NC0020184_PERMIT MODIFICATION_19981007

NPDES DQCUWENT SCANNING COVER SHEET
NPDES Permit:
NCO020184
Gastonia — Long Creek WWT'P
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Correspondence
201 Facilities Plan
Instream Assessment (07B)
Environmental Assessment (EA)
Permit
History
Document Date:
October 7, 1998
his document I= printed oIM reuA5e paper - igPzore any
couteut on the Bide

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 7, 1998
Mx. Don Carmichael, P.E.
City of Gastonia
Post Office Box 1748
Gastonia, North Carolina 28053-1748
D E N R
Subject: NPDES Permit Modification/SettIement
And Water Quality Monitoring Plan
Approval
Permit No. NCO020184
Long Creels WWTP
Permit No. NCO074268
Crowders Creek WWTP
Gaston County
Dear Mr. Carmichael:
This letter provides documentation and an explanation of the modifications to the City of
Gastonia's NPDES permits, The City of Gastonia and the Division of Quality have thoroughly
discussed each of the items in this letter, so that the two parties should be in agreement on the
permit modifications and the petition for contested case can be withdrawn (see withdrawal form
attached to this letter).
sition of Concentration -Based Nutrient Limits — Lo
Catawba River)
Creek WWTP (16.0 MGD to South
The construction required to upgrade Long Creek WWTP has been delayed to the point
that a full summer of operation was not possible in 1998. The permit has been modified so that
the concentration limit for total nitrogen will take effect April 1, 2000.
The diversion of wastewater flow from Long Creek WWTP to Crowders Creek WWTP is
a viable option that may or may not be implemented, and this option will not be referenced in the
NPDES permit. It may not be necessary to divert wastewater to the Crowders Creek facility
given the upgraded Long Creek ',X'WTP is near completion.
As stated in the June 5, 1998 letter from J. Gordon Arbuckle, Fleischmann's Yeast
supports the permit modifications described in the two preceding paragraphs.
Instream Monitoring — LonECreek WWTP
Gastonia and the Division both agree on the importance of instream monitoring.
Gastonia currently monitors instream water quality at four stations, one upstream, and three
downstream of the discharge location. It could take several years to collect adequate data at
these stations reflecting base stream flows. Sampling during this flow regime is necessary to
determining the dissolved oxygen (DO) sag during the most critical stream conditions.
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

Mr. Carmichael
Page 2
October 7, 1998
Based on the complexity of the hydraulics in this system, Gastonia and the Division
agreed that Gastonia shall conduct several synoptic sampling events to occur during low stream
flows. This effort should identify the dissolved oxygen sag location on the South Fork Catawba
River downstream of the Long Creek WWTP discharge point. A water quality monitoring plan
has been prepared by the City of Gastonia and is hereby approved by the Division. Monitoring
will be performed in accordance with the approved plan. This monitoring plan will be an
enforceable part of the Long Creek WWTP NPDES permit. All data collected as part of this
monitoring requirement will be reported within one month after sample collection. Following
identification of the DO sag, the permit may be modified to include the DO sag location as a
permanent instream monitoring station.
Cyanide — Crowders Creek WWTP and Long Creek WWTP
A quantitation level of 10 ug/l has been incorporated into both WWTPs. The Division is
willing to meet with Gastonia and their consultant, CH2M HILL, to discuss additional data needs
necessary to justify a quantitation level greater than 10 ug/l.
Metals — Crowders Creek WWTP and Long Creek WWTP
Based on updated data and a statistical analysis of this information, Gastonia and the
Division have agreed to the following changes:
• Crowders Creek WWTP — eliminate cadmium, chromium, lead, and mercury limits.
• Long Creek WWTP (8.0 MGD to Long Creek) — eliminate lead limit.
• Long Creek WWTP (8.0 MGD to S. Fork Catawba River) — eliminate cadmium limit (Note:
this discharge does not have a lead limit in the permit).
• Long Creek WWTP (16.0 MGD to S. Fork Catawba River) — eliminate cadmium and lead
limits.
Mercury — Long Creek WWTP
The weekly average mercury limit in the Long Creek WWTP permit will become a daily
maximum limit, thus eliminating the weekly average limit for this parameter.
Expiration Date Changes — Crowders Creek WWTP and Long Creek WWTP
In an effort to balance the NPDES permitting schedule, the expiration dates of facilities
within certain river basins and subbasins have been changed. Please note that the expiration date
of the Crowders Creek WWTP has changed from September 30, 2001 to August 31, 2000 and
the expiration date of the Long Creek WWTP has changed from September 30, 2001 to January
31, 2000.
Please find enclosed the modified sections of the permit referenced in the preceding
paragraph. Replace the original sections in your permit with the newer enclosed sections and
discard the original sections. All other terms and conditions contained in the original permit
remain unchanged and in full effect. These permit modifications are issued pursuant to the
requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency.

Mr. Carmichael
Page 3
October 7, 1998
If you have any questions, please contact Paul Clark at [phone] ext. 580.
Sincerely,
Preston o ard, Jr., P.E.
cc, Central Files
Mooresville Regional Office, Water Quality Section
Roosevelt Childress, EPA
NPDES Unit (Permit Files)
Point Source Compliance/Enforcement Unit

Permit No. NCO020184
. STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
City of Gastonia
is hereby authorized to discharge wastewater from a facility located at
Long Creek Wastewater Treatment Plant
Old Spencer Mountain Road
Gastonia
Gaston County
to receiving waters designated as Long Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
11, III, and W hereof.
The permit shall become effective November 1, 1998
This permit and the authorization to discharge shall expire at midnight on January 31, 2000
Signed this day October 7, 1998
PrestonJr., ., Director
Division of Water Quality
By Authority of the Environmental Management Commission

SUPPLEMENT TO PERMIT COVER SHEET
City of Gastonia
is hereby authorized to:
Permit No. NCO020184
Continue to operate an existing 8.0 MGD wastewater treatment facility consists of influent
lift station, a mechanical bar screen and grit removal, primary clarifiers, trickling filters,
polishing ponds with floating aerators, dual chlorine contact chambers with deehlorination, a
static aerator, sludge lagoons, and sludge drying beds. Facilities under construction for
expansion to 16.0 MGD wastewater treatment facility include mechanical bar screens,
cyclone grit removal, anaerobic/anoxic/oxie basins, caustic and alum feed, secondary
clarifiers, tertiary filters, chlorine disinfection with dechlorination, static post aeration, and
sludge digesters. Wastewater treatment facility is located at Long Creek Wastewater
Treatment Plant, Old Spencer Mountain Road, Gastonia, Gaston County (See Part III of this
permit), and
2. Prior to relocation of discharge point, discharge wastewater from said treatment works at the
location specified on the attached map into Long Creek which is classified Class C waters in
the Catawba River Basin.
3. After relocation of discharge point, discharge wastewater from said treatment works at the
location specified on the attached map into South Fork Catawba River which is classified
Class WS-V waters in the Catawba River Basin.

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Latitude:3503 ]' 35"
Longitude:820 24' 10"
USGS Quad #:F14SE
River Basin #:030836
Receiving Stream: South Fork .
Catwba River -
City of Gastonia
NCO020184
Gaston County
Long Creek-WW rP

A.(1)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -PERMITTED DISCHARGE TO S. FORK CATAWBA RIVER Permit No. NCO020184
During the period beginning on the effective date of the permit and lasting until expansion to 16.0 MGD, the Permittee is authorized to discharge from outfall(s)
serial number 001. Such discharges shalt, be limited and monitored by the Permittee as specified below:
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Continuous
Recording
I or
BOD, 5-day, 20°C (April 1 - October 31)
11.0 mg
mgV—
composite
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BOD, 5-day, 20°C (November 1 - March 31)
22.0 mg
mg
ai y
omposi e
,
TSS
mg
mg
Daily
omposi e
-(April - October
mg
Daily
Composite
NH3-N,(November 1 - March 31)
14.0 mg
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Composite
Dissolved Oxygen3
Lially
Grab,
Fecal o i orm (geometric mean
m
m
as y
Grab
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ai y
Urab,
Total: esi ua orine
28.0 1.1911
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Monthly
composiFe
otal Phosphorus
Monthly
Uomposite
Chronic ToxiCity4
Uuarterly
Composite
Mercury
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Gra6
a mium
.2/montF
ComposiFe
Antimony
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Composite
2/monthoNra
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Rid
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m
2/month
Notes:
1Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream. Instream monitoring will not be required during the remainder of the
permit period. Instead, a synoptic instream sampling event will be conducted. See Supplement to Effluent Limitations and Monitoring
Requirements Page - Special Condition A(5).
Z The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
4 Chronic Toxicity (Cerioda hnia , P/F, no significant mortality at 10%; March, June, September, and December; See Supplement to Effluent Limitations and
Monitoring Requirements Page - Special Condition A(3).
5 The detection limit for mercury is 0.2 ugll. If the measured levels of mercury are below the detection limit, then the measurement is considered to be zero
for purposes of compliance evaluation and should be reported on the DMR as < 0.2 ugll.
The pFl 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.(2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -PERMITTED DISCHARGE TO S. FORK CATAWBA RIVER Permit No.NC0020184
During the period beginning after the expansion to 16.0 MGD 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:
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1 or
BOD, 5-day, 20°C (April 1 - October 31)
5.0 mg
mg
Daily
ompos[ e
BOD, 5-day, 20°C (November 1 - March 31)
10,0 mg
mg
a[ y
ompos[ e
,
TSS
mg
mg
a[ y
Composite
-(April - OcIoBer
mg
Daily
ompos[ e
NH3-N,(November I - March 31)
4,0 mg
Daily
composite
Dissolved Oxygen
Daily
Grab,
Fecal o [ orm (geometric mean
m
mi
Daily
Grab
-Temperature
Daily
urab,
Total es[ ua onne
ZIT, ug
Daily
ra
Conductivity
Daily
Grab
U'D
Fo-Fal Nitrogen 2+ NO3 +
800 lbs/day4
Weekly
ompos[ e
7`615`1 Nitrogen 2+ 3 +
6. 0 mg/i
Weekly
ompos[ e
rotarotal Phosphorus
1.0 mg
Weekly—
ompos[ e
Chronic Toxicity
uarterly
ompos[ e
Cyanide
ug
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Weekly
ra
Mercury
ug
Weekly
brao
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Composite
Beryllium
mon
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Cadmium
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Chlon(le2/month
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_
Lead
monGrab
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream. Instream monitoring will not be required d r-i g the rema1n`4r of the
permit period. See Supplement to Effluent Limitations and Monitoring Requirements Page - Special Condition A(5).
2 The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mgll.
4 800 Ibs/day TN limit applies only from April 1 through October 31, 1999. 6.0 mgll TN limit applies April 1 through October 31, 2000 and April 1 through
October 31, 2001 (or earlier if new permit issued prior to this date).
5 Chronic Toxicity (Cerioda hnia), P/F, no significant mortality at 19%; March, June, September, and December; See Supplement to Effluent Limitations and
Monitoring Requiremen s Page - Special Condition A(4).
6 The detection limit for cyanide is 10.0 ugll_ If the measured levels of cyanide are below the detection limit, then the measurement is considered to be zero
for purposes of compliance evaluation and should be reported on the DMR as < 10.0 ug/l.
7 The detection limit for mercury is 0.2 ug/l. If the measured levels of mercury are below the detection limit, then the measurement is considered to be zero
for purposes of compliance evaluation and should be reported on the DMR as < 0.2 ug/I.
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 ho discharge of floating solids or visible foam in other than trace amounts.

• Permit No. NCO020184
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A(3). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 10 % (defined as treatment two in the procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will be
perms ed 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 TGP313.
Additionally, DWQ Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 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 there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above,
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 the permittee fail to monitor during a month in which toxicity monitoring is required, 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
Water Quality 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, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.
QCL PIF Version 9196

Permit No. NCO020184
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A(4). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chfonic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedufe," Revised November 1995; or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 19 % (defined as treatment two in the procedure document). The permit' holder shall perform
4uarterlY monitoring using this procedure to establish compliance with the permit condition. The tests will be
performed during the months of March, June, September, and December. Effluent sampling for this testing
shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
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 TGP313_
Additionally, DWQ Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 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 there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
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 the permittee fail to monitor during a month in which toxicity monitoring is required, 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
Water Quality 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, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.
QCL PIF Version 9196

PRrmit No. NCO020184
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A(5). SYNOPTIC STREAM SAMPLING EVENT
Gastonia shall conduct eight synoptic flow -sampling events to occur during low flow conditions in an effort to
identify the dissolved oxygen (DO) sag location on the South Fork Catawba River downstream of Long Creek
WWTP. A permanent instream monitoring station will then be established at this location. A water quality
monitoring plan will be prepared, submitted to, and approved by the Division. This monitoring plan will be an
enforceable part of the Long Creek WWTP NPDES permit. All data collected as part of this monitoring
requirement will be reported within one month after sample collection. Following identification of the DO sag,
the permit will be modified to include the DO sag location as an instream monitoring station.

h
I
THU of GIM11111a
P.O. Box 1748
CE Oc.G
ins#zaniM} orill Tarolittn 28IT53-1748
DEPARTMENT OF
PUBLIC WORKS AND UTILITIES Ul �7rflfYi
September 10, 1998 MP rn
to
David A. Goodrich
NCDENR/DWQ
P.O. Box 28535
Raleigh, NC 27626-0535
RE: DWQ Request for Map with Proposed South Fork River Monitoring Sites
Dear Mr. Goodrich:
Per our phone conversation, I have enclosed a map with the proposed South Fork River monitoring sites
for your review. A copy of the monitoring proposal for low flow conditions is also enclosed. From our
phone conversation, it is my understanding that you are investigating with the DWQ modelers if some
flow rate other that 100MGD is more appropriate as a trigger for initiating the monitoring protocol.
The numbered monitoring sites on the map are as follows:
1. A point between dam at Spencer Mountain and bridge at SR2003.
2. Upstream of hydroelectric plant, prior to re-entry of raceway water into river.
3. Downstream of hydroelectric plant, below re-entry of raceway water into river.
4. Upstream of Crompton Knowles discharge,
5. Downstream of Crompton Knowles discharge.
6. Upstream of dam at McAdenville.
The unnumbered marked sites are at approximately 1/ mile intervals between the numbered sites.
The City of Gastonia looks forward to your response to this proposal and to working with DWQ staff on
this project. Please call at [phone] with any questions.
Sincerely,
arty W ummings 4`
Assistant Superintendent WWTD
Enclosures
Cc: Don Carmichael, Director of Public Works and Utilities
John Shuler, Assistant Director of Utilities
Coleman Keeter, Superintendent WWTD
GI . doc

DRAFT
AUGUST 13, 1998
PROPOSAL TO MONITOR DISSOLVED OXYGEN IN SOUTH FORK RIVER
DURING LOW FLOW CONDITIONS
CITY OF GASTONIA
WASTEWATER TREATMENT DIVISION
• City staff will monitor the DO in the South Fork River, via boat, from below the dam. at
Spencer Mountain to above the dam at McAdenville during low, flow conditions.
• DO «711 be monitored for 5 consecutive days following determination of low flow
conditions_
• Low flow conditions will be determined by:
• 5 consecutive days of flow below 100 MGD. as determined from USGS
uaging station readings, or
• zero flow over the dam at Spencer Mountain, as determined by City staff
during the routine stream monitoring required at the dam by NPDES permit.
• DO sample points will include:
• a point between dam at Spencer Mountain and bridge at SR2003
• upstream of hydroelectric plant, prior to .re-entry of raceway water into river
• downstream of hydroelectric plant, below re-entry of raceway water into
river
• upstream of Crompton Knowles discharge
• downstream of Crompton Knowles discharge
• upstream of dam at McAdenville
• upstream and downstream of any other discharge or tributary not noted
above, but located by staff during monitoring event
• at approximately '/4 mile intervals between above noted points.
• City staff understand that any special instructions regarding performance of this project will
by provided by DWQ, including specific techniques or sample locations.
• City staff will alert the DWQ of approaching low flows and pending monitoring event.
DWQ may assist or provide technical expertise as nay be required.
• City staff will return all data and develop a report as relates to DO status in the South Fork
River.
'Ciintake
y agreeing to perform this study for DWQ, the City understands that the NPDES required
tream monitoring sites will be reduced to bvo sites, one upstream at the old Ranlo water
and one downstream at the Spencer Mountain dam.
sfdo.doc

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quaiity
James B. Hunt; Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 29, 1998
TIRANSMITTED BY FACSIMILE ONLY
Mr. Donald E. Carmichael, P.E., Director
City of Gastonia Public Works and Utilities
Post Office Box 1748
Gastonia, North Carolina 28053-1748
ANT, - X y T
ID EE F=1
Subject: Proposed Resolution of Several Issues
City of Gastonia WWTP's
Gaston County
Dear Mr. Carmichael:
I have prepared this letter to address several issues regarding your NPDES permits which remain
unresolved. Prior to making formal changes in any of your NPDES permits, I will require that you submit a
written response to me regarding these proposals. Please note that the Division will continue to work with
the city to;resolve any modifications to these resolutions or any disagreements on these issues. However, in
the interest of getting as many concerns resolved as quickly as possible, formal modifications will be
withheld for any specific area for which agreement cannot be reached.
Imposition of Concentration -Based Nutrient Limits
1 received your petition for contested case regarding the imposition of mass limits for total nitrogen
during the first summer of operation of the new Long Creek V% WTP. After discussions with you and your
staff, it is my understanding that construction of this ul—rnA-4 } ea±mn_�t Facility has been delayed to the
point that a full summer of operation will not be possible in 1998. Therefore, you have requested that the
city be allowed an additional summer to meet the 800 lbs/day limit. The Division will agree to this
request and modify the NPDES permit such that the concentration limit for total nitrogen will take effect
on April 1, 2000.
The city also pointed out that the diversion to Crowders Creek WWTP, although still a viable option,
is more properly referenced outside the NPDES permit document. The Division agrees with this point. In
fact, it is my recollection that the diversion was primarily for purposes of determining whether or not the
wastewater from Fleischman's Yeast would nitrify at the Crowders Creek WWTP, which is emr?oying a
process quite similar to that being constructed at the upgraded Long Creek WWTP. Therefore, any
diversion of this wastewater would not be necessary unless the city believes that the treatment plants or
environment would benefit by changing the ultimate disposition of this particular wastestream.
Please note that the resolution of these two items must also meet the approval of Fleischman's Yeast. I
would be appreciative if you would contact Ms. Donna Forner to elicit her response to these changes. This is
necessary since your adjudication was made regarding a settlement proposal forged with Fleischman's
Yeast regarding their contestment of the permit issued in February 26, 1997.
Instream Monitoring
The Division and Gastonia both agree on the importance and value of continuous instream monitoring.
Both parties also agree that the Ranlo WTP intake is a suitable location for this type of monitoring and
should be designated as the "upstream" sample site.
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Downstream of the discharge, there are three areas of potential impact: behind the Spencer Mountain
dam; in the bypass reach; and approximately 1.5 miles downstream of `.---.-discharge in the area of the
predicted dissolved oxygen sag. As we have discussed, it may be best to delay the installation of a
continuous monitoring station downstream of the discharge until data have been collected during the current
permit term. by collecting additional data, a more informed decision could be made as to the final
placement of the downstream continuous monitoring station.
For oxygen -consuming wastes, a flow regime reflecting base stream flows is the most critical period for
defining impacts to the river. The city should be aware that additional monitoring beyond the term of this
permit may be necessary since this flow regime may not occur in the next three or four years. However, it is
the primary intent of the Division to monitor areas of potential impact during critical times, and I believe
the monitoring data collected at these three downstream sites will illuminate for us all what those areas
are.
In terms of forming a coalition, the Division continues to support these efforts. However, as you know,
there aren't a large number of dischargers in this sub -basin (near the Long Creek WWTP) that are currently
required to monitor in the river. Furthermore, it is beyond the Division's current resources to lay the
foundation for such a coalition. However, if you are able to spark some interest in such an endeavor, the
Division will be able to provide information regarding our experience with other such efforts throughout
North Carolina.
Qyanide
A cluantitation limit of 10 µgJL for cyanide is recommended by the Division for immediate inclusion in
all permits. However, it should also be noted that some additional data ,ol'.cct: ,., r. ay result in modifying
this quantitation level further. I have been in contact with your consultant (Bill Kreutzberger) regarding
further collection and analysis of data. Meetings should be convened in June of this year. However, in the
meantime, I believe we both agree that it would be prudent to move ahead with the 10 µg/L level with the
understanding that it could be modified further in the future.
Metals
Clean sampling and laboratory techniques were developed and implemented by the City of Gastonia
over the past two years or so which have greatly added to our understanding of accurate levels of these
toxicants in the effluent. I commend the excellent work which has been done thus far, and the commitment
made by the city to continue these techniques of high quality data collection and analysis.
Based on the information submitted regarding the levels of metals in effluent, limits for cadmium, Iead
and chromium will be dropped from the Crowders Creek permit. Furthermore, limits for lead and cadmium
will be eliminated from the Long Creek WWTP permit. Monitoring for all of these param^t^_s will be
continued as part of the city's Pretreatment Program. Long -Term Monitoring Plan. Therefore, they will be
removed completely from the effluent limits and monitoring requirements page of the respective NPDES
permits. Mercury was found in the effluents of both the Long Creek and Crowders Creek WWTP's and
remains a concern for the environment. Therefore, a limit will be included in this permit.
You requested a modification of your mercury limit to make it equivalent to the level of quantitation.
This is not possible. Based on the rules adopted by the Environmental Management Commission, NPDES
permit limits must be calculated on the basis of permitted flow and certain flow conditions (7Q10, in this
case). Therefore, the limit must remain as previously given.
I hope that some or all of these proposals will result in resolution of a number of these outstanding
issues. As always, I appreciate the open and communicative relationship shared by the City of Gastonia
and the Division. Please feel free to contact me at (919)-733-5083, extension 517 with comments or questions.
Respectfully,
David A. Goodrich
NPDES Unit Supervisor

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