S`� �
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V,s y,$

TOXICANT ANALYSIS
7f
iA cr/0
cbyex
Mvsaablc Co 7a Ijlu
Nkx obsel-Ved tj9 L
?jf/IG
Allo,,abl&
#11y ob6ert)-d f3,A31L
4
0
4
PA
7/21 /95
Faciffly Name
Reisdville WWTP
NPDES#
NC0024881
Ow MGD
5
7010s c15
IWC %
Rec'ving Stream
„_.._.._.._.._.._..0:2._.._.._.._.._.._..
48
.- - -_ — 97__._.._.._.._..
Little troublesome Cr.
Stream Class
C-NSW
FINAL RESULTS
MBAS
Max. Pred Cw
1.892
Allowable Cw
0.5
Flouride
Max. Pred Cw
2.556
Allowable Cw
1.8
Cyanide
Max. Pred Cw
0
Allowable Cw
5.1
Cadmium
Max. Pred Cw
5.5
Allowable Cw
2.1
Chromium
Max. Pred Cw
34.2
Allowable Cw
51.3
Nickel
Max. Pred Cw
17.6
Allowable Cw
90.3
Lead
Max. Pred Cw
50.6
Allowable Cw
25.6
Mercury
Max. Pred Cw
0.39
Allowable Cw
0.0
Silver
Max. Pred Cw
0
Allowable Cw
0.1
Arsenic
Max. Prod Cw
0
Allowable Cw
51.3
Selenium
Max. Pred Cw
0
Allowable Cw
5.1
Antimon
Max. Pred Cw
246
Allowable Cw
4411.6
L,m � /1eedcd
Max ab6olv&d > G/lou%ti.6��
Cim,f neact�
max obseraed > at/oi,.1Gb/�
i{or C, Tro�,ble5>,na C-r. on'y)
1klb Limaol /,t need
/Jo dofcoFa6 ,Jalue-5
Lim t� Aeae-Ql
No ljM,4- needed
prjiC4-ed <allo,aablr-
(,4'M,4- ieu ed
mat /`real/Gk6d > All'wz�h/t-
L;ln - /-- n e eject
max ob:5CfVe-oi > A/lawa��e
ND�- Palau h aq�ti
rl/1 an,l-ol- 5,�4 L7,11P
n1o'n,�r 1� LY/rf�
0„Jo J;m,f- Reeci�d
PAGE'

AVERAGE
2.7695
5.7
MAXIMUM
5.8100
28.0
MINIMUM
1.0900
1.0
UNIT
MGD
MG/L
.16
3.1
1.129
9.31
90
2
2.40
1796.0
15.000
12.70
90
2
.03
1.0
.300
7.30
90
2
MG/L
#/100ML
UG/L
MG/L
PASS/FAI
PASS/FAI
GKEX88/MP
03/13/95
COMPLIANCE EVALUATION ANALYSIS REPORT
PAGE 2
PERMIT--NC0024881
PIPE--001
REPORT PERIOD:
9302-9401
LOC ---
E
FACILITY--REIDSVILLE
WWTP,
CITY OF
DESIGN FLOW--
7.5000
CLASS--4
LOCATION--REIDSVILLE
REGION/COUNTY--04
ROCKINGHAM
THP3B
00010.
00400
00600
00665
00720
00951
01027
MONTH CER7DCHV
TEMP
PH
TOTAL N
PHOS-TOT
CYANIDE
FLUORIDE
CADMIUM
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
93/02
14.04
7.1-6.6
18.400
1.6916
.8750
1.092
.5000
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
93/03
14.38
7.1-6.7
13.300
1.4750
1.3000
1.092
.0000
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
93/04
17.56
7.1-6.5
20.000
1.7142
2.7250
1.032
.5250
93/05
21.70
6.8-6.4
18.100
2.2500F
2.3250
1.225
.4000
93/06
.r
23.39
6.8-6.3
18.000
2.1437F
�e
2.5000
1.344
.0000
93/07
25.05
7.2-6.5,
13.900
1.8350
.1600
1.353
.1666
93/08
25.07
7.2-6.8
14.700
1.6687
.6325
1.387
.0000
93/09
24.01
7.1-6.7
13.980
1.5937
2.0400
1.372
.0000
93/10
20.38
7.1-6.6
16.090
1.4916
.9666
1.241
.0000
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
93/11
17.42
7.2-6.6
8.800
1.3235
1.8000
1.380
.0000
93/12
14.43
7.0-6.6
10.800
1.3125
2.2000
1.214
.0000

REIDSVILLE WINTYP
NCO024881
UPSTREAM
temp
DO
sat
%sat
DWNSTREAM
temp
DO
SR2598
sat
'Yosat
DWNSTREAM
temp
DO
SR2600
sat
%sat
DWNSTREAM
temp
DO
HWY150
sat
%sat
DWNSTREAM
temp
DO
SR2620
sat
%sat
date
Ma -92
15.2
9.8
10.0
0.98
17.2
7.9
9.6
0.82
Jun-92
18.3
8.7
9.4
0.92
19.6
7.4
9.2
0.81
Jul-92
21.2
7.8
8.9
0.88
22.7
6.4
8.6
0.74
Au -92
21.1
8.5
8.9
0.96
23.7
6.0
8.5
0.71
23.1
6.9
8.6
0.81
22.4
6.9
8.7
0.80
21.8
7.4
8.8
0.84
Se -92
20.2
8.9
9.1
0.98
20.4
5.2
9.0
0.58
20.0
6.6
9.1
0.73
19.8
6.9
9.1
0.76
20.1
7.3
9.1
0.80
Oct-92
13.4
9.5
10.4
0.91
14.6
8.0
10.2
0.79
Ma -93
18.7
8.6
9.3
0.92
17.8
6.0
9.5
0.63
18.0
8.0
9.5
0.85
19.0
7.1
9.3
0.77
19.5
8.3
9.2
0.90
Jun-93
20.7
8.7
9.0
0.97
20.1
5.6
9.1
0.62
20.4
6.8
9.0
0.75
21.5
6.6
8.8,
0.75
21.7
6.9
8.8
0.78
Jul-93
23.2
7.9
8.5
0.92
23.5
6.0
8.5
0.71
23.5
7.1
8.5
0.84
25.1
6.7
8.2
0.81
25.2
7.2
8.2
0.87
Au -93
24.4
8.2
8.4
0.98
22.8
5.4
8.6
0.63
23.5
5.8
8.5
0.68
23.1
6.5
8.6
0.76
23.7
6.4
8.5
0.76
Se -93
20.6
8.3
9.0
0.92
20.6
5.2
9.0
0.58
21.4
6.9
8.8
0.78
20.9
6.5
8.9
0.73
21.0
6.9
8.9
0.77
Oct-93
14.5
8.9
10.2
0.87
15.1
5.0
10.1
0.50
14.8
7.1
10.1
0.70
14.6
7.4
10.2
0.73
14.2
7.9
10.3
0.77
Ma -94
15.5
9.3
10.0
0.93
16.2
6.9
9.8
0.70
15.7
8.1
9.9
0.82
16.5
7.6
9.8
0.78
17.0
7.7
9.7
0.80
Jun-94
20.6
8.2
9.0
0.91
21.7
5.9
8.8
0.67
21.6
7.0
8.8
0.79
22.2
6.4
8.7
0.74
22.3
6.5
8.7
0.75
Jul-94
22.2
7.9
8.7
0.91
23.2
6.0
8.5
0.70
23.3
6.9
8.5
0.81
24.0
6.1
8.4
0.72
24.5
6.5
8.3
0.78
Au -94
20.5
7.8
9.0
0.87
21.6
6.2
8.8
0.70
21.5
7.0
8.8
0.79
22.0
6.2
8.7
0.71
22.4
6.9
8.7
0.80
Se -94
17.9
9.3
9.5
0.98
18.8
6.7
9.3
0.72
18.5
8.0
9.4
0.85
19.1
7.5
9.3
0.81
19.1
8.2
9.3
0.89
Oct-94
12.8
10.1
10.6
0.95
13.9
6.5
10.3
0.63
13.2
8.3
10.5
0.79
13.0
8.6
10.5
0.82
13.0
8.8
10.5
0.84
Ma -95
17.2
9.9
9.6
1.03
18.7
6.4
9.3
0.69
18.3
8.7
9.4
0.92
18.3
8.4
9.4
0.89
18.6
8.3
9.3
0.89
AVERAGE
18.9
8.8
9.3
0.94
19.9
5.9
9.1
0.65
1 19.5
7.3
9.2
0.80
20.1
7.0
9.1
0.77 1
20.3
7.4
9.0
0.82

AVERAGE
.140
MAXIMUM
1.200
MINIMUM
.100
UNIT
MG/L UG/L
7
�

t Chemical Monitoring Summary Report
s
Page 1 of 2
LITTLE TROUBLESOME CREEK AT SR 2600 NEAR REIDSVILLE, NC
Station Number: 02093423
Drainage Area (sq mi):
® Stream
STORET Number. B0160000
Average Flow (cfs):
❑ Estuary
Water Quality Class: C NSW
Summer 7Q10 (cfs):
❑ Lake
Regional Office: Winston-Salem
Winter 7Q10 (cfs):
Topographic Map: B20SE
30Q2 (cfs):
❑
Fish Tissue
County: Rockingham
Gage: No Gage
❑
Fish Community
Subbasin: 030601
❑ Benthic
STORET NC State Beginning Ending
Parameter Name Units Code Criterion Min Med Max n > Det > Crit Date Date
Dissolved Oxygen
mg/1
00300
4
6.2
8.8
12
17
17
0
3/3/92
7/22/93
pH
SU
001100
6-9
6.7
7.1
7.5
17
17
0
3/3/92
7/22/93
Conductivity
Who
00094
N/C
136
329
510
17
17
0
3/3/92
7/22/93
Chlorophyll a (Corr)
µg/1
32209
N/C
NIS
Fecal Coliform, MF
#/100 ml
31616
200
10
153.56
1200
17
17
8
3/3/92
7/22/93
Total Phosphorus
mg/1
00665
N/C
0.04
0.44
0.9
17
17
0
3/3/92
7/22/93
Ammonia -Nitrogen
mg/1
00610
N/C
0.01
0.09
1.3
17
16
0
3/3/92
7/22/93
Nitrate/Nitrite-N
mg/1
00630
N/C
1.2
3.1
6.4
17
17
0
3/3/92
7/22/93
Total Nitrogen
mg/1
00600
N/C
NIS
Turbidity
NTU
00076
50
7.4
14
65
17
17
2
3/3/92
7/22/93
Hardness
mg/1-
00900
N/C
28
46.5
67
16
16
0
3/3/92
7/22/93
Total Residue
mg/l
00500
N/C
NIS
Total Suspended Res
mg/1
00530
N/C
5
13
52
17
17
0
3/3/92
7/22/93
Aluminum
µg/1
01105
N/C
190
530
5900
17
17
0
3/3/92
7/22/93
Arsenic
µg/1
01002
50
10
17
0
1
3/3/92
7/22/93
Cadmium
µg/1
01027
2
2
17
0
3/3/92
7/22/93
Chromium
4g/1
01034
50
25'
17
0
3/3/92
7/22/93
Copper (AL)
µg/1
01042
7
8
11
17
17
17
17
3/3/92
7/22/93
Iron (AL)
µg/1
01045
1000
690
1400
3800
17
17
11
3/3/92
7/22/93
Lead
4g/I
01051
25
10
17
0
3/3/92
7/22/93
Mercury
µg/I
71900
0.012
0.2
17
0
3/3/92
7/22/93
Manganese
4g/1
01055
N/C
43
110
330
12
12
0
1 3/3/92
7/22/93
Nickel
µg/1
01067
88
10
10
17
17
6
0
3/3/92.
7/22/93
Zinc (AL)
I µg/1
01092
50
10
28
77
17
16
2
3/3/92
7/22/93
Abbreviations: n=number of observations; > Det=number of observations greater than the detection limit; > Crit=number of
observations greater than the criterion; N/S=No sample; N/C=No Criteria; AL --Action Level
Notes: Median values are calculated using the detection level for samples classified as below detection. The Median value for
Fecal Coliform is actually the Geometric Mean value. Data includes only surface samples. Samples recorded at less than
detection are considered at the detection level for this summary.
Station Comments:

LITTLE TROUBLESOME CREEK AT SR 2600 NEAR REIDSVILLE, NC
• _ Page 2 of 2
Summer Summary (April -October):
Observations Observs > Det Median Maximum Minimum
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/1):
Ammonia -Nitrogen (mg/1):
Nitrate/Nitrite-Nitrogen (mg/1):
Conductivity (µNfho):
Chlorophyll a (Corr) (µg/1):
Total Suspended Residue (mg/1):
11
11
7.6
9.5
6.2
11
11
7.1
7.5
6.8
11
11
0.47
0.9
0.04
11
10
0.09
0.12
0.01
11
11
3.5
6.4
1.4
11
11
335
510
165
NIS
11
11
141
52
5
Summer Summary (June -September
Ohservatinns Observs > Det Median
Dissolved Oxygen (mg/1):
pH (SU):
Total Phosphorus (mg/1):
Ammonia -Nitrogen (mg/1):
Nitrate/Nitrite-Nitrogen (mg/1):
Conductivity (µMho):
Chlorophyll a (Corr) (µg/1):
Total Suspended Residue (mg/1):
Maximum Minimum
Yearly Summar:
Dissolved Oxygen
Year Obs Ohs>Det Median Max Min
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
8.6
11.4
6.2
1993
7
7
9.2
12
7.2 -
Conductivitv
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
340
510
165
1993
7
7
212
408
136
Total Suspended Residue
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
13.5
52
5
1993
7
7
10
50
6
PE
Year Ohc Ohs5Det Median Max Min
1988
NIS
1989
N/S
1990
NIS
1991
NIS
1992
10
10
7.1
7.5
6.7
1993
7
7
7.1
7.2
1 6.8
Total Phosphorus
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
10
1 0.44
0.9
0.04
1993
7
1 7
1 0.44 j
0.77
t0.2
Ammonia -Nitrogen
1988
NIS
1989
NIS
1990
NIS
1991
NIS
1992
10
9
0.11
13
0.01
1993
7
7
0.09
0.11
0.06

AVERAGE
2.9435
4.43
8.2
.46
2.1
.315
8.87
2
MAXIMUM
9.7500
20.00
76.0
5.90
3241.0
.710
12.60
2
MINIMUM
1.4400
LESSTHAN
1.0
.05
LESSTHAN
.100
6.50
2
UNIT
MGD
MG/L
MG/L
MG/L
#/100ML
UG/L
MG/L
PASS/FAI
GKEX88/MP
03/13/95
COMPLIANCE EVALUATION ANALYSIS
REPORT
PAGE 2
PERMIT--NC0024881
PIPE--001
REPORT
PERIOD:
9202-9301
LOC---E
FACILITY--REIDSVILLE
WWTP,
CITY OF
DESIGN FLOW--
7.5000
CLASS--4
LOCATION--REIDSVILLE
REGION/COUNTY--04
ROCKINGHAM
00010
00400
00600.
00665
00720
00951
01027
01034
MONTH
TEMP
PH
TOTAL N
PHOS-TOT
CYANIDE
FLUORIDE
CADMIUM
CHROMIUM
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
NOL
92/02
14.56
7.4-6.7
18.400
.9600
2.0000
.772
.1250
.0000
92/03
16.54
7.6-6.7
16.500
1.1400
1.0000
1.025
.0000
.0000
LIMIT
NOL
9.0 6.0
NOL
NOL
NOL
NOL
NOL
NOL
92/04
18.68
7.2-6.5
14.900
1.5200
2.0600
1.196
.0000
.0000
92/05
20.89
7.2-6.8
13.700
1.2375
.9250
1.407
.0000
.0000
92/06
23.77
7.4-6.7
5.400
1.7500
-2.6500
.r
.0000
.0000
92/07
26.30
7.3-6.5
18.600
1.6200
2.8000
1.286
.5000
50.0000
92/08
26.24
7.4-7.0
12.200
1.8500
1.2000
1.402
.5000
.0000
92/09
24.65
7.5-7.0
13.700
1.6400
7.2000
1.112
3.8000
15.4000
92/10
20.13
7.4-6.9
13.400
1.5300
3.4000
1.372
4.0000
.0000
LIMIT NOL 9.0 6.0 NOL NOL NOL NOL NOL NOL
92/11 18.85 7.4-6.8 7.100 1.6363 5.5714 1.714 7.7500 18.7500
912/12 15.45 7.2-6.8 14.900 1.6700 4.3846 1.306 .9000 5.2000

DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
May 25, 1995
TO: Reginald Sutton, Construction Grants
FROM: Monica Swihart"; Water Quality Planning
SUBJECT: City of Reidsville 201 Facilities Plan
Permits and Engineering staff of the Water Quality Section
have confirmed that the Winston-Salem Regional Office concurs
with the N.C. Wildlife Resources Commission request regarding the
subject document to increase the frequency of chronic toxicity
testing from quarterly to monthly for an interim period through
December 1996.
Please let me know if you have any questions regarding this
memo.
cc: Permits and Engineering°
Winston-Salem Regional Office
Owen Anderson, Wildlife Resources Commission