NC0020800_PERMIT ISSUANCE_20031121

NPDES DOCUMENT SCANNIM& COVER SHEET
NPDES Permit:
NC0020800
Andrews WWTP
Document Type:
Permit Issuance
':�
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
November 21, 2003
Thig document La priaited on reuiae paper - ignore any
content on the reveriae icicle

F"
DF NArF9 Michael F Easley
Governor
� NCDENR William G Ross Jr Secretary
y North Carolina Department of Environment and Natural Resources
O Alan W Klimek P E Director
Division of Water Quality
Nov cmbu 21, 2003
\It Jun DvIC\
l own of Anchcws
P 0 Hos 1210
AndrCw s, North C uohn 1 24901
Sublcct lssdlanCC of NPDFPumit N00020800
Andr,�Ns \\,\\, 113
Chcrohcc Count%
DCirNIr DvlCt
Drstsron pctsonrud h tic res IV.PUI tnd npprosed NOW ipphcatton for tcncwil of the Sublcct pcnnu
Accorchngli, we uc tonvvchng the lit chcd NPDI"S dischnrgc pctmtt I his puma is issued pursulnt to the
requircinents of North Cnolinl Genet tl SC1CUCe 143-215 1 1nd the Dlemornnclum of Agrcununt betwecn Nor th
C tr Uh❑ t and the U S I m uonmutnl PlOtLCnon Agenet clgtccl N1 IN 9, 1994 (or is subuqucnth unended)
This final permit includes 011E eh tngc from the draft permtt unt to you on ScptcmbLr 10, 2003
i I he weckh tNu igc Irnnt for C i1111de has boon dck.tcd ( i vudc has i D uh NL isunum lunu only
If i ni puts, mC isurcmcnt ticqucncics or s unphtng rcquncmcnts wrtruncd in this pci nut nrC unucd.pt ihlC to
vou, t ou h is c the right to no 'ulluche-iton hevrng upon written rcqucst vuthin thutt (30) cllvs following icceipt of
this letter I his rcqucst nursi bC un ihC form of a w i utun petition, conformmg to (hnptcr 15013 of the Noi di C imlm i
Gcnerd S[1tUfeS and hlCd with the Off (-C of tAdnimrstt2nve I Icir rigs (6714 Nlnd Scr-vrec Ccntu, Rnlugh Notth
Cvohnn 27699-6714) IJuICss such dun tnd is nnndc, this dcusion shall be fin2l -tnd binding
PlonSc note that this pu mu is not transfcrlhlo esecpt after nonce to the Drs rvon I he Divlbion In n tCqurre
modification or rcu oeanon end rusty lncc of the permtt 1 hry permtt dots not lttcet the ICg11 rcqurrcmcnts to obtmo
othu permits w htch mist be rcquucdl bt the Dn isioo of \V/ntct Qunhtn or permrts requited bt the Division of I Ind
Resources, du Constal ArC1 tVlan igunutt Act or ant other I"cderll or I-oc1I gos ctnmentni per nut tint tin n be
icquirnd If iou 111%L illy questions eonecinmg this pennrt, please contact ( hnrles \Vrdnder it telCphonC number (919)
733-5083, ostulsron 511
SmCCrch
ORIGINAL SIGNED BY
Mark McIntire
Alan \\ klt nck. P 1
cc ( unt d I dos
tAshudle Rcgumd )fhec/A\ iu Quthq Seeuon
NPDI"S Unit
\qu rue Unit
1\1 rJnhu Donnim / I PA
N C Division of Water Quality / NPDES Unit Phone [phone]
1617 Mad Service Center Raleigh NC 27699 1617 fax [phone]
Internet h2o enr stale no us DENR Customer Service Center 1 800 623 7748

Permit NCO020800
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215 1 other lawful
standards and regulations promulgated and adopted by the, North Carolina Environmental
Management Commission and the Federal Water Pollution Control Act as amended the
Town of Andrews
is hereby authonzed to discharge wastewater from a facility located at the
Andrews WWTP
Reagan Avenue
Andrews
Cherokee County
to receiving waters designated as the Valley River in the Hiwassee River Basin in
accordance with effluent linutations, monitoring reclunements, and other conditions
set forth in Parts I, II, III and IV hereof
This permit shall become effective January 1 2004
This permit and authorization to discharge shall expire at midnight on August 31 2007
Signed this day November 21 2003
ORIGINAL SIGNED BY
Mark McIntire
Alan W Klimek P E Ducctor
Division of Water Quality
By Authority of the Environmental Managcmuit Commission

Permit NC0020800
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDL.S Permits issued to this faUhtV, whcthcr for operation or chseharge Ire hereby revoked As of
this permit issu inec, and previously issued permit bearing this number is no longer effective 7 hercfoic, the
exclusive authority to opetatc and disch trgc from this facihtV arises under dhc permit conditions, requirements,
toms, and provisions included heron
The Town of Andrews is hereby authorized to
1 Continue to operate a 1 5 MGD wastewater treatment facility that includes
the following components
❑ Influent Comminutor
❑ Bar screen
o Grit chamber
❑ Dual trickling filters
❑ Dual secondary clarifiers
❑ Aerated sludge digester
❑ Chlorine contact chamber
❑ Sulfur dioxide dechlormation
❑ Emergency stand-by power
This facility is located at the Andrews WWTP (Reagan Avenue, Andrews) in
Cherokee County
2 Discharge from said treatment works at the location specified on the attached
map into the Valley River classified C-Trout water s in the Hiwassee River
Basin

c
1
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3 z
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1e97
,W/
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Quad nndr«%s NC NCO020800 Facility
Subb+sm 40502 Location
Town of Andrews WWTP t # _
l.�unuk 35 Il 51 �w�
I onguude 83'50 46
actuvmg srrev„ v dl,y Hz"` SCALE 12
um000
tillClCliss C Irout North

Pernut NCO020800
A (1 ) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Dunng the penod bi guurmg on Lhi ellectivt cl de of this pi rind uld lasting until a xp❑ ition the Pcnmtl.0 is
itithon7cd to dischu Ri horn outfaI1 001 Snc h drschaigi s sh ill be Irnutcd and monitored by the Pr nmtlee as
specified below
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow
1 5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5 day (20T),
30 0 mg/L
45 0 mg/L
Daily
Composite
Elffluent, Influent
Total Suspended Solids'
30 0 mg/L
45 0 mg/L
Daily
Composite
Effluent Influent
NH3 as N
April 1 -October 31
6 0 mg/L
18 0 mg/L
Daily
Composite
Effluent
NH3 as N
November 1-March 31
14 7 mg/L
35 0 mg/L
Daily
Composite
Effluent
pH
Between 6 0 and 9 0 standard units
Daily
Grab
Effluent
Fecal Cohform
(geometric mean)
200 / 100 ml
400 / 100 ml
Daily
Grab
Effluent
Total Residual Chlorine
28 µg/L
Daily
Grab
Effluent
Temperature IT)
Daily
Grab
Effluent
Total Nitrogen
NO2 + NO3 + TKN)
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
ChronicToxicdy2
Quarterly
Composite
Effluent
Total Copper
2/Month
Composite
Effluent
Cyanide
22 pg/L
Weekly
Grab
Effluent
Total Silver
2/1VIonth
Composite
Effluent
Total Zinc
2/Month
Composite
Effluent
MBAS
2/Month
Composite
Effluent
Notes
1 The monthly average BOD, and I otaI Suspended Soltcls concentrations shall not exeeed 15% of
the respe i true influent value (85% rcnioval)
2 Chiorm loxiu(y (Cenodapluua) 13/1-at 13% tt ,is Shall be tondueLc.d in March Junr Septernbu
and DceeuibLr Ism condition A (2) lot fruthu dclailsJ
There shall be no discharge of floating solids or visible foam in other than trace
amounts

Permit NCO020800
A (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent chschaige shall at no time exhibit observable inhibition of reproduction of
significant mortality to Cenodaphma dubia at an effluent concentration of 13%
The permit holder shall perform at a minimum quarterfq monitoring using test procedut c s
outlined in the North Carolina Cenodaphma Chronic Effluent Bioassay Procedure Revise cl February
1998 or subsequent versions or North Carolina Phase 11 Chronic Whole Effluent Toxicity I est
Procedure (Revised -February 1998) or subsequent versions The tests will be performed during
the months of March, June, September and December Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes
if the test procedut c performed as the first test of any single quartet results in a failure or
ChV below the perni t limit then multiple -concentration testing shall be performed at a ❑nnnnmnin un
each of the two following months a5 described in North Carolina Phase 11 Chronic Whole Effluc nt
I oxctty Test Procedure" (Revised -February 1998) or subsequent versions
The chronic value for multiple concentration tests will be determined using the gcometne
mean of the highest concenti ation having no detectable impairment of reproduction or survival and
the lowest concentration that does have a delectable Impairment of reproduction or survival 'ihe
dcftnttion of detectable unpatrinent " collection methods exposure regimes and further statistical
methods are specified in the North Carolina Phase iI Chronic Whole Effluent Toxicity lest Procedure
(Revised -February 1998) of subsc qucut versions
All toxicity testing results required as pat L of this pernut condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed using the
parameter code 'IGP3B for the pass/fail results and IHP3B for the Chronic Value Additionally DWQ
Form AT-3 (original) is to be sent to the following adds ess
Attention NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic I oxrctty I est Forms shall be filed with the Environmental Sciences Branch no
I Ater than 30 days after thc, end of the reporting pet rod for which the report is made
I est 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 detitgnate signature Total I esrdual chlorine of the effluent toxicity s Ample 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 permrttee will complete the information located at the top of the aquatic
toxicity (All test form indicating the facility name peon t 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 tic. Environmental Sciences Branch at thc, address cited above
Should the pernutiec fail to monitor during a month in which toxicity monitoring is I( qurrcd
monitoring will be required during the following month
Should any test dal a from this monitor I ng requirement or tests performed by the Not th
Carolina Division of Watc I Quality Indicate potential impacts to the receiving stream this permit may
be re -opened and moddu d to include alternate monitoring requirements or limits
NOTE Failure to achieve, test conditions as specified in the cited document such as minimum
control organism survrv-il nununum control otgamsnn reproduction and appropriate envuonnncntal
controls shall constitute .i n nnva1id lest and will require immediate follow -tip testing to be e omplctcd
no later than the last clay of the month following the month of the initial monitoring

Permit NCO020800
A (3 ) EFFLUENT POLLUTANT SCAN
I he Perri tee shall pci form in annual Clfluurt P0111-Itaul Scan for all par - meters listed in the attached table
The analytical methods shall be in accordance with 40 CFR Pai L 136 and shall be sufhcu ntly
sensitive to determine whether parameters are prr s( nl in concentrations greater than applicable
standards and ci itei to Sainplcs shall represent seasonal variations Unless otherwise indicated
metals shall be analy71-d as total recoverable
Ammonia (as N)
Trans 12 dictnomerhylene
Bts (2 chloroethyl) ether
Chlorine (total residual TRC)
1 1 dichloroethylene
Bis (2 chloroisopropyl) ether
Dissolved oxygen
12 dichloropropane
Bis (2 ethyfhexyl) phthalate
Nitrate/Nitrite
13 dichloropropylene
4 bromophenyl phenyl ether
Kleldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2 chloronaphthalene
Phosphorus
Methyl chloride
4 chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1 12 2 tetrachlomethane
Or n butyl phthalate
Antimony
Tetrachicroethylene
Dro octyl phthalate
Arsenic
Toluene
Dibenzo(a h)anthracene
Beryllium
1 1 1 trichioroethane
12 dichlorobenzene
Cadmium
1 12 trichloroethane
13 dichlorobenzene
Chromium
Tnchloroethylene
14 dichlorobenzene
Copper
Vinyl chloride
3 3 dichlorobenzidine
Lead
Acid extractable compounds
Diethyl phthalate
Mercury
P chlom m creso
Dimethyl phthalate
Nickel
2 chlorophenol
24 dinitrotoluene
Selenium
2 4 dichlorophenol
2 6 dimirotoluene
Silver
2 4 dimethylphenol
12 diphenythydrazine
Thallium
4 6 dinitro o cresol
Fluoranthene
Zinc
2 4 dinitrophenol
Fluorene
Cyanide
2 mtrophenol
Hexachforobenzene
Total phenolic compounds
4 mtrophenol
Hexachlorobutadiene
Volatile organic compounds
Pentachlorophenol
Hexachiorocyclo pentariene
Acrolem
Phenol
Hexachloroethane
Acrylomtnle
2 4 6 trichlorophenol
Indeno(1 2 3 cd)pyrene
Benzene
Base neutral compounds
Isophorone
Bromolorm
Acenaphthene
Naphthalene
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chtorobenzene
Anthracene
N ndrosodi n propylamme
Chlorodibromomethane
Benzidme
N ndrosodimethylamine
Chioroethane
Benzo(a)anthracene
N ndrosodiphenylamme
2 chloroethylvmyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
34 benzofluoranthene
Pyrene
Dichlorobromomelhane
Benzo(ghi)perylene
124 tnchlorobenzene
1 1 dtchloroethane
Benzo(k)lluoranthene
12 dichlomethane
Bis (2 chloroethoxy) methane
Icst results shall be reported to the Division in DWQ Form- A MR-PPAI or in a foriu approved by the
Dn ector within 90 days of sampling I he report shall he submrttcd to the following adds css
NC DCNR / DWQ / Ct nti it files 1617 M ul Sr ivice Ct riLU Raleigh Nor lh Carolina 27699-1617

,map //thanes weaver%40dwq denr ncmail net@cros ncmad net 143/f
Subject Verbal affidavit
From valery Stephens <valery Stephens@ncmatl net>
Date Tue, 18 Nov 2003 10 3143 -0500
To Charles Weaver <Charles Weaver@ncmad net>
NCO020800 Town of Andrews
Ran in the Cherokee Scout on 9-17-03 per Belinda Brown on 11-18-03
Thanks
Valery
of 1
11/18/2003 11 16 AM

G'
DENR/D1VQ
FACT SHLLI HOlt NPDEti)PL+RD111 DLVELOPMENi
NPDES Permit N00020800
Facility Information
Applicant/Facility Name
1 own of Andrews/ Andrews W WTP
Applicant Address
P 0 Box 1210, Andlcws North Carolina 28901
Facility Address
Reagan Avenue, Andrews North Carolina 28901
Permitted Flow
15 MGD
Type of Waste
Domestic (95%) and industrial (5%) with pretreatment plogiam
Facility/Permit Status
Class Ill/Active, Renewal
County
I Cherokee County
Miscellaneous
Receiving Stieam
Valley River
Regional Office
Asheville (ARO)
Stream Classification
C-Trout
State Gi id / USGS Quad
G3NE
303(d) Listed?
No
Permit Waster
Natahe V Siena
Subbasm
04-05-02
Date
August 19,2003
Drainage Area (nut)
524
— r --
P °
Lai 350 11 51 N Long S30 50 46 \V
Summer 7Q 10 (cfs)
15
Winter 7Q10 (cis)
19
30Q2 (cfs)
30
Average Flow (cis)
130
IWC (%)
13%
BACKGROUND
The Andrews WWTP (Class 111) has a permitted flow of 1 5 MGD The permit was ongmally
issued on Januaiy 30, 1998 and expued on December 31, 2002 The Peimittee submitted EPA
Form 2A on July 24, 2002 in order to request renewal of the permit This form was missing
some pollutant data, which the Pei mittee is in the process of collecting
Andrews has a modified pietieatment program (though it voluntarily collects more data than is
iequued by such a program) with the Division of Watti Quality's Pretreatment Unit and will
continue to implement this program in the new permit term The facility has not requested any
changes to the permit
The facility has experienced a number of compliance problems in the last five years, most
notably toxicity
lnstreani Monitoring, Verification of Existing Conditions and DMR Data Review
This facility discharges to the Valley River in Subbasm 04-05-02 of the 1-11wassee Rivet Basin
The Valley Rivet is classified C-Trout waters at this point and is not on the 2002-303(d) kt
Andrews is not Icqurred to monitot any instream parameters, so no instieam data were available
foi analysis DMR data hom January 2001 through May 2003 were reviewed Data rot
conventional parameters ate summarized in Table I For the most pail, the Permrttce
maintained compliance with the netmit limits foi those parameters
Aver,Ic 1 0 9 I6 0 9 8 I I
Maximum 14702036 23 624 4 9 29 68 59 56 206
Minunu n 02815 92 1209 0 0 1
I ihIL I NI 0112081111 t,onmiWm it lht i l i uw u} 211111 M p 21W)
'ihis facility also collects data tot total mtiogen total phosphorus ammoma ntiogen (NH-,-N)
MBAS, and total residual chlorine These aIe summarised in Table 2 Total residual chlorine
1 1, t YIC, I
1\111A 11 M 00'0500 it'n� it
i' IL, 1

_
�yr,NH3-N �,;� gtal°N•trogeu'5�ti�r �t pTotal;{,�t� �� `�MBAS `r it p()Total R �stdual"
sN �Ptiospliorus j # d (►nP�) w' Chlorine (191L
V` ;µ .L`qk Y i{ i . 1
�Si°nM(ITI�.);F,tiY;"kF,•:rn'r�i l�ai`%rt�.'.�l�Ke{i"',+y``w�.�'�}jrF:��`{�i
®®®® tt 0
Correspondence
The Asheville Regional Office (ARO) conducted several site visits dunng this permit teem to
evaluate compliance Notices of Violation (NOVs) were issued in conjunction with some of
these inspections foi improper operations and maintenance and deficiencies in executing the
pretreatment piogiam In all, eighteen NOVs have been issued to the Town of Andiews since
April 1998 Three were foi lift station bypasses Eleven were for either toxicity failures of late
submittal of toxiuty iesults (foi which the facility was assessed in late 2002) One was for a
cyanide daily maximum violation and the remainder were associated with defiuenues noted in
compliance inspections
The Town has yet to come under the action level policy to the extent that it needs to peifoim a
TIE, but may do so in the future
PERMITTING STRATEGY
Waste Load Allocation (WLA)
The Division prepared the last WLA for the pievious permit renewal The previous and current
effluent limits were based on guidelines and water quality standaids The Division has judged
previous paiameteis and limits to be appropriate foi renewal with some exceptions Changes to
toxicant monitoring are discussed in the Reasonable Potential Analysis section with the
exception of ammonia
in the fact sheet lot the previous permit renewal, it was stated that ammonia limits were probably
needed in this permit Calculations indicate that this is the case, resulting in a summer monthly
average limit of 60 mg/L and winter monthly average limit of 147 mg/L Moreover, weekly
average ammonia limits based on a 3 1 ratio with the monthly average (but no higher than 35 0
mg/L) will be implemented in this peimit Phis is a new statewide policy that resulted from EPA
iequuements The resulting summer weekly average limit will be 18 0 mg/L and the wmtel limit
will be 35 0 mg/L
In addition, an annual pollutant scan will be added Stich that the Permittee can collect the
necessary data required by EPA Foim 2A throughout the permit term "I his condition is now
standard on all majoi municipal permits in Noith Caiolma
Reasonable Potential Analysis (RPA)
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be dischaiged by this facility, based on DMR data from January 2000-May 2003
Calculations mc,luded parameters listed in the previous permit and pre-ucatimcnt documents to
include arsenic, cadmurm chromrt1171, cyanide, lead, MBAS, nickel, silvci, coppci and zmc
Results suggest no seasonable hotenhal foi the fauhty to discharge arsenic, cadmium,
chromium, lead Mi3AS and nickel Momtormg tot all except foi MBAS and arsenic may be
eliminated fiom the permit as they are tcquncd paiameteis to be monuoicd through the
Nrui s sr ou'nYin itLna, d
P,L, '

Pletreatment Short ]elm Monitonng Plan (SIIMP) NIBAS due to the ICVCIS at which It was
cletected, will continue to be montloted twice, pet month, while alsenlc will have a seduced
monitoting frequency of quarterly
Effluent from the facility did demonstrate reasonable potential to exceed water quality urteua Poi
copper, cyanide, silver and zinc All limits and monnoiing associated with these parameters in
the cuiient permit will be cairied ovei into this permit teen QQQQQ
SUMMARY OF PROPOSED CHANGES
In keeping with Division policies, the following will be memporated into the pei nut
New monthly and weekly aveiage ammonia limits (both summer and wmtet)
Annual pollutant scan
Elimination of the cadmium, chiomrtnn, lead, and nickel monitming requirement (Peimittee
will continue to monitor these parameters through the STMP)
Reduced monitoring requirement for arsenic (from 2/Month to quarterly)
New Weekly Average and Daily Maximum limits are derived from the latest NC/EPA policies
considering'/2 I'AVs and allowable concentrations based on reasonable potential
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice
Permit Scheduled to Issue
NPDES CONTACT
September 10 2003
November 7 2003
If you have questions regarding any of the above information or on the attached permit please contact
Natalie Sierra at [phone] ext 551
NAME � DAIE
I „I bh„
\PD1 ti M 001ON00 R, n, v, it
P il-,

I a, nor Nanm =
Qu (MGD) =
W WTP CI tssnc. moo
NPDFS # =
Recen mg Stre tin
7lVC (%n) =
I mud Rc ru6,
I own of Andrews WWI P
I5
3
NCO020800
Valles Mier
1342
Reasonable Potential Summ rn
10 2- 30 4°
Stream Classification C Tr
7QIOt (c/t)= 15
30Q2 (cfs) 30
Qavg (cfs) 110
Arccmc
' Inlplunentation
M n Pied Cw
7 7 µg/I
,Are all reported x dues less than'
No
LiniO
No
Monitoring
Allow tble Cw
3726 µg/I
I Is the detection limit tcceptable'
les
Mormon'
No
Frequency
Quarterly
C tdnuunt
Ilmplementation
I
Mix Pred Cw
1 7 µill
iAre all reported silues less than'
No
UmO
No
'Monitoring
Allow tble Cw
3 0 µg/I
9s the detection Irma acceptable9
Yes
Monaca'
Yes
Frequency
None
1/2 1 AV (non 9 r ouq
15 0 µg/I
1/2 FAV (IrouQ
2 1 µgIl
I
I
Chromium
hmplementation
I
Max Pred Cw
58 5 µg/I
'Are all reported rnlues less thane
No
Lunn'
No
iMonitonng
Allow ible Cw
372 6 µg/I
its the detection limn acceptable
Yes
Monitor /
Yes
Frequency
None
1/2 FAVI
1022 µg/I
Copper
I Implementation
I
Mix Pied Cw
840 6 µg/I
Are all reported talues less [hang
No
Limit'
No
i Monitoring
Allow rble Cw
52 2 µg/I
'Is the detection limit acceptable'
Yes
Monitor'
Yes
Frequency
Weekly
1/2 1 AVI
7 3 µg/I
Ct male
Implementation
NI is Pred Cw
67 9 µg/l
]Are all reported %hues less th m9
No
Lrmn9
Yes
� Monitoring
Allow-ible Cw
37 3 µg/I
Its the detection limit acceptable /
Yes
Monitor 9
Yes
Frequency
Weekly
1/2 FAVI
22 0 µg/I
I cad
,Implementation
Mix Pied Cw
s I µg/I
lAre all reported t clues less than9
No
Lunn'
NO
Monitoring
Allow able Cw
186
Its the detection Iumrl acceptable9
Yes
Momtor9
No
I Frequency
None
1/2 Fit
33 Slag/I
DIIS its
Implementation
No
�Monitoring
Mix Pred Cw
2056 5 µg/I
,Are all reported %dues less than'
No
Lumt9
A 11ow able Cw
372� S µg/I
Its the detection limn acceptable9
Yes
1,1011nor 9
Yes
I Frequency
2/Month
Nickel
I nyilunentation
]
Mix Pred Cw
77 7 µg/l
'Are all reported � dues less th in
No
Limit'
No
IMonitoring
Allow able Cw
655 7 µg/1
ds the detection limit acceptable9
Yes
Momtor9
No
Frequency
None
I/9 FAV
261 0 µg/1
tirh er
I Implementation
I
MIX Pred CW
15 6 µg/I
IAre all reported v dues less than
No
Ltin t'
No
imonitoring
Allowable Cw
04µ (
' Is the deteuron limit tcceptable/
Yes
Momtor9
Yes
iFrequency
Weekly
I/2 FA VI
12 µg/1
/tire
Implementation
M n Pred Cw
465 5 µg/I
IArc ill reported vdues less than'
No
Limit'
No
IMonitonng
Allowable Cw
372 6 µ 1
GIs the detection Irma acceptable?
Yes
Mommr9
Yes
'Frequency
Weekly
I/2 FAV
670 µg/1

Town of Andrews W WTP
NC0020800
Flo emp
eca
a
TAP
Date x ;(MGD)
(d_eg C)
(mg/L)
(m_g/L)
(#1100 mL)
(mg/L)
(ug/L)
�0
(m_g/L)
TN (mg/L)
(m O
Jan-01
06839
957
2266
1630
000
1 07
545
Feb-01
08677
1104
1837
1780
000
052
0
265
Mar-01
06599
11 41
1383
1400
1 10
024
0
204
630
098
Apr-01
05410
1306
1324
1270
000
1 95
0
400
May-01
1597
1388
2040
270
055
0
324
Jun-01
1913
1712
1700
220
131
0
530
781
201
Jul-01
21 36
2967
1870
760
094
0
1067
Aug-01
21 48
2916
2670
1640
1 17
0
782
Sep-01
2025
2874
2950
3270
069
0
672
760
264
Oct-01
02815
1588
2503
2460
1350
0
1015
Nov 01
02895
1465
2628
2968
302
1 70
0
1054
Dec 01
04873
1333
2718
2403
343
1 63
0
533
11 60
1 70
Jan 02
08525
11 74
2750
1948
207
033
0
710
Feb 02
05903
11 75
2939
2463
296
059
0
415
Mar 02
06791
1279
2789
2063
382
085
0
606
1000
1 45
Apr 02
06346
17 14
2879
1898
1262
040
0
523
May 02
06977
1901
2795
2017
652
045
0
452
Jun 02
03928
2235
2724
2961
317
206
0
788
Jul 02
05120
2369
2665
2933
2996
094
0
670
Aug 02
04354
2322
2899
2961
5956
1 90
0
1218
Sep 02
07169
2243
2560
2600
2701
1 89
0
1058
1230
215
Oct 02
06592
2014
2948
2957
2030
1 46
0
1063
Nov 02
08078
1583
2617
2651
536
1 95
0
560
Dec-02
09953
1301
2876
2944
1399
1 76
0
283
662
078
Jan-03
07198
920
2788
2723
1 89
1 20
0
478
Feb-03
1 4036
986
2362
2073
476
086
0
1 90
Mar-03
09444
1311
2779
2333
261
1 79
0
440
328
031
Apr-03
07176
1500
2063
1766
221
069
0
480
May-03
1 3003
1760
833
1209
324
010
0
1 66
Average
07029
160
244
226
98
1 1
u 0
60,
8 2
_1 5
Maximum
, 1 4036
2369
2967
29 68
5956
20565
0
12`18
- 12 3-
264
Minimum
02815
92
833
1209
0
0097
0
166
328
0313

IWC Calculations
Andrews WWTP (NC0020800)
Prepared By Natalie Sierra NPDES Unit
Enter Design Flow (MGD) 1 5
Enter s7O10(cfs) 15
Enter w7O10 cfs) 19
Residual Chlorine
Ammonia (NH3 as N)
(summer)
7010 (CFS)
15
7010 (CFS)
15
DESIGN FLOW (MGD)
1 5
DESIGN FLOW (MGD)
1 5
DESIGN FLOW (CFS)
2 325
DESIGN FLOW (CFS)
2 325
STREAM STD (UG/L)
170
STREAM STD (MG/L)
1 0
UPS BACKGROUND LEVEL (1
0
UPS BACKGROUND LEVEL
022
IWC (%)
1342
IWC (%)
1342
Allowable Conc (ug/1)
127
Allowable Conic (mg/1)
60
Ammonia (NH3 as N)
(winter)
7010 (CFS)
19
Fecal Limit
200/100ml DESIGN FLOW (MGD)
1 5
(If DF >331, Monitor)
DESIGN FLOW (CFS)
2 325
(If DF <331, Limit)
STREAM STD (MG/L)
1 8
Dilution Factor (DF)
745 UPS BACKGROUND LEVEL
022
IWC (%)
1090
Allowable Conc (mg/I)
147
Servor/Current Versions/IWC
9/9/2003

Town of Andrews WWTP
P O Box 1210
Andrews, NC 28901
828-321-3006
828-321-5111
July 22, 2002
Mrs Valery Stephens
NCDENR/Water Quahty/Pomt Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mrs Stephens
E v E
JUL 24 2002
DENR WAi ER OUALI lY
POINT SOUHCE 4R"tiCH
This letter serves as a request to renew the Town of Andrews' wastewater treatment plant
permit #NC0020800 There have been no changes in the scope or operation of the
facility since the issuance of the last NPDES permit
All solids generated by this facility will be disposed of in the Cherokee County Landfill
If you need further information, please contact me at 828-321-5111, or Michael Ladd,
ORC at 828-479-6428
Sincerely,
Mitch Rhmehart
Mayor, Town of Andrews

W ATFR
Mr Mitch Rhmehart, Mayor
Town of Andrews
PO Box 1210
Andrews, North Carolina 28901
Michael F Easley Governor
William Ross Jr Secretary
/ XX�� P 1 North Carolina Department of Environment acid Natural Resources
June 24, 2003
Subject COPPER AND ZINC ACTION LEVEL POLICY
Effluent Toxicity Testing
NPDES Permit No NCO020800
Town of Andrews WWTP
Cherokee County
Dear Mayor Rhmehart
Alan W Klimek PE Director
Division of Water Quality
�� 1p
�L f JUN 2 5 2003 1�!
L _ 1
_4
This letter is to notify you that our office did not receive a Final Report from the Town
detailing actions to rule out copper as a causative effluent toxicant A final report was due on or before
May 30, 2003
In a Notice of Violation (NOV) dated 9/6/02 from the Asheville Regional Office, the Town
received notification that the WWTP had reasonable potential to violate the instream action level Teri
for copper Ina subsequent NOV dated 9/9/02 the Town was formally notified that it would be given
nine months to provide DWQ with evidence to definitively rule out copper as a causative effluent
toxicant The Town was also required to submit its written documentation by 9/29/02 indicating the
Town's choice of option(s) 1-4 to rule out copper as a causative effluent toxicant
A review of the facility's toxicity self -monitoring data from February 2002 through March
2003 indicates that no additional effluent toxicity permit limit violations occurred
While our office is disappointed that the Town failed to submit the required "option"
notification (due 9/29/02) and the required final report (due 5/30/03), we choose, at this time, not to
reopen your NPDES Permit to include a permit limitation for copper Please be advised that the
Town of Andrews remains subject to the provisions of DWO's Copper and Zinc Action Level
Pohcv should additional effluent toxicity violations occur in the future (le, two effluent toxicity
permit limit violations occurring within the toxicity testing calendar quarter defined by the NPDES
Permit)
Should the WET Copper and Zinc Action Level Policy become effective in the future and the
Town fails to submit the required choice of option or provide a final reportthen our office will
recommend that the NPDES permit be reopened to include a permit limit for copper
The Town may consider "spiking" effluent samples which are not toxic with known
concentrations of copper to determine a threshold concentration at which copper would impact aquatic
life in the receiving stream If the facility chooses to "spike" effluent samples with copper, then at
least three separate trials must be conducted
=M
NCDENRt
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh NC 27699 1621 [phone]
800 623 7748

Page 2
Town of Andrews -Copper and Zinc Action Level Policy
June 24. 2003
If you have any questions concerning this correspondence, please contact me or Mr Kevin
Bowden with the Aquatic Toxicology Unit at [phone]
Sincerely,
Matt Matthews, Supervisor
Aquatic Toxicology Unit
cc Forrest Westall-Asheville Regional Office
Kerry Becker -Asheville Re -tonal Office
Dave Goodnch-NPDES Unit
Susan Wilson-NPDES Unit
Kevin Bowden -Aquatic Toxicology Unit
Pretreatment Unit
Madolyn Dommy, USEPA Region IV, Water Mgt Div, Atlanta Federal Center, 61
Forsyth St , SW, Atlanta GA 30303
Shannon Langley -Point Source Compliance/Enforcement Unit
Central Files

10
State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F Easley, Governor
Winiam G Ross, Jr, Secretary
Alan W Khmek, P E , Director
Division of Water Quality
I.' 4 S •G,
WATER QUALITY SECTION
CERTIFIED MIAL
RETURN RECEIPT REQUESTED
Mr Mitch Rhinehart, Mayor
Town of Andrews
Post Office Box 1210
Andrews, North Carolina 28901
Dear Mayor Rhinehart
September 9, 2002
SUBJECT NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit Number NCO020800
Town of Andrews WWTP
Cherokee County
This is to inform you that a review of your toxicity self -monitoring report form for the month
of January, 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
Accompanying this correspondence is a Notice of Violation (dated September 6,
2002) explaining implementation of the Division's Copper and Zinc Action Level Policy It
included prospective permit limits for copper and/or 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 quaver 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 by September 29, 2002
b) Written notification indicating your choice of option(s) 1-4 below Notification is due
by September 29, 2002 DWQ approval of options 1-3 (below) is not necessary as
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
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N
Mayor Rhinehart
September 9, 2002
Page Two
the Division expects work to rule out copper and/or zinc as causative effluent
toxicants to being immediately upon the second WET Permit limit violation
• 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, N C 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) The
report is due on or before May 30, 2003
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, N C 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
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
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Mayor Rhinehart
September 9, 2002
Page Three
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
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 "AT Downloadable Files" located at the bottom of the page
If you have any questions concerning this correspondence, please contact Mr Keith Haynes
at 828/251-6208 or Mr Matt Matthews, Supervisor of the Aquatic Toxicology Unit at 9191/733-
2136
xc Keith Haynes — ARO Office
Susan Wilson — NPDES Unit
Tom Poe - Pretreatment
Lydia Mayo — USEPA Region IV
Aquatic Toxicology Unit
Sincerely, L
orrest R estall qL
Water Quality Regional Supervisor
P
r P
59 Woodrin Place, Asheville North Carolina 28801
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycled/10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F Easley, Governor
William G Ross, Jr, Secretary
Alan W Klimek, P E , Director
Division of Water Quality
WATER QUALITY SECTION
September 6, 2002
CERTIFIED MIAL
RETURN RECEIPT REQUESTED
Mr Mitch Rhinehart, Mayor
Town of Andrews
Post Office Box 1210
Andrews, North Carolina 28901
SUBJECT NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit Number NCO020800
Town of Andrews WWTP
Cherokee County
Dear Mayor Rhinehart
This is to inform you that a review of your toxicity self -monitoring report form for the month
of December, 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
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone],AX 828-251-6452
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Mayor Rhinehart
September 6, 2002
Page Two
Include numeric limits for copper and/or zinc UNLESS the permlttee provides on 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 112 ug/I
The permlttee, upon experiencing two or more toxicity limit6 violations 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
b) Written notification indicating your choice of option(s) as noted on pate 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, N C 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
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
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Mayor Rhinehart
September 6, 2002
Page Three
the data Indicate copper and/or zinc as the source of effluent toxicity or if the data are
Inconclusive as to copper and/or zlnc'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, N C 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
If the effluent is toxic, than 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
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
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
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Mayor Rhinehart
September 6, 2002
Page Four
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 "AT Downloadable Files" 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 Mr Keith Haynes
at 828/251-6208 or Mr Matt Matthews, Supervisor of the Aquatic Toxicology Unit at 9191/733-
2136
Attachments
xc Keith Haynes — ARO Office
'Susan Wilson — NPDES Unit
Lydia Mayo — USEPA Region IV
Aquatic Toxicology Unit
Sincerely,
vV
orrest R Westall
Water Quality Regional Supervisor
59 Woodfin Place, Asheville North Carolina 28801
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycied/10% post -consumer paper

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfm Place Asheville, North Carolina 28801
June 12, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
IVlr Jim Dailey
Town of Andrews
PO Box 1210
Andrews, North Carolina 28901
SUBJECT NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy a o
om
NPDES Permit No NC0020800 !
W
o
Town of Andrews WWTP
Cherokee County
C-3
o
Dear Mr Dailey I
W
Cij
This is to inform you that a review of your toxicity self -monitoring report fo'i-i or the month
of
March 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit You should
—
undertake necessary actions to clitriinate or reduce effluent toxicity to acceptable levels
In addition, this correspondence contairs important info-mation on the D,wsio^'s Copper a-d
Zinc Action Level Policy The policy is triggered by two or more toxicity limit violations which 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 permrttee 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

3
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 pernut 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 "AT Downloadable Files" 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,
'
Forres'�11t Westall
Regional Water Quality Supervisor
ATTACHMENTS
Lc Asheville Regional Office (no attachments) — —
Susan Wilson-NPDES Unit (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)