NC0020184_Permit Modification_19971211

NPDES DOCUINENT SCANNING COVER SHEET
NC0020184
Gastonia — Long Creek WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Correspondence
201 Facilities Plan
Instream Assessment (67B)
Environmental
Assessment (EA)
Permit
History
Document Date:
December 11, 1997
Thies document is printed as reuse paper - ignore may
ce nteat ern. the x-esinerise elide

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
December 11, 1997
Mr. Don Carmichael, P.E.
City of Gastonia
Post Office Box 1748
Gastonia, North Carolina 28053-1748
Dear Mr. Carmichael:
E N F
Subject: NPDES Permit Modification
Permit No. NC0020184
Long Creek WWTP
Gaston County
As a result of discussions between Fleischmann's Yeast, Burns Philp, the City of
Gastonia, and the Division of Water Quality, the Division has modified the NPDES permit
for Long Creek WWTP. Specifically, the Total Nitrogen permit limit has changed from 6
mg/1 to 800 lbs/day for the summer of 1998 (April 1 - October 31). The Division believes
that this modification will allow time for the determination of removal efficiencies at the
Long Creek WWTP. This will also provide time for Fleischmann's Yeast to continue
investigations of the treatment options available to minimize the amount of total nitrogen
being discharged to the POTW.
In addition, it is the Division's understanding that Fleischmann's Yeast will
continue efforts to identify technologies capable of removing total nitrogen at the Long
Creek WWTP. The City of Gastonia and Fleischmann's Yeast will also move forward
with the plan to divert some of the flow from Long Creek WWTP to Crowders Creek
WWTP in hopes of determining whether or not this plant can convert the nitrogen to NO3.
Please find enclosed the modified sections of the permit referenced in the preceding
paragraph. Replace the original sections in your permit with the newer enclosed sections
and discard the original sections. All other terms and conditions contained in the original
permit remain unchanged and in full effect. These permit modifications are issued pursuant
to the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this
permit modification 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, an filed with the Office of Administrative Hearings, Post Office
Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made this
decision shall be final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Carmichael
Page 2
December 11, 1997
If you have any questions, please contact Paul B. Clark at [phone]
extension 580.
Sincerely,
. Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
Roosevelt Childress, EPA
NPDES Unit (Permit Files)
Point Source Compliance/Enforcement Unit
Aquatic Toxicology Unit
Donna Forner, Fleischmann's Yeast
Laurie Gengo, The Sanford Holshouser Law Firm
Anita LeVeaux-Quigless, Attorney General's Office

A.(3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -PERMITTED DISCHARGE TO S. FORK CATAWBA RIVER Permit No. NC0020184
During the period beginning after the relocation of the discharge to the South Fork Catawba River and the expansion to 16.0 MGD and lasting until expiration,
the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT : CHARACTERISTICS -
LIMITS
MONITORING REQUIREMENTS
Monthly,
'Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location1
Flow
16.0 MGD
Continuous
Recording
I or E
BOD, 5-day, 20°C2 (April 1 - October 31)
5.0 mg/I
7.5 mg/I
Daily
Composite
-
E,I
BOD, 5-day, 20°C2 (November 1 - March 31)
10.0 mg/I
15.0 mg/I
Daily
Composite
E,I
TSS2
30.0 mg/I
45.0 mg/I
Daily
Composite
E,I
NH3-N, (April 1 - October 31)
2.0 mg/I
Daily
Composite
E
NH3-N, (November 1 - March 31)
4.0 mg/I
Daily
Composite
_
E
Dissolved Oxygen3
_
Daily
Grab
E,U,D
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
E
Temperature
Daily
Grab
E,U,D
Total Residual Chlorine
28.0 ug/I
Daily
Grab
E
Conductivity
Daily
Grab
U, D
Total Nitrogen (NO2+ NO3 + TKN)
800 Ibs/day 4
Weekly
Composite
E
Total Nitrogen (NO2+ NO3 + TKN)
6.0 mg/I 4
Weekly
Composite
E
Total Phosphorus
1.0 mq/l
Weekly
Composite
_
E
Chronic Toxicity 5
Quarterly
Composite
E
Cadmium
10.8
27.0 ug/I
Weekly
Composite
E
ug/I
Cyanide
27.0 ug/I
118.7 ug/I
Weekly
Grab
E
Lead
_.._.
-- 134.9 ug/I
182.3 ug/I
Weekly
Composite
E
Mercury 6
0.065 ug/I
0.078 ug/I
Weekly
Grab
E
Antimony
2/month
Composite
E
Beryllium
2/month
Composite
E
Chloride
2/month
Composite
E
Chloroform
2/month
Grab
E
3 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
4 800 Ibs/day TN limit applies only from April 1 through October 31, 1998. 6.0 mg/I TN limit applies April 1 through October 31, 1999, 2000 and April 1
through September 30, 2001 (or until permit expiration). If necessary, the City of Gastonia will, on a test basis, assess the efficacy of partially diverting
effluent flow from Fleischmann's Yeast facility to the Crowders Creek WWTP as a means of achieving its permit limitation.
5 Chronic Toxicity (Ceriodaphnia), P/F, no significant mortality at 19%; March, June, September, and December; See Supplement to Effluent Limitations and
Monitoring Requirements Page - Special Conditions for flow of 16.0 MGD to South Fork Catawba River.
6 The detection limit for mercury is 0.2 ug/I. If the measured levels of mercury are below the detection limit, then the measurement is considered to be zero
for purposes of compliance evaluation and should be reported on the DMR as < 0.2 ug/I.
The pH shall not be Less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharae of floatina solids or visible foam in other than trace amounts.
Notes:
' Sample locations: E - Effluent, I - Influent, U - Upstream at City of Gastonia Pump Station, D - Downstream at a) Spencer Mountain Dam
pool at dam, b) NCSR 2003, and c) 1.5 miles below tailrace at powerlines. Instream monitoring shall be grab samples taken 3/wk
(Jun -Sep) and 1/wk (Oct -May). These monitoring frequencies specified above for dissolved oxygen, temperature,
conductivity, and pH are to be used only when experiencing operational problems with the YSI 6-series system. It is assumed
that when the YSI system is operating properly, these four parameters will be monitored continuously.
2 The monthly-average-effluent-BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal).

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Donald E. Carmichael, P.E.
City of Gastonia
Post Office Box 1748
Gastonia, North Carolina 28053-1748
Dear Mr. Carmichael:
.„01
CD0EHNR
December 9, 1997
Subject: NPDES Permit Error Modification
NPDES Permit No. NC00201 4
Long Creek WWTP
Gaston County
On February 26, 1997, the Division of Water Quality issued NPDES Permit No. NC0020184 to the
City of Gastonia. A review of the permit file has indicated that the mercury limits were inadvertently
omitted from the effluent page with a permitted flow equal to 16.0 MGD. The weekly average limit
should be 0.065 ug/1 and the daily maximum limit should be 0.078 ug/1. These limits were included in
the draft permit which was noticed October 1996. We apologize for any inconvenience tlti.s error may
have generated.
Please find enclosed the modified section of the permit referenced in the first paragraph. Replace the
original section in your permit with the newer enclosed section and discard the original section. All other
terms and conditions contained in the original permit remain unchanged and in full effect. This permit
modification is issued pursuant to the requirements of North Carolina General Statutes 143-215.1 and the
Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
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, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such
demand is made, this decision shall be final and binding.
If you have any questions concerning this permit modification please contact Paul B Clark at
telephone number [phone], extension 580.
Sincerely,
Preston Howard,ar., P.E.
cc. Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance/Enforcement Unit
Aquatic Toxicology Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -PERMITTED DISCHARGE TO S. FORK CATAWBA RIVER Permit No. NC0020184
During the period beginning after the relocation of the discharge to the South Fork Catawba River and the expansion to 16.0 MGD and lasting until expiration ,
the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locations
Flow
16.0 MGD
Continuous
Recording
I or E
BOD, 5-day, 20°C2 (April 1 - October 31)
5.0 mg/I
7.5 mg/I
Daily
Composite
E,I
BOD, 5-day, 20°C2 (November 1 - March 31)
10.0 mg/I .
15.0 mg/I
Daily
Composite
E,I
TSS2
30.0 mg/I
45.0 mg/I
Daily
Composite
E,I
NH3-N, (April 1 - October 31)
2.0 mg/I
Daily
Composite
E
NH3-N, (November 1 - March 31)
4.0 mg/I
Daily
Composite
E
Dissolved Oxygen3
Daily
Grab
E,U,D
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
a E
Temperature
Daily
Grab
E,U,D
Total Residual Chlorine
28.0 ug/I
Daily
Grab
E
Conductivity
Daily
Grab
U,D
Total Nitrogen (NO2+ NO3 + TKN)
800 Ibs/day 4
Weekly
- Composite
E
Total Nitrogen (NO2+ NO3 + TKN)
6.0 mg/I 4
Weekly
. Composite
E
Total Phosphorus
1.0 mg/I
Weekly
Composite
E
Chronic Toxicity 5
Quarterly
Composite
E
Cadmium
10.8 ug/I
27.0 ug/I
Weekly
Composite
E
Cyanide
27.0 ug/I
118.7 ug/I
Weekly
Grab
E
Lead
134.9 ug/I
182.3 ug/I
Weekly
Composite
E
Mercury 6 -
0.065 ug/I
0.078 ug/I
Weekly
Grab
E
Antimony
2/month
Composite
E
Beryllium
2/month
Composite
E
Chloride
2/month
Composite
E
Chloroform
2/month
Grab
E
Notes:
1 Sample locations: E - Effluent, 1 - Influent, U - Upstream at City of Gastonia Pump Station, D - Downstream at a) Spencer Mountain Dam
pool at dam, b) NCSR 2003, and c) 1.5 miles below tailrace at powerlines. Instream monitoring shall be grab samples taken 3/wk
(Jun -Sep) and 1/wk (Oct -May). These monitoring frequencies specified above for dissolved oxygen, temperature,
conductivity, and pH are to be used only when experiencing operational problems with the YSI 6-series system. It is assumed
that when the YSI system is operating properly, these four parameters will be monitored continuously.
2 The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal).
3 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/I.
4 800 Ibs/day TN limit applies only from April 1 through October 31, 1998.
6.0 mg/I TN limit applies beginning April 1 through October 31,1999 and lasting until permit expiration.
5 Chronic Toxicity (Ceriodaphnia), P/F, no significant mortality at 19%; March, June, September, and December; See Supplement to Effluent Limitations and
Monitoring Requirements Page - Special Conditions for flow of 16.0 MGD to South Fork Catawba River.
6 The detection limit for mercury is 0.2 ug/I. If the measured levels of mercury are below the detection limit, then the measurement is considered to be zero
for purposes of compliance evaluation and should be reported on the DMR as < 0.2 ug/I.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

WES/pat
Enclosure
61965/bp/gast/goadrich letter
2570 M STREET. H.W.
WASHINGTON. D.C. 20037.1:.,o
[phone]
4R1(TMON 1 WJ.
IMPCRPAt. CENTER BUSINESS PART
110i SLATER ROAD, SUITE 230
RFSFARCH 'MANGLE PARK, NOT1T11 CAROUNA 2rro3
(91 e) 941-Men
101 WEST FHIENTxvAVENUE
c3REENURORO. NORTH CA411 INA P7401
(910} 2z J-irta
(303) 89,-6137
►arx7FA:4 aMm:r our.
David A. Goodrich
NPDES Group Supervisor
State &North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
NCDEHNRJN UES Group
P.O. Box 29535
Raleigh, NC 27626
Dear Mr. Goodrich:
PATTON BOGGS, L.L.P.
SUITE 1975
1660 LINCOLN STREET
DENVEFR, COLORADO 80264
[phone]
TELECOI'1f11: 894-9230
December 9, 1997
N1 WPRT r9 l 1 ::11•IT T
AM_TItrtwe. P4A4,1L yrl 1^f•1
r ur:1 n[A.�..
N+7^ t '•f r- A"C_!PrT
R1N rr ; nq
Ca110.� TF�r�'75:YI,
(21.1) 0714.1,
I (1!10 3Er.('. rn At'G1et 1r
r!1TT% I AM
r GATTI r, Un?Hprr±Tr)V n1t`c 1
Enclosed please find a marked up copy of the NPL)ES Permit PNCOO2O1 R4 l.« r the Citv of
Gastonia's Long Creek Wastewater Treatment Facility_ The changes in the permit con orm to the
revisions suggested in your July 28, 1997 letter. Specifically, revising the Total Nitrogen) r
limitation to a mass based SOO lbsper daylimit. through March 3 ] 19, 99 permit
rn�t
g .9 Secondly, a
concentration based limitation for Total Nitrogen of 6 mg/E. from April 1, 1999 throu l
September 30, 2001, the expiration of the permit. Finally, instruction to the City of Ga,4toni; . l o
divert effluent flow from the Long Creek facility
,. c. ty to the Crowders Creek Facility; it'tlfY (_ rry
anticipates problems with compliance.
Also, by way of this Ietter, Fleischmann's confirms that it is continuing and will continue to
assess all available technologies to identify mechanisms of removing Total Nitrogen from its
Gastonia facility's effluent.
Thank you for your attention to this matter. We look forward to resolving this issue.
V ly ,.rs,
llie
E.C �
, phe

State of North Carolina
Department of Environment,
Health and Natural Aesvurces
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
July 28, 1997
Ms. Donna Former. Plant Manager
Fleischmann's Yeast
P.O. Box 999
Gastonia, North Carolina 28053
ATA
17-3J toIN
MPE COPY
BAB COPY
WES:COPYs .
FILE COPY '?2.s. /66
Subject: Settlement Proposal
City of Gastonia Long Creek WWTP
NPDES Permit No. NC0020184
Gaston County
Dear Ms. Forner:
in response to the Petition for a Contested Case Hearing, the Division is proposing a permit
modification as discussed in our April 25, 1997 meeting held in Raleigh between members of
FFeisehmann's Yeast, Burns Philp, the City of Gastonia, and the Division. of Water Quality.
Spccitically, the proposal which the Division is wilting to make is for the revision of the Total Nitrogen
permit limit from 6 mg/1 to 800 lbs/day for the summer of 1998. It is the belief of Division staff that
this time will be adequate to determine the removal efficiencies at the Long Creek WWTP and will also
provide time for Fleischraann's Yeast to continue investigations in the treatment options available to
minimize the amount of total nitrogen being discharged to the POTW.
It is also my undexstanding thatF1eischmann's Yeest will continue efforts to find teehnvIegics
capable of removing total nitrogen at the Gastonia facility. Furthernnvrt, the City of Gastonia and
Hetschrnann's Yeast will move forward with the plait to divert some of the flow from your facility to
the Crowder; Creek WWTP in hopes of determining whetter or not this plant tan convert the nitrogen
to NO3. Finally, the Division will be glad to participate in a "monitoring workgmup" as suggested by
John Schuler of the City of Gastonia in our meeting.
If this proposal is agrcable co you, please complete the attached Notice of Withdrawal farm and
send it to the Office of Admitustrttive Hearings, P.O. Drawer 27448, Raleigh. North Carolina 27611-
7447. If you have any questions or comments regarding this matter, please contact me at (919)-733-
5083, extension 517.
Sincerely,
David A. Goodrich
NPDES Group Supervisor
cc: Central Files
Water Quality Section, Mooresville Regional Office
Kathy Cooper. Attorney General's Office
Robert M. Williams, Fleischmann's Yeast
240 Larkin Williams Industrial Court
Fenton, Missouri 63026
Kevin Healey, Burns Philp/Research Centre
67 Epping Road
North Ryde, New South Wales 2113 Australia
32pa
i
Arbu..ck

STATE OF NORTH CAROLINA
IN THE OFFICE OF
ADMINI:S TRATivE I EA i OS
COUNTY OF
v.
FILE NO.
,Petitioner,
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Respondent.
NOTICE OF WITHDRAWAL
OF PETITION
Petitioner hereby withdraws its petition for a contested case hearing_ No further pro
are needed or required to resolve the contested case captioned above.
This the day o; , I9_.
ceilings
Petitioner/Authority for Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I have this day filed an original and one copy of this i'slOTIVE OF
WITHDRAWAL in the Office of Administrative Hearings at the address specified below and that I
have. by first class mail, scrvcd a copy of the same on counsel for the Respondent at the didress
specified below:
Office of Administrative Hearings
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447
Kathy Cooper, Asst. Attorney Gen
Environmental Division
North Carolina Department of Justi
Post Office Box 629
Raleigh, North Carolina 27602.06
Date Petitioner/Attomey for Petitioner
9

4,4-1.997 13:49
SANFORD LAW FIRM
919 890 4180 P.03/03
NUCHAEL P. !A. .EY
ATTORNEY (I .rw2RAL
The Sanford Holshouser Law Firm
Laurie B. Gengo, Esq.
234 Fayetteville Street
Raleigh, North Carolina 27601
State of North Carolina
ne artmern of Justice
P. U. HOX 629
RA1.E1C3H
2 7602-0029
October 17,1997
RE: Fleischmann's Yeast, Permit No. NC0020184
Dear Ms. Gengo:
&eM 10101'41P
REPLY TO: Anita LeVeauc-Quisleas
Environmental Division
Tel. No. [phone]
Fax : [phone]
Yesterday, a copy of your August 22, 1997 letter to my client, the North Caroli
.-"epartment of Environment and Natural Resources, NPDES Group (DENR), was forwarded
my attention. DENR is pleased that the afore -referenced matter has been settled. Unfortunately,
if appropriate technologies for removing total nitrogen cannot be developed by March 1999, and
your client is unable to meet its concentration limits they will be in violation of their permit
limits. Of course, as you know, your client has redress in the Administrative Procedures Aci.
Based upon this understanding, if you wish to withdraw the petition, please notify me of the
same. Conversely, if you have any questions, please feel free to call.
Very truly yours,
Anita LeVeaux-Quigless
Assistant Attorney General

Permit No. NC0020184
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RE OURCES
DIVISION OF 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, ancc the Federal Water
Pollution Control Act, as amended,
City of Gastonia
is hereby authorized to discharge wastewater from a facility located at
Long Creek Wastewater Treatment Plant
Old Spencer Mountain Road
Gastonia
Gaston County
to receiving waters designated as Long Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on
Signed this day
David A. Goodrich
NPDES Group Supervisor
61931/lbsb

Permit No. NC0020184
SUPPLEMENT TO PERMIT COVER SHEET
City of Gastonia
is hereby authorized to:
1. Continue to operate an existing 8.0 MGD wastewater treatment facility consists of influent lift station, a
mechanical bar screen and grit removal, primary clarifiers, trickling filters, polishing ponds with floating
aerators, dual chlorine contact chambers with dechlorination, a static aerator, sludge la oons, and sludge
drying beds. Facilities under construction for expansion to 16.0 MGD wastewater treatm nt facility include
mechanical bar screens, cyclone grit removal, anaeobic/anoxic%oxic basins, caustic and alum feed,
secondary clarifiers, tertiary filters, chlorine disinfection with dechlorination, static post aeration, and
sludge digesters. Wastewater treatment facility is located at Long Creek Wastewater Tre tment Plant, Old
Spencer Mountain Road, Gastonia, Gaston County (See Part III of this permit), and
2. Prior to relocation of discharge point, discharge wastewater from said treatment wor at the location
specified on the attached map into Long Creek which is classified Class C waters in th Catawba River
Basin.
3. After relocation of discharge point, discharge wastewater from said treatment work
specified on the attached map into South Fork Catawba River which is classified Class W
Catawba River Basin.
at the location
-V waters in the
61931/lbsb

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Permit No. NC0020184
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS for FIow of 8.0 MGD to Long Creek
A(4). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is
81 % (defined as treatment two in the procedure document). The permit holder shall perform uarrerl monitoring using
this procedure to establish compliance with the permit condition. The tests will be performed uring the months of
Mar., Jun., Sept. and Dec.. Effluent sampling for this testing shall be performed at the NPDES p rmitted final effluent
discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Form (MR-1) for the month in which it was performed, using the parameter code TGP3B. Addi
AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
ischarge Monitoring
ionally, DWQ Form
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity
sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form ' dicating the facility
name, permit number, pipe number, county, and the month/year of the report with the notation f "No Flow" in the
comment area of the form. The report shall be submitted to the Environment Sciences Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing, this monthly test requir ment will revert to
quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring
will begin immediately until such time that a single test is passed. Upon passing, this monthly tst requirement will
revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate
monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minim control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall c nstitute 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.
61931/lbsb

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS PERMITTED DISCIIARGE TO S. FORK CATAWBA RIVER
Permit No. NC0020184
During the period beginning after the relocation of the discharge to the South Fork Catawba River and lasting until expansion to 16.0 MGD, the Pennittee is authorized to discharge from outfall(s) serial
number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Notes:
EFFLUENT CHARACTERISTICS•
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
8.0 MGD
Continuous
Recording
I or E
BOD 5-day 20 C2 (April 1 - October 31)
11.0 mg/1
16.5 mg/1
Daily
Composite
E, I
BOD 5-day 20 C2 (November 1 - March 31)
22.0 mg/1
33.0 mg/1
Daily
Composite
E, I
TSS2
30.0 mg/1
45.0 mg/1
Daily
Composite
E, I
NH3-N (April 1 - October 31)
4.0 mg/1
Daily
Composite
E
NH3-N (November 1 - March 31)
14.0 mg/I
Daily
Composite
E
Dissolved Oxygen'
Daily
Grab
E, U, D
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
E
Temperature
Daily
Grab
E, U, D
Total Residual Chlorine
28.0 ug/1
Daily
Grab
E
Conductivity
Daily
Grab
U, D
Total Nitrogen (NO2 + NO, + TM)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicity'
Quarterly
Composite
E
Cadmium
19.6 ug/1
49.0 ug/1
Weekly
Composite
E
Mercury
0.12 ug/1
0.47 ug/1
Weekly
Grab
E
Antimony
2/month
Composite
E
Beryllium
2/month
Composite
E
Chloride
2/month
Composite
E
Chloroform
2/month
Grab
E
' Sample locations: E = Effluent, I=Influent, Upstream -at C ty-oiGastonia-Pump-Station; D=Downstream at a) Spencer Mountain Dam pool at dam, b) NCSR 2003, and c) 1.5 miles below tailrace at
powerlines. Instream monitoring shall be grab samples taken 3/wk (Jun -Sep) and 1/wk (Oct -May). These monitoring frequencies specified above for dissolved oxygen, temperature, conductivity and pH are
to be used only when experiencing operational problems with the YSI 6-series system. It is assumed that when the YSI system is operating properly, these four parameters will be monitored continuously.
2 The monthly average effluent BODS and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal.)
3 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
Chronic Toxicity (Ceriodaphnia), P/F, no significant mortality at 10%; March, June, September and December; See Supplement to Effluent Limitations and Monitoring Requirements Page - Special
Conditions for flow of 8.0 MGD to South Fork Catawba River.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
61769/i bnt

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS PERMITTED DISCHARGE TO LONG CREEK
Permit No. NC0020184
During the period beginning on the effective date of the permit and lasting until relocation to the South Fork Catawba River, the Permittee is authorized to discharge from outfall(s) serial number 001.
Such discharges shall be limited and monitored by the Permittee as specified below:
Notes:
EFFLUENT CHARACTERISTICS
• LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
8.0 MGD
Continuous
Recording
I or E
BOD 5-day 20 C2 (April 1 - October 31)
11.0 mg/1
16.5 mg/1
Daily
Composite
E, I
BOD 5-day 20 C2 (November 1- March 31)
22.0 mg/1
33.0 mg/1
Daily
Composite
E, I
TSS2
30.0 mg/1
45.0 mg/1
Daily
Composite
E, I
NH3-N (April 1 - October 31)
7.0 mg/1
Daily
Composite
E
NH3-N (November 1 - March 31)
14.0 mg/1
Daily
Composite
E
Dissolved Oxygen'
Daily
Grab
E, U, D
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
E
Temperature
Daily
Grab
E, U, D
Total Residual Chlorine
Daily
Grab
E
Conductivity
Daily
Grab
U, D
Total Nitrogen (NO2 + NO, + TKN) -
Weekly
Composite
E
Total Phosphorus
Weekly
Composite
E
Chronic Toxicity°
Quarterly
Composite
E
Cadmium
_
2.5 ug/1
6.2 ug/1
Weekly
Composite
E
-
Cyanide
6.2 ug/1
27.3 ug/1
Weekly
Grab
E
Lead
31.0 ug/1
42.0 ug/1
Weekly
Composite
E
Mercury
0.015 ug/1
0.060 ug/1
Weekly
Grab
E
Nickel
109 ug/1
437 ug/1
Weekly
Composite
E
' Sample locations: E = Effluent, I=Influent, U=Upstream at NCSR 2264, D=Downstream at NCSR 2003. Instream monitoring shal _be_grab samples-taken-3/wk (Jun-Sep)-and-1/wk-(oct May).
The -monthly average-effluent-BOD5d Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal.)
The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mgll.
° Chronic Toxicity (Ceriodaphnia), P/F, 81%; March, June, September and December, See Supplement to Effluent Limitations and Monitoring Requirements Page - Special
Conditions for flow of 8.0 MGD to Long Creek
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
61774/ 1 bny

EFFLUENT LhMITATIONS AND MONITORING REQUIREMENTS PF.RMITIF.D DISCHARGE TO S. FORK CATAWBA RIVER
Permit No. NC0020 t84
During the period beginning after the relocation of the discharge to the South Fork Catawba River and the expansion to 16.0 MGD and lasting until expiration, the Penmittee is authorized to discharge
from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as itied below.
Taber:
tailrace at werlines. Iastresm monitoring shall be(Oct-May).` - -- ^_ _ �.- .---- �.�.~ �, ....� ", '�•••" "' n
po ng grab samples taken 3fwk (Jun-S 'p) and 1 /wk These monitoring frequencies specified abate for dissolved oxygen, temperature,
t tlnductieity and pl 1 are to be used only when eX-Feriencing operational problems with the YSI 5-series system. It is assumed that when the YSI system is operating properly, these four parameters will be
monit red continuously.
2 Tile monthly average effluent 130D5 and Total Suspended Solids concentrations shall not exceed 15°l0 of the respective influent value (8,5% removal.)
The daily average dissolved oxygen effluent concentration shall nut be les tharLS.0 mom.
TN mass -based average of 8C0 Ibs per day until March 31, 1999. Concentration based limit of 5_nJ1 rsom April. 1, 1999 through Scpt:an c. - 2001. *.f necessary, the City of Gastonia will, cn a test basis,
assess the efficacy of partially diverting effluent tlow f'rcm Clef :chrnann's Veast facility to the Crt wders Creek WWl1' is a :Deans of achieving its permit limitation.
Chronic Toxicity (Ceriodaplmia), P.1F, no significant mortality at 19%: March, June, September and December Sex; Supplement to Effluent Limitations and Monitoring Requirements Page - Special
Conditions for slow of 16.0 MGl) to South Fork Catawba :fiver.
'The detection limit for :nercury is 0.2 ug.A. it' he measured levels of mercury : are 1x:low the tla:-etion limit, then the mt asur-ement is :.onsid_ered to be ,ern for purposes of compliance evaluation and
should be reported on the Dfvt1t ns < t7.2 n i1.
Thc pH shall not be less than 6.0 standard unite nor grater than 9.') andarti units and shall be racmitoreti daily it the effluent by `.-fib sample.
There shall to no discharge of floating solids or visible ibam in :Aber than .race stnonLnts.
01'1bni
EFFLUENT CHARACTERLSTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Mesimum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
16.0 MGD
Continuos
Recording
I or E
BOD 5-day 20 C2 (April 1 - October 31)
5.0 mr/1
7.5 mg/I
Daily
Composite
E, I
130D 5-day 20 C2 (November 1-14March 31) .
10.0 mgft
15.0 mg/1
Daily
Composite
E, I
TSS2
30.0 mg/1
45.0 mg/1
Daily
Composite
E, I
NH3-N (April 1 - October 31)
2.0 mg/1
Daily
Composite
E
NH3-N (November 1 - March 31)
4.0 mg/1
Daily
Composite
E
Dissolved Oxygen'
Daily
Grab
E,1_r, D
Fecal Colifarm (geometric mean)
200/100 rnl
400/100 ml
Daily
Grab
E
1
Daily
Grab
E, U, D
Temperature
Total Residual Chlorine
28.0 ug/1
Daily
Grab
E
Conductivity
Daily
Grab
I:, 1)
Total Nitrogen` (NO2 + NO, + TICN) (April 1- September 30)
800 lbs./6mg/1
Weekly
Composite
E
Total Phosphorus
1.0 mg/1
Weekly
Composite
E
Chronic Toxicity'
Quarterly
Composite
it
Cadmium
10.S ug/1
27.0 ug/t
Weekly
Composite
E
Cyanide
27.0 itgA
118.7 ug/1
Weekly
Grab
E
Lead
134.9 ug/1
182.3 ugf1
Weekly
Composite
E
Mere
Weekly
Grab
E
Antimony
2/month
Composite
E
Beryllium
E
2/month
Composite
E
Chloride
2/month
Composite
E
Chloroform
2/month
Grab
H

Part I
Section B. Schedule of Compliance
1. The pennittee shall comply with Final Effluent Limitations specified for discharges in accordance with the
following schedule:
Pennittee shall comply with Final Effluent Limitations by the effective date of the pe
below.
it unless specified
2. Permittee shall at all times provide the operation and maintenance necessary to operate the existing facilities
at optimum efficiency.
3. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee
shall submit either a report of progress or, in the case of specific actions being required y identified dates,
a written notice of compliance or noncompliance. In the latter case, the notice shall in lude the cause of
noncompliance, any remedial actions taken, and the probability of meeting the next sched a requirements.
61931 /l bsb

Part II
Page 1 of 14
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
SECTION A. DEFINITIONS
1. Permit Issuing Authority
The Director of Division of Water Quality.
2. DEM or "the Division"
Means the Division of Water Quality, Department of Environment, Health and Natural Res urces.
3. EMC
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amende ,.33 USC 1251,
et. seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges sampled and/or
measured during a calendar month on which daily discharges are sampled and measured, divided by
the number of daily discharges sampled and/or measured during such month. It is therefore, an
arithmetic mean found by adding the weights of the pollutant found each day of the month and then
dividing this sum by the number of days the tests were reported. The limitation is identified as
"Monthly Average" in Part I of the permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled and/or
measured during the calendar week (Sunday - Saturday) on which daily discharge are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such week. It
is, therefore, an arithmetic mean found by adding the weights of pollutants found each day of the
week and then dividing this sum by the number of days the tests were reported. 's limitation is
identified as "Weekly Average" in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant dis arged during a
calendar day. If only one sample is taken during any calendar day the weight of po lutant calculated
from it is the "maximum daily discharge." This limitation is identified as "Daily Maximum," in Part
I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharge sampled and/or
measured during the calendar year on which daily discharges are sampled and me ured, divided by
the number of daily discharges sampled and/or measured during such year. It is, therefore, an
arithmetic mean found by adding the weights of pollutants found each day of a year and then
dividing this sum by the number of days the tests were reported. This limitat' n is defined as
"Annual Average" in Part I of the permit.
61931/lbsb

6. Concentration Measurement
a. The "average monthly concentration," other than for fecal coliform bacteria
concentrations of all daily discharges sampled and/or measured during a calendar
discharges are sampled and measured, divided by the number of daily disch
measured during such month (arithmetic mean of the daily concentration
concentration value is equal to the concentration of a composite sample or in the c
the arithmetic mean (weighed by flow value) of all the samples collected during th
average monthly count for fecal coliform bacteria is the geometric mean of th
collected during a calendar month. This limitation is identified as "Monthly A
Limits" in Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria,
concentrations of all daily discharges sampled and/or measured during
(Sunday/Saturday) on which daily discharges are sampled and measured divided b:
discharges sampled and/or measured during such week (arithmetic mean of th
values). The daily concentration value is equal to the concentration of a composite
of grab samples is the arithmetic mean (weighted by flow value) of all the samples
Part II
Page 2 of 14
is the sum of the
nonth on which daily
rges sampled and/or
values). The daily
se of grab samples is
�t calendar day. The
counts for samples
erage" under "Other
is the sum of the
a calendar week
the number of daily
daily concentration
sample or in the case
collected during that
calendar day. The average weekly count for fecal coliform bacteria is the geometric mean of the counts
for samples collected during a calendar week. This limitation is identified as "Weekly Average" under
"Other Limits" in Part I of the permit.
c. The "maximum daily concentration" is the concentration of a pollutant discharge d ' g a calendar day.
If only one sample is taken during any calendar day the concentration of pollutant alculated from it is
the "Maximum Daily Concentration." It is identified as "Daily Maximum" under " er Limits" in Part
I of the permit.
d. The "average annual concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar year on which daily
discharges are sampled and measured divided by the number of daily discharges sampled and/or
measured during such year (arithmetic mean of the daily concentration values). Th daily concentration
value is equal to the concentration of a composite sample or in the case of grab sam les is the arithmetic
mean (weighted by flow value) of all the samples collected during that calendar day. The average yearly
count for fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar year. This limitation is identified as "Annual Average" under "Other Limits" in Part I of the
permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable ount of dissolved
oxygen required to be available in the effluent prior to discharge averaged over a c endar day. If only
one dissolved oxygen sample is taken over a calendar day, the sample is conside ed to be the "daily
average concentration" for the discharge. It is identified as "daily average" in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a calndar quarter. It is
identified as "Quarterly Average Limitation" in the text of Part I of the permit.
g.
A calendar quarter is defined as one of the following distinct periods: January
through June, July through September ,and October through December.
March, April
61931/lbsb

7 Other Measurements
Part II
Page 3 of 14
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow, averaged monthly.
It is determined as the arithmetic mean of the total daily flows recorded during the alendar month.
b. An "instaneous flow measurement" is a measure of flow taken at the time of sam
sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the f
continually without interruption throughout the operating hours of the facility. Flo
continually except for the infrequent times when there may be no flow or for
activities on the flow device.
8. Types of Samples
a.
(3)
Composite Sample: A composite sample shall consist of:
ling, when both the
cility which occurs
shall be monitored
equent maintenance
(1) a series of grab samples collected at equal time intervals over a 24 hour per�}}o�d of discharge and
combined proportional to the rate of flow measured at the time of individual sample collection,
or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time intervals
between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the present gallon interval between sample collection fixed at no greater than 1/24
of the expected total daily flow at the treatment system, or
a single, continuous sampled collected over a 24 hour period proportional to the rate of flow.
In accordance with (1) above, the time interval between influent grab samples sh be no greater than
once per hour, and the time interval between effluent grab samples shall be no gr ater than once per
hour except at wastewater treatment systems having a detention time of greater th 24 hours. In such
cases, effluent grab samples may be collected at time intervals evenly spaced over the 24 hour period
which are equal in number of hours to the detention time of the system in number ofl days. However, in
no case may the time interval between effluent grab samples be greater than six (6) hours nor the
number of samples less than four (4) during a 24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not exceeding 15
minutes; the grab sample can be taken manually. Grab samples must be representative of the discharge
or the receiving waters.
9. Calculation of Means
a. Arithmetic Mean: The arithmetic mean of any set of values is the summation of the individual values
divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of a product of the
individual values where N is equal to the number of individual values. The eometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms of the individual v ues. For purposes
of calculating the geometric mean, values of zero (0) shall be considered to be one (1).
c. Weighted by Flow Value: Weighted by flow value means the summation of each concentration times its
respective flow divided by the summation of the respective flows.
61931/lbsb

Part II
Page 4 of 14
10. Calendar Day
A calendar day is defined as the period from midnight of one day until midnight of the ne day. However, for
purposes of this permit, any consecutive 24-hour period that reasonably represents the cale dar day may be used •
for sampling.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant o Section 311 of the
Clean Water Act.
12. Toxic Pollutant
A toxic pollutant is any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
SECTION B. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and
reissuance, or modification; or denial of a permit renewal application.
a. The permittee shall comply with effluent standards or prohibitions established un er section 307(a) of
the Clean Water Act for toxic pollutants and with standards for sewage slu ge use or disposal
established under section 405 (d) of the Clean Water Act within the time provided ' the regulations that
establish these standards or prohibitions or standards for sewage sludge use or 'sposal, even if the
permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition 's subject to a civil
penalty not to exceed $25,000 per day for each violation. Any person who neg igently violates any
permit condition is subject to criminal penalties of $2,500 to $25,000 per y of violation, or
imprisonment for not more than 1 year, or both. Any person who knowingly viola s permit conditions
is subject to criminal penalties of $5,000 to $50,000 per day of violation, or impris nment for not more
than 3 years, or both. Also, any person who violates a permit condition rray be assessed an
administrative penalty not to exceed $10,000 per violation with the maximum amount not to exceed
$125,000. [Ref: Section 309 of the Federal Act 33 U.S.C. 1319 and 40 CFR 122.4 i (a)]
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) er violation may be
assessed against any person who violates or fails to act in accordance with the t rms, conditions, or
requirements of a permit. [Ref: North Carolina General Statutes § 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating section 301,
302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation implementing any of
such sections in a permit issued under section 402 of the Act. Administrative penalties for Class I
violations are not to exceed $10,000 per violation, with the maximum amount of any Class I penalty
assessed not to exceed $25,000. Penalties for Class II violations are not to exceed i510,000 per day for
each day during which the violation continues, with the maximum amount of any Class II penalty not to
exceed $125,000.
61931/lbsb

Part II
Page 5 of 14
2. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the
environment.
3. Civil and Criminal Liabili
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power F ilures" (Part II, C-7),
nothing in this permit shall be construed to relieve the permittee from any responsibilities, liabilities, or penalties
for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC 1319.
Furthermore, the permittee is responsible for consequent damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action r relieve the permittee
from any responsibilities, liabilities, or penalties to which the permittee is or may be s bject to under NCGS
143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the permittee is responsible
for consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion a f personal rights, nor
any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore
facilities or the undertaking of any work in any navigable waters.
7. Severability
hysical structures or
The provisions of this permit are severable, and if any provision of this permit, or the application of any
provision of this permit to any circumstances, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected thereby.
8. Duty to Provide Information
The pennittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, r voking and reissuing,
or terminating this permit or to determine compliance with this permit. The permittee s 1 also furnish to the
Permit Issuing Authority upon request, copies of records required to be kept by this permit.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration cute of this permit, the
permittee must apply for and obtain a new permit.
61931/lbsb

10. Expiration of Permit
The permittee is not authorized to discharge after the expiration date. In order
authorization to discharge beyond the expiration date, the permittee shall submit such •
fees as are required by the agency authorized to issue permits no later than 180 days prior
Any permittee that has not requested renewal at least 180 days prior to expiration, or any p
have a permit after the expiration and has . not requested renewal at least 180 days pri
subject the permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 U
11. Signatory Requirements
Part II
Page 6 of 14
o receive automatic
rmation, forms, and
o the expiration date.
rmittee that does not
r to expiration, will
C 1251 et. seq.
All applications, reports, or information submitted to the Permit Issuing Authority shall be •igned and certified.
a.
All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpo
responsible corporate officer means: (a) a president, secretary, treasurer or
corporation in charge of a principal business function, or any other person
policy or decision making functions for the corporation, or (b) the man
manufacturing production or operating facilities employing more than 25
(2)
(3)
e of this Section, a
vice president of the
'ho performs similar
ger of one or more
. persons or having
gross annual sales or expenditures exceeding 25 million (in second quarter 1980 dollars), if
authority to sign documents has been assigned or delegated to the manager in accordance with
corporate procedures.
For a partnership or sole proprietorship: by a general partner or the proprie or, respectively; or
For a municipality, State, Federal, or other public agency: by either a princi al executive officer
or ranking elected official.
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall
be signed by a person described above or by a duly authorized representative of that person. A person
is a duly authorized representative only if:
(1)
(2)
(3)
The authorization is made in writing by a person described above;
The authorization specified either an individual or a position having r sponsibility for the
overall operation of the regulated facility or activity, such as the positio of plant manager,
operator of a well or well field, superintendent, a position of equivalent esponsibility, or an
individual or position having overall responsibility for environmental matt s for the company.
(A duly authorized representative may thus be either a named individu or any individual
occupying a named position.); and
The written authorization is submitted to the Permit Issuing Authority.
c. Certification. Any person signing a document under paragraphs a. or b. of this se tion shall make the
following certification:
"I certify, under penalty of law, that this document and all attachments were jrepared 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 informat on, the information
submitted is, to the best of my knowledge and belief, true, accurate, and complet . I am aware that
there are significant penalties for submitting false information, including the pos ibility of fines and
imprisonment for knowing violations."
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Part II
Page 7 of 14
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The fil' of a request by the
permittee for a permit modification, revocation and reissuance, or termination, or a n tification of planned
changes or anticipated noncompliance does not stay any permit condition.
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and
regulations contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North
Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility, whether for
operation or discharge, are hereby revoked by issuance of this permit. [The exclusive authority to operate this
facility arises under this permit. The authority to operate the facility under previously issued permits bearing
this number is no longer effective.] The conditions, requirements, terms and provisions of this permit
authorizing discharge under the National Pollutant Discharge Elimination System govem discharges from this
facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the facility by the
Certification Commission, the permittee shall employ a certified wastewater treatment plant operator in
responsible charge (ORC) of the wastewater treatment facilities. Such operator must hold a certification of the
grade equivalent to or greater than the classification assigned to the wastewater treatment facilities by the
Certification Commission. The permittee must also employ a certified back-up operator of the appropriate type
and any grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must
visit each Class I facility at least weekly and each Class II, III, and IV facility at 1 t daily, excluding
week -ends and holidays, and must properly manage and document daily operation an maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A .0202. Once the facility is
classified, the permittee shall submit a letter to the Certification Commission which desi ates the operator in
responsible charge within thirty days after the wastewater treatment facilities are 50% complete.
2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the permittee to achieve compliance with the
conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the operation of back-uli or auxiliary facility
or similar systems which are installed by a permittee only when the operation is necessary tb achieve compliance
with the conditions of the permit.
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Part II
Page8of14
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have bee necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this pe 't.
4. Bypassing of Treatment Facilities
a. Definitions
(1) "Bypass" means the known diversion of waste streams from any portion c f a treatment facility
including the collection system, which is not a designed or established or operating mode for the
facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the
treatment facilities which causes them to become inoperable, or substantial and permanent loss
of natural resources which can reasonably be expected to occur in the bsence of a bypass.
Severe property damage does not mean economic loss caused by delays in roduction.
b. Bypass not exceeding limitations
The permittee may allow any bypass to occur which does not cause effluent limita ions to be exceeded,
but only if it also is for essential maintenance to assure efficient operation. Th se bypasses are not
subject to the provisions of Paragraph c. and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a b ass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; inc uding an evaluation
of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipate bypass as required
in Part II, E.6. of this permit. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action against a
permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequat backup equipment
should have been installed in the exercise of reasonable engineering 'udgment to prevent
a bypass which occurred during normal periods of equipment do time or preventive
maintenance; and
(C) The permittees submitted notices as required under Paragraph c. of 's section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after cor}sidering its adverse
affects, if the Permit Issuing Authority determines that it will meet the three conditions listed
above in Paragraph d.(1) of this section.
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Part II
Page 9 of 14
5. Upsets,
a. Definition.
"Upset" means an exceptional incident in which there is unintentional and temp • rary noncompliance
with technology based permit effluent limitations because of factors beyond the re • • nable control of the
permittee. An upset does not include noncompliance to the extent caused b, operational error,
improperly designed treatment facilities, inadequate treatment facilities, lack of pre entive maintenance,
or careless or improper operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for nonco pliance with such
technology based permit effluent limitation if the requirements of paragraph c. of s condition are met.
No determination made during administrative review of claims that noncompliance as caused by upset,
and before an action for noncompliance, is final administrative action subject to judi ial review.
c. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through properly
signed, contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the ups t;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the notice of the upset as required in P II, E. 6. (b)(B) of
this permit.
(4) The permittee complied with any remedial measures required under Part II, B.2. of this permit.
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence
burden of proof.
6. Removed Substances
f an upset has the
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utlized/disposed of in accordance with NCGS 143-215.1 and in a manner suc as to prevent and
pollutant from such materials from entering waters of the State or navigable waters of the nited States. The
permittee shall comply with all existing federal regulations governing the disposal of se age sludge. Upon
promulgation of 40 CFR Part 503, any permit issued by the Permit Issuing Authority for th utilization/idsposal
of sludge may be reopened and modified, or revoked and reissues, to incorporate applicable requirements at 40
CFR Part 503. The permittee shall comply with the applicable 40 CFR Part 503 Standards for the Use and
Disposal of Sewage Sludge (when promulgated) within the time provided in the regulation ven if the permit is
not modified to incorporate the requirement. The permittee shall notify the Permit IssuAuthority of any
significant change in its sludge use or the disposal practices.
7. Power Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM Regulation, Title 15A,
North Carolina Administrative Code, Subchapter 2H, .0124 Reliability, to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures either by means of alternate power sources, standby
generators or retention of inadequately treated effluent.
61931/lbsb

SECTION D. MONITORING AND RECORDS
I. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of
of the permitted discharge. Samples collected at a frequency less than daily shall be taken
is characteristic of the discharge over the entire period which the sample represents. All
at the monitoring points specified in this permit and, unless otherwise specified, before
diluted by any other wastestream, body of water, or substance. Monitoring points shall n
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each m
monthly Discharge Monitoring Report (DMR) Form (DEM No. MR 1, 1.1, 2, 3) or alte
by the Director, DEM, postmarked no later than the 30th day following the completed repo
The first DMR is due on the last day of the month following the issuance of the permit or
facility, on the last day of the month following the commencement of discharge. Dupli
these, and all other reports required herein, shall be submitted to the following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
3. Flow Measurements
Part II
Page 10 or 14
e volume and nature
sn a day and time that
amples shall be taken
e effluent joins or is
t be changed without
nth and reported on a
five forms approved
g period.
•
the case of a new
ate signed copies of
Appropriate flow measurement devices and methods consistent with accepted scientifi practices shall be
selected and used to ensure the accuracy and reliability of measurements of the volume of riionitored discharges.
The devices shall be installed, calibrated and maintained to ensure that the accuracy of tie measurements are
consistent with the accepted capability of that type of device. Devices selected shall be dapable of measuring
flows with a maximum deviation of less than + 10% from the true discharge rates throughout the range of
expected discharge volumes. Once -through condenser cooling water flow which is monito ed by pump logs, or
pump hour meters as specified in Part I of this permit and based on the manufacturer's pum, curves shall not be
subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
MCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended?and Regulation 40
CFR 136; or in the case of sludge use or disposal, approved under 40 CFR 136, unless othse specified in 40
CFR 503, unless other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported
down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
61931 /l bsb

Part II
Page 11 of 14
then the most sensitive (method with the lowest possible detection and reporting level) approved method must be
used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $200,000 per day of violation, or by impnsonment of not more
than 4 years, or both.
6. Records Retention
Except for records for monitoring information required by this permit related to the permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five year (or Ion er as required by 40
CFR 503), the pernuttee shall retain records of all monitoring information, including all calibration and
maintenance records and all original strip chart recordings for continuous monitoring ' entation, copies of
all reports required by this permit, for a period of at least 3 years from the date of the s ple, measurement,
report or application. This period may be extended by request of the Director at any time.
7 Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the pe ttee shall record the
following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authori - • contractor acting
as a representative of the Director), upon the presentation of credentials and other document as may be required
by law, to:
a. Enter upon the permittee's premises where a regulated facility or activity is locat d or conducted, or
where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under a conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and bontrol equipment),
practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliaince or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location.
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Part II
Page 12 of 14
SECTION E. REPORTING REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this pe~mit. The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned ph.
additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for d
facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the qi
discharged. This notification applies to pollutants which are subject neither to 'efflu
permit, nor to notification requirements under 40 CFR Part 122.42 (a)(1).
c. The alteration or addition results in a significant change in the permittee's slu
practices, and such alteration, addition or change may justify the application of pi
are different from or absent in the existing permit, including notification of additi
sites not reported during the permit application process or not reported pursuant
application plan.
3. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the
activity which may result in noncompliance with permit requirements.
4. Transfers
sical alterations or
ermining whether a
antity of pollutants
nt limitations in the
ige use or disposal
emit conditions that
anal use or disposal
o an approved land
ermined facility or
This permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permittee and incorporate such other requirements as may be
necessary under the Clean Water Act.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (Se Part II. D. 2 of this
permit) or forms provided by the Director for reporting results of monitoring of sl dge use or disposal
practice.
b. If the pennittee monitors any pollutant more frequently than required by th permit, using test
procedures specified in Part II, D. 4 of this permit or in the case of sludge use or disposal, approved
under 40 CFR 503, or as specified in this permit, the results of this monitoring shall be included in the
calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall
means unless otherwise specified by the Director in the permit.
utilize an arithmetic
61931/lbsb

6. Twenty -Four Hour Reporting
Part II
Page 13 of 14
a. The permittee shall report tot he central office or the appropriate regional office any noncompliance
which may endanger health or the environment. Any information shall be provided orally within 24
hours from the time the permittee became aware of the circumstances. A writte ' submission shall also
be provided within 5 days of the time the permittee becomes aware of the circ . • ces. The written
submission shall contain a description of the noncompliance, and its cause; the pe od of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, e anticipated time it
is expected to continue; and steps taken or planned to reduce, eliminate, and prey • t reoccurrence of the
noncompliance.
b. The following shall be included as information which must be reported within 24 hours under this
paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the pe
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the po
Director in the permit to be reported within 24 hours.
utants listed by the
c. The Director may waive the written report on a case -by -case basis for reports undtir paragraph b. above
of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II.E.5 an
the time monitoring reports are submitted. The reports shall contain the information listed
permit.
8. Other Information
6. of this permit at
Part II.E.6. of this
Where the permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information.
9. Noncompliance Notification
The pennittee shall report by telephone to either the central office or the appropriate r:: ional office of the
Division as soon as possible, but in no case more than 24 hours or on the next workin: day following the
occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the disc arge of significant
amounts of wastes which are abnormal in quantity or characteristic, such as the d ping of the contents
of a sludge digester; the known passage of a slug of hazardous substance through the facility; or any
other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the . cility incapable of
adequate wastewater treatment such as mechanical or electrical failures oil pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters without treatment of all or any portion of the influent to such station or facility.
61931/lbsb

Part II
Page 14 of 14
Persons reporting such occurrences by telephone shall also file a written report in letter form wi 5 days following
first knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal Act,
33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspe on at the offices of
the Division of Water Quality. As required by the Act, effluent data shall not be considered confi ential. Knowingly
making any false statement on any such report may result in the imposition of criminal penalties as provided for in
NCGS 143-215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statemen ' representation, or
certification in any record or other document submitted or required to be maintained under thi permit, including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both.
61931/lbsb

PART III
OTHER REQUIREMENTS
A. Construction
No construction of wastewater treatment facilities or additions to add to the plant's trea ent capacity or to
change the type of process utilized at the treatment plant shall be begun until Final Plans an Specifications have
been submitted to the Division of Water Quality and written approval and Authorization t Construct has been
issued.
B. Groundwater Monitoring
The permittee shall, upon written notice from the Director of Water Quality, conduct groundwater monitoring as
may be required to determine the compliance of this NPDES permitted facility with the current groundwater
standards.
C. Changes in Discharges of Toxic Substances
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to
elieve:
a. That any activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1) One hundred micrograms per liter (100 ug/l);
(2) Two hundred micrograms per liter (200 ug/l) for acrolein and acrylo •trile; five hundred
micrograms per liter (500 ug/l) for 2.4-dinitrophenol and for 2-methyl-4.-dinitrophenol; and
one milligram per liter (1 mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that poll tant in the permit
application.
b. That any activity has occurred or will occur which would result in any discharge, 'on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that disc ge will exceed the
highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 ug/1);
(2) One milligram per liter (1 mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit
application.
D. Requirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most
environmentally sound alternative of the reasonably cost effective alternatives. If the facili , is in substantial
non-compliance with the terms and conditions of the NPDES permit or governing rules, regul : tions or laws, the
permittee shall submit a report in such form and detail as required by the Division evaluating thes alternatives and a
plan of action within sixty (60) days of notification by the Division.
61931/lbsb

PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE REQUII�.EMENTS
A. The permittee must pay the annual administering and compliance monitoring fee wi 30 days
(thirty) days after being billed by the Division. Failure to pay the fee in a timely manner in
accordance with 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action t revoke the
permit.
61931/lbsb

11Iig of (!azfotha
P. O. BOX 1748
6tts#oniu,'ortti (Ilttrolinn 28053-1748
DEPARTMENT OF
PUBLIC WORKS AND UTILITIES
October 20, 1997
Mr. Don Safrit
North Carolina Department of Environment,
Health, and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Long Creek WWTP
NPDES Permit No. NC0020184
Subject: South Fork River Stream Monitoring
Dear Mr. Safrit:
(0",
OCT
)I))
2 2 199/
POINT SO RCE BRANCH
The City of Gastonia staff have been working with DWQ staff, Diane Wil urn, Dave
Goodrich, and Paul Clark, for over two years to fmalize the details for is stream
monitoring project. The potential for substantial benefit to both the City f Gastonia
and the Division of Water Quality is immense. The City initially agree to install
continuous instream monitoring equipment at each of the four monit ring sites
identified in the Long WWTP NPDES permit. In turn, DWQ agreed t limit the
parameters to be monitored to those possible to monitor with the YSi instream
monitoring equipment. The State would receive an accurate and complete record of the
river condition, based upon this continuous monitoring, and the City would ve access
to this information as well as be able to reduce manpower by utilizing quipment
instead of technicians to perform stream monitoring requirements. The ne NPDES
permit for the Long WWTP reflects these commitments on the part of th City and
DWQ.
The City has developed plans, through J.N. Pease Associates, for ins lling this
automated equipment at the four sites designated in the Permit. As part of is project,
Pease contacted construction firms to develop cost estimates. The construc ion group
indicated that two of the sites were inaccessible and that the planned installat'on would
be extremely difficult or impossible. City staff and our engineering consultant met with
Dave Goodrich and other DWQ staff in July, 1997, at Gastonia to discuss the problems

October 20, 1997 303'e / o(h,
Stream Monitoring
Page 2
with installing the continuous monitoring equipment. It was pointed out at this meeting
that access to the most downstream site is currently difficult and that collecting samples
by hand is very dangerous at this location.
From this meeting, it was our understanding that DWQ was in agreement th t the most
downstream site was poorly accessible and that an alternate site would be onsidered.
It was suggested that Crompton Knowles Colors, Inc., be contacted and that it might be
possible to use their stream monitoring data for the required downstream information in
the section of the River where DO sag was a concern. A second alternative
downstream site discussed was the USGS gauging station. City staff met with
Crompton Knowles Colors, Inc., and it was determined that both their site and the
USGS site are difficult to access, and it was also learned that Crompton Knowles
Colors, Inc., does not currently perform any instream monitoring.
The City presently has funds designated for the construction of the ontinuous
monitoring sites and is eager to proceed with this project. However, the City cannot
move forward with the project until a decision is reached regarding the problems
mentioned. The City requests that only two continuous monitoring sites b required,
one upstream and one downstream, both located at sites that are accessible for
construction and subsequent maintenance. From past discussions, it appears that the
City and DWQ can agree on the upstream site being at the abandoned Ranlo water
intake. The downstream location at the dam is considered reasonable by the City, but it
appears that DWQ would prefer a site downstream of the hydro plant, either in lieu of,
or in addition to, the dam site. (Refer to enclosed map.)
iladDri
r%�',,� The City suggests that all dischargers on this section of the South Fork River be part of
a4, '(,1- a concerted effort to collect quality data for this entire section of the River. The City is
etvarc- " _certainly willing and eager to be a part of this planned approach to monitoring the water
t. j Wow- quality of the South Fork. If the StSt,112xcluki moslerate a meeting between all affected
toko ¥c LC.. parties, the City is willing to assist in any way possible to move forward with !a planned
,nt a
��� 44 % approach to monitoring this impacted section of the South Fork River.
•
p0-tt, The discharge om the Long WWTP will be diverted to the South Fork River in the
very near future. Until the above matters can be resolved, the City requests that DWQ
approve a temporary change in the NPDES permit, requiring only grab samples to be
tv
,�� collected upstream at the Ranlo intake §ite and downstream at the dam.
�
tvJ 4L 1e v ' 5 .

),•41n4.)00s
01-44 €,Zr
October 20, 1997
Stream Monitoring
Page 3
The City would like to emphasize that funds are currently available to construct the two
continuous monitoring sites, but further delays may result in the funds being diverted to
other projects within the Cityurthermore, if downstream grab sampling is required I
in addition to the continuous monitoring, the City loses its justification for installing the f
equipment to replace manpower needs.
Your assistance with moving this matter forward is greatly appreciated. City staff are
willing to meet with you and other interested parties at any time to reach a resolution of
this matter. Thank you for your assistance and consideration.
Sincerely,
Assistant Director of Utilities
pc: Paul Clark, DWQ
Don Garbrick, J.N. Pease, Associates
Don Carmichael, City of Gastonia
Coleman Keeter, City of Gastonia
Dennis Redwing, City of Gastonia
Larry Cummings, City of Gastonia
lcsm.doc

MICHAEL F. EASLEY
ATTORNEY GENERAL
State of North Carolina
Department of Justice
P. O. BOX 629
RALEIGH
27602.0629
REPLY TO: Anita LeVeaux- uigless
Environmental Division
Tel. No. (919) 7 6-6600
Fax : (919) 716- • 766
The Sanford Holshouser Law Firm
Laurie B. Gengo, Esq.
234 Fayetteville Street
Raleigh, North Carolina 27601
October 17, 1997
RE: Fleischmann's Yeast, Permit No. NC0020184
Dear Ms. Gengo:
nJ.CQ�II�
Yesterday, a copy of your August 22, 1997 letter to my client, the North IIarolina
Department of Environment and Natural Resources, NPDES Group (DENR), was forwairded to
my attention. DENR is pleased that the afore -referenced matter has been settled. Unfo
if appropriate technologies for removing total nitrogen cannot be developed by March 19
your client is unable to meet its concentration limits they will be in violation of their
limits. Of course, as you know, your client has redress in the Administrative Procedur
Based upon this understanding, if you wish to withdraw the petition, please notify me
same. Conversely, if you have any questions, please feel free to call.
Very truly yours,
Anita LeVeaux-Quigless
Assistant Attorney General
tely,
9, and
permit
s Act.
of the

Page 1
From:
Date:
Subject:
To:
Note for Paul Clark
Ruth Swanek
Wed, Oct 8, 1997 4:38 PM
RE: USGS instream monitoring
Paul Clark
The monitoring associations coordinate with us. Some sites are also at U
I don't know of any other efforts where we have coordinated with permitt
From: Paul Clark on Wed, Oct 8, 1997 10:43 AM
Subject: USGS instream monitoring
To: Juan Mangles; Ruth Swanek
Ruth, Juan,
We are working with the City of Gastonia on their instream monitoring.
interest in installing continuous instream monitoring. We are in the proces
location of these stations as well as some manual stations that would comp
continuous data. There is a USGS gaging station that could serve as a pot
monitoring station. Are either of you familiar with other sites across the st
exists coordinated monitoring between USGS, the Division, and a permitt
you have any contact name(s). Thanks.
PC
GS gage stations.
es.
ey have an
of deciding the
ement the
ntial continuous
to where there
e?? If yes, do

CORRECTIVE ACTION PLAN ADDENDUM
HONEYCUTT EXXON
127 WEST MAIN STREET
LOCUST, NORTH CAROLINA
Report Prepared For:
The Estate of Floyd E. Honeycutt
in care of G. Crawford Rippy, III
Brown, Brown, Brown, and Stokes, L.L.P.
Attorneys at Law
101 South Second Street
Albemarle, North Carolina
Report Prepared By:
HANDEX OF THE CAROLINAS, INC.
3600-G WOODPARK BOULEVARD
CHARLOTTE, NORTH CAROLINA 28206
3 (ct
CHARLES D. FLETCH , P.G. DATE
PROJECT HYDROGEOLOGIST
.(A 64Ylt
EVAN B. CLARK, P.E.
PROJECT MANAGER
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MEMORANDUM
TO:
FROM:
SUBJECT:
DATE:
File
Paul Clark
Fleishmann's/Gastonia/DWQ Agreement/Instream Sampling Update
9/30/97
Conversation between Larry Cummings (Gastonia) and Paul Clark (DWQ)
Fleishmann's
Larry Cummings stated that it was Gastonia's intent that Fleishmann's, Gastonia, and DWQ will each be members
of a team assigned with the task of removing total nitrogen (TN) from Fleishmann's wastetream. DWQ would
maintain an advisory role ensuring that continual progress is made toward meeting the TN oncentration limits.
Diversion from Long Creek WWTP to Crowders Creek WWTP had not yet begun because it may not be
necessary based on research (if Long Creek WWTP alone is capable of adequately removing nitrogen to
acceptable levels).
Fleishmann's and Gastonia's intent is to meet the TN concentration limits by March 1999.1Fleishmann's wants to
continue to discharge and Gastonia does not want to receive violations even if TN limits arenot met.
Paul Clark told Larry Cummings that either DWQ would either first, respond to Sanford Holshouser 8/22/97 letter
and then issue permit modification or only issue permit modification. Paul Clark has to speak with Kathy Cooper.
Instream Sampling
Larry Cummings confirmed that upstream at Ranlo WTP intake and downstream at the dam
bypass would be suitable locations for continuous monitoring stations.
Larry Cummings again stated that the instream sampling location in the vicinity of the hydroelectric plant has the
following problems:
1. Steep slope and thick vegetation. Gastonia had conducted sampling at this location in th past and had
terminated sampling because of poor accessibility.
2. Duke originally owned the hydroelectric plant but now Chicago firm owns plant and accessibility on to
property may be a problem.
Larry Cummings again asked if manual downstream monitoring stations were necessary even with the continuous
monitoring stations. The cost of construction and installation of the continuous monitoring stations had increased
to $250,000-$300.000. Thus, Gastonia wanted to confirm necessity of all monitoring stations. Paul Clark
confirmed that these stations were necessary because the dissolved oxygen sag occurs downstream of the point
where the bypass confluences with the South Fork Catawba River. Steve Bevington recommended the following
two downstream locations: SR 2003 and 1.5 miles below tailrace at powerlines.
and beginning of
Larry Cummings stated that Crompton -Knowles may have a more accessible instream monitoring location. Paul
Clark suggested power line location. Larry Cummings stated he would compare these three
most accessible of the three.
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NC0026646 Summary
July 25, 1997
August 27, 1997 (revised)
1995 and 1996 APAM data were reviewed. Parameters in summary table include those:
(1) above the detection limit, and (2) for which monitored is not required in either the
NPDES permit or the pretreatment permit (LIMP).
Na. e
1.0/95
11/96
WQ, Std or
e Criteria
A /
ABC/1.5MGD
AEC/3.0MGD
Alumin o.
310
590
acute 750
chronic 87
chronic 3163
chronic 1625
Antimony
46
245 .
4300 OC
not calculated
not calculated
Arsenic
: DL
194
50 aql
1818
933
Selenium
4.
175
5 aql
182
93
Barium
35
39
2000 MCL
not calculated
not calculated
Chloride
62000
52100
acute860000
chronic230000
not calculated
not calculated
Fluoride
950
730
1800 aql
not calculated
not calculated
Bromodichlo
romethane
23.2
: DL
22,46q
not calculated
not calculated
Bromoform
1.2
BD ►_
360
not calculated
not calculated
Chloroform
23.4
BDL
34
not calculated
not calculated
Dibromochlo
romethane
10.6
BDL
470
not calculated
not calculated
AEC: Allowable Effluent Concentra h.• n
BDL: Below Detection Level
MCL: Maximum Contaminant Level
q: Value determined after federal crite
All concentrations are in ug/1 unless indicate
OC: Organism Consumption
aql: aquatic life criteria
published, or new cancer potency slope factor
therwise.
Selenium monitoring will be required (but not li ed) because the 1996 detection was
greater than the allowable effluent concentration at ' 0 MGD. Monitoring will not be
required for any other inorganic parameters detected o. ng the APAM analyses because
allowable effluent concentrations are significantly greathan detected concentrations.
Bromodichloromethane, bromoform, chloroform, and dib ochloromethane were all
detected at concentrations less than 50 ug/1 during the 1995 'AM sampling event. At
those concentrations, it is expected that these four compound originated from formation of
chlorine with organic matter (i.e.are likely disinfection by -pro' cts). All four of these
compounds are carcinogens, yet monitoring will not be required . • r the following two
reasons:
1) Concentrations detected were below federal criteria, and
2) None of the four compounds were detected during most recent • ' sampling event.
The APAM will no longer be required in the NPDES permi
Page 3 of 4

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Page 1
From:
Date:
Subject:
To:
C
Note for Paul Clark
Dave Goodrich
Sat, Sep 13, 1997 10:21 AM
FW: South Fork Catawba
Paul Clark
Paul - Please print this one out and place in Gastonia - Long Creek file._ ,
Thanks, Dave
From: Steve Bevington on Fri, Aug 29, 1997 1:22 PM
Subject: South Fork Catawba
To: Dave Goodrich
Per your request, I have reviewed modeling information relevant to the dis
Gastonia' Long Creek WWTP. As you had suspected, a DO sag is predict
Fork below the confluence of the tailrace and bypass reach. This DO sag s
monitored if possible, and monitoring at the USGS gage seems appropriat
Note: Under some possible conditions of dam operation, a DO sag in the
in fact be the most significant issue. However, under true run of river con
sag below th econfluence of tailrace and bypass reach is predicted to be the
This may have resulted in some confusion. Ca11 me at [phone] if y
questions.
Thanks
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harge of the
d in the South
ould be
forebay may
itions, the DO
most significant.
u have further
.1CaLiLA
6 RM

B. Land Based Disposal
The Town of Middlesex does not own land in the area to
implement a land based disposal system. Suitable land
in the vicinity could be obtained. According to the
Soil Survey of Nash County, North Carolina by the U.S.
Department of Agriculture, the soils in the well No. 4
area are Norfolk-Georgeville-Rains. Based on a
hydraulic loading rate of 1.0 inches of water per acre
per week for the soils above, 25 percent set -aside for
crop harvesting and planting and 25 percent unusable
land due to internal roads and 150 feet buffer zone,
a total of seven (7) acres would be required. Note,
the actual hydraulic loading rate will not be know
until the land selected is tested. The cost of
constructing a lagoon storing 90 days of backwash
water, a pump station a 4-inch transmission line to
the site and spray irrigation equipment would $333,800
as shown in Table 2.
TABLE 2. OPTION "B" COST ESTIMATE
Land (7 acres) $ 35,000
Lagoons Construction 50,000.
Pump Station 90,000
Force Mains (5,000 lf) 90,000
Irrigation System 10,000
Monitoring Wells (5) 10,000
Total Construction Costs $ 275,000
Legal Fees (0.4%) 1,100
Administrative (0.4%) 1,100
Engineering Design 20,600
Inspection 8,500
Contingency Fee (10%) 27,500
TOTAL PROJECT COST $ 333,800
C. Backwater Water Re -Use:
Backwash water re -use is not a viable option.
D. Surface Water Discharge:
Surface water discharge is the proposed method of
backwater disposal. The backwash water from the
drying beds would discharge into the US 164 Alternate
3 ENGINEERING ALTERNATIVES ANALYSIS 3

NC0020184 Summary
August 15, 1996
November 15, 1996 (revised)
Instream Monitoring
Instream monitoring occurred at upstream station at NCSR 2264 and downstream station
NCSR 2003. Instream data was examined from January 1994 through May 1996. The
data summaries below refer to monthly averages.
- Dissolved oxygen dropped from the upstream to the downstream station as Jould be
expected. However, the lowest DO value was only 7.0 mg/1 (8/95).
- BOD values were generally higher downstream than upstream, but BOD monitoring may
not be necessary since DO is monitored instream.
- The majority of pH values were in the vicinity of 7.0. A few extreme pH values in recent
months 11.2 (3/96-downstream), 5.5 (1/96-downstream), and 2.1 (12/95-ups eam) may
be cause of concern and reason to continue to monitor pH instream.
- Fecal coliform values ranged from 113/100 ml to 6929/100 ml (both measured at the
downstream station) and were lower down- than upstream more than half the time.
- Conductivity values were higher downstream than upstream which is expected given the
discharge of wastewater containing metals and ions into the receiving water.
- The majority of the ammonia -nitrogen values were below 0.10 mg/1 upstreand
concentrations ranged from below 0.10 mg/1 to 2.34 mg/ (2/94) downstream.
Instream data indicate the Long Creek WWTP is not having an adverse impact
receiving water quality. Therefore, instream monitoring for BOD5 and fecal
be eliminated and instream monitoring for ammonia -nitrogen will be changed t
nitrogen to provide a greater amount of information on nutrients associated wi
The Division. received Gastonia's instream monitoring modification request to
6-series system for continuous instream monitoring, move the upstream monit
location, .and .dclete.fecal coliform .instream.monitoring..on.April.2 4,1996. Th
concurs with Gastonia's proposed instream monitoring modification, but will
specify the original monitoring frequencies in the permit. Therefore, should t
experience problems, it is expected that the monitoring frequencies specified i
would serve as a default. The Division also has no problem with relocating th
on the
oliform will
total
h nitrogen.
se the YSI
ring station
Division
ontinue to
e system
the permit
upstream
monitoring location and this new location will be specified in the proposed permit. Finally,
as is indicated in a previous paragraph, instream monitoring for fecal coliform will no
longer be required.
Page 8 of 8

Permit No. N00020184
INSTREAM MONITORING REQUIREMENTS - SOUTH FORK CATAWBA RIVER
The frequencies specified in the following table for dissolved oxygen, temperature, conductivity, and pH are to be
used only when experiencing operational problems with the YSI 6-series system. It is assumed that when the YSI
system is operating properly, these four parameters will be monitored continuously. Total Nitrogen and Total
Phosphorus will be monitored as specified in the table below because these parameters will not be monitored with
the YSI system. a (vi- 4 #D .f
o--
Freauencv ��`fi '
Parameter
Sample Type
Dissolved Oxygen
Grab
3/wk (Jun -Sep), 1/wk (Oct -May)
Temperature
Grab
3/wk (Jun -Sep), 1/wk (Oct -May)
Conductivi -�
Grab
3/wk (Jun -Sep), 1/wk (Oct -May)
pH r
Grab
31wk (Jun -Se ), 1/wk Oc -
Total Nitroge or NH3-N
Grab �—
- e , l/wk Ost.Mayr
Total Phospho s
Grab
3/wk ,
SAMPLE LOCATIONS I ti0144:141-
1. Upstream at City of Gastonia Pump Station
2. Downstream at Spencer Mountain Dam pool at dam.
3. Downstream at NCSR 2003
4. Downstream 1.5 miles below tailrace at powerlines.
Parameter
WwALG� (hrv-
"( 1
PHORUS AND TOTAL NITROGEN EFFLUENT LIMITS AND ING
ompliance shall be based upon a
Sample Tvoe Freauenc
Total Nitrogen (April 1- October 31) _//6:0
mg/1 '-�
Composite
Weekly
Total Nitrogen (November 1 -
no limit �`m
. osite
Weekly
Total Phosphorus (Apri�lj)et6ber 31)
1.0 mg/1
Co • ,,:, -
Composite
Weekly
—kly
Total Phosphorus.. veimber 1 - March 31)
1.0 mg/1

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AGENDA
CLEAN TECHNIQUES
July 31,1997
The City o Gastonia began implementing clean sampling techniques and analysis procedures in the
beginning f 1995. However, it was a gradual process beginning with pretreatment and then integrating
into the lab ratory and operations.
I. Laboratory Presentation (See Exhibit A) - David Shellenbarger
A. Bottle preparation
B. Digestion procedure
C. Analysis procedure
II. Sampler Cleaning Procedures (See Exhibit B) - Bobby James and Bobby Hanna
III. Clean Sampling Techniques (See Exhibit C) - Bobby James and Bobby Hanna
A. Procedures for setting up the sampler
B. Procedures for taking off the sampler and pouring up the samples
IV. Field Procedures for Ultra Clean Sampling Project (See Exhibit D) - Janet Maddox
A. Preparation of equipment, bottles, and clothing for transportation to sampling site
B. Procedures for setting up to sample after arriving at sampling site
C. Sampling Procedures
D. Ultra clean sampling video is available for viewing
V. Required NPDES mercury grabs are currently being collected at the Crowders Effluent. (If time
permits! or if anyone is interested in watching the collection it will be done at this time.)
As illustrated by the enclosed graphs (Exhibit E), there has been a definite decrease in the quantitated
amount of metals leaving the WWTPs since clean sampling techniques were implemented. Since the City
had seen such a drastic decrease and grouping of metals results, it was determined to continue moving
towards an ultra clean sampling protocol. However, the results of the CH2M Hill project indicate that the
biggest impr vements were made with the clean techniques implemented by the City prior to their
involvement The results from the analyses conducted during the project did show some lower levels, but
this was attributed to the research laboratory having such lower detection levels than the City laboratory.

Exhibit A
Clean echniques Used in the Laboratory for Metals Samples
The following procedures are used for the digestion and testing of metals to help insure that
samples are of contaminated and results are accurate for the samples being tested.
• Care is taken throughout the process to avoid created dust where it can contaminate samples.
Personnel try not to work over an open sample, open the door to the outside while digesting,
tear off paper towels near the metals samples, etc.
• During preparation of glassware and bottles, digestion and testing all personnel involved wear
class 10 Mclean room grade latex gloves.
• Older, etched glassware is replaced as this appears to contribute to metals in samples.
Particularly contamination with lead.
• The hoof base and counter tops in the area used for metals are washed down with special
metal soap, rinsed with water, 1+1 nitric acid then with deionized water.
• Paper towels are not used for wiping down or setting glassware on. Instead special clean
wipes are used.
• All bottles, glassware and cylinders go through the following preparation steps:
1. They are washed with special metal removing soap (Diluted Citronox).
2. Then they are thoroughly rinsed in tap water and then deionized water.
• 3. They are rinsed in 1+1 trace metal grade nitric acid.
4. Then they are rinsed in deionized water again.
5. Two milliliters of ultra high grade nitric acid (Ultrcx II brand) is placed in the
collection bottles for preservation once samples are collected.
• All glassi and plasticware (flcakers, watchglasses, pipets, funnels, and graduated cylinders) go
through 1he following preparation steps:
1. They are washed with special metal removing soap (Diluted Citronox).
2. Then they arc thoroughly rinsed in tap water and then deionized water.
3. Shortly before using, they are rinsed in 1+1 trace metal grade nitric acid.
4. Then they are rinsed in deionized water again.
• Disposable filter paper and sampling cups go through these preparation steps shortly before
use:
1. They are rinsed in 1+1 trace metal grade nitric acid.
2. Then they are riiised in deionized water.
• Samples fare cooked down on a hot plate and special ultra high grade nitric acid is added during
the digestion. The exact procedure depends on which metals the samples are being digested
for. Copies of the procedures are included.
• Samples are filtered and brought up to volume using prepared glassware and filters then are
placed in prepared storage bottles.
• Similar care is used in the testing for the metals.
1. The area is kept clean.
2. clean wipes are used instead of paper towels.
3. Samples are kept covered when possible.
4. Logical care is taken to avoid contamination of samples.
• Sample blanks are always digested and run along with each batch of samples. There has been
a great reduction in the values of these sample blanks since these clean techniques have been
put in place. _

Exhibit B
Sampler Cleaning Procedures
1. Wipe o f the outside of the suction tubing and the strainer.
2. Pump a least 2 liters of soapy water through the tubing. Use a small amount of
Citrano poured into a sink or jug of tap water.
3. Rinse oroughly with tap water.
4. Pump a 35% Nitric Acid (HNO3) solution through the tubing. Use the HNO3 for Trace
Metal Analysis which comes as 70% acid. Pour up 500 ml deionized water and (under
the hood), slowly pour 500 mi of HNO3 into the water.
5. Pump the 35% Nitric Acid solution through the sampler.
6. Pump d ionized water through the sampler long enough to ensure that acid is no longer
in the le gth of the tubing. DO NOT RINSE WITH TAP WATER.
7. The composite jug and the one liter container for metals analysis must also be cleaned
with the soap solution, rinsed, acid washed, and rinsed with deionized water.
Exhibit C
Clean Sampling Techniques for Metal Analysis:
All sampling should be done down current or downwind.
The "Clean Hands" individual is responsible for removing sampling bottles, collecting the
sample, an replacing the lids. Clean Hands must put gloves on at the sampling site and
handle all o erations involving contact with the sample bottle and with transfer of the
sample from the collection device to the sample bottle.
The "Dirty Hands" individual is responsible for all activities that do not involve direct
contact with the sample. Dirty Hands must open the box or cooler containing the sample
bottle.
Sampling set up:
1. Designate "Clean Hands" and "Dirty Hands" individuals.
2. In lab, irty Hands should remove the top of the sampler.
3. Clean ds (clean gloves) should insert sample container in sampler, remove lid and
place in o a baggy and place baggy inside of sampler.
4. Dirty H ds should replace the sampler top .
5. At sam le site, Dirty Hands should remove the top of the sampler.
6. Dirty Hands should pick up the cooler for Clean Hands to scoop the ice around the
sample ontainer.
7. Dirty Hands replaces the top of the sampler.
8. Carry s pling equipment to the manhole.
9. Remove manhole cover.
10. Clean H ds (clean gloves) removes baggy and lowers strainer into the manhole.
11. Either i dividual can program sampler.
1

After sample collection:
1. Dirty H ds turns off sampler and removes top of sampler.
2. Clean ands (clean gloves) removes individual sample container lids.
3. Clean Hands removes lid from baggy and replaces top on sample container and shakes
sample.
4. Clean H ds then pours sample into the individual sample containers and replaces the
lids.
5. Dirty Hands replaces the top on the sampler, pulls the strainer from the manhole, dumps
ice and packs up sampler.
6. Dirty Hands opens cooler.
7. Clean Hands places samples inside for transport to the lab.
2

Exhibit D
Field Procedures for Ultra Clean Sampling Project
(Provided by CH2M HILL and Implemented October, 96 through January, 97)
• Prior to going sampling there were packages put together that were put into the cooler designated
as the clean cooler. These packages included tyvex coveralls, dust/surgeons masks, and several
pairs of g loves, in case the first pairs were contaminated which were double bagged inside the
bigger b with the mask and coveralls. Teflon sampling bottles and tubing (which were double
bagged) ere provided by Battelle to be placed in the clean cooler as well as heavy duty plastic
bags for round cover.
• After arriving at the sampling site, the location was prepared for sampling by moving any metal
grates, laying plastic down for ground cover, and moving the equipment and coolers with
sampling bottles from the truck to the sampling location which included placing the masterflex
pump in the correct position for sampling.
• At this time we waited 10 minutes for any disturbances of the environment due to the truck or
movement around the site to settle.
• After the 10 minutes then the samplers were to put on the clean sampling ensembles. This
included the tyvex coveralls, dust/surgeons mask, and two pair of non -talc gloves. This was to be
done in the following order:
1 Two pair of gloves
2. Tyvex coveralls and dust/surgeons mask
31 Take off the top pair of gloves
• At this time there was a division in duties between the clean hands (CH) and dirty hands (DH)
samplers.
• The DH person opened the ice chest and remove the ziploc bags containing the sampling
apparatus that was prepared by Battelle.
• The CH person reached into the bag and removed the apparatus paying close attention not to
touch the ubing to anything especially not the ends of the tubing.
• The CH p rson lowers the weighted end of the tubing down to the sampling location at
approxim tely mid -depth and away from any metal -containing objects.
• The DH prson inserts the soft flexible portion of the tubing in to masterflex pump.
• The CH person holds the end that is in the water and the split ends of the tubing.
• The DH person puts a bucket that is to be used to collect the purged water near the CH person.
• The CH prson holds the split end of the tubing over into the bucket and the DH person turns on
the pump to begin the purging which takes place for a minimum of 5-minutes.
• After the 5-minutes of purging, the DH person opens the ice chest that has the sampling bottles
and opens the outside bags for the CH person to open the inside bags and remove the bottles.
(There are two sets of bottles, one that is preserved on site with Ultrex acid for use by the City of
Gastonia and one unpreserved to be sent to Battelle for dissolved metals analysis) The DH person
must not touch the inside bag or the bottle.
• The CH p rson does not open the bottles until the tubing is within 1-inch of the bottle and they
are ready o collect the samples. Once the bottles are open the CH person places the tops of the
bottles ba k into the inside bags to ensure they are not contaminated during the sampling process.
(The two amples are collected simultaneously which is why the tubing has a Y at the end.)
• After the ottles are filled, the CH person immediately preserves the City of Gastonia sample
with the a id provided by Battelle and replaces the tops of both bottles.
• The CH p rson then places the bottles back into the inside ziploc bags while the DH person holds
the outsid of the outer bag. Then the CH person closes the inside and outside bags.
• The CH p rson places the samples into the ice in the ice chest designated as the clean cooler for
transporta ion to either the city lab or Fed -Ex.
• At this ti e the samples were safely stored away and the samplers are able to remove their clean
sampling nsembles and return all equipment back to the truck.
3

50
45
40
35
30
25
20
15
10
5
0
CROWDERS CREEK WWTP
1994 - 1995 EFFLUENT CADMIUM
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P E A S E
Architecture Engineering Planning Interiors
July 2,1997
Mr. David A. Goodrich, NPDES Supervisor
North Carolina Department of Environment, Health
and Natural Resources
Division of Environmental Management
Water Quality Section, NPDES Group
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Reference: City of Gastonia, North Carolina
J.N. Pease Associates' Commission No. 96051-00
Subject: July 31, 1997 Proposed Meeting
Dear Mr. Goodrich:
fifi MI 01 'TT L6
Your proposed July 31, 1997 meeting with the City of Gastonia has been
confirmed. The City will have the appropriate personnel available to meet with
you.
The issues to be discussed include monitoring sites on the South Fork Catawba
River, effluent reuse at the Crowders Creek Wastewater Treatment Plant, and the
Laboratory Clean Rooms.
Please plan to meet at the City's Operations Center, at 1300 North Broad Street, at
8:00 AM, on Thursday, July 31, 1997.
In the meantime if you have any questions, or if there are other items you would
like to add to the agend., piease caii.
A. Keith West, PE
AKW/lh
cc: Mr. Don Carmichael
Mr. John Shuler
Mr. Coleman Keeter
Mr. Larry Cummings
Mr. Don Garbrick
C:\DOCS\AKW\AKW287.DOC 7/2/97
J.N. Pease Associates 2925 East Indepcndcncc Blvd. P.O. Box 18725 Charlotte, NC 28218 704 376-6423

P E A S E
Architecture Engineering
July 21,1997
Planning Interiors
Mr. David A. Goodrich, NPDES Supervisor
North Carolina Department of Environment, Health
and Natural Resources
Division of Environmental Management
Water Quality Section, NPDES Group
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Reference: Remote Monitoring Sites
Long Creek Wastewater Treatment Plant
Gastonia, North Carolina
J.N. Pease Associates' Commission No. 96051-00
Subject: Agenda for July 31, 1997 Meeting
Dear Mr. Goodrich:
The subject Agenda is as follows:
8:00 AM - Meet in the Conference Room at the Crowders Creek Wastewater
Treatment Plant (WWTP)
Topics to be Discussed:
Reuse of the Crowders Creek WWTP Effluent by Carolina
Bi-Products (CBP)
Status of NPDES Permit Modifications Based upon the
Clean Techniques/Cyanide Study
Status of the Extension of the Long Creek SOC for
Construction and Final Compliance
10:00 AM - Tour the Proposed South Fork River Monitoring Sites and Review
the Proposed Automatic Monitoring Techniques
1:30 PM - Meet in the Conference Room at the Long Creek WWTP
Topics to be Discussed:
Review and Summarize Discussions and Conclusions
Plan Follow -Up Activities
J.N. Pease Associates 2925 East Independence Blvd. P.O. Box 18725 Charlotte, NC 28218 704 376-6423
X. /37

Mr. David A. Goodrich, NPDES Supervisor
Page 2
July 21,1997
If you have any questions or would like additional information prior to the
meeting, please call.
Sincerely,
a etho.14)
A. Keith West, PE
AKW/lh
cc: Mr. John Shuler
Mr. Coleman Keeter
Mr. Larry Cummings
Mr. Thorne Martin
Mr. Don Garbrick

THE SANFORD HOLSHOUSER LAW FIRM
I'LLC
234 FAYETTEVILLE STREET
SUITE 100
RALEIGH, NORTH CAROLINA 27601
MAILING ADDRESS:
POST OFFICE BOX 2447
RALEIGH, NORTH CAROLINA 27602
Meg Scott Phipps
Administrative Law Judge
Office of Administrative Hearings
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447
TELEPHONE [phone]
FACSIMILE 919/890-4180
May 1, 1997
Re: Fleischmann's Yeast v. North Carolina Department of Environment,
Health and Natural Resources: 97 EHR 0362
Our File: 30212.001
WASHINGTON OFFICE
SUITE 470
901 15TH STREET N.W.
WASHINGTON, D.C. 20005
TELEPHONE 202/371,•6070
FACSIMILE 202/371-6279
Dear Ms. Phipps:
This letter follows up my discussion with Ms. Dean Coley, Chief Hearings Clerk of the Office of
Administrative Hearings.
As I explained to Ms. Coley, this office represents Fleischmann's Yeast ("Fleischmann's"), the
Petitioner in the above -captioned matter. Fleischmann's recently received a number of documents from your
office, including a Designation of Mediator Order, an Order for Mediated Settlement Conference, Order for
Prehearing Statements, Notice of Contested Case and Assignment, and Scheduling Order, each which establish
various due date in this matter.
Fleisc 's is in the process of negotiating a settlement of this matter with the North Carolina
Department of vironment, Health and Natural Resources, and consequently, we wish to stay all deadlines
associated with is matter. Ms. Coley advised us to send you this letter requesting that all deadlines in this
matter be stayed until further notice, rather than file a formal Motion and Order.
I trust this letter sufficiently explains why we wish to stay the deadlines in this matter. If you have any
questions or need further information, please do not hesitate to call. Thank you for your cooperation in this
matter.
Very truly yours,
THE SANFORD HOLSHOUSER LAW FIRM
L;
urie B. Gengo
cc: Richard Whisnant, DEHNR
Gordon Arbuckle/Willie Shepherd
Samuel Poole
RAL:34015

MAILING ADDRESS:
POST OFFICE BOX 2447
RALEIGH, NORTH CAROLINA 27602
THE SANFORD HOLSHOUSER LAW FIRM
PLLC
234 FAYETTEVILLE STREET
SUITE 100
RALEIGH, NORTH CAROLINA 27601
TELEPHONE [phone]
FACSIMILE 919/890-4180
April 4, 1997
Jonathan Howes, Secretary
North Carolina Department of Environment,
Health and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Fleischmann's Yeast, Gastonia, North Carolina Facility
Our File: 30212.001
Dear Mr. Howes:
WASHINGTON OFFICE
SUITE 470
901 15 fH STREET N.W.
WASHINGTON, D.C. 20005
TELEPHONE [phone]
FACSIMILE 202/371-6279
Sam Poole, Gordon Arbuckle, and I thank you and your staff for meeting with us on
Wednesday, April 2, 1997 regarding the above -captioned matter. We appreciate your
willingness to work with us regarding the nitrogen contained in the wastewater discharged into
the City of Gastonia's publicly -owned treatment works. As promised, I have enclosed a typed
copy of the attendance list from that meeting for your files.
For the reasons explained in our meeting, we have filed a Petition for Contested Case
hearing in this matter. However, once we have reviewed the study on Lake Wylie which we
are presently copying, someone will contact you to schedule a meeting in Raleigh between the
technical representatives of Fleischmann's Yeast and the City, and Mr. Goodrich and Ms. Sullins
so the technical issues can be discussed in more detail. If this matter cannot be resolved to
everyone's satisfaction in that meeting, we will schedule a followup meeting with legal
representatives present.
Thank you again for your continued cooperation. If you have questions or need further
information, please do not hesitate to call me, Sam or Gordon Arbuckle/Willie Shepherd at
Patton Boggs.
RAL:33287

THE SANFORD HOLSHOUSER LAW FIRM
PLLC
Jonathan Howes, Secretary
April 4, 1997
Page 2
Very truly yours,
THE SANFORD HOLSHOUSER LAW FIRM
Laurie B. Gengo
Enclosure
cc: Gordon Arbuckle/Willie Shepherd
David Goodrich
Coleen Sullins
Samuel Poole
RAL:33287

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LITIES
QIftg of Oatrntin
111.0.111Wc wide
tiSustal rs, iar*einaltra 28053-1748
April I, 1997
Mr. A. Prest Howard, Jr. PE, Director NC Depart nt of Environment, I Ica1th and Natural Resources
Division of star Quality
kQ Box 29 35
Raleigh, Korth Carolina 27626.0535
NO. 0074268
gto` v(
43;41 �L 2
Yam.
ITS: LONG CKitEK WW'['1', PICRMIT NO.
ASTON COUNTY; CATAWIIA C:REX
. 002U192: CRQWDERS CREEK WW rl't PERMIT
Dear Mr. I award:
its for the
Cityof Gastonia is in receipt of the above referenced NPDES peen'��e
The
wa tev a treats facilities identiticd. 'T1ic C..ity Wes the onidentified tt i given
our
by your ff to our comments on the sham NPDES permits as .nitinissued.
Decom :9, 1996 cc:rresponduux in preparation of'thc final. NYI)US '
aware,
one of our comrncnts on the draft permits hrnoivad modification of the
' ntnery fmdinfrom a pilot
As you total Creek ww'!'. Pccilc_____
ni gal Itmta at the l uur.€
�j (TN)r
tat at the Long Crock W W1`1' indicated that uns: ,of our Significant industrial
study contiuc undo to the Long
Users, Fl 's�chmann's Yeast, was coninbuting rcfras:tary� nitro n tasu
Croak W . Fleiechrnmn's Yeast provided documentation to 1lte City, wcrraw was
=� fonvto the stutter DWQ for review in Fall 1996, that indicated that these r ors i�
ry
materials cannot ba ccanrmicully rcanoved from the wastcsiream. The its the
provid byFleisctmiann's also indicated that these materials aro cxtrcrnoly stabknb
environ eat and are unlikely to degrade water quality and muse environmental nutrient
is ha:!
robiem . In -this regard and at the request of rkischmattn'ti Yeast, the Y
problem
request the DWQ to modify the total niu gcn (1N) limits in the i 4ong Creek WWTP
NPDES wit to monitoring only until such time as the queauoe of the effect of the
chseha of the refractory nitrogen compouncis can be resolved.
Oefr
44,

)fib' •-PR--t1-1957 !j:3! fIRul
2
On ' 3,1997, the City received correspondence dated February 26, 1997 from your
office, • '' g that the TN limits at the Long Creek WWII' could not be modified and
would ' based on the recommended nutrient rauagernent strategies idea tified in the
which set the TN limit at
Long k at 6.0 mg11 summer only. The City was very involved with the DWQ stain
ncgo� the nutrient management strategies in the Basinwide Plan and nadeErstru ds the
necessat to maintain these TN limits to effectively manage nutriilts in the take Wylie
stem of Lower Catawba River basin.
Upon ' 'pt of your March 3, 1997 correspondence. the City nudged Eleischaumn's
Yeast th the TN limits at the Long Creek WWTP would not be xaodifxi to monitoring
only. this lid Fleisclmiann's Yeast has requested that they he allowed to meet with
staff of a DWQ to present further details regarding the refractory nitrogen compounds
that their facility will be discharging to the long Creek +r lr} P. Representatives of the
City would be available to attend this mccting to discuss these issues.
The Long Creche WWTP is currently being upgraded and expanded from an 8 mgd
facility 16 mgd. Construction is andcipated to be completed in Nolemiter 1997. As
stated elimin findings frompilot studies conducted b y the City indite that, with
s Fr. �Y � 3 �,
the con Tibution of Flcsielunann's refractory nittogcn compounds, the City may have
difficulty complying with the 6 rngll TN limit at the Long Creek WWI?. Since August
1996, when this potential compliance problem was identified in. the pilot study, the City
has boleti working with Flcischraann's Yeast ar4 has had discussions with DWQ staff in
an to midgatc this issue well in advance of November 1997. it is imperative, *ti-
the Ci that a resolution of the F1eisc:hmann's refractory nitrogen discharge issue he
agrced , • by all parties concerned.
Theref , i respectfully request that a meeting be scheduled as soon as possible with the
e DWQ staff. Pleischmunn'a Yeast and the City to di wuss this issue further.
You or our stair can reach me at [phone] to establish a time and location for this
meeting Thank you in advance for your consideration in this matter.
Donald E. Cuumichacl, PE
Directoii of Public Works and Utl ities
pc: Dave Goodrich, NCDWQ
Shukr, Assistant Director of Utilities
ti w I . Redwing, Deputy City Mornay
Gccdtm Arbuckle, Fleischman s Yeast
Don Garbrick, JN Pease Associates
FLPSDWQ1
TOTPL P.03

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
February 10, 1997
Mr. Larry Cummings
City of Gastonia
PO Box 1748
Gastonia, North Carolina 28053-1748
Subject: Response to Partial Diversion
of Fleischmann's Flow
City of Gastonia
Gaston County
NPDES Permit # NC0020192
F=)EHNf=1.
a1A-
,r_,2„,
Dear Mr. Cummings:
The Pretreatment Group of the Division of Water Quality learned today of your intention to divert a
portion (20%-50%) of the flow from Fleischmann's Yeast to the Crowder's Creek WWTP on a temporary
basis. The Group also verified the approval given by the Mooresville Regional Office.
As of today, the Pretreatment Group has not yet received any correspondence regarding the permitting of
Fleischmann's for discharge to the Crowder's Creek WWTP. Review of preliminary calculations by the
Pretreatment Group indicates that 20% of Fleischmann's currently permitted loadings to the Long Creek
WWTP would create overallocations of Mercury and Selenium at the Crowder's Creek facility.
Additionally, Fleischmann's could contribute greater than 5% of Crowder's MAHL for Cyanide,
Mercury, Selenium and Zinc, even at 20% of their currently permitted loadings. Consequently,
Fleischmann's Yeast would be considered a Significant Industrial User of Crowder's Creek WWTP.
Upon conversation with Nancy Matherly this afternoon, the Pretreatment Group learned that no permits
have been issued or drafted for Fleischmann's Yeast to discharge to Crowder's Creek. This does not abide
by 15 A NCAC 2H .0916(a).
It is the Pretreatment Group's understanding that this discharge is on a temporary basis and should only
continue for a couple of weeks. If the City of Gastonia wishes to continue this diversion of flow beyond
February 24, 1997, it must submit to the Division a copy of an Industrial User Pretreatment Permit issued
to Fleischmann's Yeast for diversion of discharge to the- Crowder's Creek WWTP. This should be
submitted before February 25, 1997.
If you have any questions or comments. please contact Mike Blasberg at [phone] (ext. 593), or
Tom Poe, Supervisor of the Pretreatment Group.
mrb/(File name: gast.crwd.iup.032)
cc: Central Files
Michael Blasberg, Pretreatment Group'
John Lesley, Mooresville Regional Office
Rex Gleason. Mooresville Regional Office
Sincerely,
s P�
r A. Preston Howard, Jr., P.E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

City of (gastottia
P. O. BOX 1748
4.5as#oma, urtll (lztrolinn 28053-1748
DEPARTMENT OF
PUBLIC WORKS AND UTILITIES
February, 18, 1997
Mr. To Poe, Pretreatment Group Supervisor
NC DE DWQ
P.O. Bo 29535
Raleigh, C 27626-0535
Re: P
RE.CE1VED
tfEB
iMl.1TtES pSSESShiEdtt UNIT
rtial Diversion of Fleischmann's Flow from Long WWTP, NPDES Permit
No. NC0020184, to Crowders WWTP, NPDES Permit No. NC0074268
Dear Mr. Poe:
Based up n your letter, dated February 10, 1997, the City of Gastonia did not proceed
with the artial diversion of Fleischmann's Yeast flow from the Long WWTP to the
Crowder WWTP. It was our understanding, based upon our meeting with Mr. Rex
Gleason d John Lesley at the Mooresville Regional Office, that the State agreed with
our prop sal to temporarily divert part of the Fleischmann's flow to the Crowders
WWTP in order to more fully study the biodegradability of the organic nitrogen
component of the Fleischmann's wastewater. However, from your letter it appears
there are some SIU permitting concerns that must be addressed. These concerns will be
addressed upon receiving guidance from the State regarding the nutrient issue.
The results of a pilot study in early 1996, which was set up primarily to study toxicity,
indicated that Fleischmann's Yeast was contributing refractory nitrogen materials to the
Long Creek WWTP that could cause compliance problems for the new facility with its
NPDES Tbtal Nitrogen limit. When the City became aware of this potential Total
Nitrogen ompliance problem, several meetings were held with Fleischmannn's Yeast
to discuss a issue. On August 16, 1996, the City met with Fleischmann's Yeast staff,
including ?ne of their technical representatives from Burns Philp, Mr. Tony Hunt, to
review possible treatment alternatives.
After several attempts by the City to set up a meeting with the Division of Water
Quality (DWQ), the technical information from Fleischmann's was forwarded to DWQ,
at DWQ request, in October, 1996, for review prior to meeting to discuss the issue.
The City made numerous unsuccessful attempts to set up a meeting to disc
rFFEit 2'.
at 7997
vas

February 18, 1997
partial Diversion
Page 2
with DWQ. At the request of DWQ, the City agreed to a conference call, with
Fleischmann's representatives not present, to discuss the issue. This conference call
took place on December 20, 1996. It was our understanding that a written response
from DWQ, based upon the December 20th conference call, would be sent to the City
the following week. To date, the City has not received this written response.
Upon receipt of this written response from DWQ, the City and Fleischmann's Yeast
will be able to develop a plan of action. Several options have already been discussed
by the City and Fleischmann's Yeast through several meetings and phone
conversations. These options include:
• Partial diversion of flow from Fleischmann's to Crowders WWTP
• Jar testing/pilot studies
• Core team to direct activities
• SIU permit for Fleischmann's to pursue partial diversion of flow.
The first activity listed, partial diversion of flow from Fleischmann's, was being
pursued when we received your letter stating that an SIU permit would be required.
The City of Gastonia requests that DWQ immediately provide written guidance
regarding this nutrient issue, per our December conference call. Serious financial
decisions and complex compliance issues are pending this response. It is vital that this
response be received as soon as possible so the City has time to react positively toward
resolving potential noncompliance issues at the new Long Creek WWTP. Further delay
by DWQ in providing this response will create an impossible situation for successfully
achieving compliance with NPDES limits for this facility.
Thank you for your consideration in this matter. Please call if you wish to discuss the
matter further. The City would welcome the opportunity to meet with both DWQ and
Fleischmann's Yeast to discuss the issue in detail. We are looking forward to receiving
your written response in the immediate future.
Sincerely,
qtZ Larry W i'Cummings r
Assistant Superintendent of WWTD
pc: Colleen Sullins, DWQ
Don Safrit, DWQ
Rex Gleason, Mooresville Regional Office
John Shuler, City of Gastonia
fic 1 d.doc

C.-
DEPARTMENT OF
PUBLIC WORKS AN UTILITIES
October 1
, 1996
Qlifg of (lzitntia
P. O. BOX 1748
kfjtts#umtt, ur#li Qlarulirttt 28053-1748
Ms. Colleen Sullins
North Carolina Department of Environment, Health,
and Natural Resources
Division of Water Quality
P.O. Box 9535
Raleigh, 27626-0535
RE: Lot!g Creek Wastewater Treatment Plant Nutrient Compliance Issues
Gastonia, NC
Dear Ms. Sullins:
r,,
As we discussed by telephone, an issue of concern has been brought to our attention as
a result of the pilot plant study conducted to determine whether or not the new Long
Creek WWTP would comply with NPDES toxicity requirements. The main focus of
this pilots dy was toxicity, and it was confirmed that the new Long Creek facility
should meet toxicity requirements, even with the addition of the Catawba Creek
WWTP ' uent to the Long Creek facility. However, attempts were also made to
optimize a pilot plant for nitrogen removal, but the pilot plant did not meet the
required 6 g/1 discharge level. Further investigation indicated that refractory nitrogen
compounds were being received from the Fleischmann's Yeast wastewater discharged
to the City. A brief letter from Aware Environmental, the City's consultants, that
summarizes these findings is enclosed for your review.
The City, g.N. Pease, and Aware Environmental, met with Fleischmann's Yeast
representatiives to discuss this nutrient issue. Fleischmann's Yeast was represented at
the meeting by Tony Hunt, from the corporate office of Burns Philp, which owns the
Gastoniat facility. Thepresentation byMr. Hunt indicated that the refractory
Y
nitrogen c mpounds were melanoidins, a component of the molasses substrate used in
yeast prod ction. Mr. Hunt indicated that melanoidins were not biodegradable and that
it was not conomically feasible to either replace the molasses with a synthetic substrate
or remove the melanoidins from the wastewater prior to discharge to the City. A copy
of the rep rt from Mr. Hunt summarizing his presentation is enclosed for your review.

October 18, 1996
Nutrient Issues
Page 2
City staff and consultants discussed the issue on September 30, 1996, and it was
decided to request a meeting with DWQ to allow Fleischmann's Yeast to present their
information. Fleischmann's Yeast was contacted to inform them that the City would
set a meet' g with DWQ, and they were asked to identify who would attend the
meeting toprovide the Citywith actual costs estimates of treatment alternatives,
including a economic impact on the industry.
On October 9, 1996 we discussed with you by phone the possibility of setting up a
meeting with your staff, the City, and Fleischmann's to discuss this nutrient compliance
issue. At your request, we are submitting the enclosed information mentioned above
for your review. You also indicated that the economic information that we had
requested from Fleischmann's Yeast should also be submitted for review. When we
informed lleischmann's Yeast that both the economic and technical information would
be submi,d to the State, their corporate officials decided to not submit that
information to us because it was prepared for presentation at a meeting, not for written
submittal. , The City has sent a letter to Fleischmann's requesting the written submittal
of this information. A copy of this letter is also enclosed.
It is requested that the appropriate Division of Water Quality staff review the enclosed
technical information. If additional information is required from either the City or
Fleischm 's Yeast, please let me know what is specifically needed. After your staff
has had an opportunity to review this issue, we request that a meeting be scheduled to
discuss th issue and to allow Fleischmann's Yeast the opportunity to present their
concerns.
Thank you for your consideration of this matter. Please call to discuss the issue
further.
Sincerely,
;o-Aa64wu.0/ao/
Donald E. Carmichael, P.E.
Director of Public Works and Utilities
cc: Dr. Danny Crew, City Manager
John Shuler, Assistant Director of Public Works/Utilities
fle8.doc

VIIIRON NTAL INCH
MEMO
TO:
FROM:
DATE:
SUBJECT:
LARRY CUMMINGS
CITY OF GASTONIA
OB STEIN
WARE ENVIRONMENTAL INC.
UGUST 27, 1996
REVIEW OF ITEMS COVERED IN FLEISCHMANN'S MEETING
AEI JOB NO. N306-03
There were several items that we discussed in the meeting with Fleischmann's on August 16
which I want to clarify. In the meeting we discussed the source of the noncompliance with
total nitrogen. The total nitrogen limitation (TN) is 6 mg/1 and this limitation includes the sum
of the ammoni nitrogen, nitrate nitrogen and organic nitrogen.
From our stud•es and from the design of the facility the ammonia nitrogen and nitrate nitrogen
are each ex eched to be 1 m /1 or less. It appears thatFl
eischmann's g pp the Fleischmann s facility discharges
approximately
of our studies
plant flow of 1
results in an e,
100 mg/1 of organic nitrogen at a flow of approximately 0.3 MGD. The results
ndicate that this organic nitrogen is not expected to be degradable. At a total
2 MGD this results in an extra 2.5 mg/1 of TN. At a flow of 16 MGD this
tra 2 mg/1 of TN.
The refractory total kjeldahl nitrogen - TKN (a combination of organic nitrogen and ammonia)
is already 4 m /1 from the domestic waste. Therefore, in either of these cases we will exceed
the total nitrog n limitation. Based on all available data some additional removal of this
organic nitrogen will be required or we will need to obtain a variance from the State on the
total nitrogen limitation.
The results of our studies indicated a refractory total phosphorus of approximately 2.5 to 4
mg/1. Our studies were not geared to phosphorus removal and total phosphorus may not have
been removed o the optimum levels. As we discussed the program to optimize phosphorus
removal at the Crowders Creek treatment plant took approximately 1 year. However, the data
indicated that leischmann's did contribute a phosphorus that is difficult to remove and results
in approximate y 0.5 mg/1 of phosphorus in the effluent at the 12 MGD flow. We need to
review the phosphorus in more detail.
I hope this clarifies our discussions. If you need any information or have any questions,
please feel fre� to contact me.
cc: D. Gar rick, J.N. Pease
C. Keeter, City of Gastonia
J. Shuler, City of Gastonia
21064
9305 MONROE ROAD • SUITE J • CHARLOTTE, N.C.28270-1490 • TELEPHONE [phone] • FAX [phone]

......... -41. N..
- aleischmann's.
► Mk. NI. A oo.
2150 West Poplar Street, P.O. Box 999, Gastonia, NC 28053
[phone] FAX: [phone]
September 13, 1996
Mr. John Sc uler
City of Gas onia
Dept. of Pu lic Works and Utilities
P.O. Box 1748
Gastonia, NC 28053-1748
Re: Meetin
Fleisc
of August 16, 1996 -
mann's position on the nutrient issue.
Dear Mr. Schuler:
The following document summarizes the presentation given by Mr.
Tony Hunt of Burns Philp at the meeting Fleischmanns had with City
of Gastonia personnel on August 16, 1996.
If you have
provided, p
Sincerely,
any questions or would like to discuss the information
ease do not hesitate to call.
Fleischmann s Yeast, Inc.
Donna Forne `
A member of the Burns Philp Group

Refractory Nitrogen and Phosphorus Compounds in Fe
Process
Sources,
Effluent from Fleischmann's Yeast, Gastcn ;'NC'.
hemistry, Treatment Options and Environmental Fate.
30th August 1996
Introduction
The City of Gastonia is currently undertaking an upgrade of it's
Long Creek STP, which will include installation of a biological
nutrient removal (BNR) process in order to comply with tighter
discharge standards for Total Nitrogen (TN) and Total Phosphorus
(TP). Pilot trials of this process indicate that it will not quite
be able to meet the required discharge standards of 6 mg/1 TN and
1mg/1 TP. jrhis appears to be due to the presence of refractory
(ie. non -biodegradable ) organic compounds which contain nitrogen
and/or phos horus and which are not removed by the BNR process. The
process eff uent discharged by Fleischmann's Yeast into the Long
Creek sewer system has been implicated as a possible source of
these refra tory compounds. Options for addressing this issue are
examined in the paper below.
Effluent Characterization
The Fleisch ann's yeast factory at Gastonia produces bakers yeast
using a bat h aerobic fermentation process. This process utilizes
a range of ow grade sugar sources (mainly beet molasses and cane
molasses) a a substrate for the fermentation. The separation of
the yeast from the molasses substrate by centrifuging and
subsequent washing to remove residual substrate from the yeast
produces a substantial quantity of effluent - approximately 2-3
gallons per pound of yeast.
The consolidation effluent (ie. all of the various discrete
effluent streams mixed together) prior to on -site treatment is
characteriz d by high volume and high organic strength. The organic
strength i primarily derived from the molasses, which source
accounts fo over 90% of the BOD5 in the effluent. Of the complex
organic po ymers in the molasses, the yeast only utilize the
fermentable sugars, and the remaining diverse organic matter
contained in the molasses reports to the effluent stream.
Existing On -site Treatment
The Fleischmann's Yeast plant at Gastonia operates a substantial
on -site effluent treatment plant (ETP). The ETP is a biological
process which consists of a high -rate anaerobic bacterial
fermentatio (Biothane Upflow Anaerobic Sludge Blanket (UASB)
technology) as a primary treatment step followed by a high -rate
aerobic ba terial fermentation (completely mixed -type activated
sludge pro ess). After final solids separation (in a clarifier
tank) the ti-eated effluent is discharged to the sewer system. This
system has a total retention time of approximately 4.7 days (1.7
days in the anaerobic stage +3.0 days in the aerobic/clarifier
stage). The system is primarily designed to remove dissolved
organic matter (ie. BOD, over 90% reduction is achieved) and also
achieves significant removal of suspended solids. In addition, the

sequential
significant
ammonia in 1
converted t
This treatm
for on -site
size. Burns
world-wide
ombination of anaerobic and aerobic treatment achieves
nitrogen removal (by conversion of organic nitrogen to
he anaerobic stage, whii.gb_,i,gg then lost to atmosphere or
nitrate in the aerobic stage).
nt system in effect represents current best practice
treatment for effluent from a yeast factory of this
Philp operates over 30 yeast manufacturing operations
(including five in North America) and the ETP at
Gastonia is the most comprehensive on -site tre.a,tmeat.Y..s_y._s_ ,em in
9 operation within the rou . It also compares favorably with the
e r-atment systems operated by other yeast manufacturers in
y, \-North Ameri a. It should be noted, however, that this also results
W in the yeas plant in Gastonia having the highest effluent disposal
0 cost (per nit of production) of the five Fleischmann's Yeast
operations in North America. Any substantial addition to this cost
will there ore have a significant negative impact on the
competitive ess of this operation in the North American yeast
market.
uen
Origin and Themistry of Refractory Organic Substances in Molasses
Refractory rganic compounds in molasses are sometimes referred to
generically as "melanoidins" (1-3), but can be divided more
strictly into melanoidins, caramels and melanins (4) . The compounds
originate from the source plant juice and in processing (4). The
melanoidins arise from the Maillard reaction between sugars and
amino acids (5) , the caramels from degradation of sugars(6) and the
melanins f om condensation of natural polyphenolics in sugar
processing (4). Their relative abundance varies according to the
source material (beet/cane) and processing conditions (4). For
example, beet molasses is relatively richer in polyphenolic
compounds. Processing conditions of note are temperature, pH and
time. Temperature is of particular significance in terms of
accelerating the rate of formation of these compounds in sugar
solutions, while the product spread will depend on the presence of
other react nts. For example, sugar heated alone produces caramels
while the presence of amino acids allows the formation of
melanoidins (6).
In bakers' yeast production, attention has focused on melanoidins
due to their inertness in yeast manufacture and the subsequent
biological waste treatment processes (1,8,9). Since the melanoidins
are such complex mixtures, studies of their structure and
properties has tended to use synthetic melanoidins as model systems
(10), forme by heating simple mixtures of amino acids and sugars.
In the Mai lard reaction, condensation of the amino group of the
amino acids with the carbonyl of the sugar occurs, and the product
(N substit ted glucosylamine) undergoes an irreversible Amadori
rearrangement (11,12). The Amadori, products undergo a complex
series of condensations and rearrangements to eventually form inert
(13) water-soluble polymeric compounds, MW about 12,500-25,000, of
undetermined structure (14). The Amadori products are less -readily
metabolizable than the starting materials, so the organic matter is
effectively removed from the carbon cycle and preserved (12). In

this sense t ey are similar to the closely -related humic substances
(7,15). Mai lard suggested that the above reactions might be the
basis for he formation of humic substances in nature (16) and
there is evidence to suggest that humus is formed via condensation
between mel noidins and lignins (12). The melanoidins exist in
aqueous systems as highly dispersed colloids, slightly acidic and
hence negatively -charged at common pHs (15). In nature they are
thought to associate with clay particles and this is thought to
play a key role in humic acid formation (17, 18).
Supplementary Treatment Options
Any supplem ntary treatment must focus specifically on the removal
of the refr ctory organic compounds from the effluent stream. This
can be achi ved by either:
(i) source removal (ie. raw material substitution);
(ii) oxidation (either biological or chemical)
(iii) physico-chemical removal (eg. flocculation,
filtration, adsorption)
(iv) evaporative concentration
(v) non -sewer disposal of the effluent (eg. by land
application) .
As the existing ETP already represents a highly efficient
biological oxidation system, we can assume that the refractory
compounds remaining are basically non -biodegradable. Further
biological oxidation can therefore be eliminated as a viable
option.
Essential there are five points in the manufacturing and effluent
treatment processes where the remaining strategies could
theoretically be implemented as supplementary treatment to address
the issue of refractory nutrient sources in the effluent.
1. C anges to the raw material inputs to the manufacturing
process;
2. C anges to the manufacturing process;
3. re -treatment of the effluent prior to input to the
xisting ETP;
4. Changes to the existing ETP process;
5. Post -treatment in addition to the existing ETP.
Each of these is considered in turn below.
1. Changes to the raw material inputs to the manufacturing process
The raw material of concern in this instance is molasses, which is
also the p imary raw material used in the manufacturing process.
Some molas es substitution is used when other cheap sources of bulk
sugar (eg. syrups) become available. However, substitution beyond
approximat ly 15% replacement has an adverse effect on the yeast
quality, w ich is unacceptable. In addition, Burns Philp has been
using mola ses as a primary substrate for over 50 years and all of
it's accum lated fermentation know-how is predicated on the use of
molasses. These considerations, combined with the fact that
molasses i the lowest cost sugar source consistently available in
the requir d quantity means that raw material replacement is not
regarded as being a viable option.

2. Chan
The manufact
compounds al
is highly
(activity,
changes to t
in refracto
adverse eff
process are
to the manufacturin• •rocess
ring process has little or no effect on the refractory
eady present in the molasses. The fermentation process
ptimized to produce yeast with the characteristics
helf life etc) required by the bakery market. Any
is process would be unlikely to result in an reduction
y organic compounds in the effluent and may have an
ct on product quality. Changes at this point in the
therefore not regarded as being a viable option.
3. Pre-treatment of the effluent prior to input to the existing
ETP
As the mole
refractory c
highly conc
contains app
spent molas:
dilute, eff
separation,
all theoreti
isses has been defined as the main source of the
ompounds, the options at this stage would focus on the
ntrated "first separation" effluent stream, which
roximately 65% of the spent fermentation substrate (ie.
yes), prior to it being mixed into the other, more
luent streams. Chemical oxidation,physico-chemical
evaporative concentration and non -sewer disposal are
cally applicable at this point.
The chemical oxidation process uses strong oxidizing agents such as
ozone or UV -catalyzed peroxide to chemically "burn" the organic
matter in the effluent, converting it to carbon dioxide and water.
Such systems typically entail high capital cost. In addition, the
application of these methods at this point would be hindered by the
very high organic strength of the untreated first separation
effluent, which would result in high rates of usage of the chemical
oxidants and thus uneconomically high operating costs. Chemical
oxidation at this point is therefore not regarded as being a viable
option.
Physico-chemical separation by flocculation utilizes the addition
of flocculating or coagulating agents to the effluent. These agents
chemically aggregate the substances to be removed (in this case
refractory organics) into a form which can then be removed from the
effluent by physical separation processes such as flotation,
settling or filtration. As with chemical oxidation systems,
physico-chemical separation systems entail a significant capital
cost. Also like chemical oxidation systems, the high organic
strength of the untreated first separation effluent stream would
result in a high rate of use of the chemical agents, resulting in
high operating cost. It would also result in a large quantity of
sludge bein generated which would then require disposal, further
adding to he operating costs. To date, Burns Philp's direct
experience ith this type technology (using a Dissolved Air
Flotation o DAF system) is that it is extremely costly to operate
and not ve y effective, and eventually this DAF system was
decommissioned. Application of physico-chemical separation by
flocculation at this point is therefore not regarded as being a
viable option.

Physico-che ical separation by filtration involves physical
separation f suspended solids and large molecules by straining
them out wi h a fine filter. As the refractory organic compounds
are generally fairly large molecules they are in theory susceptible
removal us'ng ultrafiltration or nanofiltration technologies.
However, in this application trials with a range of filtration
membranes h ve shown that the effluent causes rapid, non -reversible
fouling of such membranes. Application of physico-chemical
separation y filtration at this point is therefore not regarded as
being a viable option.
Physico-chemical separation by adsorption uses materials such as
activated carbon or ion -exchange resins to adsorb the compounds of
interest from the solution. In this application it is clear that
the high organic strength and high volume of the effluent stream
would result in a very high rate of adsorbent usage, resulting in
unacceptably high operating cost. Fouling of the adsorbent is also
likely to be a problem, resulting in a loss of adsorption
efficiency. Application of physico-chemical separation by
adsorption t this point is therefore not regarded as being a
viable opti n.
Evaporative concentration removes the suspended and dissolved
materials i the effluent by evaporating off the water, leaving a
concentrate residue which in this instance would include the
refractory organics. This material must then be disposed of
elsewhere (typically as a low value stockfeed additive). Although
a technically elegant solution, in practice this system has several
major disadvantages. The process is very costly in terms of both
capital (equipment) costs and operating (energy) costs. In
addition, practical experience has shown that the process is
difficult toperate reliably on yeast production effluent, due to
the rapid 'uild-up of scale on heat exchange surfaces. This
results in r duced evaporation efficiency and significant down time
for cleanin . The Fleischmann's Yeast plant in Sumner, Washington,
used this s stem but was eventually forced to close due it'shigh
cost. of eff uent treatment. Evaporative concentration is therefore
not regarde as being a viable option.
Non -sewer d'sposal of the "first separation" effluent has 'been
extensively investigated by Burns Philp, and indeed in Australia a
land applic tion project is currently in transition from pilot
scale to al full scale program. The first separation effluent
contains between 0.5 and 1% potassium in addition to the organic
content, an for this reason it has some (limited) value as a
liquid fert'lizer. The critical factors which dictate the viability
of land app ication programs are:
• Availability of sufficient land within an
economically viable, transport radius. Typical
potassium application rates in agricultural systems
range from 0 to 200 kg K ha/hr.

•
Availability of appropriate agricultural systems.
To prevent potassium accumulation in the soil the
agricultural system must remove as much potassium
as is added ie. cropped systems such as vegetables,
sugar cane, corn or animal fodder are required.
Gazing pasture is not suitable.
Suitable storage facilities. Agricultural systems
typically only utilize fertilizer applications at
certain times of the year, so the effluent must be
able to be stored during periods of low demand. In
addition, land application of liquid fertilizer
requires dry weather (for vehicle access and to
prevent contamination of surface run-off) so...
storage during wet weather periods is also a
necessity.
Availability of suitable distribution and
application systems. The volume of material to be
distributed is large and suitable road tankers and
land application implements (usually tractor -towed)
are needed.
Approvalhv on
the specific materialand the jurisdiction,
licensing may be required for the transport,
storage and land application of the material from
either environmental or agricultural regulatory
authorities.
The Fleischtann's Yeast factory at Gastonia is moderately large, so
the volume of effluent requiring distribution is proportionately
large. Our assessment is that sufficient suitable land would not be
available w thin an economically viable transport radius. For this
reason non- ewer disposal is not regarded as being a viable option.
4. Changes to the existing ETP process
The existin ETP uses a high -rate biological process. Both AWARE
Consultants and Hagen Engineering have been working on process
optimizatio at the ETP for a number of years. This work has
improved a number of operating parameters but has not resulted in
an improvement in removal of refractory organic compounds. As the
refractory organics appear to be highly resistant to biological
degradation further optimization or enhancement of this system is
unlikely to yield an improvement in the removal of these compounds.
Changes to he existing ETP process are therefore not regarded as
being a via le option.
5. Additio;
At this poir
removed and
organic comj
various eff
existing ET
non -sewer
concentrati
filtration,
ial treatment after treatment by the existing ETP
t the effluent has had most of the BOD (organic matter)
most of the residual COD is comprised of the refractory
ounds. The effluent volute is also quite large, as the
uent streams are consolidated prior to treatment in the
. The large, dilute volume precludes options such as
disposal (for logistical reasons), evaporative
�n (due to the high energy cost) chemical oxidation,
filtration and adsorption (due to the high capital cost

of equipme t capable of handling the required flow rate).
Flocculatio appears an attractive option at this point but to date
a suitable flocculant chemical has not been identified (despite
extensive rials). Additional treatment after the existing ETP
process is therefore not regarded as being a viable option.
Summary
A wide rang of options for removal of refractory organic compounds
from the effluent have been considered at all points in the
production and effluent treatment processes. None of these options
appear to be viable, due to either technical or economic
constraints or both. The conclusion reached is that the existing
on -site effluent treatment process represents the best available
practice which is technologically and economically feasible for the
Fleischmann's Yeast factory at Gastonia.
Interaction with Long Creek STP Upgrade
The Long Creek STP upgrade will increase the throughput capacity of
the plant and will also include biological nutrient removal (BNR)
in the process. Pilot trials, however, reportedly indicate that the
BNR process cannot achieve the required Total Nitrogen (TN) and
Total Phosphorus (TP) limits, apparently due to the presence in the
effluent stream of refractory (ie. non -biodegradable) organic
compounds containing these elements.
The Stage 1 STP upgrade will have a daily flow of approximately 8
MGD. The daily input to the plant from Fleischmann's averages
approximate y 0.3 MGD ie. approximately 4% of the total flow.
Assuming th t all of the average TN concentration of approximately
100 mg/1 in (the effluent from Fleischmann's is refractory (ie. non -
biodegradable) , this equates to approximately 4 mg/1 TN in the Long
Creek STP d scharge - approximately equivalent to the unaccounted
for exceeds ce from the BNR pilot plant (8 mg/1 measured vs 6 mg/1
standard).
Conversely, the average TP concentration in the Fleischmann's.
effluent is approximately 20 mg/1, of which approximately 13 mg/1
is in the form of orthophosphate (ie. susceptible to removal by the
BNR process). Based on Fleischmann's accounting for 4% of the Long
Creek STP throughput, the remaining 7 mg/1 of TP equates to only
0.3 mg/1 in
biodegradab
TP concentr
it does not
effluent is
the standar'
the STP discharge, even assuming it is all in a non-
e form. As the BNR pilot plant achieved final effluent
tions of 2.5 - 4mg/1 (vs the required 1 mg/1 standard) ,
appear that refractory phosphorus in the Fleischmann's
sufficient to account for the observed exceedance of
The conclusion appears possible that Fleischmann's effluent may be
one of the ources of the refractory• nitrogen. This conclusion is
consistent ith the known chemistry of melanoidin compounds found
in molasses. However, there does not appear to be any persuasive
evidence th t Fleischmann's is a significant source of refractory
phosphorus, and again this is consistent with what we know about
the nature of phosphorus present in molasses.

Environment -1 Fate of Refractory Organics
The environ ental fate of the refractory organic compounds in the
effluent, i particular the melanoidins, is not known with any
certainty. It is apparent from the fact that they have passed
intact thr•ugh a substantial series of biological degradation
processes, noth on -site at Fleischmann's (1 x yeast fermentation,
1 x anaerobic bacterial fermentation and 1 x aerobic bacterial
fermentatio ) and at the Long Creek STP (sequential aerobic,
anaerobic a d anoxic bacterial fermentations) that they are highly
resistant t biological breakdown and can therefore be expected to
be relatively long-lived in the aquatic receiving environment as
well. A reviJew of the literature indicates that the melanoidins may
be involved (possibly as precursors) in the humic acid processes
which occur in aquatic systems. If this is true the most likely
fate of the a compounds (and the nitrogen they contain) is removal
from the system by deposition into the sedimentary sink
"compartmen ". The reported association between melanoidins and
clay particles in aquatic environments may also favor this mode of
sedimentary removal.
There al4 numhPr of repwi. Ls In ttie liLe/aturo of attempts to
isolate bac:.eria or fungi (usually from soil environments) which
are capable of breaking down melanoidin compounds. A number of such
microbes have been identified. However, when tested the rates of
breakdown have been low, efficiency of breakdown poor. and
reproductive rates of the organisms have been low, even under
optimal conditions (including feeding with supplementary nutrient
sources). This also indicates that rates of breakdown of these
compounds in the natural environment are likely to be very low.
This is likely to be particularly true at low concentrations, as
this would not favor the evolution of specialized microbial
communities capable of utilizing these compounds.
Discussion ailnd Conclusions
Two main po nts emerge from the discussion above:
1. The effluent from the Fleischmann's Yeast factory is subjected
to a high level of treatment both from the on -site effluent
treatment plant and again at the Long Creek STP, prior to discharge
into the South Fork of the Catawba River. Additional on -site
treatment Fleischmann's Yeast to effect further removal of the
refractory compounds is not a viable option. The standard of
treatment of the effluent provided both on -site at Fleischmann's
Yeast and of -site at Long Creek STP (after upgrade) is regarded as
being equivalent to best available practice.
2. The ref actory compounds in the effluent from Fleischmann's
Yeast which remain in the effluent, after BNR treatment at Long
Creek STP a e highly resistant to biological degradation. Although
their long-term fate in an aquatic environment cannot be predicted
with certainty it appears unlikely that they will be transformed
into a forin in which the nitrogen they contain will become
available as nutrient source able to be utilized by phytoplankton
(algae) .

oC27.,%.
r-A,, !,, (.;i) ,s
004-1./304.4t1./A4,)
The concluion to be drawn from these two points is that the
regulation of nutrient input into the South Fork of the Catawba
River by r gulating Total nitrogen inputs creates an anomaly in
this specif c instance, as a significant proportion of the TN input
is in a fo which is not available as a nutrient and appears
unlikely to be transformed into such a form. This, combined with
the very hi h standard of effluent treatment already applied (and
the lack of economically viable options for additional treatment)
is basis of our request that the Total Nitrogen discharge standard
applied to the Long Creek STP discharge be adjusted to include only
biologicallj available nitrogen. We believe that this would ensure
the ongoing viability of the Fleischmann's Yeast plant at Gastonia
without any adverse effect on the receiving water environment of
the South Ffrk of the Catawba River and, further downstream, Lake
Wiley.
References
1. Sirianiintapiboon, S. et al. (1995) . Biosci. Biotech. Biochem.,
59 (7) 1185 1189.
2. Sekigu hi, M. et al. (1994, 1995). JAERI Conf. Proc. 6th
Japan -China Bilateral Symp. on Radiation Chem. 95-003 & 280-284.
3. Murata M. et al. (1992). Biosci. Biotech. Biochem., 56 (8)
1182-1187.
4. Godsha}1, M., J. (1991). Sugar Beet Res., 28 (3) 155-165.
5. Mailla d. L. (1912). Compt. Rend., 154 66-68.
6. Sharma S. et al. (1984) . Proc. 48th Ann. Conv. Sugar Technol.
Assoc. Indi , M67-M80.
7. Benzing-Purdie, L. et al. (1983). J. Agric Food Chem., 31 (4)
913-915.
8. Migo, V. et al. (1993). J. Ferment. Bioeng., 75 (6) 438-442.
9. Patil, N. et al. (1995) . Indian Journal Env. Health, 37 84-87.
10. Teresa a, N. et al. (1991). Agric. Biol. Chem., 55 (6) 1507-
1504.
11. Ingles, D. et al. (1995). Chem. Ind., March 18, p194.
12. Hoerin4, T. (1973). Carnegie Institute of Washington Yearbook
1972, 682-6 0.
13. Dehort r, B. et al. (1993). FEMS Microb. Lett., 109 117-122.
14. Kato, ., et al. (1981). Prog. Food Nutr. Sci., 5 147-156.
15. Migo, . et al. (1993). J. Ferment. Bioeng., 76 (1) 29-32.
16. Mailla d, L. (1916). Ann. Chim. (Paris), 5 (Ser 9) 258.
17. Hedges, J. (1978). Geochim. Cosmochim. Acta, 42 69-76.
18. Taguchi, K. et al. (1986). Adv. Org. Geochem., 10 1081-1089.
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(gag of (!azthxta
P. O. BOX 1748
& ustaniu, (North Qlarolinu 28II53-1748
DEPARTMENT OF
PUBLIC WORKS AND
UTILITIES
October 18, 1996
Ms. Donna Forner
Fleischmann's Yeast
P.O. Box 999
Gastonia, NC 28053
RE: Nu lent Issues
Dear Ms. Forner:
Based upon a telephone conversation with Ms. Colleen Sullins, with the North Carolina
Department of Environment, Health, and Natural Resources/Division of Water Quality
(NCDEHNIZ/DWQ), the City is submitting to the State a copy of the technical report
prepared by Mr. Tony Hunt and a copy of the summary detailing the Long Creek pilot
plant nutrient findings from Aware Environmental.
Ms. Sullins
estimates fo
Yeast was p
However, s
information
be presente
State as wri
also requested a copy of any available economic information and cost
r treatment alternatives. Ms. Sullins was informed that Fleischmann's
reparing the cost information for submittal and it would be included.
ince that conversation, Fleischmann's has informed the City that the cost
will not be submitted since it was prepared as background information to
1 at a meeting with the State, and was not prepared to be submitted to the
tten.
It is our un erstanding that Ms. Sullins will set up a meeting with City and
Fleischman 's representatives after the appropriate State staff have had an opportunity
to review a information submitted to them. Ms. Sullins has requested the cost
estimates fo treatment alternatives investigated by Fleischmann's prior to setting up a
meeting wi NCDWQ staff. The City is prepared to accompany Fleischmann's
representati es to this meeting with the State and support a request for a variance in the
nutrient lim tations for the new Long Creek WWTP. However, the City considers the
cost estimat s to be a vital part of that presentation and of the City's support for the
variance. I is critical that Fleischmann's be willing to share this information with the
City and N DWQ.

October 18 1996
Nutrient Issues
Page 2
As we have discussed at several meetings in recent months, the City is firmly
committed o the new Long Creek WWTP being fully compliant with all NPDES limits
and requirements upon its completion. The Fleischmann's Yeast plant has been
identified as contributing refractory nutrient materials to the City wastewater treatment
system that are not effectively removed by either the extensive pretreatment system
currently operated by Fleischmann's or by the new state of the art nutrient removal
system currently under construction by the City of Gastonia. The Long Creek facility
is planned or completion in early 1998. The nutrient problems that have been
identified a Fleischmann's Yeast must be successfully resolved prior to the start up of
the new Log Creek facility, either through additional treatment or through a variance
in our limi .
The City h made every effort to work with Fleischmann's Yeast to reach a mutually
acceptable esolution to their nutrient problem and will continue to do so. It is critical
to the success of negotiations with the NC Division of Water Quality (NCDWQ) that
Fleischmann's provide all requested data as soon as possible to the DWQ for their
review prior to any meeting in Raleigh to discuss this issue. If Fleischmann's is
unwilling to provide this data to DWQ, that State agency will most likely not consider
a request for a variance in the City's NPDES permit for nitrogen at the Long Creek
WWTP. F eischmann's will then be required to seek alternative solutions to their
nutrient dis barge problems prior to completion of the Long Creek WWTP upgrade and
expansion i11 early 1998.
Please con ct Mr. John Shuler at [phone] or Mr. Larry Cummings at (704)
854-6670 soon as possible with your decision in this matter.
Sincerely,
Donald E. armichael, PE
Director of ublic Works and Utilities
pc: Ton Hunt, Burns Philp
Collgen Sullins, NC DEHNR/DWQ
Dr. anny O. Crew, City Manager
John Shuler, Assistant Director of Public Works/Utilities
Larry Cummings, Assistant Wastewater Superintendent
fle9.doc

City of Gastonia
Nutrient Investigation
Fleischmann's Yeast Data
Date
: `TKN (mgl) ,
T-Nit (mg/t) `
TP (mg/l)
03/16/96
31
31.3
03/17/96
45.1
03/18/96
31.7
03/19/96
196
20.2
03/20/96
319
17.2
03/21/96
201
17.2
03/22/96
20.5
03/23/96
135
17.2
03/24/96
118
16.1
03/25/96
100
16.4
03/26/96
50
16.1
03/27/96
140
36.3
03/28/96
83
13.9
03/29/96
76
16.1
03/30/96
15.6
03/31/96
15.7
04/01/96
78
17.0
04/02/96
116
19.7
04/03/96
126
18.8
04/04/96
21.7
04/05/96
95
20.8
04/06/96
73
23.7
04/07/96
104
21.3
04/08/96
92
21.7
04/09/96
134
19.3
04/10/96
104
18.1
04/11/96
108
17.6
04/12/96
110
200
24.2
04/13/96
48
18.7
04/14/96
106
20.3
04/15/96
112
20.8
04/16/96
129
19.0
04/17/96
126
18.1
04/18/96
104
16.6
04/19/96
50
18.1
04/20/96
204
16.5
04/21/96
16.5
04/22/96
17.0
07/26/96
190
270
19.0
08/20/96
180
270
25.0
09/05/96
300
350
19.0
Filename: NUTRIFNT.XLS
10/29/96 2: IOPM

City of Gastonia
Nutrient Investigation
Wastewater Treatment Plant Data
m e D
Sa ate
Long Creek
Catawba Creek
, TKN> �;,
, .
N t:
o;
,..
r. s
< ::1'KN m
1 Nit
m
TP:(mg/1)
Infl uent � :
:Effluent
_�
„Influent �
_.. Effluent
�Influ�nt
:Effluent, :
Influent' �
: Effiueot`
:Influe©t
.. Effluen , :
�Infl n _ -Effluent
t
01/10/95
14.2
<
1.0
14.9
26.3
7.18
4.06
16.8
8.3
16.9
19.2
6.63
3.22
02/10/95
26.7
9.3
26.7
12.9
6.38
5.27
25.7
4.3
25.8
8.7
6.03
3.42
03/10/93
30.17
21745
30.17
27
6.68
6.56
19.1
3.61
19.2
16.6
4.30
3.35
04/07/95
45.27
45.27
7.28
6.01
17.43
2.51
17.43
7.2
3.43
3.07
05/12/95
34
7.1
34
12.6
24.1
4.1
24.2
9.6
06/06/95
28.4
9.9
28.7
27
7.94
6.9
22.2
2.2
22.4
10.2
5.49
3.41
07/14/95
8.6
11.4
14.2
5.5
5.33
20.7
1.9
21
12
4.42
3.11
08/11/95
22
12
22.1
17.7
5.4
5.86
22.3
3.1
22.4
14
4.81
2.88
09/08/95
31
15
31
17
6.15
4.58
22
4.2
22.5
14.7
3.47
3.47
10/13/95
34
11
34
19
5.73
2.92
23
4.4
23
19
6.52
3.09
11/10/95
34
9.3
34
16
4.79
4.18
22
4.6
22
7.5
5.23
1.84
12/08/95
25
9.6
25
18
6.12
4.42
23
3.1
23
17
5.89
1.53
01/12/96
50.0
12
53.0
20
9.23
4.23
18
1.9
19
18
2.22
1.96
02/09/96
29.0
12
29.0
21
5.23
3.79
31
9.9
31
42
5.45
1.1
03/08/96
7.5
13
7.5
21
5.10
4.66
14
5.4
15
26
1.95
1.63
04/12/96
27.0
10
27.0
18
6.50
4.94
_ 27
17
27
19
6.08
3.65
05/10/96
39.0
10
39.0
19
7.26
4.39
18
2.8
18
23
4.55
0.93
06/14/96
28.0
7.8
28.0
20
6.65
5.05
21
2.5
21
20
07/12/96
34.0
12
34.0
20
5.59
4.50 I
23
2.3
23
15
4.84
1.63
08/09/96
35
11
35
19
7.69
5.11
27
2.9
27
19
6.01
2.13
09/13/96
45
16
45
28
8.13
5.00
26
2.3
26
16
6.46
1.92
- 7Ai -- Tkkit/ = VD.s_ - 410
Z
- ralle A-1-x-t,c. ekff... e I et .,0 lz, vrt.cL,
a Cto,..,cie,d awlIDetjs - 44 gyi ..
rr 4.
/t" (bn r1 b '►�%Jn i� car sGt/i$. 1 �1 �1- I l ode ,� %lC�r 6N +( R6�. i
,.&'
Ali'. 12-44‘C / :cj cm ,off a_i#,,,,, , 07,-r
oavka6 1,44. Pi 4-e liee. tv 12.147 ,Ita, ,
v.e,
Page 1
no* ficexIcf/h
Filename: NUTRIENT.XLS
10/29/96 2:12 PM

City of Gastonia
Nutrient Investigation
Wastewater Treatment Plant Data
Sample Date
Crowders Creek
TKN_(mgJ11
T-N1t (ing 1) <'-
: TP;(mg/!)
n#luen
tien
Influenx
Effluent
tiuflUs'
[ Effluent;
01/10/95
14.8
3.1
15.4
8.4
1.51
0.87
02/10/95
13.9
2.8
14.0
6.0
3.03
0.76
-
0.57
-03/10/95
-1-3 94-
2.58
--14.2
5.2
3.11
04/07/95
16.25
2.12
<
16.25
3.2
2.73
0.41
05/12/95
6.3
2.5
<
6.3
5.2
06/06/95
13.2
1.9
14.2
6.6
3.69
1.69
07/14/95
13.6
3.0
14.1
7.8
2.88
1.20
08/11/95
10.8
2.7
10.8
4.9
3.31
1.45
09/08/95
14
2.6
14.3
6.8
2.72
1.41
10/13/95
3.6
1.7
4.0
8.4
3.77
0.90
11/10/95
11
1.7
12
4.9
1.57
0.44
12/08/95
4.8
1.3
5.1
8.8
3.91
0.63
01/12/96
14
2.7
14
7.4
2.99
0.53
02/09/96
14
2.5
14
5.8
2.73
0.32
03/08/96
8.7
2.9
8.8
6.5
1.68
0.69
04/12/96
15
2.6
15
6.9
2.86
0.66
05/10/96
14
2.5
14
11
2.33
0.45
06/14/96
13
1.9
13
12
2.60
1.09
07/12/96
14
2.1
14
11
2.50
0.67
08/09/96
14
1.6
14
6.5
2.99
1.49
09/13/96
18
3.1
19
16
3.13
1.05
Filename: NUTRIENT.XLS
Page 2 10/29/96 2:12 PM

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DOWN
14 SITES
LONGITUDE
81.07'39"w
81.06'54"w
81°06'43"w
81.06'24"w
81.05'57"w
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B.M. Pim Modals 704 376-8423
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LATTITUDE ELEV.
35° 19' 13 "N 650'
35°18'38"N 642'
35°18'31"N 620°
35°16'31"N 620'
35.18'28"N 620'
LONG CREEK WWTP
NPDES PERMIT #NC0020184
SOUTH FORK CATAWBA RIVER
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