NC0020184_ENVIRONMENTAL ASSESSMENT_19910814

NPDES DOCUMENT SCANNINS COVER SHEET
f
NPDES Permit: NC0020184
Gastonia — Long Creek WWTP
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
201 Facilities Plan
Instream Assessment (f 7B)
Environmental Assessment (EA)
Mft
Permit
History
Document Date: August 14, 1991
This d0M0UmeTxt is printed CO3M reufige pjaper-iapmore Mx1-Y
coateat on the Y*eYerse side

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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Govemor August 14 , 1991 George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
Mr. John W. McLaughlin, P . E .
J .N . Pease Associates
P .O. Box 18725
Charlotte, NC 28218
Dear Mr. McLaughlin :
This is in response to the resubmittal of a draft
environmental assessment for the Long Creek Wastewater Treatment
Plant Expansion and Outfalls .
The subject EA has been reviewed by the Department of
Environment, Health and Natural Resources (EHNR) and comments
are enclosed. It is requested that you review and respond to the
enclosed comments . The response should be in the form of a
letter or an attachment to the original EA. It should also
. include copies of the agency comments . Each of the EHNR comments
should be addressed separately as recommended below.
1 . Wildlife Resources Commission
Please comment on the acceptability of each of the four
conditions set forth on page two cf their memorandum. These
appear to be reasonable and I would recommend that they be
accepted.
2 . Mooresville Regional Office -- Int2rgovernmental Review Form
The response should acknowledge receipt of these comments and
indicate the various permit requirements checked off.
3 . DEM Air Ouality Section
Important items that should be acknowledged include a) that
all work will comply with applicable State and Federal air
pollution standards, b) that open burning, if necessary, will be
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251.6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/761-2351
Poilution Prevention Pays
P.O. Sox 29535, Raleigh, North Carolina 276260535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. John W. McLaughlin
August 14 , 1991
Page 2
done as required by state regulation (t}:is was checked on the
regional office form) c) that care be taken by the contractors to
minimize fugitive dust emmissions by -:.ettina, reseeding etc . the
construction area, and d) that odors from the pump stations be
controlled through appropriate methods .
4 . Division of Water Resources
Please answer the three questions posed by Mr. Sutherland.
5 . Division of Parks and Recreation
Please indicate what will be done to assure that the project
does not impact the significantly rare bigleaf magnolia .
Once the response letter/attac1lmenf has been prepared, please
submit twelve copies of it and the EA to me for State
Clearinghouse Review. I will prepare the Finding of No
Significant Impact (FONSI) and handle submission to the
Clearinghouse . Feel free to call me if you have any questions .
Sincetely,
11-L,
C ' 1�
Alan R. Clark
Environmental Review Coordinator
Enclosure : EHNR Comments
Gastonia . Ltr/SEPA4
cc: Robert Goldstein
Robt . J. Goldstein and Assoc .
8480 Garvey Drive - Suite A
Raleigh, NC 27604
Trevor Clements
Rex Gleason
Don Safrit

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DepartnicrIL ()l L-rzvironi-n m, He lih, Irld N-.ttUrzil RCSOurCc5
�I2 \"w l3 titrcet R Kalei_,P, -N r-th C.,ir()lin,3
fames G. Nlartn, Governor
\Villiam W Cobey, Jr., 5eeretanv Director
Planning anti ;Assessment
MEMORANDUM
TO: Alan Clark
Division of Environmental Management
FROM: Melba McGee `U L-1-
Project Review Coordinator
RE: #419 - EA City of Gastonia Long Creek-Duharts
Creek Sewerline and Wastewater Treatment Plant
Expansion, Gaston County
DATE: August 12 , 1991
The referenced proposal was provided to our internal
divisions for review . Comments have been attached for your
consideration . Any adjustments made to address the concerns
raised will be considered acceptable .
Thank you for the opportunity to respond. Project should be
forwarded to the State Clearinghouse for further review.
MM:bb
Attachments
P( ?7r.1i7, k ugh, North ( .ir( lina 2701 70.87 k1cpIumic 11110 733 6376
Aio IYgiot ( )I)T>irttll i(v r111irmmmu At o,,, r Inl h,vt'I

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North Carolln�i Wildlife Resources C-0111l11iss1011
512 N. Salisbury 5iree[, Raleigh, Nardi Carolina 27b04-1188, yl9 r 33.3301
Charles R. Fullwcxki, Executive Director
MEMORANDUM
TO: Melba McGee, Planning and Assessment
Dept. of Environment , Health , & Natural Resources
FROM: Dennis Stewart, Manager , �/_Z�?
Habitat Conservation Program
DATE: July 30 , 1991
SUBJECT: Review of Environmental Assessment for City of Gastonia
Long Creek-Duharts Creek Sewerline and Wastewater
Treatment Plant Expansion, Gaston County.
I
This correspondence responds to your request for our review
of the Environmental Assessment (EA) for the Long Creek-Duharts
Creek Sewerline and Wastewater Treatment Plant Expansion by the
City of Gastonia. These comments are provided in accordance with
provisions of the North Carolina Environmental Policy Act (G.S . I
113-A, 1 through 10) .
Phase 1 of the preferred alternative for the City of
Gastonia ' s 20-year wastewater management plan includes the
following. Wastewater loads from the Duharts Creek basin will be
transferred to the Long Creek WWTP in order to reduce loading on
Catawba Creek WWTP. This will require expansion of Long Creek
WWTP from 8 to 16 million gallons per -day (MGD) , expansion of the
Duharts Creek pump station from 6. 5 to 10MGD, and construction
of 17 . 6 miles of new sewerlines along Long Creek, Kaglor Branch,
Burtons Branch, and Duharts Creek. Also, the discharge point for
the Long Creek WWTP will be moved from Long Creek to the South
Fork Catawba River, where a new outfall will be built. The
expanded Long Creek WWTP will provide tertiary treatment for
removal of phosphorus and nitrates, and effluent will be
dechlorinated before discharge. Sewerline construction will
require clearing 85 . 4 acres , including 6 . 3 acres of wetlands .
Staff field biologists of the North Carolina Wildlife
Resources Commission (NCWRC) conducted a site visit on July 25,
1991. In general , the streams in this area are somewhat degraded
from sedimentation, channelization, and point-source discharges
from municipal wastewater treatment plants and industry.
Gamefish habitat is limited, although sunfishes and catfish are

;)rc_ ent , :i some ­stre:ims .1 1 on �'h i hers and 'suckers . Wet lands
to be i mpact�d are most 1 }' ;.ssoU i ated w i th :stream dross ings .
`I,errestrial habitat includes urban areas , some hardwood f-orest
and some bottomland forest .
`rhe NCWRC is concerned over impacts to fish and wildlife
resources in the project area . We will not object to the
project, providing the following conditions are met :
1) As stated in the EA, sewerlines should cross streams at
right angles to minimize impacts to streams and associated
wetlands.
2 ) Vegetation planted along sewerlines and sewerline rights-
of-way should be selected to optimize wildlife value. The
following should be planted in early spring:
Partridge Pea 10--15 lbs/acre
VA 70 shrub lespedeza 20 lbs/acre
Korean lespedeza 15-20 lbs/acre
3) Stringent erosion control measures should be implemented
where soil is disturbed and maintained until project
completion.
4) Temporary ground cover should be placed on bare surfaces
as soon as construction is complete. Permanent vegetation
in these same areas must be established within 15 days of
project completion to provide long term erosion control.
Thank you for the opportunity to review and comment on this
project. If we can provide further assistance, please call on
us .
cc: Ms. Stephanie Goudreau, Mt. Region Habitat Biologist
Mr. Jack Mason, District 8 wildlife Biologist
Mr. Chris Goudreau, District 8 Fisheries Biologist
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,Iu]y 25, 1.991
M E M O R A N D U M
TO:: Me lba McGee
Environmental Assessm�t Section
FROM: Lee A. Daniel, Chief
SUBJECT: City of Gastonia
Long Creek-Duharts Creek Sewerline and Wastewater Treatrrient
Plant Expansion
Environments l Assert
Gaston County, North Carolina
Me Enviraru ntal Assessment for the City of Gastonia sewerline and
wastewater treatment plant improvements has been reviewed by the Air
Quality Sect-ion. The implementation of the selected alternative should
comply with all applicable State and Federal air pollution emission
limitations and ems. It is not likely that the proposed action will
contravene other provisions or requirements of the State T_rTalementation
Plan for Aar Quality (SIP) .
Care should be exercised by the contractors to comply with open burning
provisions during land clearing for the upgrading of the existing
wastewater treatment plant, pumping station, and pipelines. Adequate
wetting, reseeding and covering of disturbed areas should be utilized
during earth moving and pipeline trenching ciperations to mitigate any
adverse inpacts from fugitive dust emissions. Furthermore, odor control
measures may be needed should malodorous emissions frcan pimp stations
prove to be a problem e.g. ; the pomp stations should allow significant
buffers adequate to provide protection from malodorous emissions. Should
you require further information in this regard t, please advise.
cc: Charles F. Yirka
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titaic of North ',indirill
Departn1cm I-Icalth, 1-ind Njxur-,11 R:_ ourccs
vi,ion or W"Iter
�.,Iidnlry 5trecl "'N"wth "Irolill.1 27611
James C. Martin, Governor John N. Morris
William \V. Cobcy Jr., Sccretary Director
July 30 , 1991
MEMORANDUM
TO- Ms . Melba McGee
Division of Planning & Assessment
FROM: John Sutherland
SUBJECT: Comments on City of Gastonia' s WWTP Expansion
Project # 419
1 . Why was Alternative 2 selected as the preferred
alternative?
2 . What are the projected sewer flows based on?
Dividing total capacity (43 . 5 MGD) by total service
area population gives a per capita flow rate of
310 gallons per day . That seems very high.
3 . How does the expansion of the Long Creek WWTP impact
land use?
JS/va
K-) &-)x 27687, Raleigh, North Carolina 276;1 7687 I'Clcphonc 919 733.40i4
An FqLLal Opportuniry Alhrmanvc Acuon f.rinlover

Stale of North Carolina
' Reviewing Jil�l.0
Deparyment of Environment. Health, and Natural Resources
INTERGOVERNMENTAL REVIEW — PROJECT COMMENTS Project Numoer Due Dale
ANer review of MIS prolecl it has beer. determined Inat the EHNR oermit(s) indicated must be ootainec in order for in,s �rolecl 1,
corn Ply with Nortn Carolina Law.
Ouestions regarding tneSe permits should be addressed to the Regional Office indicated on the reverse of the form
All applications, information and guidelines relative to these pians and permits are availaole from the same
Regional Office. Normal Process
Time
PERMITS SPECIAL APPLICATION PROCEDURES or REQUIREMENTS (statutory time
fimit)
'Permit to construct S operate wastewater treatment Application 90 days before begin construction or award of 30 days
tacitilies, sewer system extensions. L sewer construction contracts on-site inspection. Post•applicason
systems not discharging into state sur-I!ace waters technical conference usual (90 days)
14PDES - permit to discharge into surface water and/or Application 180 days before begin activity. On-site inspection. 90-120 days
permit to operate and construct wastewater facilities Are-applicatron conference usual. Additionally, oblarn permit to
discharging into slate surface waters. construct wastewater treatment facility-granted after NPDES. Reply (fYlA
time, 30 days after receipt of plans or issue of NPDES
permrhwhiehever is later. �•
1 Water Use Permit Pre application technical conference usually necessary 30 days
(NIA)
7 days
J Well Construction Permit NIA
(15 days)
Application copy must be served on each riparian property owner. 55 days
Dredge and Fill Permit On-site inspection. Pre-application conference usual. Filling
may require Easement to FIII from N.C. Department of (90 days)
Administration and Federal Dredge and FIII Permit.
Permit to construct & operate Air Pollution Abatement 60 days i
facilities and/or Emission Sources NIA (90 days)
q Any open burning associated with subject proposal !
J must be in compliance with 15 NCAC 2D.0520. Ilfff
Demolition or renovations of structures containing j
7 asbestos material must be in compliance with 60 days
NCAC 20.0525 which requires notification and removal NIA
prior to demolition.
(90 days) j
Complex Source Permit required under 15 NCAC 2D.0800, I
The Sedimentation Pollution Control Act of 1973 must be properly addressed for any land disturbing activity.An erosion d sedimentation control plan
i will be required It one or more acres to be eisturbed. Plan filed with proper Regional Office(Land Quality Sect.►at least 30 days belore begin activity.
The Sedimentation Pollution Control Act of 1973 must be addressed with respect to the relerrenced Local Ordinance:
On-site inspection usual.Surety bond filed with EHNR as shown:
Any area mined greater than one acre must be permlled.
AFFECTED LAND AREA AMOUNT OF BOND 30 days
Mining Permit Less than 5 acres S 2,500
5 but less than 10 acres 5,000
10 but less than 25 acres 12.500 (60 days)
25 or more acres 5.000
} North Carolina Burning permit On-site inspection by N.C. Division Forest Resources it permit 1 day
exceeds 4 days (NIA)
Special Ground Clearance Burning Permit • 22 On-site Inspection by N.D. Division Forest Resources required "if more 1 day
i counties in coastal N.C.with organic soils than five acres of ground Oeanng activities are Involved. Inspections (NIA)
should be requested at least ten days before actual bum Is planned."
90.120 days
i Oil Refining Facilities NIA (N/A)
If permit required, application 60 days before begin construction.
Applicant must hire N.C- qualified engineer to: prepare plans, 30 days
i Dam Safely Permit Inspect construction, ceriily construction is according to EHNR approv-
ed plans. May also require permit under mosquito control program. An a (NIA)
404 permit from Corps of Engineers.
, r
Ps-105 Continued on reverse j

Ilemorai dum
TO: Melba McGee
THROUGH : Carol Tingley [�
FROM : Stephen Hall , Natural Heritage Program
SUBJECT : EA -- Sewerlines , Gastonia
REFERENCE: 419
The Natural Heritage Program database contains several records for
bigleaf magnolia ( Magnolia_ macrophylla) in the area that will be
affected by the project . This tree , considered significantly rare
in North Carolina, occurs at several locations along Long Creek,
from just below the bridge crossing on SR 2264 to the confluence
with the Catawba River . It also occurs in Burton Branch. This
species inhabits rich deciduous forests and can occur on moist
slopes as well as floodplains . Sewerlines should be routed to
avoid this species and any mature stands of hardwoods .
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor July 16, 1991 George T Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
MEMORANDUM
TO: Melba McGee
FROM: Alan Clark /(—
SUBJECT : Draft EA for Proposed Long Creek Wastewater Treatment
Plant Expansion, Duharts Creek Pump Station,
Enlargement and Sewerline Construction in Gastonia,
Gaston County
Enclosed are ten copies of an environmental assessment for
that proposed construction activities . Please circulate the EAs
to the appropriate agencies and provide me with their comments .
Let me know if you need ,any additional information .
Enclosures
Gastonia .Mem/SEPA4
cc: Robert Goldstein
Don Safrit
Trevor Clements
Rex Gleason
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 9191733-2314 919/946-6481 919/395-3900 919/761-2351
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opporruniry Affirmative Action Employer

4
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor May 23, 19 91 1°, George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary .Director
RECO VED
Mr. John W. McLaughlin, P .E .
J.N. Pease Associates MAY 2 8 1991
P .O. Box 18725 x1CHNl , �
Charlotte, NC 28218 ri SUPpORT BRANCH
Dear Mr. McLaughlin: ;
r
d
This is in response to the resubmittal of an environmental
assessment for the Long Creek Wastewater Treatment Plant
Expansion and Outfalls .
A similar version of this EA was reviewed and commented on
earlier by this office . Several of the comments were addressed
and some were not . However, in becoming reacquainted with the
project, it' s become apparent that some additional revisions are
needed to aid reviewers in understanding the project early on in
the . document . For example, one has to read through the Needs
section and eight different- project alternatives - (without aid of
a map and/or diagram) before finding out on page 8 that
alternative 2 is the preferred alternative .
It is thereford recommended that the Needs for the Project
section be expanded to include a description of the proposed
work. This should indicate that eight alternatives were reviewed
(to be presented in Section 2 . 0) and that Alternative 2 was
selected. It should then briefly describe the plant and pump
station . expansions as well as the name, length and diameter of
gravity lines and force mains . It is also recommended that
Figures 1 and 2 be referenced in the -text- -of this' description, as
appropriate, and that they be relocated from the back of the
document to immediately behind Section 1 . 0 . It is further
recommended that a map (Alternative 2) from the 1990 Master Plan
be included with figures 1 and 2 at the front of the document .
This same information could also be presented' in the form of an
Executive Summary at the front of the document .
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/761-2351
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. John McLaughlin
May 24, 1991
Page 2
In addition to the above recommendations, the document also
needs to include some additional information on secondary growth.
What are the areas that will be served by the proposed
improvements? Are these areas presently zoned? If so, will the
zoning change as a result of the project? If not presently
zoned, how is the land classifed in land use plans? How will
this change in the future with project . implementation? It is
recommmended that a land use plan, provided by Gastonia, be
included in the document .
The other items that need to be addressed are presented
below. These are basically comments that had been made on the
earlier draft but were not addressed in the new one .
o Section 4 . 6 needs to be expanded to include a discussion of
the impact of urban runoff on surface water quality in the
area. There also needs to be a discussion of the upcoming
discharge permit requirements for stormwater runoff and how
they may affect Gastonia. Contact Mr. William Mills or Ms.
Coleen Sullins for additional information (919/733--5083) .
o Section 5 . 0 should add a paragraph on control of urban runoff
through implementation of the new stormwater regulations .
o On page 13, second paragraph, the EA. states '.'that thirty NPDES
dischargers use the South Fork Catawba River and its
tributaries for wastewater disposal . Thirty discharges are
located on the lower South Fork subbasin. There are 40
more in the upper South Fork subbasin .
o A sentence should be added at the end of paragraph three on
page 14 stating that the City' s engineers are investigating
color removal in the event that North Carolina adopts a water- ,
quality standard for this parameter.
Once the above revisions have been made, please submit twelve
copies of the EA for review by our full Department . Feel free to
call me if you have any questions .
Sincerely,
Alan R. Clark
Environmental Review Coordinator
Gastonia. Ltr/SEPA3
cc: Robert Goldstein
Trevor Clements
Rex Gleason
Don Safrit

SfArz
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street 0 Raleigh, North Carolina 27611
James G.Martin,Govemor George T. Everett, Ph.D.
William W.Cobey,Jr.,Secretary Director
March 11 , 1991
P;r
MAR 1991
Mr . Robert: J . Goldstein
8460 Garvey Drive, Suite A
Raleigh, North Carolina 27604
Dear Mr. Goldstein:
DEM Planning and Technical Support staff have had an
opportunity to review the Long Creek-Duwart' s Creek Sewerline and
Wastewater Treatment Plant Expansion Environmental Assessment
(EA) . The document is generally well-written and comprehensive ;
however, it is recommended that several revisions be made.
1 . The alternatives section ( 2. 0 ) is very difficult to
follow without some type of visual aid. Recommend, as a
minimum, adding a regional map that identifies all of
the facilities referenced in the text.
2 . on page 5, would add "preferred alternative" in
parentheses after "Alternate No. 2 . 11 at the top of the
page.
3 . on page 11 , paragraph 3 , " (Non-body contact) " should be
eliminated or be revised to read " ( limited body
contact) . " Class C waters are still intended to be
swimmable and fishable but not swimmable on a formal ,
organized or regular basis as in Class B waters .
4 . Section 4 . 6 indicates water quality will be impacted by
nonpoint source pollution from increased development .
what local government controls , if any, exist within the
pro.ject area that would provide a means of controlling
nonpoinL source pollution? it is also recommended that
you cont-.act Coleen Sullins or Bill Mills of this office
,Ic)- iscuss possible urban stormwater discharge permit
d
requirements in this area .
Pollution Pvvwndon Pays
P.O. Box 27687,Raleigh,N'orrh Carol iro Z 7611-768 7 Telephone [phone]t5
An FoLial Omorrimiry Afimmivo Acr�)r Fmr;ovt!r

Mr. Robert J. Goldstein
March 11 , 1991
Page Two
5 . The third paragraph in Section 5. 1 (p. 24 ) discusses 401
Certification mitigation measures . In addition to those
mentioned, the paragraph should also indicate that
wetlands are considered as waters of the State by DEM.
Accordingly, wetlands impacts are considered by DEM
prior to issuance of a 401 Certification. DEM generally
follows the Section 404 (b) ( 1 ) guidelines in evaluating
the acceptability of a project. Please contact Mr. John
Dorney or Mr. Ron Ferrell if you have any questions in
this regard.
6 . See the attached March 1 , 1991 memo from Ruth Swanek for
additional comments from our Technical Support Branch
that should be addressed in the EA.
Once you have made these revisions , you may submit eleven
copies for Departmental review. Please feel free to contact me
if you have any questions .
Sincerely,
Alan R. Clark
Environmental Review Coordinator
ARC/kls
RJGold. ltr/ARC2
Enclosure - Swanek memo
cc: Bill Mills
John Dorney
Ruth Swanek,

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 1, 1991
MEMORANDUM
TO: Alan Clark
THROUGH: Trevor Clements
FROM: Ruth Swanek QcS
SUBJECT: , City of Gastonia' s preliminary EA
Long Creek WWTP
Gaston County
I have reviewed the preliminary EA for the City of Gastonia
and offer the following comments :
1) On page 11, the report states that thirty NPDES discharges
use the South Fork Catawba River and its tributaries for wastewater
disposal . Thirty discharges are located on the lower South Fork
subbasin, and there are approximately 40 more in the upper South
Fork subbasin.
2) On pages 12-13, the report states how the facility' s tox-
ics limits will be derived and that the City is planning on
nutrient removal . In this section, the report should also state
that the City will meet advanced tertiary limits in order to ensure
that loading to the system does not increase . In addition, the
City' s engineers are investigating color removal in the event that
North Carolina adopts a water quality standard for this parameter.
If you have any questions or comments, please do not hesitate
to contact me .

5[�A'!
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
Jaynes G. Martin,Governor George T. Everett, Ph.D.
Williarn W. Cobey,Jr., Secretary Director
February 19, 1991
V
\,lr, Rodney Uavis, Chemist ; ;
City of Gastonia/Dept. of Public Works
P.O. Box 1748
Gjsionia. N.C. 28053-1748
Uectr ,\sir. Davis,
"Ghana you for the opportunity to comment on your protocol for performing toxicity reduction screen]'11
Of' industrial discharges. Below are comments on the written material provided and additionally comments
resulting from our follow-up telephone conversation of Feb. 19.
Section A. Reagents.
A,?. 1 would define "toxicity free" make-up water with some acceptable endpoint of toxicity.
Also, is the intention here to simulate hardness of the local surface waters for the purposes of measuring
toxicity, or to simulate hardness of the discharge? I believe a case could be made for either direction but
the assumption should be defined here. Hardness of Milli-Q®/Perrier0 dilution can be adjusted by
varying the relative percentage of Perrier®. I would define what methods/chemicals can be used to
modify hardness of surface waters (if the choice is made to simulate hardness of the POTW effluent).
A.3. As different commercial media may contain different ingredients which may either increase or decrease
potential toxicity, I would recommend standardizing on, and requiring that a single, widely available
media, such as the one proposed, be used.
Section B. Procedure
13.1. 1 would define proper cleaning procedure here. It is our experience that much hardened glassware
(e.g. PYREXO, KIMAXO, etc.) can leach metals such as zinc to the extent of adding toxicity to the
sample. i would recommend that all new glassware be soaked in 20% acid overnite, at a inininulm.
Routine cleaning should also include aci(1, acetone, and distilled water rinses.
Polludon Prewndon Pays
P.O. Box NM7. f_Jeigh,North Carolina 276H-7687 Telephone [phone]
An Fo tol Opi.)nramiry APftrtnative Action F1nr)1()ve1

13.2. For editorial clar4tV I WOUld 1110C11tV tht SClltencc io read something hke:' Add iipproxiiiiiitelV 120 nil
of thickened biological scud" (0.7-2.5%; solids, between 1.5 and 3 grams dry weight) ) as it bacterial
seCd to the aerated makeup water. This sludge can be obtained from a secondary claritICY underllow. It
should be aerated at the rate of 200-400 ml/min before use."
11.6, Specif%, what chemical/nICLI10ds should be used to maintilin pH,
13.8. 111 this Section, Section C.. and Section D., different toxicity tests are disCusscd. As per mir
conversation, I lxlieve a 24 hour Ceriadaphnia dubi,t acute test is whilt i,s being rec}uircd, in idl
cases. I would clarify that specifying "N.C." tests refer to two specialized 11-ietliodolo"Ic s
which modify the EPA procedures to sonic degree. Assuming that we are dealing exclusively
with acute toxicity tests. the "N.C" procedure {North Carolina Division of Environmental
:Management. 1987. Revised April. 1989. Pass/Fail iklethodolo�(Tv I7or DeterininIiIg Acu(e:
"Foxicity In A Single Effluent Concentration.) Would require that 4 replicates of a control and 4
replicates of it treatillent, each containing 10 test organisms, be tested at sonic single defined
ctiflucrit concentration. The results of this test are defined ill there being a significant difference
in mortality between control and treatment as determined by the Student's t test. The use of four-
replicates is described as a statistical necessity in this type of analysis, i►nd I Would htghly
recommend that this be used as it minimum number. Additionally, I think: that your intent at this
point is to mix art industrial waste contribution. both treated and untreated,with ciilutian water.
in relative proportion to the total flow of the PO'I W and subsequently test whether the treatment
is effective in reducint, toxicity. As such, is it necessary to subsequently dilute both solutions to
the final IWC of the POTW's discharge'? If this is your intent, I would make the two dilution
steps much more clear at this point.
Section C. Toxicity Measurement
See comment above on correct test type. Also, in our telephone discussion you had said that there was
a suggestion to define 10% mortality as an absolute cutoff for pass/fail of the test, without
regard for control performance. I feel like this will lead to serious problems, particulariy in light
of the fact that most acute toxicity tests have a defined acceptable control mortality of 10%.
"There needs to be some definable, and defensible analysis applied to the endpoint, including
control response, particularly when using the single concentration test. As such, I would again
recommend consideration of the statistical method used in the N.C. test referenced above.
Section 1). Quality Control
Again, test types should be redefined to the intended protocol decided upon.

tiection l Data lnterpretatiMI
1.:. 1 and 2. Would it bc possible here to define some cutoff between acceptable and unacceptable toxicity
reduction, possibly based on data from pilot trials of the methodology?
Some defined difTerencc in statistical si'-1r3iticarrec of results should be defined here.
b. I::ventually. [he endpoint here n-itis[ be a Clete mlirration by the city of the allowable R)MCIty ref ractor-V to
Ole PO"TW. As discussed in C. above, this determination of the presence Of 10Xic11y should be clef inc:d
and defensible,
Once again, I'd like to thank you for the opportunity to provide technical comment on the proposed
program. i hope that it will be successful and provide you with the information you need to control
potentially toxic discharges. I believe that the City of High Point has dealt with a similar program. If
you have not talked with them, N,1r. Bill Frazier with High Point's Central Laboratory Services at
(919)$83-3410 may be ,tble to provide some insight. If I can provide you with any further infomlation.
{Tease; give me a cal at [phone]. �
Sir�ierely. 1
�.
Larry W.",AUsley, Supervisor
aquae c "Toxicology Unfit
cc:Steve Tedder
Trevor Clements

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RECEIVED
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C�itb of 645toll11
P O.9DX 7aH
ENVIRONMENTAL SCIENCES BRANCH
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(Saatnnta. :1�arti� (IIttrolina Z@U53-17�8
C)EPARTMENT Dv
PUBLIC WORKS and U11LVTIES
February 13 , 1991 '�
EES 15 1991
Mr. Steve W. Tedder WATER QUALITY
Water Quality Section Chief SECTION
N. C. Dept . of EHNR / DEM
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Tedder:
In regards to conversation with Larry Ausley on February 12 ,
please find enclosed a protocol for performing toxicity reduction
screening of industrial discharges for review and comments. The
City of Gastonia desires to incorporate a toxicity requirement in
its industrial user pretreatment permits.
Thank you for your assistance in this matter. If I can be of any
help, please contact me at 704-866-6831.
Sincerely,
CITY OF GASTONIA
Rodney Davis
Chemist
Enclosures
cc: Larry W. Ausley
Dana Rees Folley
Coleman Keeter

PROTOCOL FOR PERFORMING TOXICITY REDUCTION SCREENING
OF INDUSTRIAL DISCHARGES TO THE CITY OF GASTONIA
LONG CREEK OR CATAWBA POTW
A. REAGENTS
1. Obtain a bacterial seed source (thickened biological sludge). The seed source
should be low in toxicity and should be capable of detoxifying a 20 ppm sodium
dodecyl sulfate (SDS) during the prescribed treatment period (See Section D.1.).
2. Prepare or obtain a source of toxicity free make-up water. Milli-Q/Perrier
mixtures or local surface waters (of comparable hardness to the POTW effluent
may be used for that purpose).
3. Prepare a concentrated organic mixture that simulates the constituents of
domestic wastewater. A suggested formula is presented in Table 1. Several
of the organic constituents are available in a commercial preparation (m Plate
Count Broth - DIFCO LABORATORIES, Detroit, Michigan).
B. PROCEDURE
To set up the culture control:
1. Place approximately 750 ml of make-up water under aeration. Use a properly'
cleaned 2-liter beaker, a cleaned air-stone, and a clean air supply such as an
aquarium pump. Use of a mechanical mixer is also suggested.
2. Add between 1.5 and 3 grams (dry weight) of bacterial seed to the aerated
make-up water. This corresponds to approximately 120 mL of thickened
biological sludge (0.7-2.5% solids). This sludge can be obtained from a
secondary clarifier underflow. It should be aerated at the rate of 200-400
mLlmin before use.
3. Add thirty-six ml of simulated domestic wastewater (Table 1) to the solution.
This is intended to produce an initial BOD concentration of between 200 and
300 mg/L.
4. Add make-up water to make a total volume of 1.2 liters.
5. Allow the culture control to aerate for six hours at ambient temperature (18 to
23-C).

6. The pH should be maintained between 6.0 and 8.5 and the dissolved oxygen
(DO) should be maintained at a concentration larger than 2.0 mg/l.
7. Following the aeration period, allow solids to settle for 30 minutes and transfer
the supernatant to a clean recipient.
8. Set up a N.C. 48-hr acute chronic toxicity assay (using Ceriodaphnia dubia on
the treated supernatant. Use an instr-eam waste concentration (IWC) of 90% for
the Catawba POTW and 78% for the Long Creek POTW.
To set up the industrial sample, repeat steps 1 through 8 by substituting industrial
wastewater for make-up water in Step 1.
The volume of industrial waste sample to be added is determined based on the
following formula:
Indust. Waste (mL) = 1,200 mL x Ave. Flow of Indust. Disch. (MGD)
Ave. Flow at POTW (MGD)
C. TOXICITY MEASUREMENT
All samples including controls should be subjected to the N.C. 24-hour acute toxicity
testing prior to and following the toxicity reduction screening process, Appropriate
dilutions should be made to account for the POTW dilution of the industry effluents
prior to bench scale treatment and for the instream waste concentration of the POTW
effluent following bench scale treatment,
D. QUALITY CONTROL
The following quality control tests should be performed with each test.
1. Perform biological pretreatment of a 20 ppm solution of SIDS per steps B1
through B7. Add 10 ml of a 2.4% SDS solution (12 gm SDS per liter of make-
up water) after step B2. Submit the treated supernatant to the N.C. 48-hr acute
C. dubia mortality assay.
2. Add 8,3 mis of 0.24% SDS solution to one liter of make-up water. This will
produce a 10 ppm solution of SDS. Submit directly for N.C. 48-hr acute C.
dubia mortality assay.

E. DATA INTERPRETATION
1. Acute toxicity should be observed in the untreated SDS test (D.2.).
2. Acute toxicity should be greatly reduced in the biologically treated SDS test
(D.1.).
3. No toxicity should be observed in the untreated and treated control samples.
4. The toxicity reduction screening is positive if acute toxicity is eliminated in the
biologically treated sample.

TABLE 1
SIMULATED DOMESTIC WASTE WATER FORMULATION
CONSTITUENT CONCENTRATION, gm/L
Sucrose 7.5
Sodium Acetate (trihydrate) 16
Bacto Feed Media: 5.7
Yeast Extract 1.7
Tryptone 3.4
Glucose 0.7
Nat HPO4 • 7 H2O 2.0

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