NC0026689_PERMIT ISSUANCE_20040914

MPDBS DOCUMENT SCANNING COVER SMEBT
NPDES Permit:
NC0026689
Denton WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Renewal Application
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
September 14, 2004
Thies dooumeat is printed oa reuse paper - igaaore nay
coateat oa the reverse side

Mr. Jeff Dennard
Town of Denton
P.O. Box 306
Denton, NC
Dear Mr. Dermard:
27239
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
September 14, 2004
Subject: Issuance of NPDES Permit
NCO026689
Denton WWTP
Davidson County
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or
as subsequently amended).
This final permit contains the following changes from your draft permit:
➢ An annual pollutant scan has been added to your permit. By performing this scan
concurrent with your toxicity test (at different times of the year), you will be able to collect
sufficient data for the new renewal application required by the Environmental Protection
Agency (EPA).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such
demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. 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, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Toya Fields at telephone
number [phone], extension 551.
Sincerely,
ORIGINAL SIGNED BY
Tom BeInick
Alan W. Klimek, P.E.
cc: Central Files
Winston Salem Regional Office/Water Quality Section
CNPDES-Unit
-- t
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

Permit No. NCO026689
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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,
Town of Denton
is hereby authorized to discharge wastewater from a facility located at
Denton Wastewater Treatment Plant
300 Council Access Road
Denton
Davidson County
to receiving waters designated as Lick Creek in the Yadkin -Pee Dee River Basin in accordance
with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III, and IV hereof.
This permit shall become effective October 1, 2004.
This permit and authorization to discharge shall expire at midnight on January 31, 2009.
Signed this day September 14, 2004.
ORIGINAL SIGNED BY
Tom BeInick
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NCO026689
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit
issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to
operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included
herein.
The Town of Denton is hereby authorized to:
1. Continue to operate an existing 0.8 MGD wastewater treatment facility consisting of the
following components:
• Flow meter
• Bar screen
• Grit chamber
• Wetwell
• Comminutor
• Oxidation ditch with two mechanical aerators
• Dual secondary clarifiers with sludge return
• Sludge holding tank
• Sludge drying beds
• Effluent chlorination
• Post aeration
The facility is located at Denton WWTP on 300 Council Road, Denton, Davidson
County.
2. Discharge from said treatment works at the location specified on the attached map into
Lick Creek which is classified WS-IV waters in the Yadkin -Pee Dee River Basin.
Yct
'r �ffi�'1ij iriaT

fi
to
Discharge location
M f f
q i _
���•� s i� R t - �`r l k'�'s /`•- .t".'T-
.:,7�Z 6!2t.. I-
;�ibl-
��;,
�Town;of Denton WWTP IVC0026689 Facilit
A"y'zN``" tr„C,, y
tryn�s'4 as J
Location }
USGS Quad�Name High Rock C� eat
Receiving Stream Lick, reek a Long 80 09 17
Stream Class WS IV� 2 �� x' fi fi dNortl1 Sig Ot to SCFiLE€.`
SLibbasin: Yadkm Pee;Dee 03 07a08 g �: ? a

Permit No. NCO026689
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge wastewater treatment plant effluent from outfall serial number 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
EFFLUENT ";':
CHARACI'ERISTIC_S
• . -. _` � , £
• .MONITORING REQUIREMENTS
Monthly
Average
�' . _ :
Weekly
•Ave"rage
Daily
Mazrmum,
�,•_.
Measurement
'-Frequency
- _.
; Sample
'."Type:•°.
, �' i ,
_ .....
Sample-,
i
Location
Flow
0.8 MGD
Continuous
Recording
l or E
BOD, 5 day, 20°C
(April 1 - October 31)
5.0 mg/L
7.5 mg/L
3/Week
Composite
E,1
BOD, 5 day, 20°C
(November 7 - March 31)
10.0 mg/L
15.0 mg/L
3/ Week
Composite
E, I
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
3/Week
Composite
E, 1
Dissolved Oxygen',3
3/ Week
Grab
E, U, D
pH
Between 6.0 and 9.0 s.u.
3/Week
Grab
E
NH3 as N
(April 7 —October 31)
2.0 mg/L
6.0 mg/L
3/Week
Composite
E
NH3 as N
(November 1—March 31)
4.0 mg/L
12.0 mg/L
3/Week
Composite
E
Total Residual Chlorine4
17.0 µg/L
3/Week
Grab
E
Temperature
Daily
Grab
E
Temperature'
3/Week
Grab
U,D
Fecal Coliform'
200/100 mL
400/100 mL
3/Week
Grab
E, U, D
Total Nitrogen
(NO2 + NO, +TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Conductivity'
3/Week
Grab
E, U, D
Chronic Toxicity5
Quarterly
Composite
E
Total Mercury
/Z A �.e
°�
Grab
E
Total Nickel
2 0 µ
6 g
yMoenii ..Composite
E
Total Copper
Monthly
Composite
E
Total Zinc
Monthly
Composite
E
Notes:
1. Sample locations: E- effluent, 1-influent, U-upstream at least 50 feet above the discharge point, D-downstream
at the NCSR 1002 crossing near Healing Springs. histream monitoring shall be conducted three times per
week during June, July, August, and September, and once per week during the remaining months of the year.
Instream monitoring is provisionally waived in light of the permittee's participation in the Yadkin -Pee Dee
River Basin Association. Instream monitoring shall be conducted as stated in this permit should the permittee
end its participation in the Association.
2. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15% of the respective influent
value (85% removal).
3. The daily dissolved oxygen effluent concentration shall not be less than 6.0 mg/L.
4. Applies only if chlorine is used for disinfection.
5. Chronic Toxicity (Ceriodaphnia)P/F O 90%; February, May, August, November; See Condition A(2)
There shall be no discharge of floating solids or foam visible in other than trace amounts.

Permit No. NCO026689
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
AM. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodnphnia
dubia at an effluent concentration of 90 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodnphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase
11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of February, May, August and November. Effluent sampling for this testing shall be performed at
the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then
multiple -concentration testing shall be pertormed at a minimum, in each of the two following months as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure' (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed, using the parameter code TGP313 for the pass/fail results and THP3B
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. 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 the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required
during the following month.
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. `

Permit No. NCO026689
A. (3) EFFLUENT POLLUTANT SCAN
The permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the table below (in
accordance with 40 CFR Part 136). The annual effluent pollutant scan samples shall represent seasonal (summer,
winter, fall, spring variations over the 5-year permit cycle. Unless otherwise indicated, metals shall be analyzed as
"total recoverable." Additionally, the method detection level and the minimum level shall be the most sensitive as
provided by the appropriate analytical procedure.
Ammonia (as N)
Tmns-1,2-dichloroethylene
His (2-chloroethyl) ether
Chlorine (tow] residual, TRC)
1,1-dichloroethylene
Bis (2-chloroisopropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethylhexyl) phthalate
Nitratc/Nimte
1,3-dichlorupropylcne
4-bromophenyl phenyl ether
Total Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-thloronaphthalene
Total Phosphorus
Methyl chloride
4-chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1,1,2,2-rerrachloroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n-ocryl phthalate
Arsenic
Toluene
Dibenzo(a,h)anthmcene
Beryllium
1,1,1-nichloroelhane
1,2-dichlorobenzene
Cadmium
1, 1,2-tichloroethane
1,3-dichlorobenzene
Chromium
Trichioroerhylene
1,4-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury
P-chloro-mcreso
Dimethyl phthalate
Nickel
2-chlorophenol _
2,4-dininotoluene
Selenium
2,4-dichlorophenot,-
2,6-dinitrotoluene
Silver
2,4-dimethylphenol
1,2-diphenylhydmzinc
Thallium
4,6-dinitro-ocresol
Fluoranthene
Zinc
2,4-dinitrophenol
Pluorene
Cyanide
2-nitrophenol
Hexachlorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatile oroaaic compounds:
Penlachlomphenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroelhane
Acrylonitrile
2,4,6-trichlorophenol
Indeno(I,2,3cd)pyrenc
Benzene
Base -neutral comMunds:
Isophorone
Bromoform
Accnaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nilrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3,4 benzotluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1,2,4-trichlarobenzene
I,1-dichloroethane
Benzo(k)Buoranlhene
1,2-dichloroethane
Bis (2-chlorcethoxy) methane
Test results shall be reported to the Division
in DWQ Form DMR-PPAI or in a
form approved by the Director, within 90 days
of sampling. A copy of the report shall be
submitted to Central Files to the following address: Division of Water Quality, Water
Quality Section, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.

[Fwd: Draft NPDES Permits]
Subject: [Fwd: Draft NPDES Permits]
From: Lee Spencer <[e-mail]>
Date: Tue, 14 Sep 2004 15:15:10 -0400
To: Toya Fields <[e-mail]>
I see that e-mail was sent to "letoya.fields". Sorry about that.
------- Original Message--------
Subject:Draft NPDES Permits
Date:Wed, 11 Aug 2004 14:48:39 -0400
From:Lee Spencer <lee.spencer(cDncmai1.net>
Organization:NC DENR Public Water Supply
ToJacquelyn.nowell e ncmail.net, letoya.fieldspncmail.net
CC:Dave Goodrich <Dave.Goodrich a,ncmail.net>. lorna withrow
<lorna.withrow a,ncmail.net>
I recently received draft permits from each of you. I assume you would
like an okay from our office before issuing the final permit. Normally,
the DWQ reviewer sends a cover "check -off sheet" on which I provide any
comments and sign. This form was not on either package.
I have no objection to the issuance of either of these two permits:
City of Lexington WWTP NCO055786
Town of Denton WWTP NCO026689
Lee G. Spencer, P.E.
Regional Engineer
Winston-Salem Regional Office
Public Water Supply Section
N.C. Dept. of Environment and Natural Resources
Voice: 336-771-4608 ext 374
Lee G. Spencer, P.E.
Regional Engineer
Public Water Supply Section
NC DENR Winston-Salem Regional Office
of 2 9/14/2004 3:16 PM

NORTH CAROLINA
FORSYTH COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, personally
appeared D.H. Stanfield, who being duly sworn, deposes and says: that he is
Controller of the Winston-Salem Journal, engaged in the publishing of a newspaper
known as Winston-Salem Journal, published, issued and entered as second class mail
in the City of Winston-Salem, in said County and State: that he is authorized to
make this affidavit and sworn statement: that the notice or other legal advertisement,
a true copy of which is attached hereto, was published in Winston-Salem Journal on
the following dates:
July 24, 2004
and that the said newspaper in which such notice, paper document, or legal
advertisement was published was, at the time of each and every such publication, a
newspaper meeting all the requirements and qualifications of Section 1-597 of the
General Statues of North Carolina and was a qualified newspaper within the meaning
of Section 1-597 of the gcneral statues of North Carolina.
This 26th day of July, 2004
(signature of pers making affidavit)
Sworn to and subscribed before me, this 26th day of J 004
Notaly ublic
My Commission expires: September 23, 2005
OFFICIAL SEAL
Notary Public, North Carolina !�
COUNTY OF FORSYTH
/ 051D KIMALEY HN ON /Il
My Commission Expires•)
rF

Davidson County
The Town of Denton (P.O. Box 306, Denton, NC 27239) has applied for renewal of NPDES permit NCO026689 for the
Denton W WTP in Davidson County. This permitted facility discharges 0.8 MGD of treated wastewater to Lick Creek in
the Yadkin -Pee Dee River Basin. Currently BOD, ammonia nitrogen, total nickel and total residual chlorine are water
quality limited. This discharge may affect future allocations in this portion of the Yadkin -Pee Dee River Basin.
The City of Lexington (28 West Center Street, Lexington, NC 27292) has applied for expansion and modification of
NPDES permit NCO055786 for the Lexington Regional WWTP in Davidson County. This permitted facility discharges
treated wastewater to Abbotts Creek in the Yadkin Pee -Dee River Basin. Currently BOD, ammonia nitrogen, total
phosphorus, mercury, phenols and total residual chlorine are water quality limited. This discharge may affect future
allocations in this portion of the Yadkin Pee -Dee River Basin.
Wednesday, July 21, 2004
1617 Mail Service Center, Raliegh, North Carolina 27699-1617 -Telephone [phone] FAX 919,733-0719
An Equal Opportunity Affirmative Action Employer - 50% Recycled / 10% post -consumer paper

NCDENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Town of Denton WWTP
NCO026689
Faciht
Information _
(1.) Facility Name:
Town of Denton
(2.) Permitted Flow (MGD):
0.8 MGD
_
(6.) County
Davidson
(3J Facility Class:
--.
(4.) Pretreatment Program
(5.) Permit Status:
III
- - _- .----
Yes
Renewal
(7) Regional Office
_.-_. .......-..- ---
(8) USGS Topo Quad:
(9.) USGS Quad Name:
Winston-Salem
--- - --
E18SW
I Fli h Rock
StreamCharacteristics'
(1.) Receiving Stream:
(2.) Sub basin:
Lick Creek
03-07 08
A
(7) Drainage Area (miz):
(8) Summer 7Q10 (cfs):
0.57
0
Stream Index Number
12-126-(3)
(9.) Winter 7Q10 (cfs):
0
_(3.)
(4.) Stream Classification:
WS-IV
1 (10.) 30Q2 (cfs):
0.9
_
(5.)303(d) Status:
_
Listed
! (11.) Average Flow (cfs):
0.5
(6.)305(b) Status:
1.0 Proposed Changes Incorporated into Permit Renewal
• Add weekly average ammonia limits
• Remove limit pages for 0.3 MGD discharge (facility expanded in 2000)
• Remove cyanide limit and monitoring requirement due to lack of reasonable potential to
cause an exceedance of water quality standards.
• Remove mercury limit and reduce monitoring to monthly.
2.0 Summary
Over the past permit cycle, the Town of Denton has expanded its facility from 0.3 MGD
to 0.8 MGD and relocated its discharge to Lick Creek. The facility was Linder an SOC for flow
and toxicity that expired in 2000. While it appears that the expansion solved the facility's Flow
problems, effluent toxicity is still a concern.
Denton WWTP has two non -categorical SIUs and one CIU. Century Hosing (0.004
MGD), Thermo Product Incorporated phosphate coating operation (0.0015 MGD), and Surratt
Hosiery Mills (.009 MGD)
Lick Creek is listed on the 2002 303(d) list as impaired (cause unknown). Potential
sources include both point and non -point sources. The 1998 Yadkin Pee Dee basin plan
recommended that Denton's proposed outfall should receive tertiary limits for oxygen
consmning wastes.
3.0 Compliance Summary
DMR Data Reuiea

NPDES Permit Fact Sheet - 07/21 /04
Pal-e 2
Town of Denton W%VTP
NCO026689
A 2001-2004 DMR data review shows the facility to be in compliance with its permitted limits.
Monthly average data are summarized in Table 1. The facility's average monthly flows are at
45% capacity with maximum monthly average flows at approximately 70% capacity. In 2001,
before the facility completed its expansion, there were chronic violations of the monthly average
flow limit, but those problems appear to have been resolved. The only other violations were two
nickel weekly average limit exceedences (discussed below in RPA Analysis).
Table 1: 2001-2004 Monthly Average DMR Data Summary
Total
Residual
Flow
Temp.
Chlorine
BOD
NH3-N
TSS
Fecal
D.O.
TN
TP
Date •
(MGD)
(de C)
(u L)* -
(m L)
(m L)
mi L)
0/100 mL)
(m L)
(m L)
(m L)
Conductivity
0.36
18.60
0
2.66
0.58
2.48
1.37
8.11
2.89
0.66
453.90
-Average
Maximum
0.57
30.00
4.1
1.90
7.70
2.30
10.22
15.50
2.99
716.00
Minimum
1 0.19
10.00
2.00
0.11
1.20
1.05
6.86
0.44
0.10
272.00
5.0 (s)
2.0 (s)
Limit
0.8
17.0
10.0 (w)
14.0 (w)JI
30.0
200
> 6.0
* Regional Office: Is it possible that TRC levels are being measured in mg/L instead of µg/L?
The Town of Denton is a member of the Yadkin Pee Dee monitoring coalition, so instream
requirements have been waived. At this time, however, there is no downstream monitoring
station in the vicinity of the outfall.
RPA Analysis
RPAs were conducted for mercury, nickel, copper, zinc, and cyanide. While the facilit)
does have a STMP with the pretreatment unit, the only data that has been collected was during
February2001. According to STMP data, all parameters other than copper and zinc reported
values below the detection level.
Prior to September 2003, all mercury samples reported levels of <0.2 jig/L. Since being
required to test using method 1631, mercury values have ranged from <1.0 ng/L to 4.0 ng/L.
Based on this data, the facility's discharge does not show reasonable potential to exceed mercury
water quality standards. The limit will be removed and monitoring reduced from 2/month to
monthly.
For nickel, only 3 of 59 samples showed nickel levels above the detection limit. However
the weekly average limit of 25.0 µg/L was violated twice since the last permit renewal, once in
November 2001 (reported value 61.0 µg/L) and once in September 2002 (reported value 43.0
µg/ L). Since the limit was exceeded it cannot be removed at this time.
Copper and Zinc have been detected in the facility's effluent. At this point the facility
has not been able to rule out copper or zinc as causative agents for their WET test failures. In
February and March of 2003, Denton had consecutive WET failures, but since they passed a0 tests
administered in the following nine months, the Aquatic Toxicology Unit did not recommend
copper or zinc limits. The monthly monitoring requirement will remain in the permit, however.
All cyanide values were reported as less than the PQL of 10 µg/L. The limit and
monitoring requirement for this parameter will be removed.

NPDES Permit Fact Sheet — 07/21 /04
Page 3
Town of Denton WWTP
NCO026689
WET Test Residts
Since 2001 the facility has passed 15 of 19 WET tests. The most recent failures were in
February and March of 2003. The cause for these failures has not yet been determined.
Correspondence File RCVie70/Compliance History
Overally, the Denton W WTP appears to be well operated and maintained based on
inspection reports. There were no ongoing problems or concerns.
4.0 Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: 7/21 /04
Permit Scheduled to Issue: 9/1 /04
5.0 State Contact Information
If you have any questions on any of the above information or on the attached permit, please
contact Toya Fields at [phone], extension 551.
Copies of the following are attached to provide further information on the permit development:
• Draft permit
• RPA analysis
NPDES Recommendation by:
Signature Date
Regional Office Comments:
Regional Recommendation by:
Signature Date
Reviewed and accepted by:
Regional Supervisor:
Signature Date

REASONABLE POTENTIAL ANALYSIS
Town of Denton
NCO026689
Time Period May 2004-May 2002
Car (MGO) 0.8
70IDS (cIs) O
7010W (c/s) 0
3002 (cls) 0.09
Aug. Stream Flow, OA (1 0.5
Reeving Stream Lick Creek
W pClass III
IWC (%) 0 7010S 100
® 701OW 100
® 3002 93.233
0 CA 71.264
Stream Class Vi
Outfall 001
Ow = 0.8 MGD
STANDARDS 8
PARAMETER
TYPE
CRITERIA Q)
POL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
MC WOS/ SFAV/
ICet Wr Prai Affii CM
III
Tack erh
ACNs: WA
Remove liven, adece reenacting
Mercury
NC
12
02
nWL
50 13
108
—.
-13.--
___-___________________---- -_ _
Chronic:
ACN-I 261
Retain tail, monitoring
Nickel
NC
W0 261
UWL
59 1
eA�
CM1ronic—. _.�
Acute: 0007
Retain monitoring
Copper
NC
000> AL 00070
mryl
dp 04
13
CM1ronic: 0007 -
- _ _ _ _
Acute: 0.067
Rotainr-,crrhoring
And,
NC
0.050 AL 0067
rnprL
AO 00
00
-
_._-_._._._. _._._--._.---._._ _
I Chrmlc'0050.
Acres 22
Radii Omt and monitoring
Cyanide
NC
5 N 22
10
ugrl.
61 0
50
-
Chronic'—._. 5.--
Acute: WA
0 0
WA
i
Chronic rmr O Type
._. _.___. _. _. _. _. _---_
late: WA
0 0
WA
_
Chronic . or O Type
_
Acute: WA
0 0
WA
ICla..9me0Type
Acute: WA
0 0
WA
_
Chronic `rror O TYPe
_ — _._-_. _. _. _. _. _. _.— _._
ACu181 WA
0 0
WA
_________ _ . _______ _
Chronic: Enor0 Type
Acute: WA
0 0
WA
Chronic: reor O Type
ACvte: WA
0 0
WA
---_._-_
°.
Chronic nor OType
.—.---------------
ACWO: N/A
0 0
WA
Chronic --nor O Type
I
AGutel WA
0 0
WA
Chronic 3ror O Typo
— —-------
Acute: WA
0 0
WA
—
'. ----_. _. _.—._.---._
CM1ronic`.rror O TYpt
Legend
C= Cdremogenm
NC = Non-camnogenic
A - Aesrhrac
" Freshwater Discharge
26689_RPA. xIs, and
7/Id/200d

Whole Effluent Toxicity Testing Self -Monitoring Summary
June 15, 2004
FACIL IFIREQUIREMENT
YEAR LW
FEB
MAR
APR
MAY
JUN
JUL
AUG
SLI'
OCr
NOV
DEC
DaureInl adual N."-\Ibvrmlate ehr in, d0%
2000 Fail
>100
--
Pa.
—
-
Fag
be
74.6
Pass
NCINIy6,197,001 Begin 6II12I414 F¢quence:Q Jan Apr bad 0,l
N-Canp Subtle
2001 H
H
--
H
H
X
N
X
H
Late
>1W
—
III,:11 my R[yinn: '.d NO SubMun:YADUX
2002 Pass
...
—
LLBII 3
—
Past
—
—
NWH
-
Pata
11.111 \pvu1
ROOJ Pasb
.In
Pesa
—
--
Fall
335
H
X
>IOp
-
]Illlll 00 IttC00 IINI Ordc
2004 Paas
...
.-
Pass
Ilvcr Ch'nu Su1.0i,hioo \\"I'P cllr live 111
2000 -90
-
>100
--
--
Pau
—
Pass
-
-
NCOO63AHOO1 Begin 4/1/2003 Fr[gtlenp':Q Jan A,, Jul Us,
Nan(tal Single
2001 Fag
100
1100
Pan,
—
_.
Pass
...
_.
Lane
Fail >100
=IW
County: Wake Region: RRO Subivuib: NEIRL
2W2 Past
—
—
Pan.
—
._
Pass
Lau
Pafs
-
IF: 005 SI'wial
2003 Lau
Fad
94 9 ?160
Past
—
-.
Pass
--
-
Pass
—
-
2QIO:00 IWON)90 Old,,
2004 Lau
Late
Penn
Pas.
What NI I, chrlin: IN; Cesp 1.5NIODOLlre fv/.
2000 --
-
3,1
©
Lale
156]53
—
-
31
—
15.6
PR00061HO601 Begun 61112002 1'rcgnnnoy:Q %leNw Sep Lee
3 Nm1Canlp: Single
2001
31.1
-
—
ISb
—
—
156
-
_.
31.1
CUnnty: ( Lel,ba Region MCI Subut,in'. CTB35
2002 _.
_.
31.1
—
—
1,14
._
-_
>44
—
—
15.6
[IF: III SpvanI
2003
7.6
Jfl
156
se
—
—
al
156
7,8
311
2QI11: 12 wand, II Order:
200"
156
Ilentun \\'\\"1'I' cbr lien: 00°/n
2IN —
1.
>90
—
�
>90
—
Pam
—
—
Pe33
—
N000261.0IIII Begin all adpO FruqucneY Q Feb May Aug Nov
' NcncLang Single
2001 -
—
--
Pass
--
—
Fang! 1>p0
NR
Pass
Past
—
Umm1y: Davidson Region: LISRO Snbbn. W; YADOS
2002 -.
er)
NW>I00
Pass
--
—
Pass
—
Pass
—
IT 11.30 S".J
2003 _.
(P.J
.62.2
>IN
1100
Pass
—
-
Pass
—
)QIIli01) IWCIN)I00 Crdi,
20W —
Pass ,9a.9
--
-
Pass
I)iI ie fern.. Inc. slur filin 90%
2000 Fell
Pa..
—
Pe.t
—
—
Fai
1100
>1W
BR
Pa"
—
N'COON3I63111111 Begin 5I1PlllR Frequency:Q Jan Apr Jul Oct
N.Lcarl P: Subtle
2001 Fee Pass
>IN
97.5
Late
H
H
H
—
H
Fail
-IN
>100
Gnnuy: Slaudy It[giun'. MRO Subbnsin', YAD12
2002 Pass
-
—
Pass
—
-
NR
Pass
--
Pass
—
—
I'F: II.II2_ L e—,
2003 .an
-
Pass
_.
_.
Paba
—
Fail
79 a
H
]QIII:I IWC(N)Pill Ord-
2004 H
H
H
Fall
Dan, Pun I-ARIF. 002 cbt llm: IL%
2000 Pas
-.
_.
lit
—
...
Late
Pass
_.
Pass
N'COORIL/)'nOO2 Begin:2/I/2002 Frequency:Q Jan Apr Jul List
' Nuactun p: Single
2001 Pas.
—
—
Peff
—
—
Pau
--
—
Fag
>64
>6a
CountYa inslau Region: MRO Sub in: CFR34
2602 >92
—
—
>6a
—
—
Pas.
Pass
IF 11 6 Sleei=I
2003 Pass
-
-
Pass
Pass
Fad
452
>E4
]QI101'1511 ImI%)I6 Onlen
2004 Pass
--
—
Penn
Ou I" l'n n'rr Reluns C... 1,103 chrGm: 14%
21100 .-
Pass
Pass
--
Late
Pens
_.
pass
—
SC1102JJnnlu03 Begin 6/IR1102 FregneLL, Q Feb May Aug Nuv
* NonCobup' Shield
2001 ...
Pass
--
—
Pass
--
--
Penn
—
-
Pass
—
cut nly: SmA[> Region WSRO Subbaain1 ROA01
2002 --
Pass
--
—
Pass
>76
—
—
Pats
—
PF: NA "1
2003 —
Pass
Pass
._
._
Pan
Pen
—
7Q10:900 PVC(II)NA Order:
2Wa
Pau
—
—
D I:e I.. bulk SI'aln 1LIn 11)%
2000
invalid
—
Pass
—
Pass
Pens
N(11004IIJ 111 li gin JI/ 000 FILL, ..... . l %I,, dirt Sep Dec
N C np:Single
2001 -
-
Pass
—
—
P m
—
Pass
Pas.
( un1, KI1.111 Re" M110 S 11 .YAU04
2002 -
>28
..
—
Pam
--
Pass
—
—
Pau
IF 'A SPv.
200 _.
_.
pass
-
—
Prss
--
Penn
Pass
i QIUL Pop 1\\'CI%111.598 ONvr.
2004 -.
—
Pas.
—
II k, Poe—Clilkide It, I I i6%
200) —
-
Invaad
_
Pairs
_
sm.
—
Paai
NC(1111150 Fllfl Begin 9/I/1 rv) 4 , 're Q 1/ Atarlur5ep Dec
` Nnn nh $ geld
2001...
Pass
—
P ..
—
Farm
—
Paaa
( anly. I< ll 1 Id, : ARO StAbb.-an IJRDIP
2002
_
Pam
-
—
>e2 t
—
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Pafa
111 N.N 1pa 1
2001 ..
_-
Pass
-
-
Paas
...
-
Piss
--
Pass
I
iQIII: 2h7 VJC(%Ja51 led,
200a ...
Pass
-
Dnkv 1'nocnean Buser OIL har 1 bi
2000 _.
_-
Irani
._
—
Pat,
--
---
Pass
NCIN1I3.I6F/002 Be,,.: 91t/2002 Fr[qu[ncY Q Mar Jun Sep Dec
` Nual lap: Single
2001
Psaa
Penn
Paft
Pa.3
Caud,: Resupplies, i(egin¢WSRO Sergi ROA03
2002-
—
Pass
—
—
Paas
--
—
Paf.
—
—
Peas
IT: 1.8 SPeciol
NO _.
_
Paba
—
—
Pa..
—
—
Pass
Pant
7QIO, 314.0 P%C(Nl 1IN Order:
2004
pass
❑like leer-I.Incole Tnttran cbr find: 23%
2000 _.
._
>92
, -
—
>92
--
—
55.05
—
—
6505
SCOO6026IUI01 Begin IUIPOOI Pmgurvil :Q Jan Apr Jul On
I NOnCoab,'. Single
2001
-92
—
—
>92
—
—
>92
—
—
Lots
County: Lined Region: SIRO Subbarnin: CTBIJ
2002 >92
—
-92
—
—
-92
—
65
--
Pao
—
—
I
PF: LLi gal
2003 —
Pass
—
—
Pass
--
Pau
Pefs
2QIO: 2.1 IWC(Y)23 Order.
201 >92
—
—
--
DnAa1'uuen\Iar,ha110112 cbr lim: 12%,
2000 -
Pass
--
-
Pass
--
-
Pass
—
—
Peaa
—
NCIIIIIWIMWO02 Begri V112004 FrtgnenCY:Q Feb May Aug Nnv
F NpnCpmp Single
2001
Pass
Pass
Pens
—
—
Pnbb
-
Connly: Cmb.sba Region: MI(O S,,I,1,tallll(TB31
2002 -
Pau
--
—
Pens
Pass
—
—
Penn
—
IT 5.3 ".,1
2003 _
Pafa
--
—
Pass
—
--
Paaf
--
—
Pasb
—
2QIt. hit o I\1'C(%) 12,11 ri
2004 -
Puss
—
—
i Re 3000 ❑9a k-dable
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athghes1c
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far month in question: 0-
ORC signature needed
i

NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form
DES OR NONDISCHARGE PERMITTING UNIT COMPLETES THIS PART:
Date of Request 7/6/2004
Facili
Town of Denton WWTP
Permit #
NC0026689
Re ion
Winston-Salem
Requester
Toya Fields
Pretreatment A-F Towns- Dana Folle (ext. 523)
Contact G-M Towns- Jon Risgaard ext. 580)
N-Z Towns- Deborah Gore (ext. 593)
rMENT UNIT:
C)tl
PRETREATMENT UNIT COMPLETES THIS PART:
Status of Pretreatment
Program (circle all that apply)
1) the facility has no SIU's and does have a Division approved Pretreatment Program that is INACTIVE
2) the facili has no SIU's and does not have a Division approved Pretreatment Program
3) the facility has or a re rea ment Program
a) is Full Pi wit or 3b is Modified Program with STMP
4) the facility MUST develop a Pretreatment Program -
u o I le
5) additional conditions regarding Pretreatment attached or
listed belo
Flow
Permitted MGD Actual MGD
STMP time frame
�
Industrial
Oa0 a!a5 6.0 a I L%
most recent .1-00
Domestic
b 346/o
nextcycle
Pollutant
M-Mehl ro
�j STrn
L
Check List
lsI
Pocdue to I},
I
,.r
STMP
TMP
NPDES/Nom f yM,l
Ulf
T
Discharge Required Required by -
F equency a
Frequency
at
M
Permit Limit by EPA' 503 Sludge" POC due to SIU--
a luent
effluent
BOD
4
Q
M
TSS
L
M
4
Q
M
NH3
6-
4
Q
M
Arsenic
V
< .O
4
Q
M
Cadmium
Ir
G U0
4
Q
M
Chromium
a 00
4
Q
M
Copper
v
4
6;Lai 0(4-01S° 0
4
Q
M
11
Cyanide
L
(r
L..00
4
Q
M
Lead
i4a 4 .61
4
Q
M
v(
Mercury
4G . 000A,
4
Q
M
✓
Molybdenum
O
4
Q
M
q.Nickel
_
L, 0/
4
Q
M
Silver
L,
It CO- 4.609
4
Q
M
Selenium
4C@ 4.01
4
Q
M
Zinc
AzL
0 3' O6 0A
4
Q
M
4
Q
M
4
Q
M
4
Q
M
4
Q
M
4
Q
M
4
Q
M
'Always m the LTMP
effluent data
only in the LTMP it the POTW land applies sludge
Only in LTMP while the SIU is connected to the POi
"Only In LTMP when the
pollutant is a specific concern to the POTW (ex -Chlorides for a POTW who accepts Textile waste)
kDMRs'TMP
OurmodyM=Monthly
tach data)
Comments:
f,-
reads
eel?
t
yes
version 1 Wa103
NPDES_Pretrealment. mquest.foen.031008
Revised: August 4, 2000

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 07/06/04 Page: 1 of
Permit nc0026689 MRs Between 1 -20 { 01 ,and S 2004 Region % Violation Category: %Program Category:
I
Facility Name'r/°_ _ , _ Param Name /m,'. County.,0/, Subbasln: % Violation Action: % i
PERMIT:
NC0026689
FACILITY: Town of Denton - Denton WWTP
COUNTY: Davidson
REGION:
Winston-Salem
Limit Violation
MONITORING
OUTFALL
VIOLATION
UNITOF
CALCULATED
REPORT
/PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
VIOLATION TYPE
VIOLATION ACTION
01 - 2001
001
Effluent
Flow, in conduit or thru treatment
01/31/01
Continuous
mgd
0.3
0.38
Monthly Average Exceeded
DMR conversion
plant
history
02 - 2001
001
Effluent
Flow, in conduit or thru treatment
02/28/01
Continuous
mgd
0.3
0.42
Monthly Average Exceeded
DMR conversion
plant
history
03 - 2001
001
Effluent
Flow, in conduit or thru treatment
03/31/01
Continuous
mgd
0.3
0.5
Monthly Average Exceeded
DMR conversion
_
plant
history
04 - 2001
001
Effluent
Flow, in conduit or thru treatment
04/30/01
Continuous
mgd
0.3
0.4
Monthly Average Exceeded
DMR conversion
plant
history
05 - 2001
001
Effluent
Flow, in conduit or thru treatment
05/31/01
Continuous
mgd
0.3
0.33
Monthly Average Exceeded
DMR conversion
plant
history
O6 - 2001
001
Effluent
Flow, in conduit or thru treatment
06/30/01
Continuous
mgd
0.3
0.4
Monthly Average Exceeded
DMR conversion
plant
history
07 - 2001
001
Effluent
Flow, in conduit or thru treatment
07/31/01
Continuous
mgd
0.3
0.35
Monthly Average Exceeded
DMR conversion
plant
history
09 - 2003
001
Effluent
Mercury, Total (as Hg)
09/16/03
2 X month
ug/I
0.012
1.32
Daily Maximum Exceeded
No Action, Data
Entry Error
11 - 2001
001
Effluent
Nickel, Total (as Ni)
11/10/01
2 X month
ug/I
25
61
Weekly Average Exceeded
RIMS
Pre -Production
Violation
09 - 2002
001
Effluent
Nickel, Total (as Ni)
09/21/02
2 X month
ug/I
25
43
Weekly Average Exceeded
Proceed to
Enforcement Case
Monitoring Violation
MONITORING OUTFALL
VIOLATION
UNIT OF
CALCULATED
REPORT
/PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
VIOLATION TYPE
VIOLATION ACTION
07 -2003
001
Effluent
Cyanide, Total (as Cn)
07/31/03
2 X month
ug/I
Frequency Violation
None
05 - 2003
001
Effluent
Flow, in conduit or thru treatment
05/31/03
Continuous
mgd
Frequency Violation
None
plant
12 - 2002
001
Effluent
Temperature, Water Deg.
12/28/02
5 X week
deg c
Frequency Violation
None
Centigrade
01 - 2003
001
Effluent
Temperature, Water Deg.
01/04/03
5 X week
deg c
Frequency Violation
None
Centigrade

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 07/06/04
Page: 2 of 2
Permit:- nc0026689
^ "' MRs Between'
1 -2od1 and . 6
2004 Region.
% r
Violation Category' %
Program Category:
'Fac y Name: % .I'
.t„ I,
�. Pa�a.m Name: %
�� : -
d y
- Cou`rity:
%
Subbasin:
Violation Action: %
PERMIT: NC00266B9
FACILITY: Town of Denton - Denton WWTP
COUNTY: Davidson
REGION:
Winston-Salem
Monitoring Violation
MONITORING OUTFALL
VIOLATION
UNITOF
CALCULATED
REPORT / PPI LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT VALUE
VIOLATION TYPE
VIOLATION ACTION
09 - 2003 001 Effluent
Temperature, Water Deg.
09/06/03
5 X week
deg c
Frequency Violation
No Action, BPJ
Centigrade
12 - 2003 001 Effluent
Temperature, Water Deg.
12/27/03
5 X week
deg c
Frequency Violation
None
Centigrade
01 - 2004 001 Effluent
Temperature, Water Deg.
01/03/04
5 X week
deg c
Frequency Violation
None
Centigrade

TOWN OF DENTON
P. O. BOX 306
DENTON. NORTH CAROLINA 27239
March 1, 2004
North Carolina Department of Environment and Natural Resources
Attn: NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
RE: NPDES Permit Renewal Request - NPDES Permit #NC0026689
Town of Denton- Davidson County
To Whom it May Concern:
The Town of Denton hereby requests renewal of NPDES Permit #NC0026689. Enclosed
please find one original and two copies of EPA Forms 1 and 2A. Please note that the
Town of Denton only received the application form in January. The Town of Denton was
not aware of the new requirements for NPDES permit renewal [multiple alternate species
bioassay tests and multiple Priority Pollutant Analyses]. This is a very small town with a
population of about 1000 and the costs of these additional analyses were not included in
the current water and sewer budget. In addition, the short notice on the additional
requirements was also a problem. The Town sends out all NPDES permit analyses to a
commercial laboratory. The Town has conducted one second -species bioassay and one
set of Priority Pollutant Analyses. However, the results of these tests have not yet been
received. They will be forwarded on the appropriate forms upon receipt and review.
Could you please investigate whether there is some relief for a town this small in these
circumstances?
The Town of Denton contracts Precision Land Application of Roaring River, North
Carolina to land apply all biosolids generated at the Town of Denton facility. The Town
of Denton also has permission to deliver biosolids to the City of Lexington for
composting during any unforeseen circumstances.
I can be reached at 336-859-4460 if you need any additional information.
Sincerely
IT Dennard
Superintendent of Water and Waste

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
TUvvIn v-'
air on NLUO24��f3�j
e-✓1ewr.,L
yO-JVJn
FORM
a ir",�+ } ^[i -4S M �! M1 fit tl' 9� emu* .rJ'Ys.} j3li" xi..x .i',i�l hrY,yttC '' 1!-.t i�Y "�,�fYiL 4 YJ6L�' F+E irt-i 1-v.�.5ffy�=•.
2A
NPDES`FORM 2A AFPPL"IC`ATION OVERUIEWr'}}`'wF*',,
NPDES
�i8�".rY-,*:ns+!tYl
,. r,:'..,��. �:•t,h�P �.r'vi:);.$ ...:9Z�r:.�s�'-�'U.�.��:��i.`at`��2�'`�',n,�;3a>�`)".:�, �.�r�i;'..4�s�i�'`, ..°;
APPLICATION OVERVIEW
Form 2A has been developed in a modular format and consists of a "Basic Application Information" packet
and a "Supplemental Application Information" packet. The Basic Application Information packet is divided
into two parts. All applicants must complete Parts A and C. Applicants with a design flow greater than or
equal to 0.1 mgd must also complete Part B. Some applicants must also complete the Supplemental
Application Information packet. The following items explain which parts of Form 2A you must complete.
BASIC APPLICATION INFORMATION:
A. Basic Application Information for all Applicants. All applicants must complete questions A.1 through A.8. A treatment works
that discharges effluent to surface waters of the United States must also answer questions A.9 through A.12.
B. Additional Application Information for Applicants with a Design Flow >_ 0.1 mgd. All treatment works that have design flows
greater than or equal to 0.1 million gallons per day must complete questions B.1 through B.6.
C. Certification. All applicants must complete Part C (Certification).
SUPPLEMENTAL APPLICATION INFORMATION:.
D. Expanded Effluent Testing Data. A treatment works that discharges effluent to surface waters of the United States and meets
one or more of the following criteria must complete PaR.D (Expanded Effluent Testing Data):
1. Has a design flow rate greater than or equal to 1 mgd,
OIs required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to provide the information. -
E. Toxicity Testing Data. A treatment works that meets one or more of the following criteria must complete Part E (Toxicity Testing
Data):
1. Has a design flow rate greater than or equal to 1 mgd,
L:l Is required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to submit results of toxicity testing.
F. Industrial User Discharges and RCRA/CERCLA Wastes. A treatment works that accepts process wastewater from ally
significant industrial users (SIUs) or receives RCRA or CERCLA wastes must complete Part F (Industrial User Discharges
and. RCRA/CERCIA Wastes). SIUs are defined as:
1. All industrial users subject to Categorical Pretreatment Standards under 40 Code of Federal Regulations (CFR) 403.6 and
40 CFR Chapter I, Subchapter N (see instructions); and
2. Any other industrial user that:
a. Discharges an average of 25,000 gallons per day or more of process wastewater to the treatment works (with certain
exclusions); or
b. Contributes a process wastestream that makes up 5 percent or more of the average dry weather hydraulic or organic
capacity of the treatment plant; or
c. Is designated as an SIU by the control authority.
G. Combined Sewer Systems. A treatment works that has a combined sewer system must complete Part G (Combined Sewer
Systems).
y
fY 3'SE iy i`.hY $Y 1 "�_i3^i'-�i 5 _3 "Jii YI.';4.: h•A '�v..�H Y�3 'Y i11.„K{ F ...t. b �SLo tmk� 1F4� r- �%�.}'K -n of �2 a�.
`Oq -g �€ J
f �.BALL APP,LICANTSrMUST COMPLETE�PART C}(CERTIFICATION),
e +'� '�;'; "'�,&
s?_ :Ya+.�€4...r;.-a ws .t
EPA Form 3510 2A (Rev. 1-99). Replaces EPA fors 7550.6 & 7550-22. Page 1 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
T Vj t�Yi1 ►:IC0026669
2ene4\InL
y li�it1
BASICAPPLICATION INFOFiMAT10N
YY't„ t}�fi+*$^.a
t • K ..� Be
T,:e.k
'PART A'` BASCAPPLICATION INFORMATION FORAL '"
. ,ea._.. r,Izr:=.. 't�Wt
All treatment works must complete questions A.1 through A.8 of this Basic Application Information Packet. -
A.1. Facility Information.
Facility Name 1-TLyJn of Dt'y1 ton WnS}-P. TYZai- YYtPn1 '-PI anf-
Mailing Address Y 0, -3 Cj 6-
1c)Cr+0r) N C 2-7239
f
Contact Person _ -J e � 4 I/ Ly� � Gy C1
Title SVy Ih} E?n!.I en17 O.� VVc tev c)-n Ct.
Telephone Number 8 cJ 9- L 4& O
Facility Address 3 0 n C p U'n C t 1 Access TZ O c:. ej
(not P.O. Box) �� r1 + U r 1-1 L 27 2 ._7 `j
-A.2: -Applicant Information. If the applicant is different from the above, provide the following:
'.Applicant,Name.
Mailing Address
Contact Person
Title
Telephone Number ( )
Is the applicant the owner or operator (or both) of the treatment works? -
owner operator
Indicate whether correspondence regarding this permit should be directed to the facility or the applicant.
facility ❑ applicant
A.3. Existing Environmental Permits. Provide the permit number of any existing environmental permits that have been issued to the treatment works
(include state -issued permits).
NPDES PSD
UIC Other tom. �OSOIt d5- WQGUpiG,94,
RCRA Other
A.4. Collection System Information. Provide information on municipalities and areas served by the facility. Provide the name and population of each
entity and, if known, provide information on the type of collection system (combined vs. separate) and its ownership (municipal, private, etc.).
Name Population Served Type of Collection System Ownership
Tut —no Denton I4c -i �epavcte, To,,vr,o(.Denton
Total population served 1464
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 2 of 22

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
-1-ovv" a. ti C o02�>G�g�j Qe-h eW aL yn 1 1Ci n
e n �- h
A.S. Indian Country.
a. Is the treatment works located in Indian Country?
❑ Yes 'KNo
b. Does the treatment works discharge to a receiving water that is either in Indian Country or that is upstream from (and eventually flows
through) Indian Country?
❑ Yes No
A.6. Flow. Indicate the design flow rate of the treatment plant (i.e., the wastewater flow rate that the plant was built to handle). Also provide the
average daily flow rate and maximum daily flow rate for each of the last three years. Each year's data must be based on a 12-month time period
with the 121h month of "this year" occurring no more than three months prior to this application submittal.
a. Design flow rate
O.6
b. Annual average daily flow rate
c. Maximum daily flow rate
mgd GY'LOo1
Two Years Ano
a: 3 o 3
1. 2Uj
c.-r ZonZ_ cy 21xf3
Last Year This Year
D.40Z` 0.353
1. 4'1
1,,43
A.7. Collection System. Indicate the type(s) of collection system(s) used by the treatment plant. Check all that apply. Also estimate the percent
contribution. (by miles) of each.
Separate sanitary sewer too
❑ Combined storm and sanitary sewer _
A.B. Discharges and Other Disposal Methods.
a. Does the treatment works discharge effluent to waters of the U.S.?Yes ❑ No
If yes, list how many of each of the following types of discharge points the treatment works uses: _
1. Discharges of treated effluent
ii. Discharges of untreated or partially treated effluent
iii. Combined sewer overflow points" "
iv. . Constructed emergency overflows (prior to the headworks)
V. Other
b. Does the treatment works discharge effluent to basins, ponds, or other surface impoundments
that do not have outlets for discharge to waters of the U.S.? ❑ Yes
If yes, provide the following for each surface impoundment:
Location:
Annual average daily volume discharge to surface impoundment(s)
Is discharge ❑ continuous or ❑ intermittent?
C. Does the treatment works land -apply treated wastewater?
If yes, provide the following for each land application site:
Location:
Number of acres:
Annual average daily volume applied to site:
Is land application ❑ continuous or
❑ intermittent?
d. Does the treatment works discharge or transport treated or untreated wastewater to another
treatment works?
}1 On-e,
none.
mgd
❑ Yes X No
mgd
❑ Yes �<No
®1
EPA Form 3510-2A (Rev. 1 99). Replaces EPA forms 7550.6 8 7550-22. Page 3 of 22

FACILITY NAME AND PERMIT NUMBER:
j � °
PERMIT ACTION REQUESTED:
RIVER BASIN:
-e ��,+ - � , NCoo2.616 89
e
1Zev,z�vRL
%
If yes, describe the means) by which the wastewater from the treatment works is discharged or transported to the other treatment works
(e.g., tank truck, pipe).
If transport is by a party other than the applicant, provide:
Transporter Name
Mailing Address
Contact Person
Title
Telephone Number { )
For each treatment works that receives this discharge, provide the following:
Name
Mailing Address
Contact Person
Title
Telephone Number { )
If known, provide the NPDES permit number of the treatment works that receives this discharge
Provide the average daily flow rate from the treatment works into the receiving facility.
mgd
e. Does the treatment works discharge or dispose of its wastewater in a manner not included
in A.B. through A.B.d above (e.g., underground percolation, well injection): ❑ Yes
)SQNo
It yes, provide the following for each disposal method:
Description of method (including location and size of site(s) if applicable):
Annual daily volume disposed by this method:
Is disposal through this method ❑ continuous or ❑ intermittent?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 8 7550-22. Page 4 of 22

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
To:•te o-" N Gvoz`6616 9 2r r1 eyy n L.. �% c: d it.-i t�
-pew+c -
WASTEWATER DISCHARGES:
If you answered "Yes" to question A.8.a, complete questions A.9 through A.12 once for each outfall (including bypass points) through
which effluent is discharged. Do not include information on combined sewer overflows in this section. If you answered "No - to question
A.B.a, go to Part B, "Additional Application Information for Applicants with a Design Flow Greater than or Equal to 0.1 mgd."
A.9. Description of Outfall.
a. Outfall number
b. Location
001
D eo i-e l
2'�12.3 y
(City or town, if applicable) (Zip Code)
IDavid.3on
(County) (State)
3 7 D 3 I/ -1 ��-(10 0.9, 1''v
(Latitude) (Longitude)
C. Distance from shore (if applicable) ti tr t o I i c a b I E� it.
d. Depth below surface (if applicable) N A P 1 t C r'-J 1 �= fl.
e. Average daily flow rate (CV 200 ) J•' i53 mgd
I. Does this outfall have either an intermittent or a periodic discharge? - ❑ Yes j$j' No (go to A.9.g.)
If yes, provide the following information:
Number f times per year discharge occurs:
Average duration of each discharge:
Average flow per discharge: -
Months in which discharge occurs:
g. Is oudall equipped with a diffuser? - ❑ Yes
mgd
No
A.10. Description of Receiving Waters.
a. Name of receiving water L 1 de C
b. Name of watershed (if known) yc-iCj k 1 vn iz 1 vie 1' r:J Cl 1 M"1
United States Soil Conservation Service 14-digit watershed code (if known): _
C. Name of State ManagemenVRiver Basin (if known): y to GI k i n
United States Geological Survey 6-digit hydrologic cataloging unit code (if known): -
d. Critical low flow of receiving stream (if applicable) Nliv[- h D ;j C iJ` Cu-1 CJI� '- (A
-% Gi 1 O ) 10 L"J
acute cfs chronic
e. Total hardness of receiving stream at critical low flow (if applicable):
cis
mg/I of CaCO3
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 8 7550-22. Page 5 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
p%N V1 0 nvcoo2rvrvt�y
2ev,e�vnL
y1CLA le
-I
A.11. Description of Treatment
a. What level of treatment are provided? Check all that apply.
Primary Secondary
Advanced ❑ Other. Describe:
b. Indicate the following removal rates (as applicable):
Design BOD5 removal or Design CBOD5 removal J jO %
Design SS removal 7 eJ O e /
Design P removal
Design N removal %
Other
C. What type of disinfection is used for the effluent from this outfall? If disinfection varies by season, please describe:
GPI I OYi n C.+iO✓l
If disinfection is by chlorination is dechlorination used for this outfall? Yes ❑ No
Does the treatment plant have post aeration? Yes ❑ No
A.12. Effluent Testing Information. All Applicants that discharge to waters of the US must provide effluent testing data for the following
parameters. Provide the indicated effluent testing required by the permitting authority for each outfall through which effluent is ... .
discharged. Do not include information on combined sewer overflows in this section. All information reported must be based on data
collected through analysis conducted using 40 CFR Part 136 methods. In addition, this data must comply with QA/QC requirements of.
40 CFR Part 136 and other appropriate QA/OC requirements for standard methods for analytes not addressed by 40 CFR Part:136. -At a
minimum, effluent testing data must be based on at least three samples and must be no more than four and one-half years apart. -
1>ATi`
A 1=2C.,^' JAi i V2 Ay
�� 1
Outfall number. �i(Zt�IA CII—( pCCf�M
` r -=/ 3xrz
:MAXIMUM�DAILY VALUE,
+* �<r `2 "AVERAGE DAILY VALUEc t,
PARAMETER
Value's .+
Unrts x
`
`• I Value
+ Uriits 3 ri
=�w Number a J amples,
<
t� ,,
pH (Minimum)
6. 5.5-
s.u.
pH (Maximum)
!. 4
S.U.
._'r'.`, f4•
s �' sr{.'�
Flow Rate
'
o.
Temperature (Winter)
1 9
C* C_
14
Temperature (Summer)
ry
2 1
L L
2-4
C—
*For pH please report a minimum and a maximum daily value
AVERAGE DAILYf DISCHARGE
Un115-Conc.-_Units
?' F Number of �:
z ,z
, } �s•
�.^`a
z.it�., >7,,oSamples.�,
*
LLj
CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS Q AmII'�11 Sd5 C�"LJI rC.lCd 'P�-) C'c ,nm ei C,f (1, L0�0 , C-fr-
BIOCHEMICAL OXYGEN
BODS
5.`j
M (L
Z.�?,U
Yl'1 L
DEMAND (Report one)
CEO
FECAL COLIFORM
L'
Co cnies
OOY✓1
LI
GU and,
ioo'n
I 4�
LICulor:yt
I�Om
TOTAL SUSPENDED SOLIDS (TSS)
I `t
VY7 I L-
1. `�-✓'
m) i L.
I L3 (co(--
sra
END OF PARTVA�:` *� ` FAY
7`aF s y
���REFER,�TO�THESAPPLICATION�OVERUIEW'(PAGE 1i)TO DETERMINE�WHICH OTHER�PARTS �-;;
-3 t : fk t i.�,..$'-.. t� Y;i.�J�E �+- 2." T' -. �XT"� ��zC ��.� ��[ �. �.�'+i
.'tom _ . � ..� -•�'. .'rS-? i'�' .�`M . -c ..
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22, Page 6 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
TbN�n off- I-1coo2�v89
(Zenewal
J
YC kil)
tier+vn
g ,^" ' p't r "." }..fir+; 3d' ; r i r* +, t•r "". "'�- ! Kx '�" r k ' 'v %^ x.?" s
BASIC APPLICATION'INFORMATIONs! � b
PART B %Y' �' ADDITIONAL APPLICATION INFORMATION FOR AP PLICANfS'M1TH'ADESlGN FLOW GREATER THAN OR'.
EQ114LT001'MGD.(100000gallonspeiday) �� v
All applicants with a design flow rate 2 0.1 mgd must answer questions BA through B.6. All others go to Part C (Certification).
B.1. Inflow and Infiltration. Estimate the average number of gallons per day that flow into the treatment works from inflow and/or infiltration.
gpd ( P 0 NOT )4t-30V"')
Briefly explain any steps underway or planned to minimize inflow and infiltration.
f7�'��Cr� (.._e Ltkuvt(( :oIJecA-ivr, 14lei, .5 f'nQlcl. Vl Gi 5,15+evy- -Au
(-+e+rc+- 1-eak5
B.2. Topographic Map. Attach to this application a topographic map of the area extending at least one mile beyond facility property boundaries. This
map must show the outline of the facility and the following information. (You may submit more than one map if one map does not show the entire
area.)
a. The area surrounding the treatment plant, including all unit processes.
b. The major pipes or other structures through which wastewater enters the treatment works and the pipes or. other structures through which
treated wastewater is discharged from the treatment plant. Include outfalls from bypass piping, if applicable.
c. Each well where wastewater from the treatment plant is injected.. underground. N/A
d. Wells, springs, other surface water bodies, and drinking water wells that are: 1) within '/a mile of the property boundaries of the treatment
works, and 2) listed in public record or otherwise -known to the applicant. O/A .. -
e. Any areas where the sewage sludge produced by the treatment works is stored, treated, or disposed.
I. If the treatment works receives waste that is classified as hazardous under the Resource Conservation and Recovery Act (RCRA) by truck, rail,
or special pipe, show on the map where the hazardous waste enters the treatment works and where it is treated, stored, and/or disposed. N j
B.3. Process Flow Diagram or Schematic. Provide a diagram showing the processes of the treatment plant, including all bypass piping and all
backup power sources or redunancy in the system. Also provide a water balance showing all treatment units, including disinfection (e.g.,
chlorination and dechlonnation). The water balance must show daily average flow rates at influent and discharge points and approximate daily flow
rates between treatment units. Include a brief narrative description of the diagram. -
BA. Operation/Maintenance Performed by Contractor(s).
Are any operational or maintenance aspects (related to wastewater treatment and effluent quality) of the treatment works the responsibility of a
contractor? ❑ Yes .X No
If yes, list the name, address, telephone number, and status of each contractor and describe the contractor's responsibilities (attach additional
pages if necessary).
Name:
Mailing Address:
Telephone Number: 1 )
Responsibilities of Contractor:
B.5. Scheduled improvements and Schedules of Implementation. Provide information on any uncompleted implementation schedule or
uncompleted plans for improvements that will affect the wastewater treatment, effluent quality, or design capacity of the treatment works. If the
treatment works has several different implementation schedules or is planning several improvements, submit separate responses to question 6.5
for each. (If none, go to question B.6.) �11L r a P P L. 0 A f3 L_IE -
a. List the oulfall number (assigned in question A.9) for each outfall that is covered by this implementation schedule.
b. Indicate whether the planned improvements or implementation schedule are required by local, State, or Federal agencies.
❑ Yes ❑ No
EPA Form 3510-2A (Rev. 1-99). Replaces EPA farms 7550-6 R 7550-22, Page 7 of 22

.FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
STDeri-rooil tvCy002-6b69
2eviewex- L
-/aJ1gfiIr)
C. If the answer to B.5.b is "Yes," briefly describe, including new maximum daily inflow rate (it applicable).
d. Provide dates imposed by any compliance schedule or any actual dates of completion for the implementation steps listed below, as
applicable. For improvements planned independently of local, State, or Federal agencies, indicate planned or actual completion dates, as
applicable. Indicate dates as accurately as possible.
Schedule Actual Completion
Implementation Stage MM/DD/YYYY MM/DD/YYYY
- Begin Construction
- End Construction
- Begin Discharge
- Attain Operational Level
e. Have appropriate permits/clearances concerning other Federal/State requirements been obtained? ❑ Yes ❑ No
Describe briefly:
B.6. EFFLUENT TESTING DATA (GREATER THAN 0.1 MGD ONLY).
Applicants that discharge to waters of the US must provide effluent testing data for the following parameters. Provide the indicated
effluent testing required by the permitting authority for each outfall through which effluent is discharged. Do not include Information
on combine sewer overflows in this section. All information reported must be based on data collected through analysis conducted
using 40 CFR Part 136 methods. In addition, this data must comply with QA/QC requirements of 40 CFR Part 136 and other appropriate
- QA/QC requirements for standard methods for analyzes not addressed by 40 CFR Part 136. At a minimum effluent testing data must be
based on at least three pollutant scans and must be no more than four and on -half years old. .. .. ..
A T A F t2o r+^
001•.-_1AN'Io�A2-1_bCc c`Mfie2 26o3
OulfallNumber: .
-L
MAXIMUM DAILY'Is;~
a "i�''�{ h .�`F. r .,+, .�
r
-•-,. t „N :-,.-
`r- i'- a:
a .✓
*"POLLUTANT
< s-t"�'-1'
DISCHARGE,{'f .1
AVERAGE DAILY DISCHARGE
4jT'- ,,,Yt +4, 4�,e I. Y jkr
H{ANALVTICAL>*
ii4 r?'
s Mw1v1w
xm_,
r ecr mr,vp
f„ - +.
k=
t n� 4
Number
.Unit'sy
w`'Conc
-..
r-,Unrts„�,
of
�. artg
ra
as-t-::- n.�,.,s i:i:.y ..v :rs*=
zN .-_-. .: r>
a, ...:xr ..,
i
e„'•-.:.�
•Samples:.
CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS A,r., R+-YSEA aur.,OurrGD 15y c.>�+r+'K�-�-, •'+� LH'13
AMMONIA (as N)
(V • �-
YYl t; / L
y1'1 J L
I CJ
r
CHLORINE (TOTAL
RESIDUAL, TRC)
y$i-irl.
17
t�
t 1
�bl. •'',�,
t s4�
r ':
459,0 r <-I Ca
..
F4,
DISSOLVED OXYGEN
(3. O `l
yvs. i
l S b
NITROGEN (T40+
:Z 1 E^ B
rn,5 f L
1 •1 Y
MDC )L
15
N L.i r C)s
NFPo4TEPLIJ 1 GITF
NITanr_EN
1
OIL and GREASE
t-4y;.VA-VA
N`!
nTA
`
PHOSPHORUS (Total)
8Z•9 9
M I L,
Q, E?�j
11'�e IL-
1
TOTAL DISSOLVED SOLIDS
N U
(TDS)
DATA
174TA
OTHER
^ yt -.a c'L'-at
r#a; 4END,OFPARTB X aF `,
.7,r
REFER TO THESAPPLICATION OVERVIEW (PAGE't) TO DETERMINEaWHICKOTHER PARTSft
sus , w i 3q >z- tz "+r yv"'• ,a,,, �. {
x OF FORM 2A�YOU MUST COMPLETE `ice ; X=z � r Al
_
.ii,,..,et
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7560-6 8 7550-22. Page 8 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED: RIVER BASIN:
ow rn 0. N Lo02E E� gy
2ec, r=��n 1 yctd ►mot n
ID t n t c
i {t- £' 1� a^. `�Y �f ^+ �"tv^. bia�'S +e. ' `•yy ri Sa S.�'�
BASIC APPLL ICATION INFORMATION *.
x * Tt ({rr�
'u-
PART C. CERTIFICATION a �. i4 x t t♦♦. d y yy
C
tY. •l. �.3 k. e. _ S i Aim. ..I\ L.diL- d�..P
All applicants must complete the Certification Section. Refer to instructions to determine who Is an officer for the purposes of this
certification. All applicants must complete all applicable sections of Form 2A, as explained in the Application Overview. Indicate below which
parts of Form 2A you have completed and are submitting. By signing this certification statement, applicants confirm that they have reviewed
Form 2A and have completed all sections that apply to the facility for which this application is submitted.
Indicate which parts of Form 2A you have completed and are submitting:
Basic Application Information packet Supplemental Application Information packet:
❑ Part D (Expanded Effluent Testing Data) (i o'u0ow)
❑ Part E (Toxicity Testing: Biomonitoring Data) ('
Part F (Industrial User Discharges and RCRA/CERCLA Wastes)
❑ Part G (Combined Sewer Systems)
,�ycY
ALL APPLICANTS MUST COMPLETE THE FOLLOWING CERTIFICATION'.y,,
a r rsyp�u,(}
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 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 fine and imprisonment
for knowing violations.
p�t1n�1Y —.�.� +'-Y III tc_ockt;vV f CA' VVCute-VCt- )Cll l4VCiS 4"e,
Name and official title •Je
Signature
E"5 44 �Ci
Telephone number _ (3�)
Date signed'
Upon request of the permitting authority, you must submit any other information necessary to assure wastewater treatment practices at the treatment
works or identify appropriate permitting requirements.
SEND COMPLETED FORMS TO:
NCDENR/ DWO
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550 6 & 7550-22. Page 9 of 22

FACILITY NAME AND PERMIT NUMBER:
U
PERMIT ACTION REQUESTED:
RIVER BASIN -
To V-4 n -{
Deity IvC002C &&C)
Re-Y-) e-VV CL
yC,d�"irk
9 v'<r:,` RCf^ { t�'t %.. M 1 d 1$ t Y.. 4 i
S
UPPLEMENTALAPPICATION INFORMATION ti x
iPART ^-q�.•< Ztt- {yis
D' E..sX.u�PANDEu..
N�eL
a ,rtyxap'�a',,`,n.».,''y'l,,'h��QJ�,..giiA'�yy.}
i M _ hP,1 i's.}. �M111',},,.
-.n�i•T�_:'4`.av2 w..�l' .: jE1i154A
Refer to the directions on the cover page to determine whether this section applies to the treatment works.
Effluent Testing: 1.0 mgd and Pretreatment Works. If the treatment works has a design flow greater than or equal to 1.0 mgd or it has (or is required
to have) a pretreatment program, or is otherwise required by the permitting authority to provide the data, then provide effluent testing data for the following
pollutants. Provide the indicated effluent testing information and any other information required by the permitting authority for each outfall through which
effluent is discharged. Do not include information on combined sewer overflows in this section. All information reported must be based on data collected
through analyses conducted using 40 CFR Part 136 methods. In addition, these data must comply with OA/OC requirements of 40 CFR Part 136 and
other appropriate OA/OC requirements for standard methods for analyzes not addressed by 40 CFR Part 136. Indicate in the blank rows provided below
any data you may have on pollutants not specifically listed in this form. At a minimum, effluent testing data must be based on at least three pollutant
scans and must be no more than four and one-half years old.
Outfall number: (Complete once for each outfall discharging effluent to waters of the United States.)
:MAXIMUM DAILY DISCHARGE'•r -- i".gVERAOE DAILY;DISCHARGE
�'�, '
3 y�o
k:'v}., POLLUTANT tizn •1 e t utTyfi des : ,, 4& } .'aa°`tr'•s_. za "g, ','yY e Number�lr "ANALYTICAL 4MUMDLI•
�"r t
;d`•°7w x C' 1 vz' d Conc , -'Units Mass . UnttS 'jConc ; Units aMass "
.:Sam les ,: � •� .��,-;t}�ss
METALS (TOTAL RECOVERABLE), CYANIDE, PHENOLS, AND HARDNESS.
ANTIMONY
ARSENIC"
BERYLLIUM -
-
-
CADMIUM
CHROMIUM
COPPER,
LEAD
MERCURY
NICKEL
SELENIUM
SILVER
THALLIUM
ZINC
CYANIDE
TOTAL PHENOLIC
COMPOUNDS
HARDNESS (as CaCO3)
Use this space (or a separate sheet) to provide information on other metals requested by the permit writer
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550.6 8 7550-22. Page 10 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTEDI
RIVER BASIN:
T0tiN r p_.
r`1coa2rvC769
fZ���ev.�LzL.
�cut k v�
per U
Chronic:
NOEC
%
%
%
IC25
%
%
%
Control percent survival
%
%
%
Other (describe)
m. Quality Control/Quality Assurance.
Is reference toxicant data available?
Was reference toxicant test within
acceptable bounds?
What date was reference toxicant test
run (MM/DD/YYYY)7
Other (describe)
E.3. Toxicity Reduction Evaluation. Is the treatment works involved in a Toxicity Reduction Evaluation?
❑ Yes . ❑ No If yes, describe:.
E.4. Summary of Submitted Biomonitoring Test Information. If you have submitted biomonitoring test information,or information regarding the
cause of toxicity, within the past four and one-half years, provide the dates the information was submitted to the permitting authority and a summary
of the results. -
Date submitted: / / (MM/DD/YYYY)
Summary of results: (see instructions) - ..
i `j& h�'4 r ap � h n54 v.- K dMe, �a mpy„ Y_��q� ��•`
a�«��REFER�TO�THE'AQPLICATyION OVERVIEW (PAGE 1)�TO7DETERMINE WHICH OTHER�PARTSu�,
� ;�-d:k - OF, FORM 2A;Y,OUzMUST1COMPLETE•:'�"�f�i-`�,�,, » #�.�h�i;'ix �_;�,a s
y���3���
,� .��.�,~,� x �� sue.., .w>, � � _ _�,,, _��.���^��€--i„�>E,�•.�� , ?�=..�� .�_�, r�
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 17 of 22

FACILITY NAME. AND, PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Ta�v n o
en(� t� GOO'L�C, gy
2eh e vv a- L
Yc��l lLi Y�
*K_r e F
SUPPLEMENTAL APsPLICATION INFORMATIONS #.,
t,4
f
PART FI INDUSTRIALS USER DISCHARGES AND RCRA/CERCLA WASTES may, -' t r � ` -. z
,
All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.I. Pretreatment program. Does the treatment works have, or is subject of, an approved pretreatment program?
XYes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
L
a. Number of non -categorical SIUs.
II
b. Number of CIUs. 1
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following Information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works.. Submit additional pages
as necessary. -
Name: G 51 e
�• G 1� (:iX I I ❑
Mailing Address: ..
Oe n+O yl . ry C' 27 2 39
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge. .., .. -
reyt;l� open i ;ors (Hos•ieN)
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
i
Principal product(s): H (J ie i' t.t / S- G C-IG S
Raw material(s):
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent. ,
4r COO gpd continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ', Yes ❑ No
b. Categorical pretreatment standards ❑ YesNo
If subject to categorical pretreatment standards, which category and subcategory?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
C vi 4LwL1
hiu� i �t
Pag18 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Tvw t� o
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes KNo If yes, describe each episode.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE: JERIMEMM
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RGRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes X No (go to F. 12)
F.10. Waste transport. Method by which RCRA waste is received (check all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
FA 4. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
II yes, describe the treatment (provide information about the removal efficiency): "
b. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
�j
END�OFPARTFkri
x}REFER�TO THE'APPLICATIONOVERVIEW (PAGE 1) TOXDETERMINE,WHICH OTHER PARTS
?OF FORM 2A�YOU MUST GOIVI > � rN
PLETE M r
r, ' ;. 1
y
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 19 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
1 c W f", U
fZCnGuVet-L
j/ad I��v1
SUPPLEMENTAL -,APPLICATION INFO'RMATION`r . - k A ''� f
WA
..�,.�.xn~2��..,a.:'M?�.�'..+�...,,.i� ,� .�;a� �f-�.>J.^,`>z3 �i c`a.aar.�• ••,�.��ar �'?c�'i
PART G COMBINED:SEWER SYSTEMS N:QTs>L�`�P PtLIa�G°AT`"g L;E `7*0'"��"
�.�i_
,, a-r.�.--,... x1�la- hN a.t�'t�,ri... Sf .. .....li r.t<4—. ..�tSt ...rx ev.Xz< •Ct' r. $:.'S:
If the treatment works has a combined sewer system, complete Part G.
G.1. System Map. Provide a map indicating the following: (may be included with Basic Application Information)
a. All CSO discharge points.
b. Sensitive use areas potentially affected by CSOs (e.g., beaches, drinking water supplies, shellfish beds, sensitive aquatic ecosystems, and
outstanding natural resource waters).
C. Waters that support threatened and endangered species potentially affected by CSOs.
G.2. System Diagram. Provide a diagram, either in the map provided in CA or on a separate drawing, of the combined sewer collection system that
includes the following information.
a. Location of major sewer trunk lines, both combined and separate sanitary.
b. Locations of points where separate sanitary sewers feed into the combined sewer system.
C. Locations of in -line and off-line storage structures.
d. Locations of flow -regulating devices.
e. Locations of pump stations.
CSO OUTFALLS:
Complete questions G.3 through G.6 once for each CSO discharge point. ... _
G.3. Description of Outfall. -
a. Outfall number - _ ..... _.
b. -Location
(City or town, if applicable) (Zip Code)
(County) (State) -
(Latitude) (Longitude)
C. Distance from shore (if applicable) ft.
d. Depth below surface (if applicable) ft.
e. Which of the following were monitored during the last year for this CSO?
❑ Rainfall ❑ CSO pollutant concentrations ❑ CSO frequency
❑ CSO flow volume ❑ Receiving water quality
I. How many storm events were monitored during the last year?
GA. CSO Events.
a. Give the number of CSO events in the last year.
events (❑ actual or ❑ approx.)
b. Give the average duration per CSO event.
hours (❑ actual or ❑ approx.)
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 20 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Tov';'n ,a G00 2-06 89
IZcv� C�Uv o-L,
trh'Ua Nr s.:r"�Y tF-a,rrt'--v74T er7`x.,� nY f3T'tr{,k's",,, .v51.a`r s t .a -t .v.
• `,.
i 7eYi-i•'
a N.1141 yi"3,K4 %.-nv}
SUPPLEMENTAL APPLICATION INFORMATION 4F� ?
4 ..a e .§r7nf
.!:.z�'?
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCL�`AMWAST�ES h Sga' i.. " n,ii_ �a� '�'4,�;�j
«.
All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.1. Pretreatment program. Does the treatment works have, or is subject of, an approved pretreatment program?
x Yes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs. Z-
b. Number of CIUs.
SIGNIFICANT INDUSTRIAL USER INFORMATION: -
Supply the following Information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works.. Submitadditional pages
as necessary.
Nam a: cr ry)U 1'�YY0 d1,1C_+��- 1'�C.Ort'JQr(.l.�P_--(A
Ih-
Mailing Address: 9 Z V V P.S+ LAI' , Jil-QP t
7t>.v) Ir-o n 2 12 39
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge. .. _
IL+i0CcoC,-"✓�q�
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Fu.,r t' N ck C d 5
Raw material(s):
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent
I S CCU gpd ( continuous or V11 intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits KYes ❑ No
b. Categorical pretreatment standards KYes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
EPA Form 3510-2A (Rev. 1-98). Replaces EPA forms 7550-6 8 7550.22. --1 Page 18 of 22
j Y 1 C'YYyI (G

FACILITY NAME AND PERMIT NUMBER:
Tvt� I� o
t"� GC.)C3z��>��,
PERMIT ACTION REQUESTED:
RIVER BASIN: -
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes XNo If yes, describe each episode. -
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes No (go to F.12)
F.10. Waste transport. Method by which RCRA waste is received (check all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation.Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities? -
❑ Yes (complete F.13 through F. 15.) )<No - ..
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRAior other remedial waste originates (or is excepted to origniate in
the next five years). .
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets it necessary.)
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
If yes, describe the treatment (provide information about the removal efficiency):
b. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
77 qt344A r� 5R &_
FARTs�F�'k>��f��,,`"`�mk�'��
,�""�RE�FER TO��H�APP�La3ICAT170FpOORM 2A�YpFO, U MUST1�'COMP.�LERE�NEW$j'y�H+t�IC OTHE � ��TyS�"sri�d
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 19 of 22
1, rl zYmu "i'rt:c�uC+S

:Y
FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVE`R /BASIN:
Tav�✓1 .� tv C-00'L(,C1 �9 IZGv� �'\N CL 7 ki h
E n +it
PART F INDUSTRIAL'USER DISCHARGES�AND RCRA/C ERCLA WASTE§{ �t {
v
All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.1. Pretreatment program. Does the treatment works have, or is subject ot, an approved pretreatment program?
xYes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs. 2-
b. Number of CIUs.
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.B and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SL1 discharging to the treatment works.. Submit.additional pages
as necessary. Name: 5u_Yl'aiL 1-kosierujMtl`S -
Mailing Address: % 3'7 �Pt?el C_U G IL A-V.26'1 tAe
Z'7 2 ?,9 .
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge. ... -
F.S. PrincipalProduct(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s):
Raw material(s):
F.B. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
9 7 _5 0 gpd ( continuous or L intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits X Yes ❑ No
b. Categorical pretreatment standards ❑ Yes X'No
If subject to categorical pretreatment standards, which category and subcategory?
EPA Form 3510 2A (Rev. 1-99). Replaces EPA forms 7550-6 8 7550-22.
S LAY r rti µ_
}-)os I
Page 18 of 22

FACILITY NAME AND PERMIT NUMBER:
—j—vL.v r1 y
c����
PERMIT ACTION REQUESTED:
2c�revvaL.
RIVER BASIN: '
yadlt:i��
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes XNo It yes, describe each episode.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes No (go to F.12)
F.10. Waste transport. Method by which RCRA waste is received'(chock all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) No
FA 3. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years). -
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
It yes, describe the treatment (provide information about the removal efficiency):
to. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
6j a fifix,
-tc `c r�. ,, r �.r .� y #,.,#•.>dim,,t�`us.,....�'`*'a�33�Sa�i'-fix' a''� r
REFER TO'THEIAPPLICATION OVERVIEW1 A. 1.1— 1ETERMINE4WHICH OTHERsPARTSv
;r'k.Yr.ta,uiit;'xT;, !,r.k.%�e3�.'° autut'S,er^:�•e`:v:..r..i;'S"?.:.4k tu3�'Tv. 'N.?sta..v. ix,irf,Y a..+it,rrs�'L�S ,Y:iF:ir,„i.
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22,
j U,VVrti 1+
I-IDSi eve
Page 19 of 22

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
) CJLu 11 ('tf
D<z +lol-) NC-C,C) �g��
Qe✓�e n-L
ycLctl�iv�
C. Give the average volume per CSO event.
million gallons (❑ actual or ❑ approx.)
d. Give the minimum rainfall that caused a CSO event in the last year
Inches of rainfall
G.S. Description of Receiving Waters.
a. Name of receiving water:
b. Name of watershed/river/stream system:
United State Soil Conservation Service 14-digit watershed code (if known):
C. Name of State Management/River Basin:
United States Geological Survey 8-digit hydrologic cataloging unit code (if known):
G.6. CSO Operations.
Describe any known water quality impacts on the receiving water caused by this CSO (e.g., permanent or intermittent beach closings, permanent or
intermittent shell fish bed closings, fish kills, fish advisories, other recreational loss, or violation of any applicable State water quality standard).
REFER�TO�T�HEAP�PLIC?T�IOF'
ICH#O�ER�_¢PAR��T�
ORM 2IA YOU IVIUST�COMPLETE�I�r�W a
EPA Form 3510-2A (Rev, 1-99). Replaces EPA forms 7550-6 & 7550.22. Page 21 of 22

S
12" SCREEE 1—_ GH TMBER 1—_ rEUXPJ@TWoGCD
8"h10=
DISINf. v�i (AERSATIDDOE) 1yI MH �IS ODiFAt

DESCRIPTION OF TREATMENT PROCESS:
THE TOWN OF DENTON WASTE PLANT HAS A CAPACITY
-- OF .800 MGD AND UNITS AT THE PLANT ARE AS
FOLLOWS: AHEILI-SEIVE, GRIT CHAMBER, FOUR
INFLUENT PUMPS, TWO OXIDATION CHANNELS, FOUR
SECONDARY CLARIFIERS, TWO DIGESTORS, TWO
TERIARY FILTERS, CHLORINE CONTACT CHAMBER
WITH DECHLORINATION, EFFLUENT FLOW METER,
LAND APPLICATION CAPABILITIES WITH SIX DRYING
BEDS FOR BACKUP IN CASE OF INCLIMATE WEATHER. A
STANDBY GENERATOR IS ON SITE FOR POWER
FAILURES.

Michael F. Easley
Governor
March 4, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jeff Dennard
Town of Denton
PO Box 306
Denton, North Carolina 27239
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: Evaluation of Copper and Zinc per DWQ's Copper and Zinc Action Level Policy
Town of Denton WWTP
NPDES No. NCO026689
Davidson County
Dear Mr. Dennard:
This office has received a copy of your letter dated February 5, 2004 documenting
the Town's actions to rule out copper and zinc as causative effluent toxicants. DWQ's
Copper and Zinc Action Level Policy was triggered by the February and March 2003
Whole Effluent Toxicity test failures. An evaluation of reasonable potential to violate
instream action levelsTotal for these parameters was conducted by the NPDES Unit and
NOVs dated February 24, 2003 and May 23, 2003 were sent to the facility.
Initially, the City submitted correspondence dated June 20, 2003 to the Winston-
Salem Regional Office indicating that the Town would accept the copper and zinc permit
limits because no additional money was available to perform TIE testing.
Your February 5, 2004 letter indicated that no additional effluent toxicity permit limit
violations occurred during the nine month review period and that the Town felt "pressured" to
accept the limits based on the Town's operating budget and manpower shortages. The letter
indicates that the Town has reevaluated its initial position to accept the limits and currently does
not want to accept copper and zinc permit limits.
A review of the facility's toxicity self -monitoring data from March 2003 through
February 2004 indicates that no additional effluent toxicity permit limit violations occurred
during the review period.
Based on information contained in the most recent correspondence-subrmtted-by-the—
I,--. r r n nn I r
Town, our office will not recommend the NPDES Permit be reopened to -include copper. ana
permit limits at this time. 1 [I� 11
MAR c 4 2004 ---
NIEDENM
Customer Service
800 623-7748
Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621
[phone]

Page 2
Town of Denton -Copper and Zinc Action Level Policy
March 4, 2004
Please be reminded that the City remains subiect to the provisions of DWO's Copper and
Zinc Action Level Policy should additional effluent toxicity violations occur in the future (ie
two effluent toxicity permit limit violations occurring within the toxicity testing calendar quarter
defined by the NPDES Permit).
Please feel free to contact me or Kevin Bowden at [phone] if you have
any questions.
Sincerely,
Matt Matthews, Supervi sor
Aquatic Toxicology Unit
cc: Steve Tedder/Winston-Salem Regional Office
Steve Mauney/Winston-Salem Regional Office
Dave Goodrich-NPDES Unit
Susan Wilson-NPDES Unit
Pretreatment Unit
Kevin Bowden -Aquatic Toxicology Unit
Madelyn Dominy, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta, Georgia 30303
Aquatic Toxicology Unit Files
Central Files

[Fwd: FW: Town of Denton NPDES Permit Renewal]
Subject: (Fwd: FW: Town of Denton NFDF-5 Permit Renewal)
From: valery stepkcns <valery.stCp6ensQncmaiI.nct>
Date: Fri, ZO Feb 2001 10:0�:22 -0500
To: Tom 5eInick <-[ [e-mail]>
subject: FW: Town of Denton Nf Dr 5 Ter'mit renewaI
From: "Groome, Martie"<[e-mail].u5>
Date: Wed, Is Feb 2.00h 1 I:03r59 -0500
To: "Valery steFhens" <[e-mail]>
-----Original Message -----
From: Groome, i�iartie
Sent: Friday, February 13, 2004 4:08 PM
To: 'Valerie Stephens'
Subject: FW: Town of Denton NPDES Permit Renewal
-----Original Message -----
From: Groome, Martie
Sent: Friday, February 13, 2004 4:06 PM
To: 'Tom Belnick'; 'Valarie Stephens'
Cc: 'Jeff Dennard'
Subject: Town of Denton NPDES Permit Renewal
Alan
AINo2��-8�
Nak -fir npd
TB vo/ciy
This email wilIcon firm my recent Eel ep6onc conversation with Tom I)elnic� concerninS the Town of Denton NI DI-5 Ferri it
Renewal. I am assisting the Town of Denton in the renewal of their NrDT 5 Permit. The Nr[)r 5 Permit application is clue
on Marcb't. The Town received the application form in lateianuary. The Town of Denton was not aware of the new
requir-ements for Permit renewal [multiple Z species bioassay tests and multiple f riority rollutant Analyses).. Tki5 is a very small
town [— I 000 POPulation] and the costs of these analyses were not included in the current water and sewer budset. In
addition, the short notice on the additional recluiremcnts is also n problem. The Town will attempt to conduct one set of
analyses prior to the application one date. However, it is unliLcly that the results will 6e available. T6crefore.. the Town will
submit the rest of the application by the deadline and will forward the results of the first set of sets upon receipt and review.
COUld you please investiSate wketbcr tbcrc is some relief for a town this small in tkcse circumstances.
T 6anlcyou.
Martic Groome
556-674-6661 (home)
jj6-4jj-7229 [�ity of Greensboro)
C
I of 1 2/23/2004 10:48 AM

(
�vtnP�irz�

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street Wins ton-Salem,%North Carol na, L1107 - ....
May 23, 2003
CERTIFIED MAII
RETURN RECEIPT REQUESTED
Mr. Jeff Dennard
Town of Denton
PO Box 306
Denton. North Carolina 27239
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testin
Copper and Zinc Action Level Policy
NPDES Permit No. NC0026689
Town of Denton WWTP
Davidson County
Dear Mr. Dennard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
March 2003 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper
and Zinc Action Level Policy. The correspondence included prospective permit limits for copper and
zinc and stated that the trigger for implementing the policy would be two or more WET limit violations
which occur during a toxicity testing calendar quarter. Please note that the second WET limit violation
has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and/or
zinc permit limit. Notification is due by June 23, 2003.
••
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by
June 23. 2003.
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or
zinc as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above. ,you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion. The report is due by
February 23. 2004.
Three copies of the final report shall be submitted to:
North Carolina Division of Water QualitN
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh. North Carolina 27699-1621
Failure to notify DWQ of your acceptance of a copper and/or zinc limit. failure to notify DWQ
of your option selection or failure to make acceptable demonstration to DWQ that copper and/or zinc are
not causative effluent toxicants within the stated time frames will result in reopening of the NPDES
Permit to include copper and/or zinc numeric limitations. as appropriate.
If the effluent is toxic. then we expect work to commence immediately with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and zinc as causative effluent toxicants.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - htlp://wcvw.esb.ennstate.nc.Lis/. Click on the Aquatic Toxicology
Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Vlatt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
cc: Winston-Salem Regional Office
Susan Wilson-NPDES Unit y
Pretreatment Unit
Madolyn Dominy-USEPA Region Iv
Central Files
Aquatic Toxicology Unit Files
Sincerelv.
Steve lylauney
Acting Regional Water Quality Supervisor
Atlanta Federal Center, 61 Forsyth St.. SW, .Atlanta. GA 30303

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
585 Waughto"In Street Winston-Salem, North Carolina 27107
April 24, 2003
CERTIFIED MAIL _ _ ----- —
RETURN RECEIPT REQUESTED I
G_ Q
Mr. Jeff Dennard `� — —1 i
Town of Denton j I APR 2 $ 2003
PO Box 306
Denton, North Carolina 27239 L__
Dc..n - :. ER Btv TY
FJm.T SG...'�E [iRgniKH
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NCO026689
Town of Denton WWTP
Davidson County
Dear Mr. Dennard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
February 2003 indicates a violation of the toxicity limitation specified in your NPDES Permit -You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition. this correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by two or more toxicity limit violations that occur during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and the data indicate that the levels
of copper/zinc in your effluent have the potential to cause an exceedance of the NC water quality action
level for this (these) parameter(s) in your receiving stream during low stream flow conditions. The
policy states that whenever a facility experiences two or more toxicity limit violations during a toxicity
testing calendar quarter, the NPDES Permit will be modified to include numeric limits for copper and/or
zinc UNLESS the permittee provides one or more of the following:
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

2
The Division has evaluated your copper and/or zinc monitoring data. The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the
copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
copper permit limit is 14 pg/L and your prospective zinc permit limit is 111 µg/L.
The permittee, upon experiencing two or more toxicity limit kiolations during a toxicity
testing calendar quarter must either provide DWQ with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
W
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation. DWQ approval of options 1-3
(previous page) is not necessary as the Division expects work to rule out
copper and/or zinc as causative effluent toxicants to begin immediately upon
the second WET permit limit violation.
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
---.... --- - -- --- -- -- - - -
-"-- iiidicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive a—
s to copper -- - -
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh. North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include eupper and/or zinc numeric limitations, as appropriate.
If the effluent is toxic, then we expel vlork to commence immediately with toxic effluent
samples. Failure to initiate work with toxic c1'11uent samples during the study period is unacceptable and

3
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more toxicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper and/or zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You may consider entering into a Special Order by Consent (SOC) with DWQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://www.esb.enr.state.nc.us. Click on the "Aquatic
Toxicology" Unit and go to the prompt "DOWNLOADS" located at the bottom of the page. This web
site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater Treatment
Plants." Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
Steve Mauney�
Acting Regional Water Quality Supervisor
ATTACHMENTS
cc: Winston-Salem Regional Office (no attachments)
Susan WilsomNPDES-Unit,,(no attachments)
Pretreatment Unit(no attachments)
Madelyn Dominy-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA
30303 (no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)

[Fwd: Ourfall Location:]
,u oo�66sy
To: Charles Weaver <Charles.
Hi ya,
See attached email.
Good catch! I should have plotted the tat/longs provided to me. I
certainly didn't plot this; one. Your guess of 35 37 27 sounds right, but
that puts the outfall still on Lick Creek, I'll see what: I can dig up at
the region rather than contacting the facility. I'll get back to you on
this.
Lauren
Mail:
Lauren Elmore
Coalition Coordinator
NC Division of Water Quality
1621 Mail Service Center
Raleigh NC 27699-1621.
Location:
440i Reedy Creek Road
Raleigh, N.C. 27607
Phone: [phone]
Fax: [phone]
OUTFALL LOCATION!
LAT: 37 37' 27''
LONG: 90 , 09' 17''
----- Original Message -----
From: "Lauren Elmore" <[e-mail]>
To: <[e-mail]>
Cc: "Roger Spach" <[e-mail]>; "John R Mease"
<[e-mail]>; <[e-mail]>
Sent: Sunday, April. 13, 2003 2:00 PM
Subject: Outfall Location?
> Hello!
> I'm trying to yg ri fy the eXOK location of the Denton WW`T" oLl tfall.
> Would you please provide me with the latitude and longitude of your
> current outfall. I also need the date when this outfall moved from. the
> old racej.ving water,. unknown Trihotary to Ldck Creek (25 37 26/ nu 07
> 32), to .its new location. This will help considerably with interpreting
> the water quality data.
> Tkink you lot your help! LGE into know if I need Lu ob Lain Lhls
> information from someone else.
> Lauren Elmore
1 of 2 4/22/2003 9:03 ANI

Aquatic Bioassay Testing • Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments • NPDES Testing
Reporting & Data Handling Services
BURLINGTON
RESEARCH 615 Huffman Mill Road • Burlington, NC 27215-5122 • [phone] • Fax [phone] Ext. 202
PESTICIDES AND PCB's - LIQUIDS
EPA METHOD 608/8080
WORK ORDER #: 95-05-532-01 EXTRACTED: 05/29/95 BY: HIP
SAMPLE: Priority Pollutant Analysis ANALYZED: 06/01/95 BY: HTP
Effluent Comp. 5/24-25/95 QUANTITATION LIMIT MULTIPLIER: 1
ONLY ANALYTES THAT WERE DETECTED ARE REPORTED BELOW.
ANALYTE CONCENTRATION
(ug/L)
NONE TO REPORT
SURROGATES % RECOVERY
2,4,5,6-TETRACHLORO-m-XYLENE 60.0
DIBUTYL CHLORENDATE 60.0
SIMULTANEOUS DUAL COLUMN GC/ECD USED TO CONFIRM ALL REPORTED COMPOUNDS.
A COMPLETE LIST OF TARGET ANALYTES AND THEIR QUANTITATION LIMITS ARE
ATTACHED AT THE END OF THIS REPORT.

Re: Yadkin Outfall updates
BCC: Dare Goodrich GDave.Goodrichln ncmail.net%
Lauren, I've updated the lat/long data as you requested. However, I
have some questions:
NC0026689 (Denton): How did Denton relocate their outfall to the yadkin
mainstem, and where? Their existing permit allows for relocation to
Lick Creek, not the Yadkin River.
Also, the latitude you provided [37'37'27"] would be outside the basin,
so I entered it as 35037'27". Did you mean for it to be 35 instead of.
37?
Thanks,
CHW
,I
-V•
4/22/2003 9:04 AM

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
585 Waughtown Street Winston-Salem, North Carolina 27107
April 26, 2002
CERTIFIED MAIL 7001 2510 0001 4778 6885
RETURN RECEIPT REQUESTED
Mr. Jeff Dennard
Town of Denton
PO Box 306
Denton, North Carolina 27239
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0026689
Town of Denton WWTP
Davidson County
Dear Mr. Dennard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
February 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit. You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
You previously received correspondence concerning the Division's Copper and Zinc Action
Level Policy. The Policy is triggered by two or more toxicity limit violations that occur during the
toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations dining a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2.-- A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity
The Division has evaluated your copper and/or zinc monitoring data. The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the

copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
copper permit limit is 14 µg/L and your prospective zinc permit limit is 111 µg/L.
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide D1R'Q with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
M
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation. DWQ approval of options 1-3
(previous page) is not necessary as the Division expects work to rule out
copper and/or zinc as causative effluent toxicants to begin immediately upon
the second WET permit limit violation.
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to not DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
If the effluent is toxic, then we expect work to commence immediately with toxic effluent
samples. Failure to initiate work with toxic effluent samples during the study period is unacceptable and
will be considered a failure to make acceptable demonstration as cited above. We recommend a
minimum of three separate sampling events during the nine month period to definitively rule out copper
and/or zinc as causative effluent toxicants.

3
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more toxicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper and/or zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You may consider entering into a Special Order by Consent (SOC) with DWQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://vvww.esb.enr.state.nc.us. Click on the "Aquatic
Toxicology" Unit and go to the prompt "DOWNLOADS" located at the bottom of the page. This web
site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater Treatment
Plants." Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions conceming this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
Larry Coble
Regional Water Quality Supervisor
ATTACHMENTS
cc: Winston-Salem Regional Office (no attachments)
Sut san-Wilson_NPDES-U_niC(o.ftachments)_3
Tom Poe -Pretreatment (no attachments)
Lydia Mayo-USEPA Region IV, Atlanta Federal Center
(no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)
61 Forsyth St., SW, Atlanta, GA 30303
MAY 1 6 2002
pEkR
ia, Qun iY
PUINT SUURCC

State of North Carolina
Enyironmen# and•Natural Resources
}Department of
Division of Water Quality
585'Waughtown Street
vv
Winston-Salem, North Carolina 27107
yR
October 22, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jeff Dennard
Town of Denton
PO Box 306
Denton, North Carolina 27239
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0026689
Town of Denton W WTP
Davidson County
Dear Mr. Dennard:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
August 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition, this correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by two or more toxicity limit violations that occur during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations during a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
I. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

rr+
The Division has evaluated your copper and/or zmc monitoring data.' The Division has also
«3 ,?,'
„
developed a NPDES Fetnut limit based on your facility's instream waste concentration the
1 fi
prospective
copper and/or imc action level cntenon and a translator procedure: Based on this data your prospective
"
_ ..
n.
copper perntit limit is 14 pg/1.. and your prospective zinc permit limit is 111 pg/L:
i
r
4
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide DWQ with:
of � .
- . � • ..
Written indicating acceptance of the prospective coppef
� 1
'
a) notification
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
M'
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation.
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more toxicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.

M I S1 �i{ '��. Nk\Y Y th�}A.jS � i % V S '+NSF F Y.• ;n
f ru 'i
Yisr�
y PA1 O" nl e4thatiTe�NET limit will remain m your NPDES permit regardless of whether metals
la are'fhe source of effluent toxici y 'The data,iesulting;from your actions to disp"rove copper and/or zinc as
F , sources oY effluent yKity will deter'min whether NI'DES Permit limits will be assigned for these
t parameters Youyare responsible16r mitiatmg actions to address these issues.
You may consider entering mto a Special Order by Consent (SOC) with DWQ. A SOC provides
v regulatoryirelief forispeclftc NPDES permit limit violations and, if signed, will contain a requirement to
^' con"duct a Toxicity Reduction Evaluaiion..The SOC will contain a compliance schedule, stipulated
penalties for'failing to meet milestone activity dates and may contain upfront penalties to settle past
,... ..
t, permit limit violations. —
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://www.esb.enr.state.nc.iis. Click on the "Aquatic
Toxicology" Unit and go to the prompt "DOWNLOADS" located at the bottom of the page. This web
site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater Treatment
Plants." Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
D•e Cr_e
Larry Coble
Regional Water Quality Supervisor
ATTACHMENTS
cc: Winston-Salem Regional Office (no attachments)
Susan Wilson-NPDES Uni[-(no attachments)
Tom Poe -Pretreatment (no attachments)
Lydia Mayo-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
(no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)
f i Q _
r.. W
W �>