NC0025151_Regional Office Historical File Pre 2016

Collection
`. r, _ c_ ___ _ RECEIVED
Sewer Collection Systeim Annuar Pet'l �riiriance Report N.C. Deot ofENR
City of Eden, North Carolina JUL 3 0 2010
July 1, 2009 to June 30, 2010 I Winston-Salerr
Regional Of ce
I. General Information
Facility/System Name: City of Eden, Sewer Collection and Treatment System
Responsible Entity: City of Eden, Brad Corcoran, City Manager
Person in Charge/ Contact: Collection System and Pump Stations, Mark T. Builins,
Operator -in -Responsible Charge, 336-627-7783
Mebane Bridge Wastewater Treatment Plant, Melinda S. Ward,
Operator -in -Responsible Charge, 336-627-1009
Dry Creek Wastewater Treatment Plant, Ralph Potter,
Operator -in -Responsible Charge, 336-627-1009
Applicable Permits: Sewer Collection System — WQC200018
Mebane Bridge Wastewater Treatment Plant — NPDES Permit NCO025071
Dry Creek Wastewater Treatment Plant — NPDES Permit NCO025151
Land Application of Wastewater Residuals — NC Permit WQ0003035
Description of Collection and Treatment Process:
The collection system consists of 145+ miles of gravity and force main sewer pipelines. The
pipelines are composed of a mixture of clay and ductile iron pipe, ranging in size from 2 to 36 inches.
Age of the sewer pipelines range from new to more than 50 years old. Collection is accomplished by
gravity from homes and businesses until it is necessary to pump from low elevations in force main
sewer lines that transport the sewage to the treatment plants. There are 19 pump stations in the
collection system. These range in size from pumping a few thousand gallons per day to more than
five million gallons a day (MGD). The City has two separate collection drainage areas. The
Northeast section of the city that is primarily domestic sewage is treated at the Dry Creek
Wastewater Treatment Plant (DCWWTP) which has a capacity of 0.5 million gallons a day. The rest
of the city sewer drains, collects or is pumped to the Mebane Bridge Wastewater Treatment Plant
(MBWWTP), which can treat 13.5 million gallons per day.
The treatment plants have treated on average about 0.295 MGD at DCWWTP and 3.793
MGD at MBWWTP. This means that currently the Dry Creek plant operates at about one half of its
permitted capacity and the Mebane Bridge plant operates at less than one third. The plants are
nearly identical in their process design with their main difference only being in scale. Each of the
plants has mechanical barscreens to remove larger inert material. Each plant has a grit removal
system following the barscreening. Extended aeration using activated sludge is the next process at
each plant to reduce and remove biochemical oxygen demand. The sludge is separated from
treated water by circular clarifiers. Collected sludge or biosolids are wasted to the aerobic digesters
or returned to the aeration system. Treated water to the effluent leaves the clarifiers and is
disinfected with chlorine and then dechlorinated. The treated effluent is then returned to the Dan
River meeting all State Permit Discharge requirements.
Annual Performance Report
f -�71jj
G JUL
DENRir
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Page 1 of 3

II. Maintenance
Collection Svstem
The City of Eden completed the requirements for the Special Order of Consent and
requested to have the Order removed. The state approved this request in October 2009.
The City has Collection & Distribution field personnel to respond to emergencies in order to
maintain the sewer collection system. Their job is to repair broken lines, installation of new sewer
line, mow and maintain sewer outfall lines, and respond to, rectify and mitigate sewer bypasses.
Personnel are on call nights and weekends year round to respond to emergency problems in the
collection system. The City's 19 pump stations are monitored by (2) Collection & Distribution
Operators 24 hours per day, 7 days per week, by remote telemetry (Mission Communications) and
physically checked on normal workdays by Collection & Distribution personnel for proper operation.
Maintenance crews along with C&D personnel perform scheduled preventative maintenance on
each of these pump stations to protect the equipment and insure long life. An extensive warehouse
of supplies and parts are maintained to address emergency breakdowns and failures in the pump
stations and the sewer lines.
The following was accomplished during fiscal year 2009-2010:
A total of 37 Inflow & Infiltration problems were responded to and repaired.
A total of 194 laterals and sewer mains were responded to and unstopped.
A total of 14.55 miles (76,832') of sewer mains throughout the City of Eden were cleaned by
sewer jet or rodder and inspected by CCTV throughout the City of Eden.
Treatment Plants
Treatment Plant Operators are on duty 24 hours per day, 7 days per week, to insure proper
treatment of all incoming wastewater. They monitor plant equipment and do inspections during each
shift to insure process control and the mechanical operation of the equipment. Maintenance
personnel are available each day to service equipment and are on call nights and weekends for
emergency repairs, if the treatment equipment suffers failure. A large parts inventory is maintained
of the items that have historically been prone to failure.
III. Performance
Collection Svstem Operations
There were 35 events in the past 12 months where raw sewage was overflowed or bypassed
from the gravity collection system to surface waters. Gravity flow/Force Mains pipelines in the
collection system bypassed to surface waters totaled 6,970 gallons. Causes of these overflows
were blockages from grease, roots entering pipes at taps and pipe joints, and collapsed sewer force
mains.
Of our 19 pump stations; (7) pump stations had sanitary sewer overflows during the last 12
months in 16 separate events. They were as follows: Bridge Street (5) — 141,465 gallons, Covenant
Branch (9) — 197,241 gallons, Meadow Greens (4) — 115,492 gallons, New Street (2) — 6,412
gallons, Village(2) — 20,205 gallons, Dan River (1) — 32,619 gallons and Junction (1) 2,250 gallons.
The cause for these overflows were inflow and infiltration of storm water from extreme weather
conditions with storm events that deposited up to 10.71 inches of rain, some in conjunction with melt
from frozen precipitation already on the ground.
When overflows or bypasses occurred, the affected sites were evaluated, treated with
hydrated lime and/or receiving streams monitored for environmental impacts as conditions dictated.
Annual Performance Report Page 2 of 3

VFV
Treatment Plants Operations
Compliance with North Carolina NPDES (National Pollution Discharge Elimination System)
Permit is based on meeting discharge parameters set forth in the NPDES Permit. This information is
reported monthly to the North Carolina Department of Environment and Natural Resources through
self -monitoring reports. The following is a summary of our plant permit compliance for the last 12
months:
Reporting Month
Mebane Bridge Plant
Dry Creek Plant
July 2009
Compliant
Compliant
August 2009
Compliant
Compliant
September 2009
Compliant
Compliant
October 2009
Non -Compliant'
Compliant
November 2009
Compliant
Compliant
December 2009
Non -compliant'
Non -Compliant'
January 2010
Compliant
Compliant
February 2010
Compliant
Compliant
March 2010
Compliant
Compliant
April 2010
Compliant
Compliant
May 2010
Compliant
Compliant
June 2010
Compliant
*Compliant
' The Dry Creek WWTP was non -compliant for the month for violation of its permitted flow limit.
It exceeded its monthly limit of 0.5 MGD due to I & 1.
2 The Mebane Bridge WWTP was non -compliant for one day due to effluent pH being outside of
the limits of 6-9 SU.
3 The Mebane Bridge WWTP was non -compliant for the month for failure to collect and analyze
required monthly samples within the allowed timeframe.
*The Dry Creek permit was rescinded on June 14, 2010 and the facility was officially closed out.
IV. Notification
This report will be submitted to the State Division of Water Quality and be released to the local news
media and posted on the City's internet web site at www.ci.eden.nc.us.
V. Certification
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction of supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fines and imprisonment for knowing violation."
Brad
Signature of
Date
Annual Performance Report Page 3 of 3

Boone, Ron
From:
Boone, Ron
Sent:
Monday, June 14, 2010 7:32 AM
To:
Belnick, Tom
Cc:
Tedder, Steve
Subject:
Dry Creek WWTP, Eden, NC0025151
Tom,
WSRO received from Melinda Ward, Wastewater Superintendent for the City of Eden, a copy of the letter dated June 10,
2010, that she sent to you regarding the closure of the City of Eden's Dry Creek WWTP and the steps they've taken to do
so thus far with our guidance and approval. WSRO fully concurs with the letter and agree that the Division should
proceed with rescission of the permit for the Dry Creek plant. If you have any questions or concerns, don't hesitate to
give me a call. Thanks.
Ron
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Quality, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue, Governor Coleen H. Sullins, Director
June 14, 2010
Ms. Melinda Ward
Wastewater Superintendent
City of Eden
P.O. Box 70
Eden, N.C. 27289-0070
T
ED
E14R
2010
lem
Regional Office
Resources
Dee Freeman, Secretary
Subject: Rescission of NPDES Permit NCO025151
Dry Creek WWTP
Rockingham County
Dear Ms. Ward:
Division staff has confirmed that the subject permit is no longer required. Therefore, in
accordance with your request, NPDES Permit NCO025151 is rescinded, effective immediately.
If in the future your community wishes to discharge wastewater to the State's surface waters, you
must first apply for and receive a new NPDES permit. Discharge of wastewater without a valid
NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per day.
If you have questions about this matter, please contact Charles Weaver of my staff at the
telephone number or address listed below.
Since ely,
j/ Coleen H.
cc: Central Files
Winston-Salem Regional Office / Ron Boone
NPDES Permit file
Fran McPherson, DWQ Budget Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Internet: www.ncwaterquality.org
Phone: [phone] / FAX 919 807-M5
[e-mail]
i7 ' Y//z'UC
Sullins
NorthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

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N.C. Oeot. of ENR
JU 1 12010
ew& Regional Office
Depmhttent of &watoninerttd Smtkw
Wa6kwa&4 J wAtment J'&W
June 10, 2010
NPDES Supervisor
DENR-DWQ
Surface Water Protection
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Permit Rescission Request
Permit Number NCO025151
City of Eden — Dry Creek WWTP
Rockingham County
Dear Mr. Belnick,
When this permit was renewed on December 12, 2008, it was understood by all parties
that we planned to shut down this facility. We understood that any efforts to proceed
with this had to be completed before July 2010 or else we had to be compliant with a new
TRC limit. We have now begun our process of shutting down this facility. As of June 4,
2010, all flow has been stopped from leaving the effluent.
At 0815 on June 2nd, flow was diverted from the Dry Creek line using sand bags. Our
maintenance staff then attached a metal plate and gasket over one side of the pipe in the
splitter box to permanently block any flow from entering this line. They also sealed the
edges of the metal plate to make sure that all openings were closed. Next a crew from
our Collection and Distribution division removed a section of pipe leaving this box.
Finally, they filled the rest of the hole with brick and hydraulic cement to insure that this
line will be closed for good. At 2:00 that afternoon, it was observed that all flow had
ceased coming into the Dry Creek plant. On June 3rd and 4th, we emptied the clarifier by
pumping the water from the basin into the trough so that it would finish going through the
treatment process. There is only a small amount of water and solids left on the bottom of
the clarifier, so there is room in case of a significant rain event to keep any flow from
going out the effluent. We also had a Vacuum truck pull several loads from our digester
and a couple of loads from our aeration basin so that we would have room to prevent any
further flow from leaving the basins. This was all emptied out at one of our pump
stations to send the flow to our Mebane Bridge Plant. On June 8th, our maintenance staff
completed plugging the influent pipe with brick and hydraulic cement to insure that no
flow of any kind could enter the plant.
P. O. Box 70 • Eden, NC 27289-0070 • [phone] • Fax [phone]

IPW
All of these plans were reviewed by our Regional Office in Winston Salem before
proceeding. The remaining wastewater will be pulled out by Synagro next month and
hauled to our Mebane Bridge plant. We plan to work with our contacts in Winston Salem
to make sure that everything is removed to their satisfaction.
Due to these measures already taken, we feel that we have succeeded in deactivating the
Dry Creek plant. We are now requesting that you rescind this permit so that we can
proceed with this plant's closure. If there are further questions, feel free to contact me.
Sincerely,
A"- A 0"
Melinda Ward
Wastewater Superintendent
Cc: Steve Tedder, Winston Salem Regional Office
Brad Corcoran, City Manager
Dennis Asbury, Director of Environmental Services

Cover Sheet from
Staff Afember to
Regional Supervisor
DTN1R Review Record
Facility:�`�" `• Permit/Pipe No.: !1a 1\lonth/YearOA a
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
Weekly/Daily Violations
Date Parameter Permit Limitf rvne DN R Value °Io Over Limit
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Oth�Vi ation
Com eZdb yfug `Z Date:
Regional Water Quality
Supervisor Signoff: Date:

EFFLUENT
PERMIT NO. NCO025151 DISCHARGE NO. 001 MONTH December YEAR 2009
ACILITY NAME Dry Creek Wastewater Treatment Plant GRADE II COUNTY Rockingham
OPERATOR IN RESPONSIBLE CHARGE (ORC) Ralph Potter GRADE IV PHONE [phone] ext.103
CERTIFIED LABORATORIES (1) Mebane Bridge Wastewater Treatment Plant (2) Pace Analytical
CHECK BOX W ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES Operators -
Mail ORIGINAL and ONE COPY to: feat. O` ENQA
ATTN: CENTRAL FILESFES 1
DIV.OFENVIRONMENTALMANAGEMENT ELq X lz-�'
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DEHNR FEB 0 R
P.O BOX 29535
RALEIGH, NC 27626-0535
1 Q (SIGMA URE OF OPERATOR IN RESPONSIBLE CHARGE) I DA
BY THIS SIGNITURE, I CERTIFY THAT THE REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE
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0.564
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0.489
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200
240
240
DEM Form MR-1 (12/93)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
Compliant
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation,
maintenance, etc., and a time table for improvements to be made.
Estimated BOD Values: Influent & Effluent -12/8 - High GGA
Estimated BOD Values: Influent - 12/16 - DO usage <2mg/l for all dilution sets.
Estimated BOD Values: Influent & Effluent -12/30 - Do Depletion of dilution water blank exceeded 0.2
Monthly flow average was exceeded due to I & I from rain events and snow melt for the month.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Brad Corcor^ City Manager
Perviiee (PJA print or type)
- ( 11eq r, / � ;?- 4 (0
Signiture of Permittee*' 1 Date
City of Eden PO. Box 70 Eden, NC. 27289-0070 336-623-2110 4/30/2012
Permittee Address Phone Number Permit Exp. Date
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00092 Color (ADMI)
00095 Conductivity
00300 Dissolved Oxygen
00310 BODS
00340 COD
00400 pH
00530 Total Suspended
Residue
00545 Settleable Matter
00556 Oil & Grease
00600 Total Nitrogen
00610 Ammonia Nitrogen
00626 Total Kjeldhal
Nitrogen
00630 Nitrates/Nitrites
00666 Total Phosphorous
00720 Cyanide
00745 Total Sulfide
00927 Total Magnesium
00929 Total Sodium
00940 Total Chloride
PARAMETER CODES
00961 Total Fluoride 01067 Nickel
01002 Total Arsenic 01077 Silver
01092 Zinc
01027 Cadmium 01105 Aluminum
01032 Hexavalent Chromium
01147 Total Selenium
01034 Chromium
31616 Fecal Coliform
32730 Total Phenolics
01037 Total Colbalt
34235 Benzene
01042 Copper
34481 Toluene
38260 MBAS
01046 Iron
39616 PCBs
01051 Lead
50050 Flow
50060 Total
Residual
Chlorine
71880 Formaldehyde
71900 Mercury
81551 Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of signatory authority must be on file with the state per 16A NCAC 26 .0506 (b)

VCINAME-
PLITY
NC0025151
Influent
DISCHARGE NO: 001 MONTH: December YEAR: 2009
Dry
Creek Wastewater Treatment Plant COUNTY: Rockingham
i l• 1 1
1 1 1 1
1 1
1 1 1
1 1. 1
1 1 1 1
1 1 1
1 1 - 1
_______�
ENTER E• CODE ABOVEAND UNrrS 13ELOW
missing
DEM Form MR-2 (11 /84)

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RECEIVED
FEB 0 4 200
Information Processing Unit
DWQ/BOG

Permit NCO025151
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly.,.,Daily
Average
Maximum
Measurement
Frequency
Sample_,.
-Type'
Sample Location',
Flow
0.5 MGD
Continuous
Recording
Influent or Effluent
Total Residual Chlorine (TRC) 2
28 /ug/L
2/Week
Grab
Effluent
BOD, 5-day (202C) 3
30.0 mg/L
45.0 mg/L
Weekly
Composite
Effluent, Influent
Total Suspended Solids (TSS) 3
30.0 mg/L
45.0 mg/L
Weekly
Composite
Effluent, Influent
pH 4
Weekly
Grab
Effluent,
Downstream
Fecal Coliform
(geometric mean
200 / 100 ml
400 1100 ml
Weekly
Grab
Effluent
Temperature ('C)
Weekly
Grab
Effluent,
Downstream
Dissolved Oxygen (DO)
Weekly
Grab
Effluent,
Downstream
NH3 as N
2/Month
Composite
Effluent
Total Nitrogen (TN)
TN = NO2 + NOs + TKN
Quarterly
Composite
Effluent
Total Phosphorus TP
Quarterly
Composite
Effluent
Acute Toxicity 5
Quarterly
Composite
Effluent
Total Zinc
Monthly
Com osite
Effluent
Color 6
240 ADMI
Epsiodic
Grab
Effluent
Notes:
1. Sample locations: Downstream - Downstream at NCSR 1761 bridge.
2. The TRC compliance limit will become effective July 1, 2010. TRC monitoring shall continue.
Total Residual Chlorine compliance is required for chlorine or chlorine derivative used for
disinfection. The Division shall consider all effluent TRC values reported below 50 ug/1 to be
in compliance with the permit. However, the Permittee shall continue to record and submit
all values reported by a North Carolina certified laboratory (including field certified), even if
these values fall below 50 ug/l.
3. The monthly average BOD5 and TSS concentrations shall not exceed 15% of the respective
influent value (85% removal)
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Acute Toxicity (Fathead Minnow) P/F at 90%. Toxicity testing shall be performed in the
months of March, June, September and December (see Part A. (2.).
6. No colored effluent is to be discharged from this facility. Limit is an instantaneous maximum
(i.e. not to be exceeded at any time). Color monitoring shall be performed daily at times
when the Mebane Bridge WWTP overflow is diverted from the Railroad Pump Station to
the Dry Creek WWTP. Daily monitoring shall continue for 24 hours after flow is diverted
back to Mebane Bridge WWTP.
There shall be no discharge of floating solids or visible foam in other than trace
amounts.

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 03/10/10 Page: 1 of 1
PERMIT: FACILITY: COUNTY: REGION:
MONITORING OUTFALL/ VIOLATION UNIT OF CALCULATED
REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE % OVER LIMIT VIOLATION TYPE VIOLATION ACTION
41,00-111

Permit Enforcement History by Owner
03/10/10
1
Owner: City of Eden
Facility: Dry Creek VW TP
Permit: NCO025151
Region: Winston-Salem County: Rockingham
Penalty Remission Enf EMC EMC OAH Collection Has
Assessment Penalty Enforcement Request Enf Conf Remission Hearing Remission Remission Memo Sent Pmt Case
Case Number MR Approved Amount Costs Damages Received Held Amount Held Amount Amount to AGO Total Paid Balance Due Plan Closed
LV-2000-0195 06/02/00 $500 $73.00 $.00 $573.00 $.00 No 06/28/00
LV-2001-0219 06/20/01 $1,250 $46.00 $.00 $1,296.00 $.00 No 07/05/01
LV-2002-0134 05/15/02 $250 $99.00 $349.00 $.00 No 06/13/02
LV-2002-0318 08/16/02 $1,250 $99.00 $1,349.00 $.00 No 08/29/02
TX-2002-0033 10/15/02 $1,000 $24.24 $1,024.24 $.00 No 11/01/02
LV-2003-0568 5-2003 09/03/03 $1,250 $86.00 $1,336.00 $.00 No 09/16/03
LV-2003-0622 6-2003 09/22/03 $1,000 $86.00 $1,086.00 $.00 No 10/09/03
LV-2005-0064 11-2004 02/08/05 $1,350 $97.00 $1,447.00 $.00 No 02/28/05
Total Cases: 8 $610.24 $8,460.24 $.00
Total Penalties: $8,460.24 Total Penalties after remission(s): $8,460.24
D �
I,0

,�. !
4-1-
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
MELINDA S WARD
WASTEWATER SUPERINTENDENT
CITY OF EDEN
PO BOX 70
EDEN NC 27289-0070
Division of Water Quality
Coleen H. Sullins
Director
November 19, 2009
Subject: Acknowledgement of Permit Modification Request for NCO025151
City of Eden
Dry Creek WWTP
Rockingham County
Dear Ms. Ward:
Dee Freeman
Secretary
RECEIVED
N.C. Deot. of FNR
NOV 2 3 2009 i
Yr,ns;cn•3alem
Regional Office
The Division of Water Quality acknowledges receipt of your permit modification request and has assigned it to a
reviewer.
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To
ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a
timely and complete response to any additional information requests.
Please note at this time, processing permit applications can take as long as 60 — 90 days after receipt of a complete
application.
If you have any questions, please contact Bob Sledge at 919-807-6398, or via email at [e-mail]. If the
reviewer is unavailable, you may leave a message, and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
,f11c./1,CL
Dina Sprinkle
Cc: Central Files
Winston Salem Regional Office Surface Water Protection Section
Permit application file NCO025151
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 9I M07-64921 Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
NorthCarolina
Naturallrl
An Fanal Onnortunh 1,, Affirmative Antinn Fmnlover

Ceti`{ a^
N
eu�t of Edw NOV 1 LOUD
Depasctmn of bwiwnnrerrt Sexcdw
Wwkwcacten Jwabnent '9'CadENR. WATER QUALITY
POINT SOURCE BRANCH
November 12, 2009
NCDENR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attn.: Ron Barry
Subject: Modification of NPDES Permit
NPDES Permit #NC0025151
City of Eden Dry Creek WWTP
Rockingham County
Dear Mr. Barry,
This letter is a request for your office to rescind the 1.0 MGD Tiered Permit allowing for
expansion at our Dry Creek Wastewater facility. We are not planning an expansion
above the 0.5 MGD current plant flow and will be closing the plant by June 2010, so
there is no more need for this option. Since this option was placed in our permit, we have
stayed below the 0.5 MGD limit and should be considered a minor discharger.
If there is any further information required, please feel free to contact my office.
Sincerely,
Melinda S. Ward
Wastewater Superintendent
Cc: Ralph Potter, Pretreatment Coordinator/Chief Operator, City of Eden
Dennis Asbury, Director of Environmental Services, City of Eden
Brad Corcoran, City Manager, City of Eden
P. O. Box 70 • Eden, NC 27289-0070 9 [phone] • Fax [phone]

Sewer Collection Sy --tern Annual Perfor IV
City of Eden, North Carolin ci! ED
July 1, 2008 to June 30, 2009
' UG 2 7 2009
I. General Information
nn��^^II , WATER QUALITY
Facility/System Name:
City of Eden, Sewer Collection and Treap t Ks;tem
POINT SOURCE BRANCH
Responsible Entity:
City of Eden, Brad Corcoran, City Manager
Person in Charge/ Contact:
Collection System and Pump Stations, William Harvey, RECEIVED
.
N.0Beot of ENR
Operator -in -Responsible Charge, 336-627-7783
Mebane Bridge Wastewater Treatment Plant, Melinda S. ard,SEP 14 20
Operator -in -Responsible Charge, 336-627-1009
D Creek Wastewater Treatment Plant, Ralph Potter, Winston-Salem
Dry P Regional office
Operator -in -Responsible Charge, 336-627-1009
Applicable Permits: Sewer Collection System — WQC200018
Mebane Bridge Wastewater Treatment Plant — NPDES Permit NCO025071
Dry Creek Wastewater Treatment Plant — NPDES Permit NCO025151
Land Application of Wastewater Residuals — NC Permit WQ0003035
Description of Collection and Treatment Process:
The collection system consists of 145+ miles of gravity and force main sewer pipelines. The
pipelines are composed of a mixture of clay and ductile iron pipe, ranging in size from 2 to 36 inches.
Age of the sewer pipelines range from new to more than 50 years old. Collection is accomplished by
gravity from homes and businesses until it is necessary to pump from low elevations in force main
sewer lines that transport the sewage to the treatment plants. There are 19 pump stations in the
collection system. These range in size from pumping a few thousand gallons per day to more than
five million gallons a day (MGD). The City has two separate collection drainage areas. The
Northeast section of the city that is primarily domestic sewage is treated at the Dry Creek
Wastewater Treatment Plant (DCWWTP) which has a capacity of 0.5 million gallons a day. The rest
of the city sewer drains, collects or is pumped to the Mebane Bridge Wastewater Treatment Plant
(MBWWTP), which can treat 13.5 million gallons per day.
The treatment plants have treated on average about 0.256 MGD at DCWWTP and 5.161
MGD at MBWWTP. This means that currently the Dry Creek plant operates at about one half of its
permitted capacity and the Mebane Bridge plant operates at less than half. The plants are nearly
identical in their process design with their main difference only being in scale. Each of the plants
has mechanical barscreens to remove larger inert material. Each plant has a grit removal system
following the barscreening. Extended aeration using activated sludge is the next process at each
plant to reduce and remove biochemical oxygen demand. The sludge is separated from treated
water by circular clarifiers. Collected sludge or biosolids are wasted to the aerobic digesters or
returned to the aeration system. Treated water to the effluent leaves the clarifiers and is disinfected
with chlorine and then dechlorinated. The treated effluent is then returned to the Dan River meeting
all State Permit Discharge requirements.
Annual Performance Report Page 1 of 3

IF,,. Maintenance
Collection System
The City of Eden is presently under a Special Order of Consent and has met all requirements
on time to date.
The City has Collection & Distribution field personnel to respond to emergencies in order to
maintain the sewer collection system. Their job is to repair broken lines, installation of new sewer
line, mow and maintain sewer outfall lines, and respond to, rectify and mitigate sewer bypasses.
Personnel are on call nights and weekends year round to respond to emergency problems in the
collection system. The City's 19 pump stations are monitored by (2) Collection & Distribution
Operators 24 hours per day, 7 days per week, by remote telemetry (Mission Communications) and
physically checked on normal workdays by Collection & Distribution personnel for proper operation.
Maintenance crews along with C&D personnel perform scheduled preventative maintenance on
each of these pump stations to protect the equipment and insure long life. An extensive warehouse
of supplies and parts are maintained to address emergency breakdowns and failures in the pump
stations and the sewer lines.
The following was accomplished during fiscal year 2008-2009:
A total of 79 Inflow & Infiltration problems were responded to and repaired.
A total of 213 laterals and sewer mains were responded to and unstopped.
A total of 18.46 miles (97,466') of sewer mains throughout the City of Eden were either
CCTV & or Rodded throughout the City of Eden.
Treatment Plants
Treatment Plant Operators are on duty 24 hours per day, 7 days per week, to insure proper
treatment of all incoming wastewater. They monitor plant equipment and do inspections during each
shift to insure process control and the mechanical operation of the equipment. Maintenance
personnel are available each day to service equipment and are on call nights and weekends for
emergency repairs, if the treatment equipment suffers failure. A large parts inventory is maintained
of the items that have historically been prone to failure.
III. Performance
Collection Svstem Operations
There were 20 events in the past 12 months where raw sewage was overflowed or bypassed
from the gravity collection system to surface waters. Gravity flow/Force Mains pipelines in the
collection system bypassed to surface waters totaled 7,411 gallons. Causes of these bypasses
were blockages from grease, roots entering pipes at taps and pipe joints, and vandalism where
rocks, sticks, boards and other debris were placed in manholes.
Of our 19 pump stations; (4) pump stations had bypassing during the last 12 months in 16
separate events. They were as follows: Bridge Street (4) — 39,796 gallons, Covenant Branch (6) —
125,881 gallons, Meadow Greens (4) — Railroad (2) 1,224 gallons.
When overflows or bypasses occurred, the affected sites were evaluated, disinfected or
receiving streams monitored for environmental impacts as conditions dictated.
Annual Performance Report Page 2 of 3

IF
Treatment Plants Operations
Compliance with North Carolina NPDES (National Pollution Discharge Elimination System)
Permit is based on meeting discharge parameters set forth in the NPDES Permit. This information is
reported monthly to the North Carolina Department of Environment and Natural Resources through
self -monitoring reports. The following is a summary of our plant permit compliance for the last 12
months:
Reporting Month
Mebane Bridge Plant
Dry Creek Plant
July 2008
Compliant
Compliant
August 2008
Compliant
Compliant
September 2008
Compliant
Compliant
October 2008
Compliant
Compliant
November 2008
Compliant
Non -Compliant'
December 2008
Complian?
Non-Complian?
January 2009
Compliant
Compliant
February 2009
Compliant
Compliant
March 2009
Compliant
Compliant
April 2009
Compliant
Compliant
May 2009
Compliant
Compliant
June 2009
Compliant
Compliant
' The Dry Creek WWTP was non -compliant for the week for violation of its permitted fecal
coliform limit.
2 The Dry Creek WWTP was non -compliant for the month for failure to collect and analyze
required quarterly samples within the allowed timeframe.
3 The Mebane Bridge WWTP met all limits, but failed to achieve 85% removal of Total
Suspended Solids.
IV. Notification
This report will be submitted to the State Division of Water Quality and be released to the local news
media and posted on the City's intemet web site at www.ci.eden.nc.us.
V. Certification
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction of supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fines and imprisonment for knowing violation."
Brad Co ran
Signature of City Manager
If arLe
Date
Annual Performance Report Page 3 of 3

Q
NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue, Governor Coleen H. Sullins, Director
William N. Parke
166 Forestdale Drive
Reidsville, NC
Dear Permittee:
27320-8733
September 15, 2009
RECEIVED
N.C. Deot. of E N R
Sp 17 2009
wi"ton-salem
Natural Resource®ionalOffice
Dee Freeman, Secretary
Subject: Renewal of coverage ! General Permit NCG550000
166 Forestdale Drive
Certificate of Coverage NCG550200
Rockingham County
In accordance with your renewal application [received on September 15, 20091, the Division is
renewing Certificate of Coverage (CoC) NCG550200 to discharge under NCG550000. This CoC is issued
pursuant to the requirements of North Carolina General Statue 143-215.1 and the Memorandum of
Agreement between North Carolina and the US Environmental Protection agency dated October 15, 2007 [or
as subsequently amended].
If any parts, measurement frequencies or sampling requirements contained in this General Permit
are unacceptable to you, you have the right to request an individual permit by submitting an individual
permit application. Unless such demand is made, the certificate of coverage shall be final and binding.
Please take notice that this Certificate of Coverage is not transferable except after notice to the
Division. The Division may require modification or revocation and reissuance of the certificate of coverage.
Contact the Winston. -Salem Regional Office prior to any sale or transfer of the permitted facility.
Regional Office staff will assist you in documenting the transfer of this CoC.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning the requirements of the General Permit, please contact Charles
Weaver of the NPDES staff [919 807-6391 or [e-mail]].
Sincerely,
Jo�leen H. Sullins
cc: Central Files
Winston-Salem Regional Office / Surface Water Protection
NPDES file
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604 -
Phone: [phone] / FAX [phone] / Internet: www.ncwaterquality.org
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Nne
orthCarolina
;Vatarallff

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NCG550000
CERTIFICATE OF COVERAGE NCG550200
DISCHARGE OF DOMESTIC WASTEWATER FROM SINGLE FAMILY RESIDENCES AND
OTHER 100% DOMESTIC DISCHARGES WITH SIMILAR CHARACTERISTICS 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,
William N. Parks
is hereby authorized to discharge domestic wastewater [450 GPD] from a facility located at
166 Forestdale Drive
Reidsville
Rockingham County
to receiving waters designated as an unnamed tributary to Town Creek, a class C stream in
subbasin 03-02-03 of the Roanoke River Basin in accordance with the effluent limitations,
monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This certificate of coverage shall become effective September 15, 2009.
This Certificate of Coverage shall expire on July 31, 2012.
Signed this day September 15, 2009
for ieen Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

a �5A
�di
NCDENR
North Carolina Department of Environment and Natura
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
September 21, 2009
Ms. Julie Haigler Cubeta, Program Director
NC Rural Economic Development Center
4021 Carya Drive
Raleigh, North Carolina 27610
RE: City of Eden
Dry Creek Wastewater Treatment Plant
NPDES Permit NCO025151
Rockingham County
Dear Mrs. Cubeta:
Resources
Dee Freeman
Secretary
This letter is to provide information regarding the City of Eden's Dry Creek
Wastewater Treatment Plant (WWTP). This facility was reissued its NPDES
permit from NCDENR on December 12, 2008. The new permit included a major
change from the previous NPDES permit with regard to total residual chlorine
(TCR) limits. This limit goes into effect on July 10, 2010. The City must either
make major modifications to its WWTP in order to meet this new limit or it must
cease discharge from the facility.
Given the costs associated with the plant modifications, the City has elected to
cease the operation of the Dry Creek facility. NCDENR supports this action by
the City in order to comply with the new NPDES permit. We believe that this is
the most cost-effective and efficient option and will also serve to reduce the
number of point source discharges into the waters of the state.
Please feel free to contact me at (336-771-4950) if you should have any
questions or need additional information.
Sinc rely,
Steve W. Tedder
Water Quality Supervisor
cc: Brad Corcoran, Manager - City of Eden
Mark Fisher, PE — WK Dickson & Co., Inc.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
One
NorthCarohna
An Equal Opportunity 1 Affirmative Action Employer

9A
NCDENR
North Carolina Department of Environment and Natura
Beverly Eaves Perdue
Governor
Mr. Brad Corcoran, City Manager
City of Eden
308 East Stadium Dr.
Eden, NC 27288
Dear Mr. Corcoran:
Division of Water Quality
Coleen H. Sullins
Director
June 18, 2009
RECEIVED
N.C. Deot. of ENR
JUN 2 6 2W9
Winston-Salem
Regional Office
Resources- -
Dee Freeman
Secretary
SUBJECT: City of Eden
Dry Creek Phase 1 / Smith River Phase 1
Approval of Addendum No. 1
Project No. 2W370458-03
Reference is made to Addendum No. 1, received June 18, 2009, from the engineer for
revisions to the subject project.
The proposed addendum, as described in the attachment, has been reviewed by this
office, and is hereby approved, and eligible for funding in accordance with the loan offer and
conditions thereof.
The approval of this addendum does not constitute any change in the amount of your loan
for this project.
It is the responsibility of the recipient and the consulting engineer to insure that the
project plan documents are in compliance with Amended N.C.G.S. 133-3 (ratified July 13,
1993). The administrative review and approval of addenda do not imply approval of a restrictive
specification for bidding purposes; nor is it an authorization for noncompetitive procurement
actions.
Adequate time must be allowed for the potential bidders and this office to receive and act
on addenda prior to the receipt of bids for subject project.
A copy of the approved addendum is attached for your files, and one (1) copy retained for
our files.
1633 Mail Service Center, Raleigh, North Carolina 27699-1633
Location: 2728 Capital Blvd. Raleigh, North Carolina 27604 One
NorthCarolina
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www.nnity k Affirmative
Action
NatimallyAn Equal Opportunity 1 Affirmative Action Employer

Mr. Brad Corcoran
Page 2
June 18, 2009
Should you have any questions regarding this matter, please do not hesitate to contact
Michelle McKay, E.I. at [phone].
Sincerely,
Seth Robertson, P.E., Supervisor
Design Management Unit
Construction Grants & Loans Section
MM/sr
cc: Mark Fisher, P.E., WK Dickson & Co., Inc.
DWQ Winston-Salem Regional Office
Mark Hubbard, P.E.
Michelle McKay, E.I.
SRF

A�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
13 February 2009
Mr. Dennis Asbury, Director of Public Utilities
City of Eden
P.O. Box 70
Eden, NC 27289-0070
SUBJECT: Notice of Violation - NOV-2009-LV-0050
Dry Creek Wastewater Treatment Plant
NPDES Permit NCO025151
Rockingham County
Dear Mr. Asbury:
Dee Freeman
Secretary
A review of the November 2008 discharge monitoring report (DMR) for the Dry Creek
Wastewater Treatment Plant revealed the following violations:
Parameter
Date
Limit
Reported
Limit Type
Remarks
Value
Value
Fecal
11/08/2008
400/100
600/100 ml
Weekly
None
Coliform
ml
Geometric
Mean
2. Remedial actions, if not already implemented, should be taken to correct the above
noncompliance problems. Please be aware that violations of your NPDES permit could
result in enforcement action by the Division of Water Quality for this and any additional
violations of State law. If you should have any questions, please do not hesitate to
contact Ron Boone at [phone].
Since ely,
Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
CC: Central Files
NPDES West Unit
(Nsi�lSw? F;Ios
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterqual4.org
An Equal Opportunity 1 Affirmative Action Employer
Nne
orthCarofina
Naturally

Cover Sheet from
Staff Member to
Regional Supervisor
DMR Review Record
Facility: o zei mJ77 Permit/Pipe No.: 2,515 / n"l Month/Year
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value % Over Limit
41D
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Other Violations
_fir,22t AU//..'r A -it . /G /hfl1N.✓h..S �/�Q-Vt. r//c-( r�'l lia�r�� (✓Gr/Yl r'�ryyii�.r V7G/����.5' r�'t cd��'1 f,
Completed by: i
Regional Water Quality
Super\risor Sisnoff:
Nol/
Date: 62-/ 2- rrq
Date: % -- 13 —tl 5
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O�O W A T �9QG
o �c
Mr. Brad Corcoran, City Manager
City of Eden
308 East Stadium Drive
Eden, NC 27288
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
26 November 2008
Coleen H. Sullins, Director
Division of Water Quality
Subject: Compliance Evaluation Inspection
NPDES Permit NC0025071, Mebane Bridge Wastewater Treatment Plant &
NPDES Permit NC0025151, Dry Creek Wastewater Treatment Plant
Rockingham County
Dear Mr. Corcoran:
1. On 21 November 2008, Mr. Ron Boone of the Winston-Salem Regional Office of the
Division of Water Quality (DWQ) conducted compliance evaluation inspections (CEI) of
the City of Eden's Mebane Bridge Wastewater Treatment Plant (WWTP) located at 191
Mebane Bridge Road and the Dry Creek WWTP located on NC Hwy 770 east, in Eden,
Rockingham County, North Carolina. The assistance and cooperation of Ms. Melinda
Ward, Operator in Responsible Charge (ORC) of the Mebane Bridge facility, and Mr.
Ralph.Potter, ORC of the Dry Creek Facility, was greatly appreciated. Inspection findings
are summarized below and inspection reports are attached for your records.
Mebane Bridge Wastewater Treatment Plant, NCO025071
2. The Mebane Bridge WWTP discharges into receiving waters known as the Dan River,
this section of which is currently classified as a WS-IV (water supply) water in the
Roanoke River basin. The plant consists of an influent flow meter, bar screens, grit
separator, extended aeration basins, secondary clarifiers, gas chlorination, liquid sodium
bisulfite dechlorination, polymer addition, aerobic digestion, sludge lagoons, and a
dissolved air floatation unit, which is no longer in use. There is also an effluent flow
meter. The influent meter is used for reporting flow.
Documentation Review
3. This permit is currently expired and under review by the Division. The initial draft was
issued and we have received the city's comments on the draft. A second draft should
soon be issued for comment and approval. Please note that the 'conditions of the
previous permit, effective 1 September 2002, with a major modification that became
effective 1 August 2005, remain in full effect until the new permit is issued.
4. Mr. Boone evaluated laboratory data and all required records were available and
complete. Comparison of lab reports with discharge monitoring reports (DMR) revealed
no transcription errors. Chains of custody were also complete. All lab records were well
organized. The plant lab's certification for field laboratory tests is current and expires on
North Carolina Division of Water Quality 585 Waughtown Street; Winston-Salem, NC 27107 Phone [phone] N rthCarolina
Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org Fax [phone] atura!!y
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/] 0% Post Consumer Paper

Mr. Brad Corcoran
26 November 2008
Page 2 of 4
31 December 2008. The only discrepancy noted was the incorrect reporting of data for
several required parameters, including BOD5, TSS and ammonia. The values for these
parameters are currently being rounded and reported to the nearest milligram, however
the permit requires these parameters to be reported down to the nearest tenth of a
milligram. Discussion with Ms. Ward revealed a simple electronic formatting error in the
spreadsheet that automatically rounds the entered values to the nearest milligram. Ms.
Ward stated that she would have this corrected immediately.
4. Ms. Ward has daily sign -in logs that are complete and current. Records of plant
operations and maintenance were also available, complete and current. All records aside
from laboratory records must be maintained for a period of three years.
Site Review
5. Several of the floating rotor aerators were out of service for maintenance during the
inspection. Ms. Ward stated that they were still able to sustain sufficient dissolved
oxygen levels in the basins without the aerators. There were no other indicators of
insufficient aeration noted. The basins did appear to have some mild dead spots, most
likely due to the out -of -service rotors, but again, this doesn't appear to be adversely
affecting plant efficiency.
6. The perimeter scum baffles on the secondary clarifiers were severely corroded and in
need of replacement. The corrosion has completely eaten through the baffles at water
level and the upper halves are completely separated from the lower halves over a large
percentage of their overall linear footage. Ms. Ward stated that she is currently in the
process of gathering quotes from several contractors for baffle replacement. Scum
entrapment and removal doesn't appear to have become an issue despite the poor
condition of the baffles.
7. The chemical feed lines for the sodium bisulfite are installed above ground and are
supported by five -gallon buckets. Although this hasn't caused any problems, the city
should strongly consider a more permanent installation of these lines. Ms. Ward
indicated that the previous underground installation of the chemical feed lines resulted in
frequent breakage of the pipes and that eventually operators decided to install the pipes
aboveground. The lines should be better supported with a more permanent and reliable
type of support system.
8. The NCG110000 general stormwater permit covers wastewater treatment plants with an
average daily flow of more than 1 million gallons per day, however the plant currently
does not have an NCG110000 permit. The city must immediately submit a Notice of
Intent (NOI) for the NCG110000 permit. Please use the following link to navigate to the
Division's web page where the NOI can be downloaded and printed.
http://h2o.enr.state.nc.us/su/Forms Documents htm
11

r. Brad Corcoran
F
6November 2008
age 3 of 4
Dry Creek Wastewater Treatment Plant, NC0025151
9. The Dry Creek WWTP also discharges into receiving waters known as the Dan River, this
section of which is currently classified as a WS-IV (water supply) water in the Roanoke
River basin. The plant consists of an influent pump station, influent flow meter, bar
screen, grit separator, extended aeration basin, secondary clarifier, tablet chlorinator,
effluent flow meter and an aerobic digester.
10. According to Mr. Potter, the city plans to shut down and decommission this plant,
permanently diverting all flow through the Railroad pump station to the Mebane Bridge
plant. The city is highly encouraged to make this a priority to eliminate the discharge and
permit. Please note that in order for this to occur, all plant units will need to be
completely drained and all plant wastes completely removed and properly disposed.
Also, the influent and effluent lines will need to be permanently capped or plugged, so as
to prevent all inflow and any further accumulation of waste in the plant. Mr. Boone will
need to perform another inspection of the facility to verify that is has been properly and
permanently shutdown and isolated prior to permit rescission.
Documentation Review
11. This permit is currently expired and under review by the Division. The initial draft was
issued and we have received the city's comments on the draft. Please note that the
conditions of the previous permit, effective 1 June 2002, remain in full effect until the new
permit is issued.
12. Mr. Boone evaluated laboratory data and all required records were available and
complete. Comparison of lab reports with discharge monitoring reports (DMR) revealed
no transcription errors. Chains of custody were also complete. All lab records were well
organized. The plant lab's certification for field laboratory tests is current and expires on
31 December 2008. The only discrepancy noted was the incorrect reporting of data for
several required parameters, including BOD5, TSS and ammonia. The values for these
parameters are currently being rounded and reported to the nearest milligram, however
the permit requires these parameters to be reported down to the nearest tenth of a
milligram. Discussion with Mr. Potter revealed a simple electronic formatting error in the
spreadsheet that automatically rounds the entered values to the nearest milligram. Mr.
Potter stated that he would have this corrected immediately.
13. Mr. Potter has daily sign -in logs that are complete and current. Records of plant
operations and maintenance were also available, complete and current. All records aside
from laboratory records must be maintained for a period of three years.
Site Review
14. The plant appears to be well maintained, although some of the equipment, such as the
samplers and chlorination system, were somewhat dilapidated and/or outdated. Despite
this, the equipment still appears to be fully functional. The Division recognizes that this is
in part due to the impending closure of the facility and the reluctance to expend capital

Mr. Brad Corcoran
26 November 2008
Page 4 of 4
assets at the facility. At the same time we must convey to the city the importance of
maintaining all plant equipment in the best condition at all times. This should underscore
the value of decommissioning the Dry Creek plant and diverting flow to the Mebane
Bridge plant as soon as possible.
15. Please submit to the Division the NOI for the NCG110000 general stormwater permit for
the Mebane Bridge plant as soon as possible. When submitting the NOI to the Division's
central office in Raleigh, please also send a courtesy copy to this office so we're aware of
your submittal. If you have any questions regarding the inspection or this letter, please
do not hesitate to contact Mr. Boone or me at [phone].
Sincerely,
Steve W. Tedder
Water Quality Regional Supervisor
Winston-Salem Region
Division of Water Quality
Attachments:
1. BIMS Inspection Report NC0025071, Mebane Bridge WWTP
2. BIMS Inspection Report NC0025151, Dry Creek WWTP
cc: 1WSRO — SWP w/ atch'
Central Files w/ atch
NPDES West Unit
11

United States Environmental Protection Agency
EPA Washington, D.C. 20460 Form Approved.
OMB No. 2040-0057
Water Com liance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 INI 2 Is L
3) NCO025071 I11 12I 08/11/21 117 18tCI 191Gt 20I I
LJ
21IIIIIIIIIIIIIIIIIIIIIIIRemarks
L U IIII111111111111111111116E
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 OA --------------------------- Reserved ----------------------
67 69 70u 71 U 72 —I . 73L -- 74 75I I I I I I I 180
Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number)
Mebane Bridge WWTP
191 Mebane Bridge Rd
Eden NC 27288
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Ralph H Potter/ORC/336-627-1009/
08:30 AM 08/11/21 05/08/01
Exit Time/Date Permit Expiration
10:30 AM 08/11/21 07/04/30
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Dennis G Asbury,308 E Stadium Dr Eden NC Contacted
27288/Director/336-627-2110/3366233933 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit N Flow Measurement 0 Operations & Maintenance Records/Reports
Self -Monitoring Program N Sludge Handling Disposal . Facility Site Review Effluent/Receiving Waters
Laboratory 0 Storm Water
al sheets of narrative and checklists
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone WSRO WQ//704-663-1699 Ext.2202/
Signature of Management Q A Reviewer
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Agency/Office/Phone and Fax Numbers
Date
/i/5.41V
Page # 1

NPDES yr/mo/day Inspection Type 11
3L NCO025071 I11 12I 08/11/21 I17 18�
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please refer to inspection summary letter.
Page # 2

Permit: NCO025071
Inspection Date: 11/21/2008
Owner - Facility: Mebane Bridge WWTP
Inspection Type: Compliance Evaluation
Laboratory
Yes
No
NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
❑
❑
❑
# Is the facility using a contract lab?
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
0
❑
N
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
f1
❑
m
❑
Comment: Plant field certification expires 12/31/08. Pace Analytical lab is used for
non -field parameters.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
❑
❑
Is the chain -of -custody complete?
❑ ❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
0❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
■
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
■
❑
❑
❑
Is the ORC visitation log available and current?
0
n
Cl
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
0
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
Cl
❑
❑
Is a copy of the current NPDES permit available on site?
E
0
❑
❑
Facility has copy of previous year's Annual Report on file for review?
0❑
❑
❑
Comment:
Permit
Page # 3

Permit: NCO025071
Inspection Date: 11/21/2008
Owner - Facility: Mebane Bridge WWTP
Inspection Type: Compliance Evaluation
11
Permit
Yes
No
NA NE
(if the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
❑
❑
❑
Is the facility as described in the permit?
■
❑
❑
❑
# Are there any special conditions for the permit?
❑
■
❑
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment:
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is sampling performed according to the permit?
■
❑
❑
❑
Comment:
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational?
■
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment: Meters calibrated quarterly. No flow recorder, only a flow totalizer.
gar Screens
Yes No
NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
■
Are the bars adequately screening debris?
■
❑
❑
❑
Is the screen free of excessive debris?
■
❑
❑
❑
Is disposal of screening in compliance?
■
❑
❑
❑
Is the unit in good condition?
■
❑
❑
❑
Comment:
Page # 4

Permit: NCO025071
Inspection Date: 11/21/2008
Owner - Facility: Mebane Bridge WWTP
Inspection Type: Compliance Evaluation
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
❑
b.Mechanical
■
Is the grit free of excessive organic matter?
■ ❑ ❑
❑
Is the grit free of excessive odor?
■ ❑ ❑
❑
# Is disposal of grit in compliance?
■ ❑ ❑
0
Comment:
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
■ ❑ ❑
❑
Are surface aerators and mixers operational?
■ ❑ ❑
❑
Are the diffusers operational?
n ❑ ■
❑
Is the foam the proper color for the treatment process?
■ ❑ ❑
Cl
Does the foam cover less than 25% of the basin's surface?
■ ❑ ❑
❑
Is the DO level acceptable?
❑ ❑ ❑
■
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑ ❑
■
Comment: Some of the floating rotor aerators were out of service during the
inspection but the ORC stated this is not detrimentally affecting their ability to maintain
the DO level.
Secondary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the return rate acceptable (low turbulence)?
■
❑
❑
❑
Page # 5

Permit: NCO025071
Inspection Date: 11/21/2008
Owner - Facility: Mebane Bridge WWTP
Inspection Type: Compliance Evaluation
�I
Secondary Clarifier Yes No NA NE
Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately 1/. of the sidewall depth) ■ ❑ ❑ ❑
Comment: Perimeter baffles were severely corroded to the point of separation at
water surface level. ORC stated this is not detrimentally affecting operations and that
she is currently in the process of gathering contractor quotes for the replacement of the
baffles.
Pumps-RAS-WAS Yes No NA NE
Are pumps in place? ■ n ❑ ❑
Are pumps operational? ■ ❑ ❑ ❑
Are there adequate spare parts and supplies on site? ■ ❑ ❑ f1
Comment:
Disinfection -Gas
Yes
No
NA NE
Are cylinders secured adequately?
■
❑
❑
❑
Are cylinders protected from direct sunlight?
■
❑
❑
❑
Is there adequate reserve supply of disinfectant?
■
❑
fl
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
■
Is the contact chamber free of growth, or sludge buildup?
■
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
n
❑
o
■
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
❑
■
❑
If yes, then is there a Risk Management Plan on site?
❑
❑
■
❑
If yes, then what is the EPA twelve digit ID Number? (1000
If yes, then when was the RMP last updated?
Comment:
De -chlorination Yes No NA NE
Type of system ? Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ ■
Is storage appropriate for cylinders? n ❑ ■ ❑
# Is de -chlorination substance stored away from chlorine containers? ■ ❑ ❑ ❑
Comment:
Are the tablets the proper size and type? n ❑ ■ ❑
Are tablet de -chlorinators operational? ❑ ❑ ■ n
Page # 6

Permit: NCO025071 Owner - Facility: Mebane Bridge WWTP
Inspection Date: 11/21/2008 Inspection Type: Compliance Evaluation
Aerobic Digester Yes No NA NE
Comment: Northern wall of digester failed some time back and was repaired. Eastern
wall of digester appears to be experiencing some of the same issues; walls are
beginning to buckle slightly at seams in concrete. City needs to monitor this closely to
detect and prepare for failure.
Drying Beds
Yes No NA NE
Is there adequate drying bed space?
E ❑ ❑ ❑
Is the sludge distribution on drying beds appropriate?
❑ ❑ 0 ❑
Are the drying beds free of vegetation?
❑ ❑ ❑
# Is the site free of dry sludge remaining in beds?
❑ ❑ ❑
Is the site free of stockpiled sludge?
❑ ❑ ❑
Is the filtrate from sludge drying beds returned to the front of the plant?
❑ ❑ ❑
# Is the sludge disposed of through county landfill?
❑ 0 ❑ ❑
# Is the sludge land applied?
❑ 0 ❑
(Vacuum filters) Is polymer mixing adequate?
0 ❑ ❑ ❑
Comment: Drying beds used only to dry grit and bar screenings before being
disposed. Beds not used for sludge.
Standby Power
Yes No NA NE
Is automatically activated standby power available?
0 ❑ ❑ ❑
Is the'generator tested by interrupting primary power source?
a 0 iJ' ❑
Is the generator tested under load?
0 ❑ ❑ ❑
Was generator tested & operational during the inspection?
fl E ❑ ❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
■ ❑ ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑ ❑ ❑ E
Is the generator fuel level monitored?
0 ❑ ❑ ❑
Comment:
Operations & Maintenance
Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
E ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge
Judge, and other that are applicable?
■ ❑ ❑ ❑
Comment:
Page # 8

United States Environmental Protection Agency
EPA Washington, D.C. 20460 Form Approved.
OMB No. 2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N L 2 ICI 3I NCO025151 111 121 08/11/21 117 18I C 19I SI 20IU
J U ern arks J L
21111111111111 II11111111R11 IIII IIII Jill 1111 1111 1116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 QA --------------------------- Reserved ----------------------
67 69 70 U 71 U 72 U N) 73 L I 174 751 I I I I I Li 80
Section B: Facility Data u W
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Dry Creek WWTP
11:00 AM 08/11/21 02/06/01
NC Hwy 770 E Exit Time/Date Permit Expiration Date
Eden NC 27288 01:00 PM 08/11/21 07/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Ralph H Potter/ORC/336-627-1009/
Name, Address of Responsible OfficialfTitle/Phone and Fax Number
Dennis G Asbury,308 E Stadium Dr Eden NC Contacted
27288/Director/336-627=2110/3366233933 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement 0 Operations & Maintenance Records/Reports
Self -Monitoring Program . Sludge Handling Disposal ■ Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Find in /Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone WSRO WQ//704-663-1699 Ext.2202/
Signature of Managerner A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

FF
NPDES yr/mo/day Inspection Type 1
31
NC0025151 I11 12I 08/11/21 I17 181_'
Section D: Summary of 1Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please refer to inspection summary letter.
Page # 2

Permit: NCO025151
Inspection Date: 11/21/2008
Owner - Facility: Dry Creek WWTP
Inspection Type: Compliance Evaluation
11
Record Keeping
Yes
No NA
NE
Are records kept and maintained as required by the permit?
■
❑ ❑
n
Is all required information readily available, complete and current?
■
n ❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n ❑
❑
Are analytical results consistent with data reported on DMRs?
■
❑ ❑
❑
Is the chain -of -custody complete?
■
❑ ❑
0
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Resultsbf analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
■
❑
n
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
■
n
n
Is the ORC visitation log available and current?
■
n
n
0
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
❑
❑
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
■
❑
❑
n
Comment:
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
n
n
Are all other parameters(excluding field parameters) performed by a certified lab?
■
n
n
❑
# Is the facility using a contract lab?
■
0
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
■
n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
■
n
Comment:
Permit
V..
u
us
uC
Page # 3

Permit: NC0025151
Inspection Date: 11/21/2008
Owner - Facility: Dry Creek WWTP
Inspection Type: Compliance Evaluation
Permit
Yes
No
NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
❑
❑ ❑
Is the facility as described in the permit?
■
❑
❑ ❑
# Are there any special conditions for the permit?
n
■
❑ ❑
Is access to the plant site restricted to the general public?
■
❑
❑ ❑
Is the inspector granted access to all areas for inspection?
■
❑
❑ ❑
Comment:
Pump Station - Influent
Yes
No NA NE
Is the pump wet well free of bypass lines or structures?
■
❑ ❑
❑
Is the wet well free of excessive grease?
■
❑ ❑
❑
Are all pumps present?
■
❑ ❑
❑
Are all pumps operable?
■
❑ ❑
n
Are float controls operable?
■
0 ❑
❑
Is SCADA telemetry available and operational?
■
❑ ❑
❑
Is audible and visual alarm available and operational?
■
❑ ❑
n
Comment:
Influent Sampling
Yes
No
NA NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
■
❑
❑
0
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is sampling performed according to the permit?
■
❑
❑
❑
Comment:
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
0
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational?
■
Cl
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment: Meters calibrated quarterly. No flow recorder, only a flow totalizer.
Bar Screens
Yes Nn
NA
NF
Page # 4

Permit: NCO025151
Inspection Date: 11/21/2008
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Owner - Facility: Dry Creek WWTP
Inspection Type: Compliance Evaluation
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Comment:
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Yes No NA NE
Yes No NA NE
Ext. Air
■❑❑❑
■ ❑ ❑ ❑
Page # 5
11

Permit: NC0025151
Inspection Date: 11/21/2008
Owner - Facility: Dry Creek WWTP
Inspection Type: Compliance Evaluation
Secondary Clarifier
Yes No NA NE
Are weirs level?
■ ❑ ❑ ❑
Is the site free of weir blockage?
■ ❑ ❑ ❑
Is the site free of evidence of short-circuiting?
■ ❑ ❑ ❑
Is scum removal adequate?
■ ❑ ❑ ❑
Is the site free of excessive floating sludge?
■ ❑ ❑ ❑
Is the drive unit operational?
■ ❑ ❑ 0
Is the return rate acceptable (low turbulence)?
■ ❑ ❑ 0
Is the overflow clear of excessive solids/pin floc?
■ ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
❑ ❑ ❑ ■
Comment:
Pumps-RAS-WAS
Yes No NA NE
Are pumps in place?
■ ❑ ❑ ❑
Are pumps operational?
■ ❑ ❑ ❑
Are there adequate spare parts and supplies on site?
■ ❑ ❑ ❑
Comment:
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
■ ❑ ❑ ❑
Are the tablets the proper size and type?
■ ❑ ❑ 0
Number of tubes in use?
1
Is the level of chlorine residual acceptable?
❑ ❑ ❑ ■
Is the contact chamber free of growth, or sludge buildup?
■ ❑ ❑ ❑
Is there chlorine residual prior to de -chlorination?
❑ ❑ ■ ❑
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
■ ❑ ❑ ❑
Is flow meter calibrated annually?
■ ❑ ❑ 0
Is the flow meter operational?
■ ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter?
❑ ❑ ■ ❑
Comment: Meters calibrated quarterly. No flow recorder, only a flow totalizer.
Effluent Sampling
Yes No NA NE
Page # 6

Permit: NCO025151 Owner - Facility: Dry Creek WWTP 11
Inspection Date: 11/21/2008 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ■ ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ ■
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ ❑ ❑ ❑
Comment:
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
❑
❑
❑
Is the mixing adequate?
■
❑
n
❑
Is the site free of excessive foaming in the tank?
■
❑
❑
❑
# Is the odor acceptable?
■
❑
❑
❑
# Is tankage available for properly waste sludge?
■
❑
❑
❑
Comment:
Operations $ Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment:
Page # 7

�0 WAT�c�Q
co
V
Mr. Brad Corcoran
City Manager
City of Eden
308 E. Stadium Drive
Eden, NC 27288
Dear Mr. Corcoran:
October 29, 2008
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
RECEIVED
N.C. Dept of ENR
OCT 3 01006
Winston-Salem
Regional office
Subject: Response to Comments on Renewal Drafts
(1) NPDES Permit NCO025071
City of Eden Mebane Bridge WWTP
(2) NPDES Permit NCO025151
City of Eden Dry Creek WWTP
Rockingham County
The Division has reviewed the comments in your staff October 20, 2008 letter. We have the following
information to offer after re-evaluation of the North Carolina statues water quality standards, and as
requested in your letter. We are addressing both permit draft renewals for the City of Eden WWTPs.
Dry Creek NCO025151
It has been the Division policy to include a permit page for an approved expanded capacity since
Permittees typically want to keep any approved capacity. We acknowledge this is not the case and
support you efforts for centralization of your treatment efforts to the Mebane Bridge facility. However,
to be consistent with Division policy we will continue to list the expanded capacity permit page in the
renewal permit. When you rescind the Dry Creek NPDES permit all permit pages will be deemed null
and void.
The 18 months timetable to meet TRC compliance, 28 µg/1, is per the Division standard policy to allow
you a one time opportunity to install the necessary equipment to meet the imposed TRC limit. We
acknowledge the City of Eden plans are to close this facility and cease discharge prior to the 18 month
deadline. If any discharge did occur after the 18 month period you will have to be in compliance with
the TRC limit. As often the case, your preliminary investigation indicates additional equipment would
be required to meet the TRC compliance limit requiring construction approval and capital investment.
The decision on how to move forward is up to you. To be consistent with Division policy the 18 month
TRC compliance timetable will be in the applicable permit page. Note, on the expanded permit page
TRC compliance is immediate upon expansion.
Mebane Bridtse NC_0025071
The evaluation to determine if a pollutant parameter has the possible potential to exceed any
applicable water quality standards is part of the normal permit review process and is based on the
most recent 48 month data you have submitted through DMRs or PPAs. In the case of mercury the
one high data point did occur within this time frame and prompted the addition of the provisional
compliance timetable. We acknowledge that the facility should not create mercury but without
substantial documented evidence of the err or a full documented disclosure of all source we have to
assume there is an unknown source.
Page 1 of 2
Telephone [phone] One
Division of Water Quality, Point Source Branch FAX [phone] NorthCarolina
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 ,Naturally
512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http://h2o.enr.state.nc.us/
An Equal Opportunity/Affirmative Action Employer

There is one major correction the Division will make, the provisional mercury compliance limit should
not go into effect until 18 months after the permit effective date. During the first 18 months 2/Month
monitoring is required. If after the first 12 months of monitoring you feel the data show no reasonable
potential to exceed the mercury compliance limit then you can petition the Division in writing to
remove the mercury limit and reduce the monitoring frequency back to the pretreatment condition of
quarterly without reopening the permit. If no petition is received or the Division evaluation of the first
12 months mercury data does not support the removal of the mercury compliance limit, the mercury
compliance limit with weekly monitoring is required beginning after the 18 month provisional timeline.
The 2/Month monitorimg is consistent with Division policy for NPDES effluent monitored parameters
for your facility. Unfortunately, we can only reduce the mercury monitoring under the terms specified
in the provisional limit.
Per your written request we provide the following statue quote:
The aesthetic problem, odor and taste, is defined under North Carolina Statute 15A NCAC 02B .0216
(3) "Quality standards applicable to Class WS-IV Waters are as follows:" protect water supplies from
(e) "Chlorinated phenolic compounds: not greater than 1.0 µg/L to
taste and odor problems due to chlorinated phenols shall be allowed. Specific he
compounds may be given a different limit if it is demonstrated not to cause taste and odor
problems and not to be detrimental to other best usage"
After verification of which available data defines chlorinated phenolic compounds the Division re-
evaluated the possible potential to exceed the chlorinated phenolic compounds water quality standard
and has concluded no potential exist and no limits is required. Monitoring requirements will revert
back to pretreatment total phenols requiremre�eatment group. Thve any e enewaler cerns permi bwill be correcteout total d
monitoring you should contact the DWQ p
accordingly. The Fact Sheet will be revised to read as follows:
Phenolic Compounds - Monitoring is part of pretreatment requirement. There is a water quality
standard, aesthetic standard dealing with odor and taste, required for chlorinated phenolic compounds
because the receiving stream, Dan River, is classified as a WS. Evaluation of available PPA data
indicates all chlorinated phenolic compounds are below detection limits so no further action is required.
Future permit renewals will include evaluation of the PPA data for chlorinated phenolic compounds.
l be issued
rther comments and
A corrected draft permit for Mbane Bridge NCO025071 estionse concerning this letter pleaselcall Ron Berryratu
approval. If you have qu [phone] or by
email at ron.berry®ncmail.net.
Sincerely,
Ron Berry
Eastern NPDES Program
Attachments:
Cc: Winston Salem Regional Office/Surface Water Protection Section (copy of City of Eden October
20, 2008 letter)
NPDES Unit (original City of Eden October 20, 2008 letter)
Central Files (copy of City of Eden October 20, 2008 letter)
Page 2 of 2

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October 20, 2008
Ron Berry
Eastern NPDES Program
Division of Water Quality, Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Mr. Berry,
0� 2 2
Subject: Comments for Draft of Renewal Permits
NPDES Permit NCO025071
City of Eden Mebane Bridge WWTP
NPDES Permit NCO025151
City of Eden Dry Creek WWTP
Rockingham County
Our staff has received and reviewed both of the draft NPDES permits for our city's
wastewater treatment plants. We understand the changes being proposed and the
reasoning behind these changes, but we still wish to comment on a few of these changes.
Concerning the permit renewal for the Dry Creek WWTP, #NC0025151, there was only
one major change noted along with directives to go along with a plant expansion. We
will not be pursuing a plant expansion. I'm not sure if this section could be removed, but
it will not be needed for the future. We are currently looking at plans for closing Dry
Creek permanently and rerouting all flows to the Mebane Bridge Plant. As for the TRC
limit, we have reviewed the plant layout and have determined that modifications to the
effluent structure would have to be in place before we could effectively chlorinate and
dechlorinate. This pushes us further in our desire to close the Dry Creek plant. We are
hoping to have plans in place within a year to have all flows diverted before the end of
2009. This should keep us within the 18 month timeline that will be imposed to meet the
new TRC limit.
Concerning the permit renewal for the Mebane Bridge WWTP, #NC0025071, there were
several major changes noted but we only wish to comment on two. We see no problems
with the new effluent weekly average maximum limit. We have always seen results less
than our current monthly average, so meeting the new limit should not be a problem. We
have no problems with the reduction in silver monitoring as well.
P. O. Box 70 • Eden, NC 27289-0070 • [phone] • Fax [phone]

We are, though, concerned about the increased monitoring for Mercury as well as the
weekly average maximum limit. We have already budgeted for our annual analysis and
this increase in testing was not planned for. For as far back as 2001, we have
consistently shown < 0.0002 mg/L Mercury in our Effluent. The majority of our Influent
data has also been < 0.0002 mg/L with only five data points being above the detection
limit. Only one date showed a hit of 0.0011 mg/L in the Effluent while the Influent for
that day was 0.0008 mg/L. We feel strongly that this was an erroneous reading either
from contamination through sampling or the analysis itself. Nothing could be identified
at the time to prove a lab error, but with the Effluent being higher than the Influent, an
error would have had to occur. It is not feasible that we would produce Mercury in our
operation. We understand the protocol for reasonable potential, but I'm asking that you
reconsider the length of time for required conditional monitoring. We ask that it be
reduced to 3 — 6 months with the understanding that if another hit occurs, we will
continue the bi-monthly sampling for the rest of the permit term.
Our other concern is with the newly imposed Phenol limit. We are not aware of any
aesthetic problems with the downstream drinking water supply or do we foresee any
problems contributed from our plant due to the size of the stream that we discharge into.
First, we would like to see a Fact Sheet that shows how this limit was initially
established. Next, we ask that you consider a conditional monitoring requirement for a 3
— 6 month period for this parameter with the understanding that if we have any results
above the limit, we will continue monitoring bi-monthly. Otherwise, we can revert back
to monitoring quarterly for the duration of the permit. We know there have been a few
results near or above the new proposed limit, but again, we feel that some amount of lab
error could have contributed to these results. In the past year, we have switched private
labs due to some continual problems and have worked on improving our sampling
techniques from within. Due to the difficulty of treating Phenol once it comes into the
plant, we ask that we be given a chance to prove that there is not a problem.
These above mentioned concerns are all that we have at this time. Thank you for the
opportunity to discuss these issues with your office and present a response for your
review. We will soon lose our largest industrial contributor which will surely impact the
overall makeup of our stream. It will also have a detrimental financial impact on our
facility as well as the community as a whole. Any reconsideration of these matters will
be appreciated.
Sincerely,
Melinda S. Ward
Wastewater Superintendent
Cc: Brad Corcoran
Demos Asbury
Ralph Potter

RECEIVED
N.C. Dept. of ENR
OCT 3 0 I Michael F. Easley, Governor
State of North Carolina
Winston-Salem I William G. Ross, Jr., Secretary
Rewonai Office Department of Environment and Natural Resources
October 29, 2008
Ms. Shari L. Bryant, Regional Coordinator
Habitat Conservation Program
Division of Marine Fisheries
1721 Mail Service Center
Raleigh, NC 27699-1721
Subject: NPDES Proposed Permit Response
Permit Number NCO025151
City of Eden Dry Creek WWTP
Rockingham County
Dear Ms. Bryant:
Coleen H. Sullins, Director
Division of Water Quality
The Division offers the following information to address the comments in your October 23, 2008 letter
for the Dry Creek facility. Your concerns about the impact to the diverse aquatic community in Dan River will be
conveyed to the City of Eden.
The Dry Creek facility is a domestic treatment facility with a small intermittent limited industrial source
that has a monthly average treated effluent discharge less than 300,000 gallons per day. Dry Creek was not
required to meet a Total Chlorine Residual (TRC) limit during the last permit cycle unless they expanded. Dry
Creek disinfection is tablet chlorination with no dechlorination. However, since March 2004 quarterly effluent
acute toxicity test has been conducted using fathead minnows, out of 18 tests only one failure has occurred. There
is no power back up. One issue under study is Dan River high Fecal Coliform levels.
Per Division policy in this renewal permit for the unexpanded discharge, a 18 month compliance table
will be as imposed to allow the City of Eden to make the necessary changes to comply with the required 28 µg1l
TRC acute limit. The expanded discharge has an imposed TRC limit. The City of Eden plans are to permanently
shutdown the Dry Creek facility prior to reaching the 18 month compliance deadline. Conseqnently, the City of
Eden dose not want to make any capital investments or improvements. Likewise, the City of Eden has stated they
have no intentions of utilizing the expansion permit.
The Division will issue the renewal permit with the compliance timeline and will advise the City of Eden
that in future application alternative disinfection methods should be considered. We will emphasis that any
discharge beyond the 18 month time limit will be subject to the TRC compliance limit and that the permit should
be rescinded once the facility is shutdown.
If you have any questions, please contact Ron Berry at telephone number [phone].
Sincerely
i" &"'�/
Ron Berry
cc: Central Files (w/ copy October 23, 2008 letter)
NPDES Permit File [w/ original October 23, 2008 letter)
Winston Salem Regional Office, Water Quality Section [w/ copy October 23, 2008 letter)
Division of Water Quality, Point Source Branch Telephone [phone] are
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 FAX [phone] NorthCarolina
512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http.//h``o.enr.state.nc.usl Naturally
An Equal Opportunity/Affirmative Action Employer

® North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Ron Berry, NPDES Unit
Division of Water Quality
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 23 October 2008
SUBJECT: Proposed Permit Renewal for Dry Creek WWTP, City of Eden, Rockingham County,
NPDES Permit No. NCO025151
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject
document. Our comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), North
Carolina General Statutes (G.S. 113-131 et seq.), and North Carolina Administrative Code 15A NCAC
10I.0102.
The City of Eden has applied for renewal of its NPDES permit to discharge treated domestic
wastewater into Dan River in the Roanoke River basin. According to the public notice, total residual
chlorine (TRC) and color are water quality limited.
Dan River supports a diverse aquatic community and there are records for the federal and state
endangered Roanoke logperch (Percina rex), the federal species of concern and state endangered green
floater (Lasmigona subvirdis), the state threatened bigeye jumprock (Scartomyzon ariommus), and the
state significantly rare Roanoke hogsucker (Hypentelium roanokense) in Dan River.
We offer the following recommendations to reduce impacts to aquatic resources, particularly to
the Roanoke logperch.
If the facility uses chlorine disinfection, chlorine systems should be replaced by ultraviolet light
or ozone systems. Chlorine is acutely toxic to aquatic organisms and can form secondary
compounds that are detrimental to aquatic life.
2. If not already in place, a stand-by power system should be installed.
Thank you for the opportunity to comment on this permit renewal. If we can be of further
assistance, please contact our office at [phone].
ec: Rob Nichols, WRC
Tom Augspurger, USFWS
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]