NC0047384_SOC (application),_20191120

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November 20, 2019
of Greensboro
Carolina
Water Resources Department
Certified Mail 7015 0640 0006 72113612 Return Receipt Requested
NC Department of Environmental Quality
NPDES Compliance & Expedited Permit Unit
1617 Mail Service Center
Raleigh, North Carolina 27600-1617
RE: City of Greensboro Special Order By Consent for T Z. Osborne NCDES Permit NCO047384
To Whom It May Concern:
Enclosed please find an original and two (2) copies of a Special Order by Consent Application package
that includes:
- City of Greensboro SOC Application (with narrative for Parts IV. And VI.) signed by Steven D.
Drew, Water Resources Director
- Hazen and Sawyer Engineers Certification (to address Part V.) signed by Aaron D. Babson, P. E.
- City of Greensboro City Council Resolution authorizing the City of Greensboro to enter into a
Special Order by Consent with NCDEQ/Environmental Management Commission with signatures
of: Mayor, Nancy Vaughan; Mayor Pro Tern Yvonne J. Johnson; and City Attorney Charles Watts
Pleas eel free to contac me if you need additional information.
C
Ste en D. Drew
Water Resources Director
cc: Mike Borchers, Water Resources Department Assistant Director (via email)
Elijah Williams, Water Reclamation Manager (via email)
Bradley Flynt, T. Z. Osborne ORC (via email)
Martie Groome, Laboratory and Industrial Waste Section Supervisor (via email)
Alicia Goots, Laboratory Coordinator, (via email)
Andrew Kelly, City of Greensboro Assistant City Attorney (via email)
Julie Grzyb, NCDEQ, NPDES Supervisor (via email)
Lon Snider, NCDEQ, Winston Salem Regional Office Superviso
Glenn Dunn, Poyner Spruill (via email) 1
N�Dir{�lD�R
21 NOV 2019
Nora -Discharge
Perini ttial Unit
PO Box 3136 C�r•F;�•n.sboro, NC 27402-3136 � www.greensboro-nc Gov :33-:3i,i-t%I"I'Y (2489) TTY# 333-6930

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RESOLUTION FOR A SPECIAL ORDER BY CONSENT (SOC)
BETWEEN THE.CITY OF GREENSBORO AND THE
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
WHEREAS, Water Resources requests approval to pursue and negotiate a Special Order by
Consent (SOC) with the North Carolina Department of Environmental Quality;
WHEREAS, the T. Z. Osborne Water Reclamation Facility has a permit to discharge treated
wastewater to South Buffalo Creek, a tributary to the Haw River, classified WS-V waters of this
State in the Cape Fear River Basin;
WHEREAS, the. discharge is allowed under National Pollutant Discharge Elimination System
(NPDES) Permit Number NCO047384 effective July 1, 2014, and expired on June 30, 2019, and
administratively extended until reissued by the state;
WHEREAS, the City of Greensboro has voluntarily worked to reduce the concentrations of the
unregulated constituent, 1,4-dioxane, discharged from the T. Z. Osborne Water Reclamation
Facility;
WHEREAS, the SOC will officially outline the steps that Greensboro will continue to take to
further reduce concentrations of 1,4-dioxane in order to protect downstream drinking water
sources;
WHEREAS, the T. Z. Osborne Water Reclamation Facility agrees to maintain and operate the
wastewater treatment system at its maximum level of efficiency, during the interim period of the
Special Order by Consent and thereafter; and
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
GREENSBORO:
That the City is authorized to enter into a Special Order by Consent from the Environmental
Management Commission and the City hereby authorizes Steven D. Drew, Water Resources
Director, to sign and execute this document on behalf of the City of Greensboro.
THE FOREGOING RESOLUTION WAS ADOPTED
BY THE CITY COUNCIL OF THE CITY OF
GREENSBORO ON THE 19t DAY
OF NOVEMBER, 2019 APPROVED AS TO FORM
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DEPUTY CI CLERK
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, or other): CITY OF GREENSBORO
2. Print or Type Owner's or Signing Official's Name and Title:
STEVEN D. DREW, WATER RESOURCES DIRECTOR
3. Facility Name (as shown on Permit)
4. Owner Phone:
5. Owner Email
4. Application Date:
T. Z. OSBORNE WWTP
[phone] (or)
.Steve. dreniggreensboro-nc.gov
NOVEMBER 20, 2019
5. NPDES Permit No. (if applicable)
NCO047384
6. Name of the specific wastewater treatment facility (if different from I.3. above):
SAME
II. PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittec:
Representative: Date: 10-23-2019
DEQ WSRO Staff: Lon Snider, Jenny Graznak DEQ Raleigh Staff. Jeff Poupart, Julie Grzyb
City of Greensboro Staff: Elijah Williams, Martie Groome, Alicia Goots
III. ADDITIONAL FLOW OR FLOW REALLOCATION: NOTAPPLICABLE
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non -discharge permit. These circumstances do not include failure to perform proper
maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.

•' 4
If the requested additional flow is non -domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non -domestic wastewater.
The total domestic additional flow requested:
The total non -domestic additional flow requested:
gallons per day.
gallons per day.
The total additional flow (sum of the above): gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• **Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
• The existing treatment process and any process modifications that have been.made to
date to ensure optimum performance of existing facilities, NOTAPPLICABLE
• Collection system rehabilitation work completed or scheduled (including dates),
• **Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non -compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements,
• **Date and outcome of last Industrial Waste Survey, "SEENARRATIVE
• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs. NOT APPLICABLE
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the .requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.
2

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction. ending construction, and achieving final compliance at a minimum. In
determining the milestone dates, the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval. NOT APPLICABLE
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.) to include a plan of action to minimize
impacts to surface waters. NOT APPLICABLE
• Infiltration/Inflow work, if necessary. NOT APPLICABLE
• **Industrial users achieving compliance with their pretreatment permits if applicable.
• Toxicity Reduction Evaluations (TRE), if necessary. NOTAPPLICABLE
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments, bonds, letters of credit, block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
If funding is not available at the beginning of the SOC process, the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Reguired Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
3

Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources. IDEPARTMENT OF ENVIRONMENTAL QUALIM
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)
APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, STEVEN D. DREW , attest this application for a
Special Order by Consent (SOC) has been reviewed by me and is accurate and complete to the
best of my knowledge. I understand if all required parts of this application are not completed
and if all required supporting information and attachments are not included, this application
package may be returned as incomplete. (Please be advised that the return of this application
does not prevent DWR from collecting all outstanding penalties upon request). Furthermore, I
attest by my signature that I fully understand that an upfront penalty, which may satisfy as
a full settlement of outstanding violations, may be imposed. {Note: Reference to upfront
penalties in Special Orders by Consent may be found in the North Carolina Administrative Code
[T15A NCfiC 2H .1206(c)(3)].)
Date G
of Signing Official
STEVEND. DREW
Printed Name of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
NPDES COMPLIANCE & EXPEDITED PERMIT UNIT
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636
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NARRATIVE ADDENDUM:
City of Greensboro Special Order by Consent (SOC) Application - November 20, 2019
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• **Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
Although the T. Z. Osborne WWTP does not currently have an NPDES permit limit for 1,4-
dioxane, the City of Greensboro seeks an SOC to provide documentation and guidance for the
continued proactive voluntary activities to address and further reduce the levels of 1,4-dioxane
discharged from the WWTP. Our ultimate goal is to be good stewards of the environment by
protecting downstream drinking water supplied and water quality standards.
• **Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non -compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements,
The City of Greensboro developed and implemented a 1,4-dioxane investigation and reduction
plan in 2015. The plan included a literature search, WWTP and collection system trunkline
sampling and analyses. We also facilitated meetings, in coordination with industrial users,
NCDEQ, and other WWTPs. After seven months of sampling, analyses, and data review, the
investigation indicated Shamrock Environmental Corporation (Shamrock) was the significant
source.
When notified, Shamrock voluntarily implemented their own 1,4-dioxane investigation and
reduction strategy that included source reduction and the addition of 1, 4-dioxane to their waste
characterization review for each client. In addition, Shamrock has committed to explore the
latest technology and pretreatment systems for 1, 4-dioxane reduction.
The City of Greensboro will continue to oversee the work with Shamrock, which could include a
consent agreement and/or a SIU Permit modification.
• **Date and outcome of last Industrial Waste Survey,
The City of Greensboro submitted an Industrial Waste Survey (IWS) to NCDEQ Pretreatment
Staff on October 1, 2019. Over 768 industrial users were contacted, surveyed, and/or visited
during the process. Five industrial dischargers were identified for further follow-up activities
(Wastewater Permit Application submittal, on -site visits, etc.) to determine if they meet the EPA
definition of Significant Industrial User. A report on the final resolutions for the five outstanding
dischargers will be submitted to NCDEQ by January 1, 2020.
5

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VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning _construction. ending construction, and achieving final compliance at a minimum. In
determining the milestone dates, the following should be considered:
• "Industrial users achieving compliance with their pretreatment permits if applicable.
SOC Year One:
Review and modify, if necessary, previous monitoring plan from 2015
- Revisit trunkline monitoring (1600 miles of sewer line) at previously identified
junction locations, including North Buffalo Transfer Line
- Determine other minor sources of I, 4-dioxane
- Investigate and determine background levels of 1, 4-dioxane
- Compile data, validate results, determine findings and further actions
Continue collaboration and oversight of Shamrock Environmental re: discharge of 1, 4-
dioxane
- Review voluntary source reduction program and slug control plan
- Increase inspection of Shamrock to twice per year
Contact, interview and survey identified minor sources
Report all T. Z. Osborne effluent 1, 4-dioxane results by email to NCDEQ as soon as all data
is received and has been validated, to allow NCDEQ to notify interested parties
- Increase T.Z. Osborne 1, 4-dioxane effluent eDMR monitoring frequency to 2/month
when NCDEQ Special Study ends
Within 12 months of effective date of SOC, submit report to NCDEQ on Year One activities.
SOC Year Two:
Work with minor sources to reduce or eliminate 1, 4-dioxane discharges
Based on NCDEQ Special Study including City of Greensboro split sample data, determine:
- Long-term achievable effectiveness of Shamrock's source reduction efforts and
resulting T. Z. Osborne WWTP effluent reductions
- Calculate T. Z. Osborne 1, 4-dioxane mass balance using all data (industrial,
domestic, and collection system data)
Within 24 months of effective date of SOC, submit report to NCDEQ on Year Two activities.
SOC Year Three:
Based on information generated in Years One and Two, determine, along with NCDEQ, a
T. Z. Osborne WWTP effluent target that is technically based, attainable and protective. This
target would also include consideration of background concentrations in incoming potable
water, domestic discharges, and other uncontrollable sources.
Conduct headworks analysis calculations for 1, 4-dioxane relative to target effluent
luent
concentration
- Implement headworks analysis via Industrial User Wastewater Discharge Permits
Within 36 months of effective date of SOC, submit report to NCDEQ on Year Three activities.
31

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Hazen
is�
November 16, 2019
Technical Memorandum
To: Steven D. Drew
Director of Water Resources
City of Greensboro, NC
Water Resources Department
From: Patricia Drummey Stiegel, PE
Aaron D, Babson, PE
cc: Elijah L. Williams, P17
Matrtie Groome
Bradley Flynt
Re: Certification of TZ Osborne WWTP Treatment Capabilities
NPDES Permit No. N00047384
Special Order by Consent Third Party Certification of TZ Osborne WWTP
Introduction
The TZ Osborne WWTP is a conventional wastewater treatmentfacility
that consistently complies with effluent limits. It does not have treatment
processes designed to remove emerging constituents such as 1,4-
Dioxane. This memorandum addresses Section V Certification of the
4pplication for a Special Order by Consent,
Hazen and Sawyer • 4011 WestChase Boulevard, Suite 500 - Raleigh, NC :27607 •919.833.7152

Hazen
November 16, 2019
1. Evaluation of existing treatment units, operational procedures and
recommendations as to how the efficiencies of the T.Z. Osborne
WWTP can be maximized
The T.Z. Osborne Wastewater Treatment Plant is a 40-mgd treatment facility designed to meet all
existing NPDBS permit requirements. Improvements are underway to expand the plant to 56 mgd and
upgrade the secondary process to Biological Nutrient Removal (BNR). Treatment processes at the plant
include preliminary, primary, secondary, and tertiary conventional wastewater treatment.
Preliminary treatment includes step screens followed by influent pumping. The influent pump station
has a firm capacity of 75 mgd, consisting of four 25 mgd vertical, centrifugal non -clog pumps that operate
on variable frequency drives. Stirred. vortex grit removal follows the influent pump station.
The T.Z. Osborne WWTP has 6 primary clarifiers, 4 rectangular and 2 circular, which receive flow from
the preliminary treatment facilities,
The secondary treatment facilities at the T,Z. Osborne WWTP include the following; aeration basins,
secondary clarifiers, return activated sludge (RAS) and waste activated sludge (WAS) pumping and
aeration equipment for providing oxygen to the biological process, There are a total of 12 aeration basins,
with Basins 1-4 having twice the capacity of the other basins. The aeration basins currently operate in a
two -stage process. T,Z, Osborne WWTP has a total of 10 circular secondary clarifiers, 7 with a diameter
of 130 feet and 3 with a diameter of 160 feet,
Tertiary treatment includes filtration and disinfection. The facility has a total of 6 traveling bridge cloth
media falters, and filtration is followed by sodium hypochlorite disinfection, A total of 6 chlorine contact
tams provide contact time for disinfection. Sodium bisulfate is then dosed to remove residual sodium
hypochlorite before treated effluent is discharged to South Buffalo Creek in the Cape Fear River Basin.
The plant is operated in an efficient manner, The T.Z, Osborne WWTP is not capable of treating 1,4-
Dioxane and therefore, operational changes are not available to remove this constituent.
2. Certification T,Z. Osborne WWTP could not be operated to remove
1,4-Dioxane to achieve compliance with final permit limits
IA-Dioxane is a synthetic industrial chemical_ and is often a by-product present in many goods, including
paint atrippers, dyes, greasers; antifreeze and aircraft deicing fluids and in some consumer products. T,Z.
Osborne WWTP operates under an existing NPDES permit that does not include 1,4-Dioxane effluent
limits. The plant is not designed to remove 1,4-Dioxane and does not have the capability to treat this
constituent with existing conventional treatment or after the completion of ongoing upgrades.
Special Order by Consent Third Party Certification of TZ Osborne WWTP Page 2 of 3

Hazen
November 16, 2019
3. The effluent limits that the facility could be expected to meet if
operated at their maximum efficiency during the term of the
requested SOC (be sure to consider interim construction phases).
Not Applicable for this SOC
4. Any other actions taken to correct problems prior to requesting
the SOC
The City of Greensboro submitted a "Corrective Action plan" to NC DEQ NP®ES/Pretreatment on
September 23, 2019, This document outlines activities by the City of Greensboro Industrial Waste
Section in relation to locating sources of and reducing discharges of 1,4-Dioxane to the Greensboro
sanitary sewer system,
Special Order by Consent Third Party Certification of TZ Osborne WWTP Page 3 of 3