NC0026123_Permit Modification_19940106

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. David Leonard
City of Asheboro
146 N. Church Street
Asheboro, NC 27204-1106
Dear Mr. Leonard:
LTR?FA
E)EHNR
January 6, 1994
Subject: Permit No. NCO026123
Asheboro WWTP
Adjudication Withdraw
Randolph County
In accordance with your Petition for Contested Case Hearing filed on September 27 ,1993,
and subsequent Notice of Withdrawal dated December 13, 1993, we are forwarding herewith the
subject permit. The permit has been modified as follows:
• Effluent limitations for outfall 001:
The fluoride limit is 1.8 mg/l. The mercury limit will take effect on April 1, 1996.
Monitoring will be required from the effective date of the permit until April 1, 1996.
During this monitoring period, a compliance schedule has been drafted to assist the City
of Asheboro to be in compliance by the mercury limit date. The schedule is as follows:
Quarterly reports starting January 1, 1994 shall be submitted to the regional office
documenting the progress of the review of the mercury problems
Complete a detailed survey of all industrial users discharging into the Asheboro WWTP
to determine potential sources of mercury. Submit a report outlining the results of
the survey to DEM's pretreatment unit.. . . . . . . . . . July 1, 1994
Investigate other potential sources of mercury contamination(ex. hospitals, dentists, -
laboratories, etc.) . . . . . . . . . . . . . . January 1, 1995
Submit report detailing any actions required to be taken (such as cleaning lines,
upgrading WWTP and establish best management) to control the sources of mercury.
This should be submitted to both the regional office and the pretreatment unit.
. . . . . . . . . . . . . . . . . . . . April 1, 1995
Comply with mercury limit . . . . . . . . . . . . . April 1, 1996
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

All other terms and conditions contained in the original permit remain unchanged and in full
effect. These modifications are 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.
It is our understanding that this modification will resolve all items contained in the Petition
for Contested Case Hearing. If this is not the case, the City of Asheboro should notify us
immediately, but no later than ten (10) days following receipt of this letter. Unless such demand is
made, this decision shall be final and binding.
If you have any questions concerning this permit, please contact Randy L. Kepler at
telephone number 919-733-5083.
Sincerely,
original Signed BY
a
Coleen H.
A. Preston Howard, Jr. PE.
cc: Mr. Jim Patrick, EPA
Winston-Salem Regional Office
Kathy Cooper, Attorney General's Office
Yvonne Bailey, Womble Carlyle
Permits and Engineering Unit
Central Files
Compliance

Permit No. NC0026123
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
PE-
TO DISCHARGE WASTEWATER UNDER THE
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
City of Asheboro
is hereby authorized to discharge wastewater from a facility located at
Asheboro WWTP
on Bonkemeyer Drive
northeast of Asheboro
Randolph County
to receiving waters designated as Haskett's 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.
This permit shall become effective January 7, 1994
This permit and the authorization to discharge shall expire at midnight on April 30,1996
Signed this day January 7, 1994
Original Signed By
Coleen K Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

Permit No. NC0026123
SUPPLEMENT TO PERMIT COV18R SHEET
City of Asheboro
is hereby authorized to:
1. Continue to operate a 6.0 MGD wastewater treatment facility consisting of an influent pump
station, preliminary treatment by bar screen and grit removal, ultrasonic flow measurement,
primary clarifiers, biological treatment using trickling filters, secondary settling tanks, biological
treatment by nitrification aeration, final clarification, gas chlorine disinfection, contact chamber
and cascade aeration at discharge point located at Asheboro VWVTP, on Bonkemeyer Drive,
northeast of Asheboro, Randolph County (See Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into Haskett's
Creek which is classified Class C waters in the Cape Fear River Basin.

A. Q. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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:
Effi�:►t Characteristics
Flow
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3asN
Dissolved Oxygen "*
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity""
Conductivity
Oil and Grease
Discharge
Limitations
Monitoring
Requirements
Measurement
Sample
'Sample
Monthly
Avg.
Weekly Avg. Daily
Max. Frequency
Type
Location
6.0
MGD
Continuous
Recording
I or E
5.0
mg/I
7.5 mg/I
Daily
Composite
E, 1
30.0
mg/I
45.0 mg/I
Daily
Composite
E, 1
2.0
mg/I
Daily
Composite
E
Daily
Grab
E, U, D
200.0
/100 ml
400.0 /100 ml
Daily
Grab
E, U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The monthly average effluent BOD5 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/I.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90 %; March, June, September, December, 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 in other than trace amounts.
,,

A. Q. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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
CaoTlum
Chromium
Cyr de
Fluoride
Lead
Nickel
Arsenic
Aluminum (++)
Antimony (++)
Chloride (++)
Chloroform
Copper
Mercury
Zinc
Discharge Limitations
Monitoring
Requirements
Measurement
Sample
*Sample
Monthly Avg. Weekly Avg. Daily Max.
Frequency
Type
Location
2.0
µg/I
Weekly
Composite
E
50.0
µg/l
Weekly
Composite
E
5.0 µg/I 20.0
µg/I
Weekly
Grab
E
1.8
mg/l
Weekly
Composite
E
25.0
µg/I
Weekly
Composite
E
88.0
µg/l
Weekly
Composite
E
50.0
µg/I
Weekly
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
(++) Monitoring of these parameters shall begin on January 1, 1994. Fluoride monitoring shall begin upon the effective date of the permit and the limit shall
begin February 1, 1994.
r
4

A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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
BOD, 5-Day, 20°C **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Tpta .-,nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chrer'Ac Toxicity****
Conductivity
Oil and Grease
Discharge Limitations
Monthly
6.0
Avg.
MGD
10.0
mg/I
30.0
mg/I
4.0
mg/I
200.0 /100 ml
Weekly Avg.
15.0 mg/I
45.0 mg/I
400.0 /100 ml
Monitoring
Requirements
Measurement
Sample
*Sample
Daily Max. Frequency
Type
Location
Continuous
Recording
I or E
Daily
Composite
E, I
Daily
Composite
E, I
Daily
Composite
E
Daily
Grab
E, U, D
Daily
Grab
E, U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The monthly average effluent BOD5 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/I.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, December, 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 in other than trace amounts.
r
,,

A. . EFFLUENT LEVM ATIONS AND MONITORING REQUIREMENTS Winter '
0 Q (November 1-March 31) Permit No. NC0026123
During the period beginning on the effective date of the permit and lasting until March 31,1996, 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
Cadmium
Chromium
Cyanide
Fluoride
Lead
Nickel
Arsenic
Aluminum (++)
Antimony (++)
Chloride (++)
Chloroform
Copp$r.
Mer.-ury
Zinc-r}
Discharge Limitations
Monthly __ AY . Weekly Avg. Daily Max.
5.0 µg/l
2.0 µg/I
50.0 µg/l
20.0 µg/I
1.8 mg/I
25.0 µg/I
88.0 µg/I
50.0 µg/I
Monitoring
Requirements
Measurement
Sample
*SamRle
Frequency
Type
Location
Weekly
Composite
E
Weekly
Composite
E
Weekly
Grab
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
(++) Monitoring of these parameters shall begin on January 1, 1994. Fluoride monitoring shall begin upon the effective date of the permit and the limit shall
-. begin February 1, 1994.

A
A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on April 1, 1996 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:
Ef 1 ent Characteristics
V.
Flow
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity****
Conductivity
Oil and Grease
Discharge Limitations
Monthly
6.0
Avg.
MGD
5.0
mg/I
30.0
mg/I
2.0
mg/I
200.0 /100 ml
Weekly Avg.
7.5 mg/I
45.0 mg/I
400.0 /100 ml
Monitoring
Requirements
Measuremen
Daily Max. Frequency
Sample
Type
*Sample
Location
Continuous
Recording
I or E
Daily
Composite
E, I
Daily
Composite
E, I
Daily
Composite
E
Daily
Grab
E, U, D
Daily
Grab
E, U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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 weak during the remaining months of the year.
** T;e monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15 % of the respective influent value (85% removal).
*** lie daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
**** Chronic Toxicity(Ceriodaphnia) P/F at 900/9;March, June, September, December; 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 in other than trace amounts.

A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on April 1, 1996 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
Cad)ririum
Chromium
Cyanide
Fluoride
Lead
Mercury
Nickel
Arsenic
Aluminum (++)
Antimony (++)
Chloride (++)
Chloroform
Copper
Zinc
Discharge Limitations
Monthly Ay Weekly Avg. Daily
Max.
2.0
µg/I
50.0
µg/I
5.0 µg/l 20.0
µg/I
1.8
mg/I
25.0
µg/l
0.012 µg/I (+) 0.048
µg/l (+)
88.0
µg/I
50.0
µg/I
Monitoring
Requirements
Measurement
Frequency
SamRle
Type
*Sample
Location
Weekly
Composite
E
Weekly
Composite
E
Weekly
Grab
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
Weekly
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
2/Month
Composite
E
41
(+) If the measurement of mercury is below detection limits the quantity for the purposes of compliance evaluation is considered to be zero. The detection limit
for this parameter shall be considered 0.2 µg/l. It should be reported on the DMR to be < 0.2 µg/I.
(++) Monitoring of these parameters shall begin on January 1, 1994. Mercury and Fluoride monitoring shall begin upon the effective date of the permit and the
limits shall begin February 1, 1994.
r

A
A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning on April 1, 1996 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
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
At
Temperature
T.ctal Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity****
Conductivity
Oil and Grease
Discharge Limitations
Monthly
Avg.
6.0
MGD
10.0
mg/I
30.0
mg/I
4.0
mg/I
200.0 /100 ml
Weekly Avg.
15.0 mg/I
45.0 mg/I
400.0 /100 ml
Wonitoring
Requirements
Measurement
Sample
*Sample
Daily Max. Frequency
Type
Location
Continuous
Recording
1 or E
Daily
Composite
E, I
Daily
Composite
E, I
Daily
Composite
E
Daily
Grab
E, U, D
Daily
Grab
E, U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The monthly average effluent BOD5 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/I.
**** Chronic Toxicity(Ceriodaphnia) P/F at 90%;March, June, September, December; 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 in other than trace amounts.

e
A. Q. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning on April 1, 1996 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
Cadmium
2.0 µ g / I
Weekly
Composite
E
Chromium
50.0 µg/I
Weekly
Composite
E
Cyanide
5.0 µg/I 20.0 µg/l
Weekly
Grab
E
Fluoride
1.8 mg/I
Weekly
Composite
E
Lead
25.0 µg/l
Weekly
Composite
E
Mercury
0.012 µg/l (+) 0.048 µg/l (+)
Weekly
Composite
E
Nickel
88.0 µg/I
Weekly
Composite
E
Arsenic
50.0 µg/I
Weekly
Composite
E
Aluminum (++)
2/Month
Composite
E
Antimony (++)
2/Month
Composite
E
Chloride (++)
2/Month
Composite
E
Chicroform
2/Month
Composite
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
(+) If the measurement of mercury is below detection limits the quantity for the purposes of compliance evaluation is considered to be zero. The detection limit
for this parameter shall be considered 0.2 µg/l. It should be reported on the DMR to be < 0.2 µg/l.
(++) Monitoring of these parameters shall begin on January 1, 1994. Mercury and Fluoride monitoring shall begin upon the effective date of the permit and the
limits shall begin February 1, 1994.

Part I
Permit No. NCO026123
1. The Permittee shall comply with Final Effluent Limitations specified for discharges in
accordance with the following schedule:
Quarterly reports starting January 1,1994 shall be submitted to the regional office
documenting the progress of the review of the mercury problems
Complete a detailed survey of all industrial users discharging into the Asheboro
WWTP to determine potential sources of mercury. Submit a report outlining the
results of the survey to DEM's pretreatment unit.. . . . . . . July 1,1994
Investigate other potential sources of mercury contamination(ex. hospitals, dentists,
laboratories, etc.). . . . . . . . . . . . . . . January 1,1995
Submit report detailing any actions required to be taken (such as cleaning lines,
upgrading WWTP and establishment of best management practices for control of
mercury disposal) to control the sources of mercury. This should be submitted to
both the regional office and the pretreatment unit. . . . . . . April 1,1995
Comply with mercury limit. . . . . . . . . . . . . . April 1,1996
2. Permittee shall at all times provide the operation and maintenance necessary to
operate the existing facilities at optimum efficiency.
3. No later than 14 calendar days following a date identified in the above schedule of
compliance, the Permittee shall submit either a report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next schedule
requirements.

Permit No. NCO026123
F. Disposal Alternatives
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.
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 March, June, September and December. 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 monitorhl.g requirements.

COUNTY OF RANDOLPH
CITY OF ASHEBORO,
Petitioner,
V.
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES,
DIVISION OF ENVIRONMENTAL
MANAGEMENT,
Respondent.
Ant 0,1 h14-L _
G1--
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
93 EHR 1042
NOTICE OF WITHDRAWAL
OF PETITION
Petitioner hereby withdraws its petition for a contested case hearing.
proceedings are needed or required to resolve the contested case captioned above.
0
m D T
'r
c� rn
_,
Newfurther-..
c.�
This the day of December, 1993.
C
Yvon e C. Bailey
WO LE CARLYLE SANDRIDGE &
Attorneys for Petitioner
Post Office Box 831
Raleigh, North Carolina 27602
Tel. No. [phone]
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the attached NOTICE OF WITHDRAWAL
on all parties by having the same placed in the United States Mail bearing sufficient postage for
delivery by first class mail and addressed as follows:
Kathryn Jones Cooper, Esq.
Attorney General's Office
Environmental Protection Section
Post Office Box 629
Raleigh, NC 27602-0629
This the � day of December, 1993.
R#101967.
/VlC aa�
Yvo C. Bailey

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. David Leonard
City of Asheboro
146 N. Church Street
Asheboro, NC 27204-1106
Dear Mr. Leonard:
e��
�EHIL
NR
December 7, 1993
Subject: NPDES Permit No. NCO026123
Asheboro WWTP/Adjudication
Draft Error
Randolph County
On November 19, 1993, the Division of Environmental Management sent the draft permit to
Asheboro to satisfy the Petition for Contested Case Hearing. Upon further review an error has been
found and corrected. Accordingly, we are forwarding herewith modifications to the subject permit to
correct the change. The effluent pages contain a limit for fluoride at 1.8 µg/1. The limit should be
1.8 mg/I.
Please find enclosed revised effluent pages which should be inserted into your draft permit. The
old pages should be discarded. If this permit modification is acceptable, The City of Asheboro must
complete the Notice of Withdrawal of Petition form within thirty days of receipt of the November 19,
1993 letter and submit one copy to the Attorney General's Office as speed on the withdrawal form
and one copy to this division. The original Notice of Withdrawal form should be submitted to the
Office of Administrative Hearings.
Please examine the enclosed effluent pages and ensure that the changes are acceptable to
you. When you have withdrawn your request for Contested Case Hearing, the modified permit will
be issued. If the proposed modifications are not acceptable to you, please notify us and we will
proceed with the adjudicatory process.
If you have any questions concerning these changes, please contact Mr. Randy Kepler at
telephone number 919/733-5083.
rely you s,
i.
Preston o )r., P.E.
cc. Mr. Jim Patrick, EPA
Winston-Salem Regional office
Kathy Cooper, Attorney General's Office
Yvonne Bailey, Womble Carlyle
Permits and Engineering
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

A. Q. EFFLUENT LMTATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity****
Conductivity
Oil and Grease
Discharge Limitations
Monthly Ava.
6.0 MGD
5.0 mg/I
30.0 mg/I
2.0 mg/I
200.0 /100 ml
Weekly Avg.
7.5 mg/I
45.0 mg/I
400.0 /100 ml
Monitoring
Requirements
Measurement
S
alriple
`
*S�aFnple
Daily Max. Frequency
Type
Location
Continuous
Recording
I or E
Daily
Composite
E, I
Daily
Composite
E, I
Daily
Composite
E
Daily
Grab
E, U, D
Daily
Grab
E, U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations:- E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The monthly average effluent BOD5 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.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, December; 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 in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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 ,
Cadmium
2.0
µg/I
Weekly
Composite
.E
Chromium
50.0
µg/I
Weekly
Composite
E
Cyanide
5.0 µg/I 20.0
µg/I
Weekly
Grab
E
Fluoride
1.8
mg/l
Weekly
Composite
E
Lead
25.0
µ g / I
Weekly
Composite
E
Nickel
88.0
µg/I
Weekly
Composite
E
Arsenic
50.0
µg/I
Weekly
Composite
E
Aluminum (++)
2/Month
Composite
E
Antimony (++)
2/Month
Composite
E
Chloride (++)
2/Month
Composite
E
Chloroform
2/Month
Composite
E
Copper
2/Month
Composite
E
Mercury
2/Month
Composite
E
Zinc
2/Month
Composite
E,'
(++) Monitoring of these parameters shall begin on January 1, 1994. Fluoride monitoring shall begin upon the effective date of the permit and the limit shall
begin February 1, 1994.

A. 0. EFFLUENT LRvffrAT'IONS AND. MONITORING.REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31, 1996, 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
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity""
Conductivity
Oil and Grease
Discharge Limitations
Monthly
Avg.
6.0
MGD
10.0
mg/I
30.0
mg/I
4.0
mg/l
200.0 /100 ml
Weekly Avg.
15.0 mg/I
45.0 mg/I
400.0 /100 ml
Monitoring
Requirements
Measurement
Sample
*Sample
Daily Max. Frequency
Type
Lo cat i o n
Continuous
Recording
I or E
Daily
Composite
E I ;
Daily
Composite
E, l
Daily
Composite
E
Daily
Grab
E, U, D
Daily
Gra}
E U, D
Daily
Grab
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The rrtonthly average effluent BOD5 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.
**** Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, December; 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 in other than trace amounts.

A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning on the effective date of the permit and lasting until March 31,1996, 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
*Sa m plle
Monthly
Avg. Weekly Avg. Daily Max.
Frequency
Type
Lo cation
Cadmium
2.0
µ g / I
Weekly
Composite
E
Chromium
50.0
µg/l
Weekly
Composite
E
Cyanide
5.0 µg/I 20.0
µg/I
Weekly
Grab '
E
Fluoride
1.8
mg/I
Weekly
Composite
E
Lead
25.0
µg/i
Weekly
Composite
E
Nickel
88.0
µg/i
Weekly
Composite
E
Arsenic
50.0
µg/I
Weekly
Composite
E
Aluminum (++)
2/Month
Composite
E
Antimony (++)
2/Month
Composite
E
Chloride (++)
2/Month
Composite
E
Chloroform
2/Month
Composite
E
Copper
2/Month
Composite
E
Mercury
2/Month
Composite
E
Zinc
2/Month
Composite
E
(++) Monitoring of these parameters shall begin on January 1, 1994. Fluoride monitoring shall begin upon the effective date of the permit and the limit shall
begin February 1, 1994.

A.(). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NC0026123
During the period beginning on April 1, 1996 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
BOD, 5-Day, 200C **
Total Suspended Residue **
NH3 asN
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity****
Conductivity
Oil and Grease
Discharge
Limitations
Monitoring
Requirements
.Measurement
Sample
*S
Monthly
Avg.
Weekly Avg. Daily Max.
Frequency
Type
Location
6.0
MGD
Continuous
Recording
I or E
5.0
mg/I
7.5 mg/I
Daily
Composite
E, I
30.0
mg/I
45.0 mg/I
Daily
Composite
E, 1
2.0
mg/I
Daily
Composite
E
Daily
Grab
E, U, D
200.0
/100 ml
400.0 /100 ml
Daily
Grab
E, U, D
Daily
Grab
61
E
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
*
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
z
** The monthly average effluent BOD5 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/I.
**** Chronic Toxici Cerioda hnia P/F at 90%•March June September, December; 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 in other than trace amounts.

A. (). EFFLUENT LIWrATIONS AND MONITORING REQUIREMENTS Summer (April 1- October 31) Permit No. NCO026123
'During the period beginning on April 1, 1996 and lasting until expiration, the Pennittee 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 Lo cat i o n
Cadmium
2.0
µg/I
Weekly
Composite E
Chromium
50.0
µg/I
Weekly
Composite E
Cyanide
5.0 µg/I 20.0
µg/I
Weekly
Grab E
Fluoride
1.8
m g/ I
Weekly
Composite E
Lead
25.0
µg/I
Weekly
Composite E
Mercury
0.012 µg/I (+} 0.048 µg/I (+)
Weekly
Composite E
Nickel
88.0
µg/I
Weekly
Composite E
Arsenic
50.0
µg/I
Weekly
Composite E
Aluminum (++)
2/Month
Composite E
Antimony (++)
2/Month
Composite E
Chloride (++)
2/Month
Composite E
Chloroform
2/Month
Composite E
Copper
2/Month
Composite E
Zinc
2/Month
Composite E
(+) If the measurement of mercury is below detection limits the quantity for the purposes of compliance evaluation is considered to be zero. The detection limit
for this parameter shall be considered 0.2 µg/l. It should be reported on the DMR to be < 0.2 µg/l.
(++) Monitoring of these parameters shall begin on January 1, 1994. Mercury and Fluoride monitoring shall begin upon the effective date of the permit and the
limits shall begin February 1, 1994.

A. p. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1 - March 31) Permit No. N00026123
During the period beginning on April 1, 1996 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
BOD, 5-Day, 20*C '*
Total Suspended Residue **
NH3 as N
Dissolved Oxygen ***
Fecal Coliform (geometric mean)
Total Residual Chlorine
Temperature
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Chronic Toxicity*""
Conductivity
Oil and Grease
Discharge
Limitations
Monitoring
Requirements
Measurement
Sample
*Sample
Monthly Avg.
Weekly Avg. Daily Max.
Frequency
Type
Location
6.0
MGD
Continuous
Recording
I or E
10.0
mg/I
15.0 mg/I
Daily
Composite
E,
30.0
mg/I
45.0 mg/I
Daily
Composite
E, 1
4.0
mg/I
Daily
Composite
E
Daily
Grab
E, U, D
200.0
/100 ml
400.0 /100 ml
Daily
Grab
E, U, D
Daily
Grab
E.
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
Quarterly
Composite
E
Grab
U, D
Monthly
Grab
E
* Sample locations: E - Effluent, I - Influent, U - Upstream 800 feet from the outfall, D - Downstream at SR 2128 and on the Deep River at SR 2261
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.
** The monthly average effluent BOD5 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.
**** Chronic Toxicity(Ceriodaphnia) P/F at 90%;March, June, September, December; 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 in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Winter (November 1- March 31) Permit No. NCO026123
During the period beginning
on April 1, 1996 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
Cadmium
2.0 µ g / 1
Weekly
Composite
E
Chromium
50.0 µg/I
Weekly
Composite
E
Cyanide
5.0 µg/I 20.0 µg/I
Weekly
Grab
E
Fluoride
1.8 mg/I
Weekly
Composite
E
Lead
25.0 µg/I
Weekly
Composite
E
Mercury
0.012 µg/I (+} 0.048 µgh (+}
Weekly
Composite
E
N ickel
88.0 µ g/ I
Weekly
Composite
E
Arsenic
50.0 µg/I
Weekly
Composite
E
Aluminum (++)
2/Month
Composite
E
Antimony (++)
2/Month
Composite
E
Chloride (++)
2/Month
Composite
E
Chloroform
2/Month
Co'mposite
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
(+) If the measurement of mercury is below detection limits the quantity for the purposes of compliance evaluation is considered to be zero. The detection limit
for this parameter shall be considered 0.2 µg/I. It should be reported on the DMR to be < 0.2 µg/I.
(++) Monitoring of these parameters shall begin on January 1, 1994. Mercury and Fluoride monitoring shall begin upon the effective date of the permit and the
limits shall begin February 1, 1994.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
November 19, 1993
Mr. David Leonard
City of Asheboro
146 N Church Street
Asheboro, NC 27204-1106
Subject: NPDES Permit No. NC00026123
Asheboro WWTP / Adjudication
Randolph County
Dear Mr. Leonard:
In accordance with your Petition for Contested Case Hearing filed on September 27, 1993,
we are forwarding herewith a draft permit outlining the modification the Division is willing to make
to the subject permit The modification is as follows:
• Effluent limitations for outfall 001:
The mercury limit will take effect on April 1, 1996. Monitoring will be required from the
effective date of the permit until April 1, 1996. During this monitoring period, a compliance
schedule has been drafted to assist the City of Asheboro achieve compliance with the future mercury
limit. The schedule is as follows:
Quarterly reports starting January 1, 1994 shall be submitted to the regional office
documenting the progress of the review of the mercury problems
Complete a detailed survey of all industrial users discharging into the Asheboro WWTP
to determine potential sources of mercury. Submit a report outlining the results of
the survey to DEM's pretreatment unit.. . . . . . . . . . July 1, 1994
Investigate other potential sources of mercury contamination(ex. hospitals, dentists,
laboratories, etc.). . . . . . . . . . . . . . January 1, 1995
Submit report detailing any actions required to be taken (such as cleaning lines,
upgrading WWTP and establishment of best management practices for control of
mercury disposal) to control the sources of mercury. This should be submitted to
both the regional office and the pretreatment unit. . . . . . . April 1, 1995
Comply with mercury limit.
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunfty Affirmative Action Employer
April 1, 1996
Telephone [phone] FAX [phone]
50% recyclec! 109', post -consumer paper

Attached is a draft of the revised permit. If any terns or conditions adjudicated proposed
by this modification are unacceptable to you, you should notify us within thirty (30) days following
receipt of this letter. If this permit modification is acceptable, The City of Asheboro must complete
the attached Notice of Withdrawal of Petition form within thirty days of receipt of this modification
and submit one copy to the Attorney General's Office as specified on the withdrawal form and one
copy to this division. The original Notice of Withdrawal form should be submitted to the Office of
Administrative Hearings.
Please examine the enclosed draft permit and ensure that the changes are acceptable to you.
When you have withdrawn your request for Contested Case Hearing, the modified permit will be
issued. If the proposed modifications are not acceptable to you, please notify us within thirty days
and we will proceed with the adjudicatory process.
If you have any questions or comments, please contact Randy L. Kepler of our Permits and
Engineering Unit at 919-733-5083.
Sincerely,
LA. Preston ward, Jr. P.E.
cc: Mr. Jim Patrick, EPA
Kathy Cooper, Attorney General's Office
Winston-Salem Regional Office
Permits and Engineering Unit
Yvonne Bailey, Womble Carlyle

STAIZ
aw.
State of North Carolina
MICHAEL F. EASLEY Department of Justice REPLY TO: Kathryn Jones Cooper
ATTORNEY GENERAL. P. O. BOX 629 Environmental Division
RALEIGH [phone]
27602-0629
November 16, 1993 d -n
�r
c rn
The Honorable Dolores O. Nesnow FM
Administrative Law Judge ,
Office of Administrative Hearings
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447
l.tJ
RE: City of Asheboro, Inc. v. North Carolina Department of EnviroAdent,
Health and Natural Resources, Division of Environmental Manage-
ment„ 93 EHR 1042, Randolph County
Dear Judge Nesnow:
Attached for filing in the above -referenced matter are two copies of the
document constituting agency action which caused the filing of the Petition.
Although an extension of time was granted for the parties to file
PreHearing Statements, the time limit was not extended for filing the attached
document. Therefore, Respondent respectfully requests that this document be
deemed timely filed.
In addition, please enter my appearance as counsel for the Respondent.
Sincerely,
Kathryn J es C oper
Special Deputy ttorney General
KJC/klj
1 �J
Attachments
cc: Yvonne C. Bailey
Coleen Sullins
An Equal Opportunity / Affirmative Action Employer

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Health and Natural Resource
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. David Leonard
City of Asheboro
146 N. Church Street
P.O. Box 1106
Asheboro, N.C.27204-1106
Dear Mr. Leonard:
,w�''�-4M
eel �-
EDFEE HNI1
August 16, 1993
Subject: Draft NPDES Comments
Asheboro WWTP
NPDES Permit No. NCO026123
Randolph County
In accordance with your application for discharge permit received on January 24, 1992, 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 of May
19, 1993, regarding your draft permit, the following comments are in the order of the draft permit
Due to a recent DEM policy decision, the annual priority pollutant analysis test has been withdrawn
from this facility.
The monitoring of conductivity, aluminum, antimony and chloride have been postponed to January 1,
1994, to provide sufficient time for your laboratories to become certified to test for these specific
parameters. The monitoring for Mercury and Fluoride will begin at the effective date of the permit,
however, the limit will not go into effect until February 1, 1994. If the facility is not certified for these
parameters then they must be contracted out for the monitoring until such time as the certification is
received.
Concerning the weekly average and daily maximum limits for Cyanide and Mercury, the facility is
responsible for compliance with both the weekly and daily limitations. One exceedance of a limit would
constitute a violation of the permit limit and would cause an enforcement action by the Division. With these
parameters, the facility can consider the value to be zero for purposes of compliance if the parameter is
measured below detection. This should be indicated on the discharge monitoring report as a less than
value, i.e. for mercury, you would list it a < 0.2 µg/l. The detection limit for Cyanide is 5.0 µgIl and for
Mercury is 0.2 µg/1. If there any concerns with specifics on the compliance of the parameters please
contact the Winston-Salem Regional Office at 919-896-7007.
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.
AUG 25 1993
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fl�r?Wft+7, 3-91!5LB COPY
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please take notice this permit is not transferable. Part H, 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 Mr. Randy Kepler at telephone
number 919/733-5083.
Sin y,
estop ard, Jr.
cc: Mr. Jim Patrick, EPA
Winston-Salem Regional Office
Compliance
Central Files
CENTRAL FILE COPY

e
C ! t u t2 t .Ats 1J c t3 t: r t1
`► �� .`
�.,, !, «�.
,
•�``��rA ;'`'�
Nvvtll Quraltna 272-049.1 l as
14F X. (94urc4 f.pt.. ip. (). iMax 1106
May 19, 1993
Ms. Coleen Sullins, NPDES Permit Group
N.C. DEHNR
Div. of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Subject: Draft NPDES Comments
Asheboro Wastewater Treatment Plant
NPDES Permit No. NCO026123
Randolph County
In reference to your letter dated April 23, 1993, and telephone
conversation with Ralph Kepler on May 4, 1993, we submit the following
questions and comments for your consideration.
We acknowledge the correction of the location for the upstream
location (2) and fluoride limit (d) of 1.8 mg/l.
We are in agreement with the re-evaluation and removal of Bis
(2-ethylhexyl) phthalate (b) from the NPDES weekly monitoring and in-
cluded only in the Annual Pollutant Analysis Monitoring (APAM) Report.
Will the city be required to contract a commercial lab for the
monitoring of draft limited parameters (Conductivity, Fluoride,
7 Aluminum, antimony, and Chloride) which we are not presently certified
�
to anal yze? It would represent an economic savings of approximately
=AyrIL� $490/month if these requirements were delayed until our laboratory
►�. became certified before reporting is required.
We do have some questions and comments in response to the
Cyanide (C) and Mercury (E) monitoring requirements and their corre-
sponding options.
In considering the daily maximum and weekly average limits, we
question how compliance and enforcement determination will be
addressed for the duration of this permit? Which limits will determine
compliance and noncompliance? In defining noncompliance for a daily
or weekly limit, what number of exceedences and within what period of
time would determine noncompliance? Also, what would initiate a re-
portable noncompliance to EPA regional office and/or cause an enforce-
ment action by your office? When significant noncompliance and/or
reportable noncompliance does occur, what action would be I
the purpose of calculating the weekly averages, what numer
is given to less than detection values?�.;,�,
ROW of X (9. Zoological 11ark CENTRAL FEE COPY
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In response to the Mercury limit, we request only a monitoring
requirement for the duration of this permit (April 30, 1996). This
parameter was not added to our monitoring requirement until this
draft. The draft limited parameters (Cd, Cr, CN, Pb, Ni, As) were
monitored for the duration of a permit period (5 years) prior to
limits being placed upon them.
This period allowed time to update the pretreatment/sewer use
ordinance program to ensure compliance. Based on monitoring for
headworks/plant operation information, we will measure Mercury at
levels above detection levels on a frequency which could cause non-
compliance. Why should we be imposed with restrictive limits causing
noncompliance before we have the opportunity to address and remedy
the issue? It should also be noted that effluent toxicity as
measured by Ceriodaphnia Mini -Chronic pass/fail (99%) has continued
to be met on a consistent basis.
Consideration of either Mercury options could be incidental
because both limits are below detection levels for our determination
of Mercury by cold vapor method. A detection level of 0.25 ug/l is
recognized by laboratory procedure; therefore, a sample measured at a
detectable level of .25 ug/l would require 5 additional samples
less than detection levels to average below the draft weekly limit of
0.048 ug/l (using zero for all values less than detection levels).
Under either Mercury option with the draft limits, it would be almost
impossible to comply if one sample was at a detectable concentration
or higher. For this reason, we request a monitoring requirement
prior to a concentration limit.
After review of these comments and questions, advise us of your
comments. If you have any questions or need additional information,
please contact Mr. Melvin Allen at [phone].
Si e y,
4P'S
David B. Leonard
City Manager
MLA/lr
CC: Mr. Dumont Bunker, City Engineer
Mr. Melvin Allen, Supt. of Plants
Winston-Salem Regional Office
.. :"-:..•:. is
25
CENTRAL FILE COPY

MEMORANb rtK
May 18, 1993
TO: Randy Kepler
THROUGH: Steve Mauney 1411.�
FROM: George Smith
SUBJECT: Asheboro WWTP Draft Permit
Permit #NC0026123
Randolph County �
Per your request, my previous memo addressed comments from the City
of Asheboro. In this memo I did not comment on the limit for,"?
mercury because I thought the City was meeting the proposed mercury
limit.
:.n
It is my understanding a 0.012 ug/1 mercury limit can not ber
quantitated on a routine basis within acceptable statistical
tolerances. In fact, current method detection limits are not
capable of achieving this level of detection. However, it is
possible to quantitate at this level by using sample enrichment
techniques. The enrichment technique would have to be performed by
a factor of 20 times, at least. This technique is labor intensive
and therefore uneconomical.
The City of Asheboro has expressed the following concerns:
- The City is presently monitoring for mercury. They are
now being asked to meet a limit. The City cannot meet
this requirement immediately.
- The new limit of 0.012 ug/1 is below their detection
limit. Current detection limit is 0.2 ug/l.
In light of the above concerns I hope you will consider the
following alternatives:
- Assign a phase -in period for the mercury limit. This
time period should allow them to trace and eliminate the
sources of mercury to the POTW.
- Assign a limit of 0.2 ug/1 with a provision that it may
be decreased if the technology allows.
If you have any further questions please feel free to contact -,the
Winston-Salem regional office at 919-896-7007.
cc: Central File
WSRO
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CENTRAL FILE COPY
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Sta
Department of EnvironmenNoHeal Carolina
� th, and Natural Resources
Division of Environmental Management
512 North Salisbury Street - Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
Mr. David Leonard April 23, 1993 Jonathan B. Howes, Secretary
City of Asheboro
146 N. Church Street
P.O. Box 1106
Asheboro, N.C. 27204-1106
Subject: Draft NPDES Comments
Asheboro WWTP
NPDES Permit No. NCO026123
Dear Mr. Leonard: Randolph County
This office is in receipt of your letter dated February 23, 1993 regardingcomments
�.5. NPDES draft permit. The Division of Environmental Management DEM appreciates nts on the
�,t and comments and offers the following responses to your re uests. The r spoonesyour review
same order as in the February 23 letter. q responses will be in the
-yj ti
ah'I(a) The instream monitoring location
T outfall to 800 feet above the out all. has been relocated from 50 feet upstream from the
a U
a9,e*k (b) The monitoring requirement and limit that was given to Bis (2-eth Ihex I
has been reevaluated and dropped. The monitoring for this parameter will be completed phthalate
Annual Pollutant Analysis Monitoring (APAM) Report. leted in the
(c,e) After further review, Cyanide and Mercury need to stay in the permit due t
submitted. However there are two options for the requirements. Thefirstoption i the data
� parameters to remain as stated with Cyanide at 5.0 P is for the
µg/I daily maximum. The other option is for Asheboro daily maximum and Mercury at 0.012
average limit. Cyanide would have limits of 20,0 o to
accept a daily maximum and a weekly
average and Mercury would have limits of 0.048 µg ally maximum and 5.0 µg/l weekly
verage. If Asheboro agrees to the second choice, Asheboroa a choose ily maximum and 0.012 µgel weekly
c-��• for the week(for substances where holdingof samplesY to collect multiple samples
c�� determine the number of analyses to be un that weekfor this amount of time is allowed) and
on nresult
example, if the first sample is below the weekly average, then o moreanalysesthe first .sample. 'be
run for that week. Choice two has been added to the draft permit attached fowould need .to :be
viewing.
G3-A,c. (d) The limit for Fluoride at 1.8 µg/I was a typo and has been changed to the correct
1.8 mg/I. ct limit of
Asheville Fa etteville Regional Offices
Y Mooresville Raleigh Washington Wilmington Winston-Salem •
704/251-6208- 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/39
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] An Equal Opportunity Affirmative Action Employer
CENTRAL :FILE COPY

Mr. Luor�i/rc]
Attached is a copy of the corrected draft permit. Please took ovor rho draft ar,d c, _�"
(c,e) option one or option two is preferred. If OEM receives no response within t s da s
receipt of this letter, the permit will be issued as occurs in the attached drafty ��
permit.
any questions, please contact Mr. Randy Kepler at telephone number 919/733---5o83. If you have
cc. Winston-Salem Regional Office
Permits and Engineering -Unit
Central Files
Si rely,
oleen Sullins, Supervisor
Permits and Engineering, NPDES Unit
AUG 2s 1993
CENTRAL FILE COPY

North Carolina Division of Environmental Management
f+ 6t -44 L-C,Id
Water Quality Section/Rapid Assessment Group
April 19, 1993
MEMORANDUM
TO: Randy Kepler
THROUGH: Carla Sanderson
FROM: Dave Good.4(t
SUBJECT: Request for Modifications of Asheboro Draft NPDES Permit
NPDES No. NC0026123
Randolph County
030609
This is in response to the City of Asheboro's request to modify the draft NPDES
permit referenced above. A request was made to change the upstream sample location from
50 feet upstream of the outfall to 800 feet upstream of the outfall. Technical Support has
no objection to this change. Based on recent discussions within DEM regarding the use of
APAM data to determine limits/monitoring requirements, it is recommended that Bis(2-
ethylhexyl) phthalate be sampled as part of the APAM. Limits for mercury and cyanide
should remain the same, unless the City of Asheboro would agree to receiving both a daily
maximum md a weekly average. Outlined below are the two choices the facility has -
Choice #1 is to keep the limits for metals as daily maximums, and the Choice #2 is to have
less stringent limits for daily maximum limits with the addition of a weekly limit.
Choice #1 - Daily maximum limits only (units are µg/I)
Parameter
Daily Maximum
Mercury 0.012
Cyanide 5.0
Choice #2 - Daily maximum and weekly limits (units are µg/l)*
Parameter Daily Maximum Weekly Average
Mercury 0.048 0.012
Cyanide 20.0 5.0
*NOTE: If the permittee selects #2, the permittee may choose to collect multiple samples
for the week (for substances where holding of samples for this amount of time is allowed)
and determine the number of analyses to be run that week on the result of the first sample.
For example, if the fast sample is below the weekly average, then no more analyses need
to be run for that week.
= o•z `�I

' page 2-
Request for Modification o-f"Asheboro NPDES Permit
Asheboro should be advised that when calculating averages, any value reported as
less than detectable may be considered zero. If you have any questions, please call me.

State of North Carolina --Mom
Department of Environment, Health, and Natural Resources
Winston-Salem Regional Office
James B. Hunt, Jr., Governor Margaret Plemmons Foster
Jonathan B. Howes, Secretary Regional Manager
March 191 1993
-1
MEMORANDUM
TO: Randy Kepler
THROUGH: Steve Mauney --
FROM: George Smith
SUBJECT: Asheboro WWTP Draft Permit
Permit #NC0026123
Randolph County
Per your request, we have addressed the comments from the City of
Asheboro:
A
a) Sample Locations - This office has no problems in
relocating the upstream sample location to 800 feet. There
are no tributaries or discharges between this location and
their effluent discharge. Recommend relocation.
b) Bis (2-ethylhexyl) phthalate - This compound may be used in
the plastics industry to plasticize polymers. It's major
use is in vacuum pumps. These sources are numerous and
therefore the City needs time to investigate the sources.
A mini toxicity test was conducted simultaneously with the
phthalate analytical test. The results are as follows:
toxicity Bis - compound
Sample #1 pass 44.9 ug/1
#2 fail < 10 ug/1
The proposed limit is 13.6 ug/l.
Apparently the Bis - compound does not contribute to
toxicity. Therefore we recommend monitor Bis (-2-ethylhexyl)
phthalate quarterly in conjunction with Chronic T,o
5 'Co';
8025 \'orth Point Boulevard, Suite 100, Winston-Salem, NC 27106-3203 - Telephone 919-S96-7007 - FAX919-S96-7005
An Equal Opportunity Atrrmative Action Employer CENTRAL FILE COPY

Asheboro dra r t
Page 2 PQrm�t
d) Fluoride - As noted in Asheboro's report, fluorine is
added in drinking water at approximate levels of 1 mg/l.
We recommend the fluoride limit be changed to 1.8 mg/l.
We do not feel a need to comment on the remaining items. If you
have any further questions please feel free to contact the Winston-
Salem regional office at 919-896-7007.
cc: Central File
WSRO
M'
4UG n.6 1003 Z
CENTRAL FILE CQtY

� .,�,` �. •Yy ��1a rfr
Titu of Askehora
dart# &rolinn 272D4-1106
146 N. (94=4 ft, ip. (0. Nox 11 Df
February 23, 1993
Ms. Coleen Sullins, NPDES Permit Group
N. C. DEHNR
Div. of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 27611-7687
Ref: NPDES Draft Permit No. NC0026123
Dear Ms. Sullins:
Q'ffdp vne (919) 626-12DD
In response to draft NPDES Permit No. NC0026123, we respec-
tively submit for consideration the following comments:
Reference:
A( ). Effluent Limitations and Monitoring Requirements Summer/
Winter.
a) *Sample Locations - U-Upstream 50 feet from the outfall.
Should be changed t ut , g o 800 feet above the �a.fall to better
locate the sampling point.
b) Bis(2-ethylhexyl) phthalate daily maximum 13.6 ug/1
weekly:
Four Annual Effluent Pollutant Analyses have shown con-
centration levels of 44.9 ug/1 to less than detection
limits for this parameter. Mini -Chronic Toxicity
Analyses performed on the same four samples exhibited a
"fail" with a less than detection level of Bis(2-
`�,��Jg�' ethylhexyl) phthalate present and a "pass" with a 44.9
ug/1 concentration. What is the environmental or toxic
impact of this compound and at what level should it be
controlled? Some sources have contributed minute con-
centrations of Bis (2-ethylhexyl) phthalate to sample
tubing or plastic pipe since this compound is used as a
plasticizer for these materials. Could this be the
contribution to our effluent samples? Since data from
only four samples has been available, would it be
advisable to develop additional data and/or identify the
Mome of N. Cf. Zoological JOttrk

4 *'
Ms. Coleen Sullins
N. C. DEHNR
Div. of Environmental Management
2-23-93
Page -2-
source prior to establishing a weekly monitoring
frequency and a restrictive daily limit. Special
consideration should also be given the cost for
analyses - $150-300/sample based upon quantification.
c) Cyanide: 5.0 ug/1 daily maximum weekly:
This limit represents the detection level for our
analytical method.
d) Fluoride: 1.8 ug/l daily maximum weekly:
The concentration level must be in error since the
°� level of fluoridation of drinking water is in mg/l.
e) Mercury: 0.012 ug/l daily maximum weekly:
This limit is below the 0.25 ug/1 detection level of our
instrument. Our understanding is that any detectable
concentration would be above the daily maximum concentra-
,� tion, therefore would be considered a violation. Our
sampling for headworks and q
pretreatment requirements has
shown detectable levels of Mercury not only in our
effluent but also even in domestic sources. This would
1-gad us to believe that we could exhibit detectable
levels in our effluent on a frequent enough basis to be
in violation of our draft permit limit, which would in
turn cause a. pot ent i; 1 for. fines. Since t h i s s :: the
first effluent monitoring requirement for mercury, we
suggest monitoring requirements only so that efforts can
be made to assure a reduction in the Mercury present.
As indicated by the draft permit and explained by your enforcement
staff, the ,limits for Bis (2-ehtylhexyl ) phthalate, Arsenic, Cadmium,
Chromium, Cyanide, Fluoride, Lead, Mercury, and Nickel would be subject
to daily maximum limits and the EPA guidelines in determining com-
pliance. Using this formulation, two daily samples exceeding TRC limits
In two different months would constitute a violation for the six month
period. Four daily samples exceeding the daily maximum limit for the
six month period would also constitute a violation. This has the
potential to initiate fines and even a special order of consent which
could restrict development and growth` for the City of Asheboro.

i •,
e
r`
Ms. Coleen Sullins
N..C. DEHNR
Div. of Environmental Management
2-23-93
Page -3-
Via,,,, �r•S ��(+w f� � � �:�.EC G.3.�
We feel these limits to be too stringent and restrictive in that
abnormal fluctuations could cause temporary upsets for only a few days
within the six month period and would therefore become a'violation.
For this reason, we suggest monitoring f or Bi s (2-eht yl hexyl )
phthalate, Cyanide, and Mercury at a less frequent rate with no limits;
or alternately for Cyanide and/or Mercury compliance determination using
a monthly average with --a measurable limit, rather than the draft daily
maximum limit. In making this monthly average determination for Cyanide
and Mercury, we request that for any values less than our detection
levels, (.5 ug/l for Cyanide and .25 ug/1 for Mercury), that one half of
these respective values could be used (Cyanide - .25 ug/1 and Mercury -
.12 ug/1) in calculating the monthly average. For the other parameters
(Arsenic, Cadmium, Chromium, Fluoride, Lead and Nickel), we suggest a.
monthly average limit using the same monthly average calculation with
one-half the detectable level for any less than values.
The NC0026123 draft permit has increased by 9 limited parameters
and 5 monitoring requirements above our existing permit. These
additional parameters and monitoring frequencies would require an
expansion of our present monitoring frequencies, increase workload and
certification of our POTW lab, and require commercial lab assistance in
performing the analyses for Bis(2-ethylhexyl) phthalate and chloroform.
All of these would represent an increase of 375 estimated man hours/year
for our lab staff and a $22, 000 budget increase per year.
Asheboro is willing to make this investment in protecting and
cleaning our valuable water resources as we have in the past. This
April we will hold a bond referendum for funding of the expansion of our
wastewater treatment plant and outfall systems. It is th-A.ough all these
efforts and the cooperative spirit of industrial customers and the
regulatory agencies of the state and federal levels that we anticipate
even .a greater success in the future.
If you have any questions or comments or need additionai informa-
tion, please call me at [phone].
DBL/1r
Sincerely,
David B. Leonard
Cit.y Manager

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The Division needs additional information or has found
problems with the HWA calculations for arsenic,
chromium, copper, cyanide, mercury, nickel, silver, and
zinc. The headworks calculations for these parameters
will need to be resubmitted. Specific problems
'discovered during our review are as follows:
,4'1. Sludge Application. The review noted that the
HWA did not evaluate the sludge application permit
limit for zinc. The Division requests that zinc sludge
application permit limits be evaluated and the HWA
for zinc resubmitted.
2. Inhibition Criteria. The review noted that
site -specific inhibition criteria were apparently used
for arsenic, chromium, copper, cyanide, nickel, silver
and zinc. The Division requests additional support
documentation for these site -specific inhibition
criteria.
3. Mercury Loading. In response to the HWA
mercury questions posed by the City of Asheboro, the
Division recognizes that Asheboro will have
difficulty developing any allowable industrial mercury
allocation. In addition, the Division interprets the
HWA data as follows:
A. The total allowable loading is approximately
0.0012 pounds of mercury, based on a 62%
site -specific removal rate. For comparison, the
"default" removal rate for mercury is 67%.
B. The average influent load is 0.00066 mg/1 as
calculated from 39 samples. The average influent
flow is 4.7 MGD. Therefore, the average calculated
influent load was approximately 0.026 pounds of
mercury.
C. With an allowable load of 0.0012 pounds of
mercury and an influent load of 0.026 pounds of
mercury, it appears that the mercury water quality
criteria will be exceeded.
With consideration of the probable water quality
exceedance, the Division finds that a mercury
allocation for industrial users does not exist and
that the industrial users should be allocated at
the water giality standard of 0.000012 mg/1. To
test compliance to the 0.000012 mg/1 limit the
industry should be tested to the minimum detection
level. The Division currently recognizes 0.00020
mg/1 as the minimum detection level.

A
Until the above issues are resolved, the review of
any pretreatment permits with arsenic, chromium,
copper, cyanide, mercury, nickel, silver, or zinc
limits will not be completed. In addition, the
Division will be unable to complete its review of
any pretreatment permit which limits a parameter
not included in this headworks analysis until the
headworks calculations for that parameter are
submitted.
The mass -balance check indicates that the sum of
the sources does not account for all of the
mercury and TSS entering the POTW. Please check
for additional sources of these pollutants. In
addition, the arsenic, cadmium, and chromium
influent loading rate is much lower than the total
sources loading rate. Please address these issues
when conducting your long-term monitoring program
Please review the above comments and if you have
any questions or need assistance, please feel free
to call either Ms. Julia Storm of the pretreatment
staff at 919/733-5083.
Sincerely,
j
revor Clements
s stant Chief
Water Quality Section
JRP/ashehwa.01
cc: Regional Supervisor
Central Files
Julia Storm

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