NC0025909_Permit Issuance_20040414

NPDES DOCUHENT SCANNIN`: COVER SH•HEET
NPDES Permit:
NC0025909
Rutherfordton WWTP
Document Type:
LPermit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Other
Speculative Limits
Instream Assessment
(67b)
Environmental Assessment (EA)
Permit
History
Document Date:
April 14, 2004
This document is printed on reuse paper - ignore any
content on the i rerse side

Michael F. Easley, Govemor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
April 14, 2004
Ms. Karen Andrews, Town Manager
Town of Rutherfordton
129 North Main Street
Rutherfordton, North Carolina 28139
Subject: Issuance of NPDES Permit NC0025909
Rutherfordton WWTP
Rutherford County
Dear Ms. Andrews:
Attached to this letter is the final NPDES permit for the Town of Rutherfordton's wastewater
treatment plant, NPDES Permit No. NC0025909. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated May 9, 1994.
There have been no significant changes to this permit from the draft permit dated November 5, 2003.
Please refer to the cover letter of the draft permit for an explanation of changes during this permit cycle. The
following comments are offered in response to your letter dated December 23, 2003:
• Regarding Item No. 1 of your letter, the Division cannot modify the daily monitoring requirement for
the permitted flow of 3 MGD (Part I, Condition A. (2.)). As a 3 MGD facility employing a biological
treatment process, this system is automatically graded as a Class IV facility [per 15A NCAC 8G .0302
(4)]. As a Class IV facility, daily monitoring of most parameters is required. At the lesser flow of 1
MGD, the facility is a Grade III and receives the reduced monitoring requirement of 3/Week. These
rules became effective April 1, 1999.
• Due to Rutherfordton's continued toxicity failures, the copper and zinc limits have been implemented in
this final permit. At any time during this permit cycle, Rutherfordton may request, via letter and major
modification fee of $860, that the NPDES Unit review copper and zinc monitoring data, as well as
toxicity data, to determine if the copper and zinc limits are still necessary. A statistical analysis of the
data will be conducted at that time on the most recent data. The NPDES Unit will review this data
along with the Toxicity Identification Evaluation information to determine if the copper and zinc limits
should be continued in the permit. The Town may also wish to wait until the next permit renewal for
review of this information. At that time, all the information on various parameters of concern will be
re-evaluated to determine if limits for various toxicants are still necessary.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter
150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, Mail Service
Center 6714, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and
binding.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Ms. Andrews
Page 2
Please take notice that this permit is not transferable except after notice to the Division of Water
Quality. The Division of Water Quality may require modification or revocation and reissuance of the permit.
This permit does not affect the legal requirements to obtain other permits, which may be required by
the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other
federal or local governmental permit.
If you have any questions regarding the NPDES permit, please contact Susan Wilson at (919) 733 -
5083, extension 510.
Sincerely,
Odginal Signed BY
David A. Goodrich
Alan W. Klimek, P.E.
cc: Asheville Regional Office/Water Quality/ Roger Edwards
Mr. Roosevelt Childress, EPA Region IV
Central Files
NPDES Unit J
Aquatic Toxicology Unit

Permit NC0025909
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Rutherfordton
is hereby authorized to discharge wastewater from a facility located at the
Rutherfordton WWTP
1021 South Main Street
Rutherfordton
Rutherford County
to receiving waters designated as Cleghorn Creek in the Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III and IV hereof.
This permit shall become effective May 1, 2004.
This permit and authorization to discharge shall expire at midnight on July 31, 2008.
Signed this day April 14, 2004.
114
David A. Goodrich
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0025909
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge, are hereby
revoked. [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 NPDES govern discharges from this facility.
The Town of Rutherfordton is hereby authorized to:
1. Continue to operate an existing 3.0 MGD wastewater treatment facility
consisting of an influent automatic bar screen, an aeration lagoon, splitter
box, two clarifiers, a chlorine contact chamber, a temporary aeration basin
and sludge digester located at the Rutherfordton WWTP, off South Main
Street, Rutherfordton in Rutherford County.
2. Operate at 1.0 MGD until the average flow for any twelve (12) month period
exceeds 80% of the permitted flow (0.8 MGD), after which time the facility
must monitor in accordance with the effluent limitations and monitoring
requirements specified for 3.0 MGD.
3. Discharge from said treatment works at the location specified on the attached
map into Cleghorn Creek, currently classified C waters in the Broad River
Basin.

Rutherfordton WV fP
NC0025909
Rutherford County
Latitude: 35°20' 32"
Longitude: 81° 57' 22"
USGS Quad #: fl l sw
River Basin #: 03-08-02
Receiving Stream: Cleghorn Creek
Stream Class: C

Permit NC0025909
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (1.0 MGD)
During the period beginning on the effective date of this permit and lasting until the average flow for any twelve
(12) month period exceeds 80% of the permitted flow (0.8 MGD), the Permittee is authorized to discharge from
outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average.
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location1
Flow
1.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20°C 2
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent, Influent
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent, Influent
NH3 as N (April 1- October 31)
2.0 mg/L
6.0 mg/L
3/Week •
Composite
Effluent
NH3 as N (November 1-March 31)
4.7 mg/L
14.1 mg/L
3/Week
Composite
Effluent
Dissolved Oxygen&
3/Week
Grab
Effluent
Fecal Coliform
(geometric mean)
200 / 100 ml
400 / 100 ml
3/Week
Grab
Effluent
Total Residual Chlorine
28 µg/L
3/Week
Grab
Effluent
pH
Between 6.0 - 9.0 standard
units
3/Week
Grab
Effluent
Temperature (QC)
Daily
Grab
Effluent
Total Nitrogen (NO2 + NO3 + TKN)
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
Chronic Toxicity's
Quarterly
Composite
Effluent
Total Copper
40.0 µg/L
Weekly
Composite
Effluent
Cyanides
11.0 µg/L
22.0 µg/L
Weekly
Grab
Effluent
Total Zinc
339.0 pg/L
Weekly
Composite
Effluent
Total Silver
2/Month
Composite
Effluent
Dissolved 0xygen6
Footnote 6
Grab
Upstream,
Downstream
Fecal Coliform (geometric mean)6
Footnote 6
Grab
Upstream,
Downstream
Temperatures
Footnote 6
Grab
Upstream,
Downstream
Conductivity&
Footnote 6
Grab
Upstream,
Downstream
Priority Pollutant Analyses
Footnote 7
Footnote 7
Effluent
Notes:
1. Upstream - Upstream just above the outfall; Downstream - Downstream at least 300 feet below
the outfall.
2. The monthly average 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 5.0 mg/L.
4. Chronic Toxicity (Ceriodaphnia), P/F at 45%. Tests shall be conducted in January, April, July and
October. See Part A. (4.) for more details.
5. The quantitation limit for cyanide shall be 10 µg/L (10 ppb). Levels reported at less than 10 µg/L
shall be considered zero for compliance purposes.
6. Instream monitoring shall be conducted 3/week from June 1-September 30 and 1/week from
October 1-May 31.
7. Priority Pollutant Analyses, see Part A. (6.) for more details.
There shall be no discharge of floating solids or visible foam in other than trace
amounts.

Permit NC0025909.
1
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (3.0 MGD)
During the period beginning when the average flow for any twelve (12) month period exceeds 80% of the
permitted flow (0.8 MGD) and lasting until expiration, the Permittee is authorized to discharge up to 3.0 MGD
from outfall 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 Location'
Flow
3.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20°C 2
30.0 mg/L
45.0 mg/L
Daily
Composite
Effluent, Influent
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Daily
Composite
Effluent, Influent
NH3 as N (April 1- October 31)
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
NH3 as N (November 1-March 31)
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
Dissolved 0xygen3
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200 / 100 ml
400 / 100 ml
Daily
Grab
Effluent
Total Residual Chlorine
24 µg/L
Daily
Grab
Effluent
pH
Between 6.0 - 9.0 standard units
Daily
Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
Total Nitrogen (NO2 + NO3 + TKN)
Quarterly
Composite
Effluent
Total Phosphorus
Quarterly
Composite
Effluent
Chronic Toxicity4
Quarterly
Composite
Effluent
Total Cadmium
2.8 µg/L
15.0 pg/L
Weekly
Composite
Effluent
Total Copper
25 µg/L
Weekly
Composite
Effluent
Cyanides
7.0 pig/
22.0 fug/L
Weekly
Grab
Effluent
Total Zinc
216 pg/L
Weekly
Composite
Effluent
Total Silver
2/Month
Composite
Effluent
Dissolved 0xygens
Footnote 6
Grab
Upstream,
Downstream
Fecal Coliform (geometric mean)6
Footnote 6
Grab
Upstream,
Downstream
Temperatures
Footnote 6
Grab
Upstream,
Downstream
Conductivitys
Footnote 6
Grab
Upstream,
Downstream
Priority Pollutant Analyses
Footnote 7
Footnote 7
Effluent
Notes:
1. Upstream - Upstream just above outfall; Downstream - Downstream at least 300 feet below
outfall.
2. The monthly average 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 5.0 mg/L.
4. Chronic Toxicity (Ceriodaphnia), P/F at 71%. Test shall be conducted in January, April, July and
October. See Part A. (5.) for more details.
5. The quantitation limit for cyanide shall be 10 µg/L (10 ppb). Levels reported at less than 10 µg/L
shall be considered zero for compliance purposes.
6. Instream monitoring shall be conducted 3/week from June 1-September 30 and 1/week from
October 1-May 31.
7. Priority Pollutant Analyses, see Part A. (6.) for more details.
There shall be no discharge of floating solids or visible foam in other than trace
amounts.

Permit NC0025909
A. (3.) SPECIAL CONDITION — WASTEWATER MANAGEMENT PLAN
No later than 180 days after the issuance date of this permit, the Permittee shall submit to
the Division a wastewater management plan. The plan shall include, at a minimum, the
following elements:
• Future flows. Provide estimates of wastewater flows and characteristics for the
next 10-20 years and the basis for those estimates, including assumptions and
calculations.
• Facilities assessment. Describe deficiencies and operational difficulties in the
existing collection system or treatment facility which affect performance or
permit compliance, and identify potential improvements to correct those. At a
minimum, evaluate the following considerations:
• inflow and infiltration,
• headworks performance,
• aerator performance,
• diversion of wasteloads during peak flows,
• equipment repairs and preventative maintenance,
• removal of accumulated solids, wastes, other debris
• Optimization plan. Develop a strategy for optimization, rehabilitation,
expansion and/or replacement of the collection and/or treatment system to
achieve optimum performance. Identify specific measures and key tasks,
including those in the above facilities assessment, and provide an estimated
schedule for completion of each. In addition, identify potential sources of
funding for any improvements to be made.

Permit NC0025909.
A. (4.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly at 1.0 MGD)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 45%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July and October. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the Permittee will complete the information located at the top of the aquatic toxicity (AT)
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Branch at the address cited above.

Permit NC0025909
A. (5.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly at 3.0 MGD)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 71%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July and October. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ
Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the Permittee will complete the information located at the top of the aquatic toxicity (All
test form indicating the facility name, permit number, pipe number, county, and the month/year of
the report with the notation of "No Flow" in the comment area of the form. The report shall be
submitted to the Environmental Sciences Branch at the address cited above.

Permit NC0025909.
A. (6.) EFFLUENT POLLUTANT SCAN
The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached table (in
accordance with 40 CFR Part 136) and shall be sufficiently sensitive to determine whether parameters
are present in concentrations greater than applicable standards and criteria. Samples shall represent
seasonal variations. Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1 ,1 -dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury P-chloro-m•cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene
Benzene Base -neutral compounds: lsophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1•dichloroethane Benzo(k){luoranthene
1,2-dichloroethane Bis (2-chloroethoxy) methane
Test results shall be reported to the Division in DWQ Form- A MR-PPA1 or in a form approved
by the Director within 90 days of sampling. The report shall be submitted to the following
address: Division of Water Quality, Water Quality Section, Central Files, 1617 Mail Service
Center, Raleigh, North Carolina 27699-1617.

Town of Rutherfordton NC0025909
Subject: Town of Rutherfordton NC0025909
From: Roger Edwards <[e-mail]>
Date: Tue, 13 Apr 2004 09:22:35 -0400
To: [e-mail]
CC: Forrest Westall <[e-mail]>, Susan A Wilson
<[e-mail]>, Bob Sledge <[e-mail]>
Lisa,
The Town of Rutherfordton WWTP was up graded in 1999 due to the promise
of a textile industry to locate in the town limits and to discharge 1.0
MGD at start up. The industry projected to increase discharge to 1.5
MGD within months of the initial start up. The WWTP was expanded from a
lagoon system to an extended aeration system to accommodate the
projected flow from the industry. Long story short, the industry never
had a discharge that approached 1.0 MGD and went out of business. This
left the Town of Rutherfordton WWTP with a flow ranging form 0.500 to
0.800 MGD in a treatment facility designed for 3.0 MGD.
Due to NPDES permit violation the Town of Rutherfordton was placed on
moratorium in December 2000. Limits violations from June 1999 to
December 2003 total 37 with enforcement action taken for all
violations. As of April 8, 2004, the Asheville Regional Office received
an application for a Special Order by Consent from the Town of
Rutherfordton. This application will be processed as soon as possible.
If you have any questions regarding the Town of Rutherfordton please,
feel free to contact me.
Thank you,
R. Edwards
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Roger Edwards <[e-mail]>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
1 of 1 4/ 19/2004 9:47 AM

Rutherfordton File
• ♦
Subject: Rutherfordton File
From: [e-mail]
Date: Thu, 08 Apr 2004 10:36:32 -0400
To: [e-mail]
Hi Susan,
I know you'll never believe me, but we found the Rutherfordton file. I
had spoken with our compliance/enforcement person for NC regarding the
number of violations at the facility. She said she had been dealing
with the state (Central and Regional offices) regarding the violations.
I told her that I could not find the file, and this morning I got a
message from her that our pretreatment people had pulled the file to
look at it back in January. They did not go through our fileroom
checkout procedures and therefore it became MIA. But, we found it and
it is being reified.
Also, I sent you a no comment letter.
Thanks,
Madolyn Dominy
1 of 1 4/19/2004 9:33 AM

J1." sr,irFs
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i� 1, yW REGION 4
o ��� Q ATLANTA FEDERAL CENTER
,or 61 FORSYTH STREET
�rq< PRoi'� ATLANTA, GEORGIA 30303-8960
April 6, 2004
Ms. Susan A. Wilson
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
APR 1 3 2003
SUBJ: Rutherfordton WWTP
NPDES No. NC0025909
Dear Ms. Wilson:
In accordance with the EPA/NCDENR MOA, we have completed review of the permit
referenced above and have no objections to the draft permit conditions. We request that we be
afforded an additional review opportunity only if significant changes are made to the permit prior
to issuance, or if significant comments regarding the draft permit are received. Otherwise, please
send us one copy of the final permit when issued.
If you have any questions, please call me at [phone].
Sin erely,
Madyn S. Dominy, En
Permits, Grants and Technic
Water Management Division
ntal Engineer
ssistance Branch
Internet Address (URL) • http://www.epagov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

Rutherfordton
Subject: Rutherfordton
From: [e-mail]
Date: Tue, 06 Apr 2004 15:35:08 -0400
To: [e-mail]
Susan,
Marshall looked at the permit and the only comment was on the A. (2.)
effluent limitations page for 3.0 MGD, the footnotes have an "8" where
it should be a "7".
Then, we both have major concerns regarding the continual violations of
permit limits over several years. We are going to forward a message to
our compliance/enforcement group regarding this facility.
You can proceed with issuance of the permit. Would you like a formal no
comment letter from EPA? I'd be happy to send you one to complete the
file.
Thanks,
Madolyn
1 of l 4/6/2004 4:39 PM

DIVISION OF WATER QUALITY
April 2, 2004
MEMORANDUM
To: Dave Goodrich
Through: Matt Matthews ff
From: Kevin Bowden i..6)
Subject: Toxicity Identification Evaluation - January 2004
DWQ's Copper and Zinc Action Level Policy
Town of Rutherfordton WWTP
NPDES No. NC0025909
Rutherford County
Our office received Toxicity Identification Evaluation (TIE) information from the Town
concerning their efforts to rule out copper and zinc as causative effluent toxicants. The information
package was transmitted by cover letter dated 2/6/04 from Ms. Karen Andrews to this office.
The report notes that a toxicity test was conducted using effluent from a sample collected on
10/20/03. A test was initiated on 11/11/03. Effluent sample copper and zinc concentrations measured
6.0 ug/L and 52.0 ug/L, respectively. Five (5) separate treatments were conducted using 100% effluent.
Mean control organism reproduction measured 24.0 neonates. Mean control organism reproduction in
100% effluent (baseline) measured 15.9 neonates. Percent reductions in neonate reproduction for
corresponding treatments are noted below.
Treatment (test initiated 11/11/03) Mean Reproduction
Control 24.0
Treatment 1 (100% effluent, baseline) 15.9
Treatment 2 (0.5 mg/L EDTA) 18.4
Treatment 3 (3.0 mg/L EDTA) 12.6
Treatment 4 (0.5 mg/L sodium thiosulfate) 19.1
Treatment 5 (3.0 mg/L sodium thiosulfate) 16.7
Percent Reduction Percent Reduction
(compared to control) (compared to baseline)
33.75
23.33
47.5
20.42
23.74
-15.72
20.75
-20.03
-5.03
The report states, "All treated and untreated samples showed significant reduction in
reproduction as compared to the control. Both EDTA and sodium thiosulfate failed to reduce effluent
toxicity significantly." We point out that the baseline for EDTA and sodium thiosulfate manipulations
is 100% effluent. The far right column above titled "Percent Reduction (compared to baseline) has been
added for clarification. We note reductions in effluent toxicity upon 0.5 mg/L EDTA and 0.5 mg/L
sodium thiosulfate additions. Based on these manipulations, we believe the City has not conclusively
ruled out copper and zinc as causative effluent toxicants in this round of TIE testing.
Another round of '1'1 , testing was conducted with the same effluent sample collected on
10/20/03. Toxicity testing was initiated on 12/3/03. Effluent sample copper and zinc concentrations
measured 6.0 ug/L and 52.0 ug/L, respectively. In this round of testing, treatments two through six were
"spiked" with 15 ug/L copper and 55 ug/L zinc. Mean control organism reproduction measured 27.78
neonates. Mean control organism reproduction in 100% effluent (baseline) measured 17.6 neonates.

Page 2
Town of Rutherfordton
April 2, 2004
- 6 2003
The report states, "The spiked effluent showed significant reduction in reproduction (38.13%).
The addition of EDTA and sodium thiosulfate demonstrated a decrease in toxicity in spike samples
(Treatments #3 - #6), but it failed to remove or reduce effluent toxicity significantly. It is likely that the
cause of effluent toxicity is something other than metals." Again, we point out that the baseline for
EDTA and sodium thiosulfate manipulations is 100% effluent. We note reductions in effluent toxicity
upon EDTA and sodium thiosulfate additions, with the exception of 3.0 mg/L EDTA. Based on these
manipulations, we believe the City has not conclusively ruled out copper and zinc as causative effluent
toxicants in this round of TIE testing.
Our office supports innovative approaches to TIE work; however, after reviewing the TIE data,
we are not sure what is gained by spiking a toxic effluent with copper and zinc with subsequent
treatment manipulation.
In summary, the information in the current submittal does not rule out copper and zinc as
causative effluent toxicants. Baseline test results suggest that effluent toxicity is persistent. TIE test
results from 11/11/03 and 12/3/03 testing (compared to baseline) suggest that addition of EDTA and
sodium thiosulfate reduced effluent toxicity. Our office stands by previous recommendations to reissue
the NPDES Permit to include copper and zinc permit limits.
Please feel free to contact either Matt or me if 733-2136 if you have questions.
cc: Coleen Sullins -Deputy Director, DWQ
Forrest Westall-Asheville Regional Office
Keith Haynes -Asheville Regional Office
Susan Wilson-NPDES Unit
Pretreatment Unit-DWQ
Karen Andrews, Town of Rutherfordton, 129 N. Main Street, Rutherfordton, NC 28139
Frank Pasztor, Meritech, Inc. 642 Tamco Road, PO Box 27, Reidsville, NC 27320
Madolyn Dominy, US EPA Region W, Water Mgt. Div., 61 Forsyth St., SW, Atlanta,
Georgia 30303
Aquatic Toxicology Unit Files
Central Files

0
GO
BDL= I/2DL
Actual Data
V
3/200 1
qffrk-
T'giS LVkL-u.Ai one WA-5 UPOAic
hll'(+I btosT R 4T DATA Ti(/fok5 f(
PATA i biL Cu- D& Lod c.�vt2
uoviNerz_ 7& MAK • VAi-' — occ.0 2r2
W t -04,/•J T-(G PAST Z 02> /k+,'a r s T
ie
P41JIrtc/ PPi'Lc.G C&11c$4 Ir --((s w45 i2DPP 9
Nor 1i51I6.5t ti/ . ug r5 57-ir.'-. t+rg'i
6+Qok41-1 T b t1!c-EG0 fa fkc-otAlf14(z) .
`f�I& D of E2 (ow 5 No (t -c_
DQwW w4 ) )2- t7 " 141-JD 734-0- 5416A
(•Coc.DS j e ue b 2 42- /}s ki-S Fog C-c .
r4 V* t& , 5TrLL t cc.E D Ac4-0vine (..&"
Ler6-1*.
00000000 G'00,r.0c).c'00. cc: 000 Qcq c'
M r C; r iri — �l [� VJ - 'V- o N N M r - '7 �S V V) e` C I
Town of Rutherfordton
NC0025909
CO
r M r 6 es.:ri ("1�i r a cn o c�i �i 1` r c•l 4.� .6 6 v = NI nl
N M 7 tr., so 1, 00 C O — N N-1 7 tr. .7 N. CO C o — (`I r'1 7 V ; V' - CO 0 o —
N N N N N N C I N N N r+'; c•1
FINAL RESULTS
Allowable Cw
In 1--- `O r" 7
DO
cN —. c
.1- (--1
V' —
II C.)• O 7
C J y
^J ^ C.!• %
j • CI 7 X
': U
v7 % h
▪ U l
Max. Pred Cw
Allowable Cw

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
Town of Rutherfordton
NC0025909
1
1.86
Parameter =
Standard =
Copper
18.0
n < Actual Data BDL=1/2DL
32 2. 2.0
33 17. 17.0
34 5. 5.0
35 6. 6.0
36 7. 7.0
37 7. 7.0
38 19. 19.0
39 8. 8.0
40 5. 5.0
41 28. 28.0
42 11. 11.0
43 13. 13.0
44 13. 13.0
45 16. 16.0
46 23. 23.0
47 17. 17.0
48 9. 9.0
49 14. 14.0
50 12. 12.0
51 18. 18.0
52 5. 5.0
53 10. 10.0
54 11. 11.0
55 < 2 1.0
56 17. 17.0
57 17. 17.0
58 40. 40.0
59 70. 70.0
60 126. 126.0
61 13. 13.0
62 3.3 3.3
AO

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
Town of Rutherfordton
NC0025909
1
1.86
Parameter =
Standard =
Copper
18.0
n < Actual Data BDL=1/2DL
63 8. 8.0
64 14. 14.0
65 < 10 5.0
66 8. 8.0
67 18. 18.0
68 7. 7.0
69 12. 12.0
0$ 70 10. 10.0
Jul-i 71 3 3.0
72 10 10.0
73 4 4.0
74 < 2 1.0
75 < 2. 1.0
76 6. 6.0
77 16. 16.0
78 < 2. 1.0
79 13. 13.0
80 14. 14.0
81 3. 3.0
03 82 < 2. 1.0
Dea,4 83 < 2. 1.0
µgll

Facility Name =
NPDES # =
Qw(MGD)=
7Q10s (cjs)=
IWC (%) _
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Zinc
Max. Pred Cw
Allowable Cw
Allowable #/day
524.0
338.8
0.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
55.8397
76.8
0.7268
83
1.68
311.0 tig/1
524.0 µg/1
338.8 µg/1
Parameter =
Standard =
Zinc
154.0
n < Actual Data 13DL=1/2DL
1
2 70. 70.0
3 SO. 80.0
4 50. 50.0
5 60. 60.0
6 30. 30.0
7 50. 50.0
S 70. 70.0
9 < 50 25.0
10 30. 30.0
1 1 60. 60.0
12 70. 70.0
13 < 50 25.0
14 < 50 25.0
15 100. 100.0
16 < 50 25.0
17 90. 90.0
18 110. 110.0
19 90. 90.0
20 100. 100.0
21 50. 50.0
22 110. 110.0
23 90. 90.0
24 S0. 80.0
25 < 50 25.0
26 70. 70.0
27 70. 70.0
28 90. 90.0
29 60. 60.0
30 70. 70.0
31 110. 110.0
90. 90.0
µg/1
1

Facility Name =
NPDES # =
Qw (MGD) =
7Q1Os (cfs)=
Town of Rutherfordton
NC0025909
1
1.86
Parameter =
Standard =
Zinc
154.0
n < Actual Data BDL=1/2DL
32 70. 70.0
33 66. 66.0
34 208. 208.0
35 70. 70.0
36 50. 50.0
37 100. 100.0
38 100. 100.0
39 60. 60.0
40 60. 60.0
41 50. 50.0
42 120. 120.0
43 < 50 25.0
44 209. 209.0
45 115. 115.0
46 77. 77.0
47 < 50 25.0
48 < 50 25.0
49 < 50 25.0
50 < 50 25.0
51 < 50 25.0
52 < 50 25.0
53 82. 82.0
54 63. 63.0
55 193. 193.0
56 82. 82.0
57 65. 65.0
58 311. 311.0
59 146. 146.0
60 298. 298.0
61 65. 65.0
62 40. 40.0
µg/1

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
Town of Rutherfordton
NC0025909
1
1.86
Parameter =
Standard =
Zinc
154.0
n < Actual Data BDL=1/2DL
63 < 50 25.0
64 < 50 25.0
65 24. 24.0
66 122. 122.0
67 98. 98.0
68 160. 160.0
p 3 69 170. 170.0
Jun pc 70 78. 78.0
71 < 50. 25.0
72 80. 80.0
73 70. 70.0
74 < 50. 25.0
75 50. 50.0
76 60. 60.0
77 < 50. 25.0
78 60. 60.0
79 140. 140.0
80 < 50. 25.0
81 < 50. 25.0
0, 82 80. 80.0
Dec 83 60. 60.0
µgll

ti
Town of Rutherfordton - 01042 - Coppe
NC0025909
Month Day Year Comment Parameter UoM Value Modifie
5 19 2003 01042 - Coppe ug/l 18.
5 27 2003 01042 - Coppe ug/I 7.
6 4 2003 01042 - Coppe ug/I 12.
6 16 2003 01042 - Coppe ug/I 10.
7 1 2003 01042 - Coppe ug/I 3.
7 4 2003 01042 - Coppe ug/I HOLID
7 22 2003 01042 - Coppe ug/I 10.
8 4 2003 <2.0 01042 - Coppe ug/I 4.
8 18 2003 <2.0 01042 - Coppe ug/I LESST
9 1 2003 <2.0 01042 - Coppe ug/I HOLID
9 2 2003 <2.0 01042 - Coppe ug/I LESST
9 15 2003 <2.0 01042 - Coppe ug/I 6.
9 29 2003 <2.0 01042 - Coppe ug/I 16.
10 6 2003 <2 01042 - Coppe ug/l
10 13 2003 <2 01042 - Coppe ug/I
10 20 2003 <2 01042 - Coppe ug/I
11 3 2003 01042 - Coppe ug/l 14-
11 17 2003 01042 - Coppe ug/I 3.,
11 27 2003 01042 - Coppe ug/I HOLID
11 28 2003 01042 - Coppe ug/I HOLID
12 1 2003 <2.0 01042 - Coppe ug/I LESST
12 15 2003 <2.0 01042 - Coppe ug/I LESST
12 25 2003 <2.0 01042 - Coppe ug/I HOLID
14.
LESST
HOLID
2

Town of Rutherfordton - 01042 -Coppe
NC0025909
Month Day Year
1 1 2002
1 7 2002
1 11 2002
2 4 2002
2 25 2002
3 4 2002
3 25 2002
4 1 2002
4 8 2002
4 15 2002
4 29 2002
5 6 2002
5 20 2002
5 27 2002
6 3 2002
6 17 2002
7 1 2002
7 15 2002
8 5 2002
8 14 2002
9 3 2002
9 5 2002
9 30 2002
10 8 2002
10 22 2002
11 4 2002
11 13 2002
11 28 2002
11 29 2002
12 4 2002
12 16 2002
12 25 2002
1 1 2003
1 8 2003
1 20 2003
1 27 2003
2 3 2003
2 17 2003
2 18 2003
3 3 2003
3 17 2003
3 24 2003
4 2 2003
4 8 2003
4 14 2003
4 18 2003
4 21 2003
5 5 2003
Comment Parameter UoM
ug/I
01042 -Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/1
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/1
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/l
01042 - Coppe ug/l
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/l
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/l
01042 - Copps ug/I
01042 - Coppe ug/I
01042 - Coppe ug/I
01042 - Coppe ug/1
<10 01042 - Coppe ug/l
<10 01042 - Coppe ug/I
<10 01042 - Coppe ug/I
<10 01042 - Coppe ug/l
<10 01042 - Coppe ug/I
01042 - Coppe ug/1
Value Modifie
HOLD
11.
17.
7.
24.
2.
17.
5.
6.
7.
7.
19.
8.
HOLID
5.
28.
11.
13.
13.
16.
23.
17.
9.
14.
12.
18.
5.
HOLID
HOLID
10.
11.
HOLID
HOLID
LESST
HOLID
17.
17.
HOLID
40.
70. 'f� T��S
126. N ea (TA eN T �
13. Ukt-Gle Vaol 1-1I5k QJ
3.3
8.
14.
HOLID
LESST
8.
1

Town of Rutherfordton -
NC0025909
Month
1
1
1
2
2
3
3
4
4
4
4
5
5
5
6
6
7
7
8
8
9
9
9
10
10
11
11
11
11
12
12
12
1
1
1
1
2
2
2
3
3
3
4
4
4
4
4
01092 - Zinc,
Day Year Comment
1 2002
7 2002
11 2002
4 2002
25 2002
7 2002
25 2002
1 2002
a 2002
15 2002
29 2002
6 2002
20 2002
27 2002
3 2002
17 2002
1 2002 <50.0
15 2002 <50.0
5 2002
14 2002
3 2002 <50
5 2002 <50
30 2002 <S0
8 2002 <50.0
22 2002 <50.0
4 2002 <50.0
13 2002 <50.0
28 2002 <50.0
29 2002 <50.0
4 2002
16 2002
25 2002
1 2003
8 2003
20 2003
27 2003
3 2003
17 2003
18 2003
3 2003
17 2003
24 2003
2 2003 <50
8 2003 <50
14 2003 <50
18 2003 <50
21 2003 <50
UoM
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/l
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
ug/I
Value Modifie
90.
60.
70.
110.
70.
66.
208.
70.
50.
100.
100.
60.
HOLID
HOLID
60.
50.
120.
LESST
209.
115.
77.
LESST
LESST
LESST
LESST
LESST
LESST
HOLID
HOLID
82.
63.
HOLID
HOLID
193.
HOLID
82.
65.
HOLID
311.
146.
298.
65.
40.
LESST
LESST
HOLID
24.
7 Sri.'- vticiat..D U-Srr
Maid VA-c-LAG oJ4Z_
r
�-
1

n
Town of Rutherfordton - 01092 - Zinc,
NC0025909
a►
Month Day Year Comment UoM Value Modifre
5 5 2003 ug/I 122.
5 19 2003 ug/I 98.
5 27 2003 ug/I 160.
6 4 2003 ug/I 170.
6 16 2003 ug/I 78
7 1 2003 <50.0 ug/I LESST
7 4 2003 <50.0 ug/I HOLID
7 22 2003 <50.0 ugll 80.
8 4 2003 <50 ug/I 70.
8 18 2003 <50 ug/I LESST
9 1 2003 <50 ug/I HOLID
9 2 2003 <50 ug/I 50.
9 15 2003 <50 ug/I 60.
9 29 2003 <50 ug/I LESST
10 6 2003 ug/I 60.
10 13 2003 ug/I HOLID
10 20 2003 ug/I 140.
11 3 2003 <50 ug/I LESST
11 17 2003 <50 ug/I LESST
11 27 2003 <50 ug/I HOLID
11 28 2003 <50 ug/I HOLID
12 1 2003 ug/I 80.
12 15 2003 ug/I 60.
12 25 2003 ug/I HOLID
2

Town of Rutherfordton - 50050 - Flow, i
NC00259O9
Month Day Year
1 1 2003
1 2 2003
1 3 2003
1 4 2003
1 5 2003
1 6 2003
1 7 2003
1 8 2003
1 9 2003
1 10 2003
1 11 2003
1 12 2003
1 13 2003
1 14 2003
1 15 2003
1 16 2003
1 17 2003
1 18 2003
1 19 2003
1 20 2003
1 21 2003
1 22 2003
1 23 2003
1 24 2003
1 25 2003
1 26 2003
1 27 2003
1 28 2003
1 29 2003
1 30 2003
1 31 2003
2 1 2003
2 2 2003
2 3 2003
2 4 2003
2 5 2003
2 6 2003
2 7 2003
2 8 2003
2 9 2003
2 10 2003
2 11 2003
2 12 2003
2 13 2003
2 14 2003
2 15 2003
2 16 2003
2 17 2003
Comment UoM
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
mgd
Value Modifie
.375
.587
.461
.559
.427
.422
.454
.466
.477
.467
.445
.399
.359
.416
.442
.421
.476
.409
.39
.408
.463
.455
.491
.42
.448
.415
.394
.438
.473
.562
.54
.46
.448
.417
.502
.506
.409
.517
.565
.431
.398
.473
.495
.444
.438
.604
.505
.793
1

r
Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day Year Comment UoM Value Modife
2 18 2003 mgd .596
2 19 2003 mgd .579
2 20 2003 mgd .53
2 21 2003 •mgd .508
2 22 2003 mgd .638
2 23 2003 mgd 2.367
2 24 2003 mgd .828
2 25 2003 mgd .581
2 26 2003 mgd .514
2 27 2003 mgd .609
2 28 2003 mgd .705
3 1 2003 mgd .529
3 2 2003 mgd .521
3 3 2003 mgd .486
3 4 2003 mgd .425
3 5 2003 mgd .516
3 6 2003 mgd .698
3 7 2003 mgd 1.013
3 8 2003 mgd .528
3 9 2003 mgd .501
3 10 2003 mgd .419
3 11 2003 mgd .457
3 12 2003 mgd .456
3 13 2003 mgd .485
3 14 2003 mgd .5
3 15 2003 mgd .541
3 16 2003 mgd .673
3 17 2003 mgd .662
3 18 2003 mgd .703
3 19 2003 mgd 1.137
3 20 2003 mgd 2.061
3 21 2003 mgd 3.128
3 22 2003 mgd 1.396
3 23 2003 mgd .776
3 24 2003 mgd .571
3 25 2003 mgd .513
3 26 2003 mgd .534
3 27 2003 mgd .724
3 28 2003 mgd .433
3 29 2003 mgd .449
3 30 2003 mgd .514
3 31 2003 mgd .696
4 1 2003 mgd .503
4 2 2003 mgd .609
4 3 2003 mgd .48
4 4 2003 mgd .479
4 5 2003 mgd .499
4 6 2003 mgd .537
2

Town of Rutherfordton -
NC0025909
50050 - Flow, i
Month Day Year Comment UoM Value Modifie
4 7 2003 mgd .799
4 8 2003 mgd 1.48
4 9 2003 mgd 1.063
4 10 2003 mgd 1.133
4 11 2003 mgd 3.082
4 12 2003 mgd 1.537
4 13 2003 mgd .892
4 14 2003 mgd .584
4 15 2003 mgd .546
4 16 2003 mgd .524
4 17 2003 mgd .522
4 18 2003 mgd .982
4 19 2003 mgd 1.807
4 20 2003 mgd .744
4 21 2003 mgd .713
4 22 2003 mgd .601
4 23 2003 mgd .531
4 24 2003 mgd .483
4 25 2003 mgd .523
4 26 2003 mgd .586
4 27 2003 mgd .584
4 28 2003 mgd .485
4 29 2003 mgd .497
4 30 2003 mgd .607
5 1 2003 mgd .556
5 2 2003 mgd .499
5 3 2003 mgd .595
5 4 2003 mgd .558
5 5 2003 mgd .517
5 6 2003 mgd 1.219
5 7 2003 mgd 2.221
5 8 2003 mgd 2.029
5 9 2003 mgd 1.019
5 10 2003 mgd .715
5 11 2003 mgd .627
5 12 2003 mgd .611
5 13 2003 mgd .488
5 14 2003 mgd .503
5 15 2003 mgd .52
5 16 2003 mgd .607
5 17 2003 mgd .S83
5 18 2003 mgd .503
5 19 2003 mgd 519
5 20 2003 mgd .529
5 21 2003 mgd 528
5 22 2003 mgd 673
5 23 2003 mgd 2.718
5 24 2003 mgd 1 739
3

Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day Year Comment UoM Value Modifie
5 25 2003 mgd 1.755
5 26 2003 mgd .965
5 27 2003 mgd .743
5 28 2003 mgd .609
5 29 2003 mgd .549
5 30 2003 mgd .51
5 31 2003 mgd .529
6 1 2003 mgd .484
6 2 2003 mgd .421
6 3 2003 mgd .47
6 4 2003 mgd .946
6 5 2003 mgd .854
6 6 2003 mgd .566
6 7 2003 mgd .841
6 8 2003 mgd 1.396
6 9 2003 mgd 1.285
6 10 2003 mgd 1.013
6 11 2003 mgd .651
6 12 2003 mgd .565
6 13 2003 mgd .559
6 14 2003 mgd .537
6 15 2003 mgd .491
6 16 2003 mgd .44
6 17 2003 mgd .747
6 18 2003 mgd .648
6 19 2003 mgd .978
6 20 2003 mgd .85
6 21 2003 mgd .571
6 22 2003 mgd .472
6 23 2003 mgd .494
6 24 2003 mgd .476
6 25 2003 mgd .469
6 26 2003 mgd .489
6 27 2003 mgd .501
6 28 2003 mgd .495
6 29 2003 mgd .474
6 30 2003 mgd .472
7 1 2003 mgd .507
7 2 2003 mgd 1.134
7 3 2003 mgd 1.163
7 4 2003 mgd .606
7 5 2003 mgd .506
7 6 2003 mgd .365
7 7 2003 mgd .539
7 8 2003 mgd .549
7 9 2003 mgd .527
7 10 2003 mgd .519
7 11 2003 mgd .521
4

Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day Year Comment UoM Value Modifie
7 12 2003 mgd .6
7 13 2003 mgd .503
7 14 2003 mgd .477
7 15 2003 mgd .525
7 16 2003 mgd .509
7 17 2003 mgd .546
7 18 2003 mgd .508
7 19 2003 mgd .503
7 20 2003 mgd .467
7 21 2003 mgd .461
7 22 2003 mgd .485
7 23 2003 mgd .489
7 24 2003 mgd .577
7 25 2003 mgd .468
7 26 2003 mgd .454
7 27 2003 mgd .424
7 28 2003 mgd .468
7 29 2003 mgd .487
7 30 2003 mgd .593
7 31 2003 mgd 1.084
8 1 2003 mgd 1.44
8 2 2003 mgd .859
8 3 2003 mgd .627
8 4 2003 mgd .921
8 5 2003 mgd 1.361
8 6 2003 mgd 1.027
8 7 2003 mgd .878
8 8 2003 mgd 1.17
8 9 2003 mgd .697
8 10 2003 mgd .556
8 11 2003 mgd 1.269
8 12 2003 mgd .911
8 13 2003 mgd .755
8 14 2003 mgd .65
8 15 2003 mgd .655
8 16 2003 mgd .629
8 17 2003 mgd .547
8 18 2003 mgd .563
8 19 2003 mgd .566
8 20 2003 mgd .S63
8 21 2003 mgd .557
8 22 2003 mgd .532
8 23 2003 mgd .512
8 24 2003 mgd .486
8 25 2003 mgd .471
8 26 2003 mgd .505
8 27 2003 mgd .511
8 28 2003 mgd .514
5

Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day ' Year Comment UoM Value Modifie
8 29 2003 mgd .527
8 30 2003 mgd .498
8 31 2003 mgd .48
9 1 2003 mgd .452
9 2 2003 mgd .524
9 3 2003 mgd .533
9 4 2003 mgd .574
9 5 2003 mgd .547
9 6 2003 mgd .505
9 7 2003 mgd .435
9 8 2003 mgd .451
9 9 2003 mgd .184
9 10 2003 mgd .542
9 11 2003 mgd .482
9 12 2003 mgd .459
9 13 2003 mgd .48
9 14 2003 mgd .482
9 15 2003 mgd .451
9 16 2003 mgd .551
9 17 2003 mgd .497
9 18 2003 mgd .477
9 19 2003 mgd .49
9 20 2003 mgd .464
9 21 2003 mgd .422
9 22 2003 mgd .413
9 23 2003 mgd .678
9 24 2003 mgd .642
9 25 2003 mgd .47
9 26 2003 mgd .484
9 27 2003 mgd .483
9 28 2003 mgd .682
9 29 2003 mgd .403
9 30 2003 mgd .424
10 1 2003 mgd .453
10 2 2003 mgd .465
10 3 2003 mgd .423
10 4 2003 mgd .492
10 5 2003 mgd .394
10 6 2003 mgd .457
10 7 2003 mgd .496
10 8 2003 mgd .5
10 9 2003 mgd .573
10 10 2003 mgd .594
10 11 2003 mgd .539
10 12 2003 mgd .533
10 13 2003 mgd .465
10 14 2003 mgd .508
10 15 2003 mgd .535
6

Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day Year Comment UoM Value Modifie
10 16 2003 mgd .461
10 17 2003 mgd .451
10 18 2003 mgd .455
10 19 2003 mgd .427
10 20 2003 mgd .41
10 21 2003 mgd .47
10 22 2003 mgd .489
10 23 2003 mgd .44
10 24 2003 mgd .459
10 25 2003 mgd .435
10 26 2003 mgd .613
10 27 2003 mgd .38
10 28 2003 mgd .515
10 29 2003 mgd .485
10 30 2003 mgd .453
10 31 2003 mgd .456
11 1 2003 mgd .453
11 2 2003 mgd .421
11 3 2003 mgd .414
11 4 2003 mgd .469
11 5 2003 mgd .511
11 6 2003 mgd .566
11 7 2003 mgd .586
11 8 2003 mgd .509
11 9 2003 mgd .45
11 10 2003 mgd .384
11 11 2003 mgd .414
11 12 2003 mgd .45
11 13 2003 mgd .49
11 14 2003 mgd .39
11 15 2003 mgd .44
11 16 2003 mgd .42
11 17 2003 mgd .42
11 18 2003 mgd .49
11 19 2003 mgd .77
11 20 2003 mgd .94
11 21 2003 mgd .48
11 22 2003 mgd .42
11 23 2003 mgd .38
11 24 2003 mgd .41
11 25 2003 mgd .46
11 26 2003 mgd .4
11 27 2003 mgd .43
11 28 2003 mgd .42
11 29 2003 mgd .47
11 30 2003 mgd .36
12 1 2003 mgd .377
12 2 2003 mgd .41
7

Town of Rutherfordton - 50050 - Flow, i
NC0025909
Month Day Year Comment UoM Value Modifie
12 3 2003 mgd .405
12 4 2003 mgd .43
12 5 2003 mgd .676
12 6 2003 mgd .486
12 7 2003 mgd .404
12 8 2003 mgd .369
12 9 2003 mgd .421
12 10 2003 mgd .453
12 11 2003 mgd 1.021
12 12 2003 mgd .517
12 13 2003 mgd .438
12 14 2003 mgd .768
12 15 2003 mgd .845
12 16 • 2003 mgd .518
12 17 2003 mgd .53
12 18 2003 mgd .548
12 19 2003 mgd .465
12 20 2003 mgd .45
12 21 2003 mgd .397
12 22 2003 mgd .397
12 23 2003 mgd .468
12 24 2003 mgd .453
12 25 2003 mgd .416
12 26 2003 mgd .388
12 27 2003 mgd .403
12 28 2003 mgd .395
12 29 2003 mgd .393
12 30 2003 mgd .45
12 31 2003 mgd .414
8

Facility Name =
Qw (MGD) =
WWTP Classification
NPDES # =
Receiving Stream
IWC (%) =
Final Results:
Town of Rutherfordton
1
3
NC0025909
Cleghorn Creek
45.45
Reasonable Potential Summary
Stream Classification
7Q10s (cfs)=
30Q2 (cfs)
Qavg (cfs)
1°
2° 3° 4°
C
1.86
4.02
12
Arsenic
Max. Pred Cw
Allowable Cw
2.5 µg/l
110.0 µg/I
' Implementation
!Are all reported values less than?
I is the detection limit acceptable?
Yes
Yes
Limit?
Monitor?
No
No
(Monitoring
'Frequency None
Cadmium
Max. Pred Cw
Allowable Cw
3. 1 µg/1
4.4 µg/I
jlmPlementation
*Are all reported values less than?
!ls the detection limit acceptable?
No
Yes
Limit?
Monitor?
No
No
i
u Monitoring
!Frequency None
1
1/2 FAV (non Trout)
15.0 µg/I
I
Chloride :::::::: .:::::::::: .
Max. Pred Cw
Allowable Cw
53.8 mg/L
506.0 mg/L
jlmplementation
'Are all reported values less than?
!iS the detection limit acceptable?
No
Yes
Limit?
Monitor?
No
No
'Monitoring
!Frequency None
Chromium
Max. Pred Cw
Allowable Cw
5.2 µg/l
110.0 µg/I
I Implementation
!Are all reported values less than?
Is the detection limit acceptable?
No
Yes
Limit?
Monitor?
No
No
I
;Monitoring
:Frequency None
,
1/2 FAV
1022 µg/1,
i
,
Copper: .....::'::.:::.::. ::.:.:::
Max. Pred Cw
Allowable Cw
275.1 µg/1
39.6 µg/1
!Implementation
'Are all reported values less than?
jls the detection limit acceptable?
No
Yes
A•L . Arts e'f
Limit?
Monitor?
yes
D16
Yes
I
'Monitoring
' Frequency nth1/2FAV
I Lai ef�—tLl—y
04 ///173k/
LAM IT 5ks e > ON
Cyanide
Max. Pred Cw
Allowable Cw
( fit y wru.le5 13e1,ow p,. c.r — oiJc !Implementation
14t4'4 V A L`.( e) 15.1 µg/l 'Are all reported values less than?
11.0 g/1 'Is the detection limit acceptable?
No
Yes
Limit?
Monitor?
Yes
Yes
I
'Monitoring
'Frequency Weekly
1
1/2 FAV
22.01 Ag/1 . LQ6,1i r +
Lead
Max. Pred Cw
Allowable Cw
I Implementation
19.5 µg/1 'Are all reported values less than?
55.0 µg/1 jls the detection limit acceptable?
No
Yes
Limit?
Monitor?
No
No
I
I Monitoring
j Frequency None
'
1/2 Fav
33.8 µg/1
1
Mercury
Max. Pred Cw
Allowable Cw
At L f Ai- t . 0. Z 14.1(k
( ,d #}.,--E- 76 P 2TMT)
0.1000 µg/1
0.0264 µg/1
I Implementation
!Are all reported values less than?
l is the detection limit acceptable?
Yes
Yes
Limit?
Monitor?
No
No
I
I Monitoring
!Frequency None
Nickel
Max. Pred Cw
Allowable Cw
56.9 µg/l
193.6 µg/I
jlmPlementation
'Are all reported values less than?
!Is the detection limit acceptable?
I
No
Yes
Limit?
Monitor?
No
No
i
'Monitoring
!Frequency None
I
1/2 FAV
261.0 µg/1
Silver ::::::::::::::::::::::...•::::::
;Implementation
1

Max. Pred Cw
Allowable Cw
1/2 FAV
11.4 µg/1 'Are all reported values less than?
0.1 µg/1 !Is the detection limit acceptable?
µg/1 I
1.2
No Limit? No
Yes Monitor? Yes
'Monitoring
Frequency 2/Month
Selenium
Max. Pred Cw
Allowable Cw
iImplementation
2.5 µg/1 'Are all reported values less than?
11.0 µg/1 ;Is the detection limit acceptable?
Yes
Yes
Limit? No 'Monitoring
Monitor? No !Frequency None
1/2 FAV
56.0lµg/l I
Zinc:
Max. Pred Cw
Allowable Cw
1/2 FAV
I Implementation
524.0 µg/1 i Are all reported values less than? No
338.8 )1/1 i Is the detection limit acceptable? Yes
If// VY 4/1/ ! Li/4 + T hk,c/) ON PO L 1 G4
Yes.
Limit? `D4
Monitor? Yes
'Monitoring
Frequency nth
tv�=c tu,y
,

Facility Name =
NPDES # =
Qw (MGD) =
7Q1U.r (cfs)=
IWC)_
Town of Rutherfordton
NC0025909
1.86
45.45
FINAL RESULTS
Copper
Max. Pred Cw
Allowable Cw
275. 1
;9.(i
(46)
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mull Factor =
Max. Value
Max. Pred Cw
Allowable Cw
17.5177
14.0
1.2522
70
2.18
126.0 µg/l
275.1 µg/I
39.6 µg/I
Parameter ---
Standard =
Coppc r
18.0
n < Actual Data BDL=1/2DL
1 11. 11.0
2 15. 15.0
3 31. 31.0
4 7. 7.0
5 9. 9.0
6 7. 7.0
7 5. 5.0
8 < 2 1.0
9 12. 12.0
10 7. 7.0
11 8. 8.0
12 < 3 1.5
13 6. 6.0
14 11. 11.0
15 20. 20.0
16 2. 2.0
17 12. 12.0
18 < 7 3.5
19 7. 7.0
20 < 2 1.0
21 4. 4.0
22 16. 16.0
23 6. 6.0
24 11. 11.0
25 6. 6.0
26 50. 50.0
27 5. 5.0
28 11. 11.0
29 17. 17.0
30 7. 7.0
31 24. 24.0

32 2. 2.0
33 17. 17.0
34 5. . 5.0
35 6. 6.0
36 7. 7.0
37 7. 7.0
38 19. 19.0
39 8. 8.0
40 5. 5.0
41 28. 28.0
42 11. 11.0
43 13. 13.0
44 13. 13.0
45 16. 16.0
46 23. 23.0
47 17. 17.0
48 9. 9.0
49 14. 14.0
50 12. 12.0
51 18. 18.0
52 5. 5.0
53 10. 10.0
54 11. 11.0
55 < 2 1.0
56 17. 17.0
57 17. 17.0
58 40. 40.0
59 70. 70.0
60 126. 126.0
61 13. 13.0
62 3.3 3.3
63 8. 8.0
64 14. 14.0
65 < 10 5.0
66 8. 8.0

t�.: rf
67 18. 18.0
'6$. : 7. 7.0.
69 12. 12.0
70 10. 10.0

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
IWC(S6 =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Zinc
Max. Pred Cw
Allowable Cw
Allowable #/day
524.0
338.8
0.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
M+dt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
58.4276
80.7
0.7236
1.68
311.0 µg/I
524.0 µg/1
338.8 µg/l
Parameter =
Standard =
Zinc
154.0
n < Actual Data BDL=1/2DL
1 90. 90.0
2 70. 70.0
3 80. 80.0
4 50. 50.0
5 60. 60.0
6 30. 30.0
7 50. 50.0
8 70. 70.0
9 < 50 25.0
10 30. 30.0
11 60. 60.0
12 70. 70.0
13 < 50 25.0
14 < 50 25.0
15 100. 100.0
16 < 50 25.0
17 90. 90.0
18 110. 110.0
19 90. 90.0
20 100. 100.0
71 50. 50.0
22 110. 110.0
23 90. 90.0
24 80. 80.0
25 < 50 25.0
26 70. 70.0
27 70. 70.0
28 90. 90.0
29 60. 60.0
30 70. 70.0
31 110. 110.0
µg/I

32 70. 70.0
33 66. 66.0
34 208. 208.0
35 70. 70.0
36 50. 50.0
37 100. 100.0
38 I00. 100.0
39 60. 60.0
40 60. 60.0
41 50. 50.0
42 120. 120.0
43 < 50 25.0
44 209. 209.0
45 115. 115.0
46 77. 77.0
47 < 50 25.0
48 < 50 25.0
49 < 50 25.0
50 < 50 25.0
51 < 50 25.0
52 < 50 25.0
53 82. 82.0
54 63. 63.0
55 193. 193.0
56 82. 82.0
57 65. 65.0
58 311. 311.0
59 146. 146.0
60 298. 298.0
61 65. 65.0
62 40. 40.0
63 < 50 25.0
64 < 50 25.0
65 24. 24.0
66 122. 122.0

;67 98. • 98.0..
68 '.160. . 160.0
69 170. 170.0
70 78. 78.0

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
IWC (%) =
Town of Rutherfordton
NC0025909
1.86
45.45
FINAL RESULTS
Arsenic
Max. Pred Cw
Allowable Cw
2.5
110.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.0000
2.5
0.0000
12
1.00
2.5 µg/1
2.5 µg/l
110.0 µg/l
Parameter =
Standard =
Arsenic
50.0
n < Actual Data BDL=I/2DL
1 < 5 2.500
2 < 5 2.500
3 < 5 2.500
4 < 5 2.500
5 < 5 2.500
6 < 5 2.500
7 < 5 2.500
8 < 5 2.500
9 < 5 2.500
10 < 5 2.500
11 < 5 2.500
12 < 5 2.500
µg/I

Facility Name =
NPDES # =
Qiv (MGD) =
7Q10s (cfs)=
IWC(%) =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Cadmium
Max. Pred Cw
Allowable Cw
3.1
4.4
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mull Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.2323
0.5
0.4267
135
1.23
2.5 µg/I
3.1 µg/I
4.4 µg/I
Parameter =
Standard =
Cadmium
2.0
n < Actual Data BDL=1/2DL
1 < 1 0.5
2 < 1 0.5
3 < 1 0.5
4 < 1 0.5
5 < 1 0.5
6 1. 1.0
7 < 1 0.5
8 < 1 0.5
9 < 1 0.5
10 < 1 0.5
11 < 5 2.5
12 < 1 0.5
13 < 1 0.5
14 < l 0.5
15 < 2 1.0
16 < 1 0.5
17 < 1 0.5
18 < 1 0.5
19 < 1 0.5
20 < 1 0.5
21 < 1 0.5
22 < 1 0.5
23 < 1 0.5
24 < 1 0.5
25 < 2 1.0
26 < 2 1.0
27 < 1 0.5
28 < 1 0.5
29 < 1 0.5
30 < 1 0.5
31 < 1 0.5
µg/1

32 < 1 0.5
33 < 1 0.5
34 < 1 0.5
35 < 1 0.5
36 < 1 0.5
37 < 1 0.5
38 < 1 0.5
39 < 1 0.5
40 < 1 0.5
41 < 1 0.5
42 < 1 0.5
43 < 1 0.5
44 < 1 0.5
45 < 1 0.5
46 1. 1.0
47 < 1 0.5
48 < 1 0.5
49 < 1 0.5
50 < 1 0.5
51 < 1 0.5
52 < 1 0.5
53 < 1 0.5
54 < 1 0.5
55 < 1 0.5
56 < 1 0.5
57 < 1 0.5
58 < 1 0.5
59 < 1 0.5
60 < 1 0.5
61 < 1 0.5
62 < 1 0.5
63 < 1 0.5
64 < 1 0.5
65 < 1 0.5
66 < 1 0.5

67 < .1 0.5
68 < 1 0.5
69 < 1 0.5
70 < 1 0.5
71 < 1 0.5
72 < 1 0.5
73 < 1 0.5
74 < 1 0.5
75 < 1 0.5
76 < 1 0.5
77 < 1 0.5
78 < 1 0.5
79 < 1 0.5
80 2. 2.0
81 < 1 0.5
82 < 1 0.5
83 < 1 0.5
84 < 1 0.5
85 < 1 0.5
86 < 1 0.5
87 < 1 0.5
88 < 1 0.5
89 < 1 0.5
90 < 1 0.5
91 < 1 0.5
92 < 1 0.5
93 < 1 0.5
94 < 1 0.5
95 < 1 0.5
96 < 1 0.5
97 < 1 0.5
98 < 1 0.5
99 < 1 0.5
100 < 1 0.5
101 < 1 0.5

102 < I 0.5
103 < 1 0.5
104 < 1 0.5
105 < 1 0.5
106 < 1 0.5
107 < 1 0.5
108 < 1 0.5
109 < 1 0.5
110 < 1 0.5
111 < 1 0.5
112 < 1 0.5
113 < 1 0.5
114 < 1 0.5
115 < 1 0.5
116 < 1 0.5
117 < 1 0.5
118 < 1 0.5
119 < 1 0.5
120 < I 0.5
121 < 1 0.5
122 < 1 0.5
123 < 1 0.5
124 < 1 0.5
125 < 1 0.5
126 < 1 0.5
127 < 1 0.5
128 < 1 0.5
129 < 1 0.5
130 < 1 0.5
131 < 1 0.5
132 < 1 0.5
133 < 1 0.5
134 < 1 0.5
135 < 1 0.5

Facility Name =
NPDES # =
Qw (MGD) =
7Q1Os (cfs)=
1WC (%) =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Chloride
Max. Pred Cw
Allowable Cw
Allowable #/day
53.8
506.0
0.00
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Malt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
4.3130
35.5
0.1214
12
1.25
43.0 mg/L
53.8 mg/L
506.0 mg/L
Parameter =
Standard =
Chloride
230.0
n < Actual Data BDL=1/2DL
1 42.5 42.5
2 34.6 34.6
3 43 43.0
4 39 39.0
5 34.6 34.6
6 29.3 29.3
7 37.2 37.2
8 31 31.0
9 31.4 31.4
10 33.7 33.7
11 36.3 36.3
12 33.7 33.7
mg/L

Facility Name =
NPDES # =
Q►v (MGD) =
7QIOs (cfs)=
IWC (%n) _
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Chromium
Max. Pred Cw
Allowable Cw
5.2
110.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mull Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.6279
1.5
0.4296
13
2.09
2.5 µg/l
5.2 µg/1
110.0 µg/1
Parameter =
Standard =
Chromium
50.0
n < Actual Data BDL=1/2DL
1 < 5 2.5
2 < 5 2.5
3 2 2.0
4 2 2.0
5 < 2 1.0
6 < 2 1.0
7 2 2.0
8 < 2 1.0
9 < 2 1.0
10 < 2 1.0
11 < 2 1.0
12 < 2 1.0
13 < 2 1.0

Facility Name =
NPDES # =
Qtv (MGD) =
7Q1Os (cfs)=
1WC (%n) =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Cyanide
Max. Pred Cw
Allowable Cw
15.1
11.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Malt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.7775
5.I
0.1534
134
1.08
14.0 µg/I
15.1 µg/I
11.0 µg/I
Parameter =
Standard =
Cyanide
5.0
n < Actual Data BDL=1/2DL
1 < 10 5.0
2 < 10 5.0
3 < 10 5.0
4 < 10 5.0
5 < 10 5.0
6 < 10 5.0
7 < 10 5.0
8 < 10 5.0
9 < 10 5.0
10 < 10 5.0
11 < 10 5.0
12 < 10 5.0
13 < 10 5.0
14 < 10 5.0
15 < 10 5.0
16 < 10 5.0
17 < 10 5.0
18 < 10 5.0
19 < 10 5.0
20 < 10 5.0
21 < 10 5.0
22 14. 14.0
23 < 10 5.0
24 < 10 5.0
25 < 10 5.0
26 < 10 5.0
27 < 10 5.0
28 < 10 5.0
29 < 10 5.0
30 < 10 5.0
31 < 10 5.0

32 < 10 5.0
33 < 10 5.0
34 < 10 5.0
35 < 10 5.0
36 < 10 5.0
37 < 10 5.0
38 < 10 5.0
39 < 10 5.0
40 < 10 5.0
41 < 10 5.0
42 < 10 5.0
43 < 10 5.0
44 < 10 5.0
45 < 10 5.0
46 < 10 5.0
47 < 10 5.0
48 < 10 5.0
49 < 10 5.0
50 < 10 5.0
51 < 10 5.0
52 < 10 5.0
53 < 10 5.0
54 < 10 5.0
55 < 10 5.0
56 < 10 5.0
57 < 10 5.0
58 < 10 5.0
59 < 10 5.0
60 < 10 5.0
61 < 10 5.0
62 < 10 5.0
63 < 10 5.0
64 < 10 5.0
65 < 10 5.0
66 < 10 5.0

67 < 10 5.0
68 < 10 5.0
69 < 10 5.0
70 < 10 5.0
71 < 10 5.0
72 < 10 5.0
73 < 10 5.0
74 < 10 5.0
75 < 10 5.0
76 < 10 5.0
77 < 10 5.0
78 < 10 5.0
79 < 10 5.0
80 < 10 5.0
81 < 10 5.0
82 < 10 5.0
83 < 10 5.0
84 < 10 5.0
85 < 10 5.0
86 < 10 5.0
87 < 10 5.0
88 < 10 5.0
89 < 10 5.0
90 < 10 5.0
91 < 10 5.0
92 < 10 5.0
93 < 10 5.0
94 < 10 5.0
95 < 10 5.0
96 < 10 5.0
97 < 10 5.0
98 < 10 5.0
99 < 10 5.0
100 < 10 5.0
101 < 10 5.0

102 < 10 5.0
103 < 10 5.0
104 < 10 5.0
105 < 10 5.0
106 < 10 5.0
107 < 10 5.0
108 < 10 5.0
109 < 10 5.0
110 < 10 5.0
111 < 10 5.0
112 < 10 5.0
113 < 10 5.0
114 < 10 5.0
115 < 10 5.0
116 < 10 5.0
117 < 10 5.0
118 < 10 5.0
119 < 10 5.0
120 < 10 5.0
121 < 10 5.0
122 < 10 5.0
123 < 10 5.0
124 < 10 5.0
125 < 10 5.0
126 < 10 5.0
127 < 10 5.0
128 < 10 5.0
129 < 10 5.0
130 < 10 5.0
131 < 10 5.0
132 < 10 5.0
133 < 10 5.0
134 < 10 5.0

Town of Rutherfordton
NC0025909
1.86
45.45
FINAL RESULTS
Mix It I)
fi•��o�lK3�c
19.5
-GTO' SS
1.3196
1.4
0.9662
MAyc P20.
Ft.LowAn6►.E
134
1.50
13.0 µg/1
19.5 µg/1
55.0 µg/1
Parameter =
Standard =
Lead
25.0
n < Actual Data BDL=1/2DL
1 < 2 1.0
2 3. 3.0
3 2. 2.0
4 < 2 1.0
5 < 2 1.0
6 3. 3.0
7 < 2 1.0
8 < 2 1.0
9 < 2 1.0
10 < 2 1.0
11 < 2 1.0
12 < 2 1.0
13 < 2 1.0
14 < 2 1.0
15 < 5 2.5
16 < 2 1.0
17 < 2 1.0
18 < 2 1.0
19 < 2 1.0
20 < 2 1.0
21 < 2 1.0
22 2. 2.0
23 < 2 1.0
24 < 5 2.5
25 < 5 2.5
26 < 5 2.5
27 < 2 1.0
28 < 2 1.0
29 < 2 1.0
30 < 2 1.0
31 < 2 1.0

32 < 2 I.0
33 < 2 1.0
34 < 2 1.0
35 < 2 1.0
36 < 2 1.0
37 < 2 1.0
38 2. 2.0
39 < 2 1.0
40 < 2 1.0
41 < 2 1.0
42 < 2 1.0
43 < 2 1.0
44 < 2 1.0
45 < 2 1.0
46 < 2 1.0
47 < 2 1.0
48 < 2 1.0
49 < 2 1.0
50 < 2 1.0
51 < 2 1.0
52 < 2 1.0
53 < 2 1.0
54 < 2 1.0
55 3. 3.0
56 < 2 1.0
57 < 2 1.0
58 < 2 1.0
59 < 2 1.0
60 < 2 1.0
61 < 2 1.0
62 < 2 1.0
63 < 2 1.0
64 < 2 1.0
65 4. 4.0
66 < 2 1.0

67 < 2 1.0
68 < 2 1.0
69 < 2 1.0
70 < 2 1.0
71 < -2. 1.0
72 < 2 1.0
73 < 2 1.0
74 < 2 1.0
75 3. 3.0
76 < 2 1.0
77 < 2 1.0
78 < 2 1.0
79 < 2 1.0
80 < 2 1.0
81 < 2 1.0
82 < 2 1.0
83 < 2 1.0
84 < 2 1.0
85 < 2 1.0
86 < 2 1.0
87 2. 2.0
88 2. 2.0
89 < 2 1.0
90 < 2 1.0
91 < 2 1.0
92 < 2 1.0
93 < 2 1.0
94 < 2 1.0
95 3. 3.0
96 < 2 1.0
97 < 2 1.0
98 < 2 1.0
99 < 2 1.0
100 < 2 1.0
101 < 2 1.0

102 < 2 1.0
103 < 2 1.0
104 < 2 1.0
105 < 2 1.0
106 < 2 1.0
107 < 2 1.0
108 < 2 1.0
109 < 2 1.0
110 3. 3.0
111 4. 4.0
112 < 2 1.0
113 < 2 1.0
114 < 2 1.0
115 < 2 1.0
116 8. 8.0
117 < 2 1.0
118 < 2 1.0
119 < 2 1.0
120 13. 13.0
121 < 2 1.0
122 < 2 1.0
123 < 2 1.0
124 < 2 1.0
125 < 2 1.0
126 < 2 1.0
127 < 2 1.0
128 < 2 1.0
129 < 2 1.0
130 < 2 1.0
131 < 2 1.0
132 < 2 1.0
133 < 3 1.5
134 < 3 1.5

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
1WC(%) =
Town of Ruthcrfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Mercury
Max. Pred Cw
Allowable Cw
0.100
0.026
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.0000
0.100
0.0000
66
1.000
0.100 µg/I
0.100 µg/1
0.026 µg/1
Parameter =
Standard =
Mercury
0.012
n < Actual Data BDL=1/2DL
1 < 0.2 0.100
2 < 0.2 0.100
3 < 0.2 0.100
4 < 0.2 0.100
5 < 0.2 0.100
6 < 0.2 0.100
7 < 0.2 0.100
8 < 0.2 0.100
9 < 0.2 0.100
10 < 0.2 0.100
11 < 0.2 0.100
12 < 0.2 0.100
13 < 0.2 0.100
14 < 0.2 0.100
15 < 0.2 0.100
16 < 0.2 0.100
17 < 0.2 0.100
18 < 0.2 0.100
19 < 0.2 0.100
20 < 0.2 0.100
21 < 0.2 0.100
22 < 0.2 0.100
23 < 0.2 0.100
24 < 0.2 0.100
25 < 0.2 0.100
26 < 0.2 0.100
27 < 0.2 0.100
28 < 0.2 0.100
29 < 0.2 0.100
30 < 0.2 0.100
31 < 0.2 0.100
32 < 0.2 0.100
33 < 0.2 0.100
34 < 0.2 0.100
35 < 0.2 0.100
36 < 0.2 0.100
37 < 0.2 0.100
38 < 0.2 0.100
39 < 0.2 0.100
40 < 0.2 0.100
41 < 0.2 0.100
42 < 0.2 0.100
43 < 0.2 0.100
44 < 0.2 0.100
45 < 0.2 0.100

46 < 0.2 0.100
47 < 0.2 0.100
48 < 0.2 0.100
49 < 0.2 0.100
50 < 0.2 0.100
51 < 0.2 0.100
52 < 0.2 0.100
53 < 0.2 0.100
54 < 0.2 0.100
55 < 0.2 0.100
56 < 0.2 0.100
57 < 0.2. 0.100
58 < 0.2 0.I00
59 < 0.2 0.100
60 < 0.2 0.100
61 < 0.2 0.100
62 < 0.2 0.100
63 < 0.2 0.100
64 < 0.2 0.100
65 < 0.2 0.100
66 < 0.2 0.100

Facility Name =
NPDES # =
Qw (MGD) =
7Q10s (cfs)=
1WC (%) _
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Nickel
Max. Pred Cw
Allowable Cw
56.9
193.6
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Malt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
5.3349
6.7
0.7978
67
1.78
32.0 µg/I
56.9 µg/I
193.6 µg/1
Parameter =
Standard =
Nickel
88.0
n < Actual Data BDL=1/2DL
1 < 10 5.0
2 < 10 5.0
3 < 10 5.0
4 < 10 5.0
5 < 10 5.0
6 < 10 5.0
7 < 10 5.0
8 < 10 5.0
9 < 10 5.0
10 < 10 5.0
11 < 10 5.0
12 < 10 5.0
13 < 10 5.0
14 12. 12.0
15 < 10 5.0
16 19. 19.0
17 < 10 5.0
18 < 10 5.0
19 < 10 5.0
20 < 10 5.0
21 < 10 5.0
22 < 10 5.0
23 < 10 5.0
24 < 2 1.0
25 < 10 5.0
26 < 10 5.0
27 < 10 5.0
28 < 10 5.0
29 < 10 5.0
30 < 10 5.0
31 < 10 5.0

32 < 10 5.0
33 < 10 5.0
34 < 10 5.0
35 < 10 5.0
36 < 10 5.0
37 24. 24.0
38 < 10 5.0
39 < 10 5.0
40 < 10 5.0
41 < 10 5.0
42 < 10 5.0
43 < 10 5.0
44 < 10 5.0
45 < 10 5.0
46 32. 32.0
47 < 10 5.0
48 < 10 5.0
49 < 10 5.0
50 < 10 5.0
51 < 10 5.0
52 15. 15.0
53 18. 18.0
54 12. 12.0
55 25. 25.0
56 < 10 5.0
57 < 10 5.0
58 < 10 5.0
59 < 10 5.0
60 < 10 5.0
61 < 10 5.0
62 < 10 5.0
63 < 10 5.0
64 < 10 5.0
65 < 10 5.0
66 < 10 5.0

Facility Name =
NPDES # =
Qiv (MGD) =
7Q10s (cfs)=
1WC (%) =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Silver
Max. Pred Cw
Allowable Cw
11.36
0.13
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Malt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
1.2136
3.5
0.3423
11
1.89
6.00 µg/1
11.36 µg/I
0.13 µg/I
Parameter =
Standard =
Silver
0.06
n < Actual Data BDL=1/2DL
1 < 5 2.5
2 < 5 2.5
3 < 3 1.5
4 < 3 1.5
5 < 3 1.5
6 2 2.0
7 6 6.0
8 < 3 1.5
9 < 3 1.5
10 < 3 1.5
11 < 3 1.5
µg/l

Facility Name =
NPDES # =
Q►w (MGD) =
7Q10s (cfs)=
1WC (%) =
Town of Rutherfordton
NC0025909
1
1.86
45.45
FINAL RESULTS
Selenium
Max. Pred Cw
Allowable Cw
2.5
11.0
RESULTS
Std Dev.
Mean
C.V.
Number
of data points
Mull Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.0000
2.5
0.0000
13
1.00
2.5 µg/1
2.5 µg/1
11.0 µg/1
Parameter =
Standard =
Selenium
5.0
n < Actual Data BDL=I/2DL
1 < 5 2.5
2 < 5 2.5
3 < 5 2.5
4 < 5 2.5
5 < 5 2.5
6 < 5 2.5
7 < 5 2.5
8 < 5 2.5
9 < 5 2.5
10 < 5 2.5
11 < 5 2.5
12 < 5 2.5
13 < 5 2.5
µg/I

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•
TOWN O,st THERF`.ORDTON
Zd Belt"
rt tinain Street
•
N 8139
828/287-3520 , TAX�-828/286-8054
s.
February 6, 2004
NCDENR
Aquatic Toxicology Unit
ATTN: Matt Matthews
1621 Mail Service Center
Raleigh, NC 27699-1621
Re: Town of Rutherfordton
NPDES Permit No. NC0025909
Dear Mr. Matthews,
Sally Lesher
MAYOR
Christy Bare
Jimmy G. Dancy
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin, Librarian
Cele Darr-Witman, Rutherford Town Revitalization
RECEDED
FEB _ 6 2004
EnvitonmentaiSdences Brand,
Enclosed is the Toxicity Identification Evaluation Study for the Town of Rutherfordton
wastewater treatment plant. The study was conduct to rule out copper and/or zinc as
potential cause(s) of effluent toxicity. The study contains the results of our effluent
sample that was spiked with different concentrations of copper and zinc.
If you have any questions, please give me a call.
Sincerely,
Town of Rutherfordton
Karen Andrews
Town Manager
Cc: Nadine Blackwell
Paul Rhodes

RECEIVED
FEB - 6 2004
TOWN OF RUTHERFORDTON Environmental Sciences Branch
WASTEWATER TREATMENT PLANT
NPDES Permit No. NC0025909
TOXICITY IDENTIFICATION EVALUATION
as required by the
COPPER AND ZINC ACTION LEVEL POLICY
January 2004

TOXICITY IDENTIFICATION EVALUATION
as required by the
COPPER AND ZINC ACTION LEVEL POLICY
INTRODUCTION
The Town of Rutherfordton wastewater treatment plant is required by its NPDES Permit
to test for toxicity in accordance with the test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure", revised November 1995, or
subsequent revision. The effluent concentration at which there is to be no observable
inhibition of reproduction or significant mortality is 71.0%. On January 22, 2001 a
sample was collected and analyzed for toxicity. The result of the test was a failure due
to significant mortality and zero reproduction. As a result, the North Carolina
Department of Environment and Natural Resources (NCDENR) required the Town to
conduct a study to determine if copper and/or zinc were the causative(s) of the toxicity
failure.
METHOD AND MATERIALS
The Town of Rutherfordton chose to conduct a Toxicity Identification Evaluation (TIE),
to determine if copper and/or zinc were potential cause(s) of toxicity. Attachment I
provides a detailed description of the test method. The test method was approved by
NCDENR on September 26, 2001.
RESULTS AND DISCUSSION
An effluent sample was collected on October 20, 2003 and sent to Meritech, Inc. for
analysis in accordance with Attachment I. The effluent sample was non -toxic. Since the
effluent sample was non toxic, the laboratory spiked different concentrations of copper
and zinc into the effluent sample. A summary of the test method and results are
provided in the cover letter from Meritech, Inc.
The Town will collect samples during the month of February and sent them to Meritech
for the addition of the EDTA and Sodium Thiosulfate and to spike the sample with
different concentrations of copper and zinc if the effluent is nontoxic.

ATTACHMENT I
Toxicity Identification Evaluation to Rule Out Copper and/or Zinc as
Causes of Effluent Toxicity
Proposal of Study
The EPA has established procedures for bench -scale treatments of effluent that
categorically identify sources of toxicity (EPA 1992). Two of these Phase I Toxicant
Identification Evaluation procedures are designed to identify the contribution of cationic
metals to effluent toxicity: sodium thiosulfate addition and EDTA addition. Both
treatments encompass application of two concentrations of each chelating agent.
Specific evidence that copper and/or zinc are sources of toxicity are indicated as
follows:
• Copper is a potential source if toxicity is removed or reduced by addition of k
Asodium thiosulfate and EDTA. r ti
\!#
• Zinc is a potential source if toxicity is removed or reduced by addition of EDTA. O°v
To address concerns that copper and/or zinc are contributing toxicity to the effluent of
concern, the treatments noted above are applied to three unique composite effluent
samples collected over a period of several months. Untreated and treated samples are
analyzed for toxicity, hardness, total recoverable copper and zinc, and total dissolved
copper and zinc.
Reference
United States Environmental Protection Agency. Toxicity Identification Evaluation:
Characterization of Chronically Toxic Effluents, Phase I. EPA/600/6-91 /005F. May
1992. EPA Office of Research and Development. Washington, D.C.

MERITECH, INC.
ENVIRONMENTAL LABORATORIES
A Division of Water Technology and Controls, Inc.
1
Rutherfordton WWTP is required by the state of North Carolina to demonstrate
that its effluent toxicity is not caused by the presence of copper and zinc concentrations
.Lhy in the effluent. Meritech, Inc., conducted this study on an effluent sample collected on
\" F October 20th, 2003. The same sample was used in the test initiated on November 11th,
,-2003,-Copper and zinc were present at concentrations of 6.0 µg/L and 52.0 µg/L,
respectively as orted in the first test series. In this test series, the effluent was spiked
with copper (15 µg/L) and zinc 5( may). The test was started on December 3rd, 2003,-
using 100% effluent. The test was set-up with six treatments and a control as follows:
• Control
• Treatment #1 100% effluent only
• Treatment #2 100% effluent + Copper and Zinc
• Treatment #3 100% effluent + Copper and Zinc + 0.5 mg/L EDTA
• Treatment #4 100% effluent + Copper and Zinc + 3.0 mg/L EDTA
• Treatment #5 100% effluent + Copper and Zinc + 0.5 mg/L Sodium Thiosulfate
• Treatment #6 100% effluent + Copper and Zinc + 3.0 mg/L Sodium Thiosulfate
Toxicity data is presented in Attachment A. Treatment #1 was set up with 100%
effluent to check effluent toxicity. A 36.69% reduction in reproduction was noted as
compared to the control. In treatment #2, the sample was spiked with 15 µg/L of copper
and 55 µg/L of zinc. A significant reduction of 38.13% in reproduction was observed.
Treatments 3-6 were also spiked with copper and zinc, and then two different
concentrations of EDTA and Sodium Thiosulfate were used to chelate metals.
In all EDTA and thiosulfate treated samples (Treatments 3-6), the effluent
exhibited toxicity. The expected increase in toxicity due to spiking, did not occur in
Treatment #3 (0.5 mg/L EDTA) and in Treatments #5 and #6 (0.5 mg/L and 3.0 mg/L
Thiosulfate), because metals complexed with EDTA and Thiosulfate. In Treatment #4, a
greater reduction (60.43%) in reproduction was observed, which may be attributed to
unbound EDTA.
Rutherfordton effluent contains low levels of copper and zinc. The effluent
(100%) exhibited toxicity in both test series, 33.75% reduction in the first test started on
November 11th, 2003 and 36.69% reduction in this test series. The spiked 100% effluent
showed significant reduction in reproduction (38.13%). The addition of EDTA and
Thiosulfate demonstrated a decrease in toxicity in spiked samples (Treatments #3 - #6),
but it failed to remove or reduce effluent toxicity significantly. It is likely that the cause
of effluent toxicity is something other than metals.
642 Tamco Road • P.O. Box 27 • Reidsville, NC 27320
[phone] • [phone] Fax

Client:
NPDES#:
%Effluent Dav#
3
Control 5
7
Total
V.Ipcevpi-
3
5
7
Total
3
Keel
7
Total
3
b94 d2.s` 1I 5
61)71)
5fri 7
Total
3
/t90 1L 3.0 111- 01,5
S1+'1W 7
Total
3
Imo? a.$i)r. 5
I)77,6 rI14r`) 51'!xeA 7
Total
Meritech
Ceriodaphnia Chronic Reproduction Data Sheet
1
2
3
4
Start Date:
End Date:
$e/7niwP
y u
; -a g Time: g -57o p4
.Io -o .S Time:
Replicates
5
6
7
8
Reviewed by:
9
1t• (5,9Mr
10
6/Il
0
s/,o
s///
4//.2-
7-
/5-
/5-
/1
g
SA
30
7
ab
s/4/
3/7
�7S
04
Sig
lf/d
411
3/6
414
3/5-
9
ci
S
6
/o
6/7
6//
5/2
Ski
/6'
6
7
?
S
t o
19
I q
,21
a 1
Pi-
612.
*
3/o
Wo
5/3
_
7-
a
7
$
is
01
5
/0
16
61‘
j-#
-/ -
G!
5/
8
9
8
i►
ER
° ,,
(9-r
/$
AP---
%3rd Brood
C.V. Mean
Reproduction
% RED.
% RED.
% RED.
% RED.
% RED.
' 7,g
36.61
3 $. 13
ao•9
25.11?
bo��F3
/9•6
029-S

Client:
NPDES#:
Meritech
Ceriodaphnia Chronic Reproduction Data Sheet
%Effluent Day# 1
foe% 3'dWI1-3
i'
Total
3
5
7
Total
3
5
7
Total
3
5
7
Total
3
5
7
Total
3
5
7
Total
2
3
4
Start Date: /,Z , , U Time:
End Date: /c9 _ • e S Time:
Reviewed by:
Replicates
5
6
7
8
9
10
(;4
5-/1
6/1
s/q
57 '
1!
q
9
_
(0
‘
3
d22
co
.2it
I `7
%3rd Brood
C.V.
n11.1,J-^
Mean
Reproduction
�!•ad
% RED.
% RED.
% RED.
% RED.
RED.

MERITECH, INC.
ENVIRONMENTAL LABORATORIES
A Division of Water Technology and Controls, Inc.
Rutherfordton WWTP is required by the state of North Carolina to demonstrate
that their effluent toxicity is not caused by copper and zinc. Meritech, Inc., conducted
this study on an effluent sample collected on October 20th, 2003. The sample was first
analyzed for metals. Copper and zinc were present at concentrations of 6.0 gg/L and 52.0
gg/L, respectively. Copper was present below the NOEC value of 12.0 gg/L, as
described in "Quality Criteria for Water" (EPA publication, 1986). Zinc was present at a
concentration (52.0 gg/L) that was slightly higher than the NOEC of 47gg/L. The metals
analysis results are presented in Attachment A.
Toxicity testing was started on November 11`h 2003 using the aforementioned
effluent sample. The test was set up with a control and five treatments. 100% effluent
concentration was used in all treatments. Ten replicates were run for both the control and
each treatment. The test was set up as follows:
• Control
• Treatment #1 100% effluent only.
• Treatment #2 100% effluent + 0.5 mg/L EDTA
• Treatment #3 100% effluent + 3.0 mg/L EDTA
• Treatment #4 100% effluent + 0.5 mg/L Sodium Thiosulfate
• Treatment #5 100% effluent + 3.0 mg/L Sodium Thiosulfate
Toxicity data is presented in Attachment B. Treatment #1 was set up with 100%
effluent to check effluent toxicity. In treatment #1 a significant reduction (33.75%) in
reproduction was observed. In treatments #2 and #3, different EDTA concentrations
were utilized to chelate metals. In treatments # 2 and #3 a 23.33% and 47.5% reduction
in reproduction was observed from the control respectively. In treatments #4 and #5
(treated with Sodium Thiosulfate) a reduction of 20.42% and 30.42% in reproduction
from the control was observed.
- Metal analysis of the October 20th effluent sample indicate that copper and zinc
were present either below or close to the NOEC values for these metals as cited in the
EPA's "Quality Criteria for Water" (1986). All treated and untreated samples showed
significant reduction in reproduction as compared to the control. Both EDTA and
Sodium Thiosulfate failed to reduce effluent toxicity significantly. Higher concentrations
(3.0 mg/L) of EDTA and Sodium Thiosulfate caused an even greater reduction in
reproduction, which may be attributed to unbound EDTA and Sodium Thiosulfate. It is
likely that the cause of effluent toxicity is something other than metals.
642 Tamco Road • P.O. Box 27 • Reidsville, NC 27320
[phone] • [phone] Fax

kotic4/14.1f-m-i
Sample Name: Bio Assay 10/27 Acquired: 10/29/2003 11:46:53 Type: Unk
Method: IRIS REG 3 Mode: CONC Corr. Factor: 1.000000
User: admin
Comment:
Custom ID1:
Custom ID2: Custom ID3:
Atah100 A n
Elem A13944 Sb2068 As1890 Ba4554 Be3131 B_2089 Cd2288 Cr2677
Units ppm ppm ppm ppm ppm ppm ppm ppm
Avg .0879 -.0032 .0044 .0084 .0002 .1773 -.0001 -.0007
Stddev .0010 .0025 .0036 .0000 .0000 .0015 .0001 .0002
%RSD 1.150 78.05 83.02 .3435 20.91 .8264 231.5 22.75
#1 .0884 -.0060 .0002 .0084 .0002 .1764 .0001 -.0009
#2 .0886 -.0014 .0069 .0083 .0001 .1790 .0000 -.0006
#3 .0867 -.0021 .0060 .0084 .0002 .1765 -.0002 -.0006
Elem Co2286! Cu3247 Fe2599 Pb2203 Mn2576 Mo2020 Ni2316 Se1960
Units ppm �04 ppm ppm ppm ppm ppm ppm ppm
Avg .00110• .0059 .1404 -.0040 .0157 .0035 .0008 -.0027
Stddev .00021 .0001 .0004 .0005 .0001 .0004 .0004 .0009
%RSD 19.72 �g�1.031 .3201 13.74 .5083 11.93 55.26 31.64
#1 .0009 .0058 .1399 -.0046 .0158 .0032 .0005 -.0021
#2 .0011 .0060 .1408 -.0037 .0157 .0034 .0013 -.0023
#3 .0013 .0059 .1405 -.0037 .0157 .0040 .0006 -.0037
Elem Ag3280 TI1908 Sn1899 Ti3383 V_2924 Zn2138
Units ppm ppm ppm ppm ppm ppm o. o S
Avg .0028 .0162 -.0029 .0021 .0012 .0524
Stddev .0002 .0005 .0031 .0002 .0001 .0004 L
%RSD 7.806 3.114 109.6 7.958 5.564 .7072 vs v.sit_
#1 .0026 .0157 -.0046 .0020 .0013 .0521
#2 .0027 .0167 -.0048 .0023 .0012 .0528
#3 .0030 .0163 .0008 .0022 .0011 .0522. ",,aa.....,
Int. Std. Sc2273 Sc3353
Units Cts/S Cts/S
Avg 19.162 487.51
Stddev .173 .71
%RSD .90335 .14513
#1 19.356 488.29
#2 19.023 487.33
#3 19.106 486.91

Client:
NPDES#:
%Effluent Dav#
3
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Total
3
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Total
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Total
3
loo,eE66LeoJ 311-5
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Total
Meritech
Ceriodaphnia Chronic Reproduction Data Sheet
1
2
3
Start Date:
End Date:
11•-i(-a3 Time:
1/ • i9-r0 3 Time:
Replicates
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4-1

TOWN OF RUTHERFORDTON
"The Heart of the Thermal Belt"
Sally Lesher Karen E. Andrews, Town Manager
MAYOR Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Town Hall • 129 North Main Street Jimmy G. Dancy Keith Ward, Public Works Superintendent
Rutherfordton, NC 28139 Ron Giles C. Thomas Blanton, Fire Chief
Christy Bare Pat A. Hardin, Librarian
Bobby E. Jones Donald Hutchins, Zoning/Code Enforcement
828/287-3520 * FAX [phone] COUNCIL MEMBERS Frank G. Keel,Jr., Rutherford Town Revitalization
CERTIFIED
December 23, 2003
Ms. Susan Wilson
NCDENR-DWQ-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft NPDES Permit NC0025909
Dear Ms. Wilson:
This correspondence is in reply to the draft NPDES Permit that we received from you on November 24, 2003. The
Town greatly appreciates the Division granting our request for a Tier permit with two different flow limits. We have
reviewed the draft permit and are providing the following comments/requests:
1. Daily Monitoring - The monitoring frequency on the effluent limits page at 3.0 MGD requires
daily monitoring for BOD, TSS, NH3-N, and Fecal Coliform. Our existing NPDES Permit requires
these pollutants to be monitored three times per week (3/Week). The daily monitoring frequency is
more typical for a Grade IV facility rather than a Grade ID facility. We are requesting that the
monitoring frequency be changed to 3/Week or a condition included in the Permit that allows the
monitoring frequency to be reduced to 3/Week based on the Town demonstrating complete
compliance for a specific period of time once the Wastewater Management Plan has been fulfilled.
- ISA 1J C C 84 •0= oZf d1
2. Cooper and Zinc Limits - It is our understanding that these limits were included in the Permit
based on the Town's toxicity failures and the insufficient data provided to the Division to eliminate
cooper and zinc as the cause of the toxicity failures. The Town is continuing with the Toxicity
Identification Evaluation (TIE) and providing the Division with our findings. We are requesting that a
condition be included in the Permit, which states that the copper and zinc limits will be removed upon
the Division's approval of the TIE data, which demonstrates that copper and zinc are not the cause of
toxicity failures. The Town requests an amendment to the Permit to allow for the amending of the
numbers based on the results of the toxicity testing.
We appreciate any consideration you can provide to our request. If you require additional information or would like to
discuss our request, please advise.
Sincerely,
TOWN OF RUTHERFORDTON
e 4104--
Karen E. Andrews
Town Manager
cc: Roger Edwards - NCDENR/Asheville Regional Office
Gary Stainback

Draft Permit Review
Subject: Draft Permit Review
From: John Giorgino <[e-mail]>
Date: Mon, 01 Dec 2003 09:45:57 -0500
To: Susan A Wilson <[e-mail]>
Hi Susan, thanks for forwarding the draft permit for Rutherford WWTP
(NC0025909). I have no comments concerning the tox sections.
-John
John Giorgino
Environmental Biologist
North Carolina Division of Water Quality
Aquatic Toxicology Unit
Office: 919 733-2136
Fax: [phone]
Mailing Address:
1621 MSC
Raleigh, NC 27699-1621
1 of I 12/ 1 /2003 10:03 AM

Re: NPDES deadline
/20.1711ER-Aq,111)Te.
Subject: Re: NPDES deadline
Date: Tue, 25 Nov 2003 08:31:41 -0500
From: Susan A Wilson <[e-mail]>
Organization: NC DENR DWQ
To: Karen Andrews <[e-mail]>
CC: Louis Nanney <[e-mail]>,
Matt Matthews <[e-mail]>
Ms. Andrews,
Yes, unfortunately, our administrative assistant notified me that there was a problem with the mail -out and
I was expecting to hear from you. You may have until December 24 to submit comments, sorry about the
mix-up (I think we had an address error on the envelope).
Susan Wilson
Karen Andrews wrote:
Ms. Wilson, I have today, 11/24/03, received your letter of 11/5/03 concerning the draft NPDES Permit for the
Town of Rutherfordton. I note the Town has 30 days to make comments or questions about the draft permit, with
the approximate due date of December 10, 2003, according to your letter. Your 11/5/03 letter was not postmarked
until 11/20/03 and we received it in the mail today 11/24/03. I would ask you to consider the 30 days for comments
and questions to be until December 24, 2003, instead of the 10th. This will give the Town time to respond to any
questions you have asked and to review the draft permit properly. Thank you for your consideration of this
request. Please advise us of your answer. Karen AndrewsTown ManagerTown of Rutherfordton129 N Main
StreetRutherfordton, NC 28139 828 287-3591 ext 1213828 286-8054 fax
Susan A. Wilson, P.E.
Environmental Engineer
NPDES Unit, Division of Water Quality
1 of 1 11/25/03 8:46 AM

PUBLIC NOTICE
STATE of NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION/NPDES UNIT
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
NOTIFICATION OF INTENT TO ISSUE
A NPDES WASTEWATER PERMIT
On the basis of thorough staff review and
application of NC General Statute 145.21, Public
law 92-500 and other lawful standards and
regulations, the North Carolina Environmental
Management Commission proposes to issue a
National Pollutant Discharge Elimination System
(NPDES) wastewater discharge permit to the
person(s) listed below effective 45 days from the
publish date of this notice.
Written comments regarding the proposed
permit will be accepted until 30 days after the
publish date of this notice. All comments
received prior to that date are considered in the
final determinations regarding the proposed
permit. The Director of the NC Division of Water
Quality may decide to hold a public meeting for
the proposed permit should the Division receive
a significant degree of public interest.
Copies of the draft permit and other supporting
information on file used to determine conditions
present in the draft permit are available
upon request and payment of the costs of
reproduction. Mail comments and/or requests
for information to the NC Division of Water
Quality at the above address or call Ms. Valery
Stephens at [phone], extension 520.
Please include the NPDES permit number
(attached) in any communication. Interested
persons may also visit the Division of Water
Quality at 512 N Salisbury Street Raleigh, NC
27604-1148 between the hours of 8:00 a.m. and
5:00 p.m to review information on file.
The Town of Rutherfordton, 129 North Main
Street, Rutherfordton, North Carolina 28139, has
applied for renewal of its NPDES permit,
NC0025909, discharging treated municipal
wastewater to Cleghom Creek in the Broad River
Basin. Ammonia, fecal coliform, copper, cyanide
and zinc are water quality limited. This may affect
future discharges in this portion of the basin.
i
klq
AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
RUTHERFORD COUNTY
:fore the undersigned, a Notary Public of said County and State,
ly commissioned, qualified, and authorized by law to administer
ths, personally appeared
HEATHER RHODES
to being first duly sworn, deposes and says: that they are
Classified Advertising Representitive
wner, partner, publisher, or other officer or employee authorized to
Ike this affidavit) of THE DAILY COURIER, a newspaper
blished, issued and entered as second class mail In the town of
)REST CITY, In said County and State; that they are authorized to
ake this affidavit and sworn statement; that the notice or other legal
ivertisement, a true copy of which is attached hereto, was published
THE DAILY COURIER on the following dates:
November 7, 2003
nd that said newspaper in which such notice, paper, document, or
;gal advertisement was published was, at the time of each and every
uch publication, a newspaper meeting all of the requirements and
ualifications of Section 1-597 of the General Statutes of North
I;arolina and was a qualified newspaper within the meaning of Section
-597 of the General Statutes of North Carolina.
i his the 14th day of November, 2003.
Heather Sodes, Classified Advertising Representitive
Sworn to and subscribed before me this the 14th day of November,
2003.
Q,Litd'm f1.0
:1-11/1L(sa Flynn, Nota Public)
My commission expires: November 21, 2007
pPnFltlPr`
NOV 2 5 2003
Di'JhlbUuGt, • ..,,.,

Re: rutherfordton
Subject: Re: rutherfordton
Date: Tue, 04 Nov 2003 16:39:39 -0500
From: Dana FolIey <[e-mail]>
Organization: NC DENR DWQ
To: Susan A Wilson <[e-mail]>,
"Deborah.Gore" <[e-mail]>
Yes, that big textile never came, and no, I say it's not needed. Same would apply to chlorides, MBAS,
sodium, CTAS, also if we had you put those in too. Rutherfordton is now Deborah's town, so I'm sending
this to her for her final word.
Susan A Wilson wrote:
Dana,
quarterly sulfate monitoring was placed in Rutherfordton's permit at you
guys' request last time around. is this still a request? Since they
never got that big textile (and likely never will) do you think it
necessary?
Susan A. Wilson, P.E.
Environmental Engineer
NPDES Unit, Division of Water Quality
Dana Rees Folley
Pretreatment Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
919-733-5083 ext. 523
fax [phone]
website: http://h2o.enr.state.nc.us/Pretreat/index.html
1 of 1 11 /4/03 4:52 PM

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0025909
Facility Information
Applicant/Facility Name:
Town of Rutherfordton/ Rutherfordton WWTP
Applicant Address:
134 North Washington Street; Rutherfordton, North Carolina 28139
Facility Address:
1021 South Main Street; Rutherfordton, North Carolina 28139
Permitted Flow
3.0 MGD & 1.0 MGD
Type of Waste:
Domestic (90%) and industrial (10%) with pretreatment program
Facility/Permit Status:
Class IV (3.0 MGD), Class III (1.0 MGD) /Active; Renewal
County:
Rutherford County
Miscellaneous
Receivin: Stream:
Stream Classification:
303(d) Listed?
Subbasin:
Drainage Area (mi2):
Summer 7Q10 (cfs)
Cleghorn Creek
No
03-08-02
7.8
1.86
Winter 7Q10 (cfs)
2.88
30Q2 (cfs)
4.02
Average Flow (cfs):
IWC (%):
12
45% (1.0 MGD)
71% (3.0 MGD)
Regional Office:
State Grid / USGS
Quad:
Permit Writer:
Asheville (ARO)
Fl ISW/Rutherfordton
South, NC /
Susan A. Wilson �•,
Date:
November 3, 200
Lat. 35° 55' 92" N Long. 82° 04' 46" W
BACKGROUND
The Rutherfordton WWTP is a Class IV facility with a permitted flow of 3.0 MGD. The plant serves
domestic customers in the Town of Rutherfordton and one Significant Industrial User (SIU). The permit
was originally issued on June 9, 1999 and expired on July 31, 2003. The Permittee submitted EPA Form
2A on January 17, 2003 in order to request renewal of the permit.
Rutherfordton has a full pretreatment program with the Division of Water Quality's Pretreatment Unit
and will continue to implement this program in the new permit term.
At the time of the last permit renewal, Rutherfordton anticipated the addition of a textile plant, the flow
from which would be treated at the Rutherfordton WWTP. Accordingly, the Town expanded the plant
from 1 MGD to 3 MGD. The industry, however, never relocated to Rutherfordton. Lower than
anticipated flows have created operational problems at the plant; one described by the regional office is
excess aeration which is interfering with the ability of nitrifying bacteria to nitrify. This has resulted in
non-compliance with the ammonia nitrogen limit. The facility has also experienced a number of
compliance problems relating to toxicity failures and BOD violations..
The facility has requested (via the Asheville Regional Office) that the flow be phased at 1.0 MGD and
3.0 MGD. The draft permit reflects this request, with the trigger being when the facility reaches an
annual average flow of 0.8 MGD (80% of 1.0 MGD). The facility will be rated as Class III at the lower
flow of 1.0 MGD and monitoring frequencies will reflect that.
Instream Monitoring, Verification of Existing Conditions and DMR Data Review
This facility discharges to Cleghorn Creek in sub basin 03-08-02 of the Broad River Basin. Cleghorn
Creek is classified C waters at the point of discharge and is not on the 2002-303(d) list.
Instreatn data for dissolved oxygen, temperature, fecal coliform and conductivity were reviewed based
on reported Discharge Monitoring Report (DMR) data from January 2001 through July 2003. Plots of
these data are attached to this fact sheet. Little downstream impact on dissolved oxygen, temperature
and conductivity was observed and the instream dissolved oxygen was always above the standard of 5.0
mg/L. No distinct trend could be drawn for the instream fecal coliform data.
1LS ' (A)02`J1(1')
('tt ac I

Effluent data from DMRS dating from January 2001 through June 2003 were also reviewed. Monthly
average data for conventional parameters are summarized in Table 1. For the most part, the Permittee
maintained compliance with the permit limits for those parameters. Violations of the BOD and Total
Sus ended Solids (TSS) limits can be noted in the maximum values for those •arameters.
•
Flow Temperature Dissolved BOD TSS (mg/L) Fecal
(MGD) ("C) Oxygen
(mg/L) (#/100 mL)
Average
0.5126
6.71
15.30
15.51
4.38
15.35
Maximum
0.86245
23.94
7.96
37.85
32.25
32.2
Minimum
0.40757
6.28
5.47
1
2.93
1.1
Table 1. NC0025909 Conventional Data (January 2001-June 2003)
This facility also collects data for total nitrogen, total phosphorus, ammonia nitrogen (NI-1,-N), sulfate,
and total residual chlorine. These are summarized in Table 2. Considering the fact that the current
summer ammonia limit is 2.0 mg/L and the winter limit is 4.0 mg/L, the average and maximum values
for this parameter are high. This is reflected in the facility's repeated non-compliance with this limit,
which is discussed further in the Correspondence section.
NH; N
(mg/L)
Total Nitrogen Total
(mg/L) Phosphorus
Sulfate Total Residual
(mg/L) Chlorine (ug/L)
Average
3.07
•
2.35
32.68
0.5
11.73
Maximum
12.45
21.75
3.9
40
8.7
Minimum
0.12
3.1
1.29
27
0
Table 2. NC0025909 Nutrient and Toxicant Data (January 2001 - June 2003)
A review of the metals (from both the DMRs and Pretreatment data) data was also performed. These are
discussed in the Reasonable Potential Analysis section.
Correspondence
The Asheville Regional Office (ARO) conducted several site visits during this permit term to evaluate
compliance. In the more recent reports, ARO indicates that the facility's problems with compliance are
attributable to low flows through an oversized plant. The WWTP has temporarily modified its operations
to handle lower flow volume. ARO's 2003 staff report offers several recommendations for the facility
and its NPDES permit:
Town should pursue a final disposal method for the sludge other than hauling to Town of Forest
City.
Permit should include language that requires the town to submit a schedule for permanent
modification of the treatment plant (currently using temporary modifications that use the design
digester as an aeration basin and the design aeration basin as flow equalizer). This schedule should
include a timeline for request of an ATC for the modifications.
Town is under a moratorium due to the number of permit violations received since the new plant was
placed on line in June 1999. Regional office has suggested a SOC however the town has not pursued
the SOC.
The Permittee has been issued civil penalties on 26 occasions during the past 5 years for violations of
their permits. At least 20 NOVs and/or civil penalties were issued during the 2001-2003 period. The total
amount of penalties assessed is $44,441.06, according to a January 2003 assessment of civil penalties for
violations in which the facility was fined an additional $8211.00. During this particular assessment, the
facility was penalized for "failure to properly operate and maintain the wastewater treatment plant from
March 26, 2001 until Jan 8, 2003." This refers to the fact that the influent automatic bar screen retrained
out of service during this time. The inoperable bar screen directly resulted in five overflows of influent
at the headworks from 2001-2003.
Many of the remaining civil penalties were due to repeated violations of Whole Effluent Toxicity, BOD
(weekly and monthly average limits) and ammonia nitrogen. An NOV was also issued for violations of
the weekly and monthly average TSS limits.
Shci
NPDES NC002S9:)t) Renewal

In addition, as a result of repeated toxicity failures, in March 2003 there was a request to reopen the
NPDES Permit and incorporate effluent limitations for copper and zinc. The Town failed to submit TIE
data, as required, to rule out copper or zinc as causative of toxicity problems. The Aquatic Toxicology
Unit therefore recommended that the permit include limits for these parameters. As calculated by the
NPDES Unit, prospective copper and zinc limits would be 25 µg/L and 216 µg/L, respectively (at 3.0
MGD). These limits were also calculated for 1.0 MGD and would be 40 ug/1 and 339 ug/l, respectively.
PERMITTING STRATEGY
Waste Load Allocation (WLA)
The Division prepared the last WLA for the previous permit renewal. The previous and current effluent
limits were based on guidelines and water quality standards. The Division has judged previous
parameters and limits to be appropriate for renewal with some exceptions. Effluent sheets for 1.0 MGD
and 3.0 MGD were placed in the draft permit.
Changes to toxicant monitoring are discussed in the Reasonable Potential Analysis section, with the
exception of ammonia. Ammonia limits are updated based on the flow of 1.0 MGD (which resulted in
summer/winter limits of 2.0 mg/1 and 4.7 mg/1). The limits were also updated at 3.0 MGD and reflect
summer/winter limits of 1.3 and 2.8 mg/1.
Weekly average ammonia limits based on a 3:1 ratio with the monthly average (but no higher than 35.0
mg/L) will be implemented in this permit. This is a new statewide policy that resulted from EPA
requirements. The resulting summer weekly average limit will be 6.0 mg/L and the winter limit will be
14.1 mg/L for 1.0 MGD; 3.9 mg/1 and 8.4 mg/1 for 3.0 MGD.
In addition, an annual pollutant scan will be added such that the Permittee can collect the necessary data
required by EPA Form 2A throughout the permit term. This condition is now standard on all major
municipal permits in North Carolina.
Finally, as per the recommendations of the Asheville Regional Office, a Wastewater Management Plan
will be included as a special condition in this permit. This Plan will require the facility to address
operational problems and recommend changes to the plant.
Reasonable Potential Analysis (RPA)
The Division conducted EPA -recommended analyses to determine the reasonable potential for toxicants
to be discharged by this facility, based on DMR data from January 2000-June 2003 for both 1.0 MGD
and 3.0 MGD. Calculations included parameters listed in the previous permit and pre-treatment
documents to include: arsenic, cadmium, chlorides, chromium, copper, cyanide, lead, mercury, nickel,
silver, selenium and zinc.
Results suggest no reasonable potential at 1.0 MGD for the facility to discharge arsenic, cadmium,
chlorides, chromium, lead, mercury, nickel and selenium. Cadmium, nickel, mercury, chlorides and
lead, all currently monitored through the NPDES permit, may be eliminated from the permit, as they are
required parameters to be monitored through the Pretreatment Long Term Monitoring Plan (LTMP).
Effluent from the facility did demonstrate reasonable potential to exceed water quality criteria for
copper, cyanide, silver and zinc. Cyanide is already monitored and limited in the permit. Copper and
zinc are action level parameters, but have been identified by the Aquatic Toxicology Unit as
necessitating limits. These limits will be 40 µg/L and 339 µg/L, respectively, and monitoring will be
conducted weekly. The limits are based upon re -calculated values that take into account TSS levels for
the individual sub -basin. Silver is also an action level parameter, but will not be limited unless toxicity
can be attributed to elevated levels of silver in the effluent. Silver will be monitored twice per month in
the permit.
For the 3 MGD flow, results suggest no reasonable potential for the facility to discharge arsenic,
chlorides, chromium, lead, mercury, nickel and selenium. Nickel, mercury, chlorides and lead, all
currently monitored through the NPDES permit, may be eliminated from the permit, as they are required
parameters to be monitored through the Pretreatment Long Term Monitoring Plan (LTMP).
Effluent from the facility did demonstrate reasonable potential to exceed water quality criteria for
cadmium, copper, cyanide, silver and zinc. Cadmium and cyanide are already monitored and limited in
the permit.
1.,ct tiltci
Nil >Es N(:002: M)t)

Copper and zinc are action level parameters, but have been identified by the Aquatic Toxicology Unit as
necessitating limits. These limits will be 25 µg/L and 216 µg/L, respectively, and monitoring will be
conducted weekly. The limits are based upon re -calculated values that take into account TSS levels for
the individual sub -basin. Silver is also an action level parameter, but will not be limited unless toxicity
can be attributed to elevated levels of silver in the effluent. Silver will be monitored twice per month in
the permit.
Sulfate has been eliminated at both flows (this was in the permit at the request of the
Pretreatment Unit in case of the large textile industry relocating to Rutherfordton — since this
never took place, this monitoring requirement may be eliminated).
SUMMARY OF PROPOSED CHANGES
In keeping with Division policies, the following will be incorporated into the permit:
• New monthly and weekly average ammonia limits (both summer and winter)
• Annual pollutant scan
• Addition of Wastewater Management Plan
• Elimination of the chlorides, sulfate, nickel, mercury and lead monitoring requirements and limits
(Permittee will continue to monitor these parameters through the LTMP).
• Addition of 2/month silver monitoring
• Addition of copper limit, increase monitoring frequency to weekly
• Addition of zinc limit, increase monitoring frequency to weekly.
New Weekly Average and Daily Maximum limits are derived from the latest NC/EPA policies considering
FA Vs and allowable concentrations based on reasonable potential.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
November 4, 2003 (est.)
December 29, 2003
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Susan A. Wilson at [phone] ext. 510.
NAME: DATE:
REGIONAL OFFICE COMMENTS
Comments from the staff report and other communications have been incorporated into the permit.
NAME: DATE:
Fact Shcct
NC:00251 )t) Rc;icwaI
Pa 4

Rutherfordton DMR Data Summary
NC0025909
Jan-01
Feb-01
Mar-01
Apr-01
May-01
Jun-01
Ju1-01
Aug-01
Sep-01
Oct-01
Nov-01
Dec-01
Jan-02
Feb-02
Mar-02
Apr-02
May-02
Jun-02
Ju1-02
Aug-02
Sep-02
Oct-02
Nov-02
Dec-02
Jan-03
Feb-03
Mar-03
Apr-03
May-03
0.491
0.4625
0.546
0.42233
0.4485
0.4575
0.4841
0.4122
0.5563
0.4231
0.415567
0.481677
0.503677
0.459893
0.485968
0.4318
0.443419
0.407567
0.431319
0.425548
0.470233
0.533
0.5202
0.680871
0.45029
0.602143
0.743387
0.813733
0.862452
7.76
10.54
10.92
14.86
18.63
21.84
23.14
23.86
19.97
14.91
12.77
10.88
8.49
9.1
11.34
16.55
17.63
22.3
23.94
23.03
21.79
18.26
13.28
8.295
6.28
8.05
12.91
14.93
18.9
6.91
5.95
5.68
5.76
6.63
6.34
6.2
6.2
6.78
7.23
7.68
7.84
7.38
6.79
6.97
6.47
7.37
6.17
6.72
5.92
5.47
6.08
6.92
7.67
7.96
7.69
6.42
6.89
6.48
37.85
24.66
30
29.07
18.92
9
1
10.41
7.86
15.85
18
26.08
13.33
7.58
1.5
3.77
5.41
2.13
4.25
8.77
7.86
9
15.92
31.5
34.58
15.67
19.13
19.25
•:tilJff:•1JY::
/'( �: x: v.•rvrn��;r...
Y. l.•A %} 1: •'1OV.J:.•f �' j. ti...r. :. ••' •.• •} : .h . y!h{: J •J
A� .:Jh.. ::.•:: . .: JJ : JNrlrl. !{r.
28
14.7
22
24.6
22.6
21.1
20.3
19.4
10
14.2
13.92
24.08
15.85
32.25
13.5
2.93
6.85
4.42
4.4
3.83
7.31
10.07
9.25
14.15
22.57
31.25
18.75
9.07
8.5
1.1 0 31.9
1.3 0 43
1.3
2.1
2.9
5
32.2
7.1
2.3
1.76
1.47
2.59
3.27
4.22
2.38
3.19
2.46
1.53
3
3.95
1.33
3.35
3.23
2.78
2.15
17.59
7.26
2.18
1.93
0 25
0
0.714
0 32.8
0 40.55
0 34.6
0 29.3
0
0 37.2
0 31
0
0
0 30.85
0
0
0 33.7
0 35.4
0 33.7
0 42.9
8.67 23.5
4.85 47
0 23.5
0
0.58
0
0
39

40 12.45 21.75 3.54
36 8.55
5.44
33 4.68 13.2 1.85
2.56
0.49
33 1.31
35 2.88
29 1.82
29 1.21
2.24 7.5
31 2.99 6.8 2.48
33 4.59
0.33
0.23
27.25 0.15 3.1 1.32
0.23
0.12
27 0.24 15.8 1.29
33 0.91 13.7 1.45
32 0.93
30 1.42 11.1 3.9
35 3.65
39 3.42
35 9.14 15.3 2.3
5.84
3.64
31 3.7 13.8 1.9
3.93
7 2.6
3.22
2.3

NC0025909 Rutherfordton
Upstream
Downstream
Month
Temp (2C)
D.O. (mg/L)
Fecal
(100mL)
Conductivity
(umhos/cm)
D.O. (mg/L) Temp (QC)
Fecal
(100mL)
Conductivity
(umhos/cm)
Jul-03
19.7
7
315.3
79.1
7
19.9
394.7
90.2
Jun-03
18.2
7.7
422.2
78.5
7.7
18.7
480.7
86.6
May-03
15.7
7.2
1273.1
79.3
7.2
15.9
437.4
91.3
Apr-03
-
-
Mar-03
10.6
7.6
783.2
83.5
7.5
10.9
524.9
95
Feb-03
6.9
8.3
427.1
93
8.3
7
502
106.3
Jan-03
5.2
8.3
239.4
77
8.2
5.2
227.3
97.5
Dec-02
7.1
8.3
727.7
89.7
8.2
7.7
710.7
97.9
Nov-02
15.4
7.9
930.7
76.2
7.4
12.9
778.6
101.8
Oct-02
16.4
7.4
1469.4
86.3
7.3
16.7
1271.8
116.6
Sep-02
19.3
6.6
1041.4
93
6.5
19.7
650.4
128.9
Aug-02
20.9
6.6
847.1
94.8
6.3
21.5
727.6
165.1
Jul-02
21.5
7.7
434.4
93.3
7.6
21.9
588.8
141.7
Jun-02
19.7
7.1
443.6
89.8
7.2
20.1
406.4
125.6
May-02
16.2
7.1
292.7
122.3
7.1
16.7
239.5
133
Apr-02
-
-
Mar-02
9.1
8.3
338
85
8.3
9.4
67.9
111.3
Feb-02
6.5
8.3
241.7
88
8.3
6.7
128.6
108.5
Jan-02
6.8
8.1
417.9
83.5
8.1
6.7
33.7
108.8
Dec-01
8.3
8.3
100
87.2
8.3
8.4
93.1
127.2
Nov-01
10.1
8
80.6
90.7
8.1
10.4
110.1
125.8
Oct-01
12
7.5
273
96.1
7.4
12.5
431
114.3
Sep-01
18.1
7.3
776.6
90.6
7.3
18.4
600.5
112.2
Aug-01
20.9
6.9
244
91.8
6.8
21.4
1079.8
131.9
Jul-01
20.1
6.8
503.7
84.7
6.8
20.6
219.5
115
Jun-01
19
7.2
449.7
99.2
6.9
19.5
167.4
136.8
May-01
14.4
8.2
331.4
92.3
8.1
15.9
1783.1
117
Apr-01
13.1
6.7
601
103
6.7
13.7
1044.7
11.4
Mar-01
10.3
5.5
207.5
93.8
5.8
10.4
981.1
1590.8
Feb-01
8.1
6.3
173.8
95.6
6.3
8.5
336.6
111
Jan-01
6.7
7.4
221
90.2
7.3
7
1113.1
101
Average
13.66552
7.434483
503.70
89.91
7.37931
13.94138
556.24
162.09
Maximum
21.5
8.3
1469.40
122.30
8.3
21.9 •
1783.10
1590.80
Minimum
5.2
5.5
80.60
76.20
5.8
5.2
33.70
11.40

NC0025909
Facility: Rutherfordton WWTP
Discharge to: Cleghorn Creek, C
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (ug/I)
Fecal Limit
Ratio of 1.2 :1
Ammonia as NH3
(summer)
1.86 7010 (CFS)
1 DESIGN FLOW (MGD)
1.55 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 UPS BACKGROUND LEVEL (MG/L)
45.45 IWC (%)
37.40 Allowable Concentration (mg/I)
Ammonia as NH3
(winter)
7Q10 (CFS)
200/100mI DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (mg/I)
For Minor domestic -type facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/I (winter) NH3-N
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
1.86
1
1.55
1.0
0.22
45.45
1.94
2.88
1
1.55
1.8
0.22
34.99
4.74

NC0025909
Facility: Rutherfordton WWTP
Discharge to: Cleghorn Creek, C
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (ug/I)
Fecal Limit
Ratio of 0.4 :1
Ammonia as NH3
(summer)
1.86 7010 (CFS)
3 DESIGN FLOW (MGD)
4.65 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 UPS BACKGROUND LEVEL (MG/L)
71.43 IWC (%)
23.80 Allowable Concentration (mg/I)
Ammonia as NH3
(winter)
7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (mg/I)
For Minor domestic ype facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/I (winter) NH3-N
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
1.86
3
4.65
1.0
0.22
71.43
1.31
2.88
3
4.65
1.8
0.22
61.75
2.78

Rutherfordton Reopener (reopener request for Cu and Zn) NC0025909
Action Level Calculation 5/7/03 ? li/3/o3,,,.r
Metal Chronic AL Acutet^AL 1/2 FAV Chronic CF Acute CF Kpo alpha WQCdis(chrnc) WQCdis(ac)
Copper 7 7.3 0.96 0.96 1.04E+06 -0.7436 6.72 7.008
Zinc 50 67 0.986 0.978 1.25E+06 -0.7038 49.3 65.526
Facility Permit No. Flow 7Q10s IWC Subbasin TSS(15th ptci Cu fD=cD/cT Zn fD=cD/cT Cu C instrm Zn C instrm Cu Ac Ins Zn Ac Inst
Rutherfordton NC0025909 1 1.86 45.45 BRD02 6 3.78E-01 3.20E-01 18 154 19 205
WWTP
Rutherfordton NC0025909 3 1.86 71.43 BRD02 6 3.78E-01 3.20E-01 18 154 19 205
WWTP
Facility Permit No. Cu Limit Zn Limit (If blank, no RP to exceed the recalculated Action Level)
Rutherfordton NC0025909 40 339 (at 1.0 MGD)
WWTP
Rutherfordton NC0025909 25 216 (at 3.0 MGD)
WWTP

RE: [Fwd: Rutherrordton1
Subject: Re: [Fwd: Rutherfordton]
Date: Thu, 16 Oct 2003 16:27:26 -0400
From: [e-mail]
To: "Susan A Wilson" <[e-mail]>
OK, here ya go. Note that on the effluent limits page I have not included
a trigger for when they go to the higher flow because I don't know what you
guys agreed on. I also didn't put in the limits for copper or zinc on the
eff. limits or the fact sheet paragraph because I don't know how you calculate
tiose. I think everything else should be A -OK.
Let me know if you need me to do something else for this.
-Natalia
>-- Original Message --
>Date: Tue, 14 Oct 2003 11:10:11 -0400
>From: Susan A Wilson <[e-mail]>
>To: [e-mail]
>Subject: Re: (Fwd: Rutherfordton]
>yep. (sorry, i'll put the finger on Dave for that).
>Natalie.Sierra&ncmail.net wrote:
» SO do you want me to calculate the limits and do an effluent limits page
» for the other flow?
> >-- Original Message --
» >Date: Mon, 13 Oct 2003 11:25:50 -0400
» >From: Susan A Wilson <[e-mail]>
» >To: Natalie Sierra <[e-mail]>
» >Subject: (Fwd: Rutherfordton]
» >
» >
» >
» >--- Start of the Attached Message ---
» >
» >Date: Mon, 13 Oct 2003 11:22:22 -0400
» >From: Roger Edwards <[e-mail]>
» >To: Susan A Wilson <[e-mail]>
» >CC: Forrest Westall <[e-mail]>,
» > Dave Goodrich <[e-mail]>
» >Subject: Re: Rutherfordton
» >
» >
» >Susan,
» >
» >If it is OK I would like to go with the 1.0 & 3.0 MGD limits pages for
>Town
» >of Rutherfordton NPDES permit.
» >
» >Thanks,
» >R. Edwards
» >
» >Susan A Wilson wrote:
» >
» » Dave-
» »
» » Just saw a note in the file from Roger and Forrest regarding the request
» » to drop Rutherfordton's flow down from 3 MGD to 1 MGD and do a tiered
» » permit because of their loss of industries. (sorry - don't think
» » Natalie knew about this when she was drafting it). I think their max
» » monthly flow has been 0.86 (May 03). I don't have a problem with this
I nf2_
I0/20/03 5:04 PM

Re: [Fwd: Rutherfordton]
» » if they are in agreement to the 1 MGD (and we can put the 80% language
» » in there like Spindale's).
» »
» » This may affect their RPA for Cu/zn (change in IWC) - don't know yet
>(if
» » so - we'll have to discuss)
» »
» » Natalie - I'll reconfirm with Roger about this flow before getting
back
» » with you about re -doing for 1 & 3 MGD. Roger and I were talking about
» » 1.5 MGD and 3 MGD the other day.
» »
» » Susan
» >
» >--
» >Roger Edwards - [e-mail]
» >North Carolina Dept. of Environment and Natural Resources
» >Asheville Regional Office
» >Division of Water Quality - Water Quality Section
» >59 Woodfin Place
» >Asheville, NC 28801
» >Tel: [phone]
» >Fax: [phone]
» >
» >
» >Attachment: Roger.Edwards.vcf
» >
» >--- End of the Attached Message
» >
DRutherfordton Aquatic Life RP 1MGD.xls
Name: Rutherfordton Aquatic Life
RP_1MGD.xls
Type: Microsoft Excel Worksheet
(application/vnd.ms-excel)
Encoding: base64
Download Status: Not downloaded with message
Rutherfordton draft 1 MGD effluent page.doc
Name: Rutherfordton draft_1MGD effluent
page.doc
Type: Microsoft Word Document
(application/msword)
Encoding: base64
Download Status: Not downloaded with message
Rutherfordton paragraph for fact sheet.doc
Name: Rutherfordton paragraph for fact
sheet.doc
Type: Microsoft Word Document
(application/msword)
Encoding: base64
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10/20/03 5:04 PM

IMPORTANT ISSUES: RUTHERFORDTON
10/14/03
NC0025909
I. # of times the Town the Town has requested additional time to complete TIE work:
1. 1/24/02 Nadine called KB and requested additional time to submit TIE work due to snow.
Additional time granted till 2/1/02. (our 2/14/02 memo cited disappointment with
amount of time passed, clarification of metal spiking and notification that the
Town remains subject to Cu/Zn AL Policy. The Town was given a break)
2. 4/23/03 Ltr from Karen Andrews to Susan Wilson requesting additional time. Ltr notes
that TIE testing will commence for the three month period from 5/03-7/03 using
TIE for toxic effluent and metal spiking for non -toxic effluent.
3. 5/12/03 Ltr from Karen Andrews to Susan Wilson requesting time extension till end of
October 2003 to complete work
4. 8/13/03 Ltr from Karen Andrews to Susan Wilson requesting more time to conduct TIE
study.
II. # of times the Town indicated that they would commence TIE testing of toxic
effluent:
1. 1/30/02 Ltr from Karen Andrews to Matt indicating TIE Testing will commence with
toxic effluent. (additional n/c events in 4/02, 7/02, 8/02 (TIE), 1/03, 2/03 and
3/03 (TIE?)
2. 11/18/02 Ltr from Karen Andrews to ATU concerning receipt of our 10/23/02 RP II NOV.
Ltr notes that TIE testing will commence with toxic effluent. Ltr transmits 8/02
TIE results (inconclusive — attributed to sample hardness issues from polymer
usage)
3. 4/23/03 Ltr from Karen Andrews to Susan Wilson referencing our 3/7/03 request to
Goodrich to reopen permit and include cu/zn permit limits. Ltr notes TIE testing
in 3/03-WHERE ARE RESULTS?. Could have performed metal spiking in
11/02, 4/03 and 7/03). Town states that they "will proceed with" toxicity testing
(TIE for toxic effluent AND metal spiking for non -toxic effluent) for period 5/03-
7/03. WHERE ARE TEST RESULTS? Additional time requested to complete
TIE studies.
III. # memo/ltrs from ATU concerning TIE work:
1. 9/26/01
2. 2/14/02
Ltr from Matt to Karen Andrews acknowledging Nadine's fax of 9/18/01. Ltr
specifies report format and notes that TIE test should be performed during 3
separate testing months during the nine month period. Final report due 1/24/02
memo from Kevin to Goodrich concerning Town's submittal. Memo cited
disappointment with amount of time passed, clarification of metal spiking and
notification that the Town remains subject to Cu/Zn AL Policy.

3. 1/23/03 memo from Kevin to Goodrich concerning 8/02 TIE testing and the technical
issues that resulted. Memo states that TIE testing should commence upon next
toxicity test failure.
4. 3/7/03 memo from Kevin to Goodrich citing past missed opportunities to conduct '1'1E
testing of toxic effluent. Ltr notes that if TIE test results are inconclusive, identify
cu/zn as causes of toxicity or if TIE work is not conducted on a sample that fails
to achieve compliance with WET permit limit, then our office will recommend
the permit be reopened. Town has not taken advantage of TIE testing
opportunities. We have been flexible in this situation but must remain consistent
in our response. Recommend the permit be reopened to include cu/zn permit
limits.
5. 5/29/03 ltr from MM to Karen Andrews noting that our office is working with Permit Unit
on the issue of time extension
6. 6/23/03 ltr from MM to Karen Andrews granting time extension till 8/31/03 to complete
TIE work
7. 10/1/03 memo from Kevin to Goodrich noting that an effluent sample was collected on
8/20/03 and the information presented in the submittal does not rule out cu and zn
as causative effluent toxicants. Town has missed opportunities to conduct TIE
testing. We stand by our previous recommendation to reopen the Permit and
include cu and zn limits.
IV. # of times the town was notified that "spiking" of non -toxic samples is acceptable:
1. 2/14/02 Memo from Kevin to Goodrich mentioning that ATU spoke with facility's
toxicity consultant in 9/01 concerning spiking of tox samples.
2. 10/23/02 RP II NOV to facility
3. 1/23/03 memo from Kevin to Goodrich concerning 8/02 TIE results.
4. 3/7/03 memo from Kevin to Goodrich to reopen permit
5. 4/16/03 ltr from Botts to Nadine Blackwell
6. 4/23/03 ltr from Karen Andrews to Susan Wilson referencing our 3/7/03 request to reopen
the permit and include cu/zn permit limits
7. 10/1/03 memo from Kevin to Goodrich
8. 8/13/03 ltr from Karen Andrews to Susan Wilson requesting more time to conduct TIE
studies.

Town of Rutherfordton (Copper/Zinc)
Subject: Town of Rutherfordton (Copper/Zinc)
Date: Thu, 09 Oct 2003 14:56:11 -0400
From: [e-mail]
To: [e-mail], [e-mail]
Susan and Dave,
I recently received a memo from Kevin Bowden and Matt Matthews to your
office regarding the Toxicity Identification Evaluation (TIE) for the
Town of Rutherfordton and Kevin's request that the permit be reopened to
include copper and zinc limits. There are five memos and letters since
January 23, 2003 which discusses toxicity concerns relating to copper
and zinc. The latest memo dated October 1, 2003 discusses the TIE and
copper and zinc as causative effluent toxicants. The last sentence in
the memo states that "Our office stands by our previous recommendation
to reopen the NPDES permit and include copper and zinc permit limits."
I am aware of the state's Copper and Zinc Action Level Policy. In
reference to the policy and Kevin Bowden's suggestions, I would like to
know what the state plans to do with regards to toxicity failures and
the possibility of a permit modification to include copper and zinc
limits.
Thanks,
Madolyn Dominy
[e-mail]
[phone]
1 of 1
10/9/03 3:13 PM

DIVISION OF WATER QUALITY
October 1, 2003
MEMORANDUM
To: Dave Goodrich
Through: Matt Matthews ff`rN
From: Kevin Bowden 66
Subject: Toxicity Identification Evaluation
DWQ's Copper and Zinc Action Level Policy
Town of Rutherfordton WWTP
NPDES No. NC0025909
Rutherford County
OCT - 3 2003
Our office received a Toxicity Identification Evaluation report from the Town of
Rutherfordton dated 9/10/03 concerning the Town's efforts to rule out copper and zinc as
causative effluent toxicants. The information package was received by our office on 9/12/03.
The report notes that an effluent sample was collected on 8/20/03 and submitted to
Meritech, Inc. for metal analyses and effluent manipulation. Effluent sample copper and zinc
concentrations measured 6 ug/L and 30 ug/L, respectively.
A toxicity test was initiated on 8/27/03 with 0.5 mg/L and 3.0 mg/L EDTA and Sodium
Thiosulfate. Effluent percent reduction (control versus treatment reproduction) measured
18.97% in the 8/20/03 sample and 18.01% in the 8/27 toxicity test. The report notes that EDTA
and Sodium Thiosulfate addition at 0.5 mg/L produced a 20.30% and 19.92% reduction from the
control, respectively. EDTA and Sodium Thiosulfate addition at 3.0 mg/L produced a 40.99%
and 24.90% reduction from the control, respectively. The facility attributes an increase in
toxicity at 3.0 mg/L EDTA and Sodium Thiosulfate to unbound EDTA and Sodium Thiosulfate.
The facility believes that copper and zinc did not contribute to effluent toxicity and mentions that
copper and zinc concentrations measured in the sample were below EPA's Water Quality
Criteria(1986) of 12 ug/L and 47 ug/L, respectively.
The 8/20/03 sample will be spiked with known concentrations of copper and zinc to
determine the concentration at which copper and zinc would affect aquatic life in the receiving
stream.
We question why the facility did not conduct TIE work at 100% effluent, knowing that
18.97% reduction and 18.01% reduction (control versus treatment reproduction) were present in
samples at 71% effluent concentration.
The Town has been afforded sufficient time to produce data that would rule out copper
and zinc as causative effluent toxicants. The information in this submittal does not rule out

Page 2
Town of Rutherfordton
October 1, 2003
copper and zinc as causative effluent toxicants. The Town was granted additional time to
complete TIE work (from 7/23/03 to 8/31/03). The Town, in past correspondence to the
Division, indicated that they would commence TIE work when effluent samples exhibited
toxicity. Several opportunities to commence testing of toxic effluent samples were missed. Our
office stands by our previous recommendation to reopen the NPDES Permit and include copper
and zinc permit limits.
Please feel free to contact me or Matt at 733-2136 if you have questions.
cc: Coleen Sullins -Deputy Director, DWQ
Forrest Westall-Asheville Regional Office
Keith Haynes -Asheville Regional Office
Susan Wilson-NPDES Unit
Pretreatment Unit-DWQ
Jimmie Overton-ESB
Karen Andrews, Town of Rutherfordton, 134 N. Washington Street, Rutherfordton, NC 28139
Madolyn Dominy, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta,
Georgia 30303
Aquatic Toxicology Unit Files
Central Files

TOWN OF RUTHERFORDTON
" /f2€ dte44 r al the heiistal Belt"
Town Hall I20r—North_Main Street
Rutherfordtoii, NC28139
828/287-3520' ;';FAX'828/286-8054
September 10, 2003
Sally Lesher
MAYOR
Christy Bare
Jimmy C. Dancy
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin, Librarian
CERTIFIED MAIL/RETURN RECEIPT
nr.1
NCDENR
Aquatic Toxicology Unit
Attn: Matt Matthews
1621 Mail Service Center
Raleigh, NC 27699-1621
Dear Mr. Matthews:
Enclosed is the Toxicity Identification Evaluation Study for the Town of
Rutherfordton's wastewater treatment plant. The study was conducted to rule
out copper and/or zinc as potential cause(s) of effluent toxicity. The study was
conducted on an effluent sample collected on August 20, 2003.
If you have any questions, please call me (828 287-3520).
Sincerely,
TOWN OF RUTHERFORDTON
Karen E. Andrews
Town Manager
KEA/em
cc: Nadine Blackwell
Paul Rhodes
11;;() _ STALL
e() - 5'u5AN wi1SoN
//3
CA4
c1 /,,,aq /63 0I"1,1
RECEIVED
SEP 1 2 2003
Environmental Sciences Brandt

TOWN OF RUTHERFORDTON
WASTEWATER TREATMENT PLANT
NPDES Permit No. NC0025909
TOXICITY IDENTIFICATION EVALUATION
as required by the
COPPER AND ZINC ACTION LEVEL POLICY
September 2003
RECEIVED
SEP 12 2003

TOXICITY IDENTIFICATION EVALUATION
as required by the
COPPER AND ZINC ACTION LEVEL POLICY
INTRODUCTION
The Town of Rutherfordton wastewater treatment plant is required by its NPDES Permit
to test for toxicity in accordance with the test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure", revised November 1995, or
subsequent revision. The effluent concentration at which there is to be no observable
inhibition of reproduction or significant mortality is 71.0%. On January 22, 2001 a
sample was collected and analyzed for toxicity. The result of the test was a failure due
to significant mortality and zero reproduction. As a result, the North Carolina
Department of Environment and Natural Resources (NCDENR) required the Town to
conduct a study to determine if copper and/or zinc were the causative(s) of the toxicity
failure.
METHOD AND MATERIALS
The Town of Rutherfordton chose to conduct a Toxicity Identification Evaluation (TIE),
to determine if copper and/or zinc were potential cause(s) of toxicity. Attachment I
provides a detailed description of the test method. The test method was approved by
NCDENR on September 26, 2001.
RESULTS AND DISCUSSION
An effluent sample was collected on August 20, 2003 and sent to Meritech, Inc. for
analysis in accordance with Attachment I. The effluent sample was non -toxic. Different
treatments were set up and toxicity testing was conducted using different concentrations
of EDTA and Sodium Thiosulfate. Please see the Analytical Report Cover from
Meritech which provides a detailed desciption of the test and summary of findings.
Since the effluent sample was non toxic, the laboratory is proceeding with spiking
concentrations of copper and zinc into the effluent sample. As soon as those results
are available, a copy will be provided to the State.
RECEIVED
SEP 1 2 2003
Environmental Sciences &arch

ATTACHMENT I
Toxicity Identification Evaluation to Rule Out Copper and/or Zinc as
Causes of Effluent Toxicity
Proposal of Study
The EPA has established procedures for bench -scale treatments of effluent that
categorically identify sources of toxicity (EPA 1992). Two of these Phase I Toxicant
Identification Evaluation procedures are designed to identify the contribution of cationic
metals to effluent toxicity: sodium thiosulfate addition and EDTA addition. Both
treatments encompass application of two concentrations of each chelating agent.
Specific evidence that copper and/or zinc are sources of toxicity are indicated as
follows:
• Copper is a potential source if toxicity is removed or reduced by addition of
sodium thiosulfate and EDTA.
• Zinc is a potential source if toxicity is removed or reduced by addition of EDTA.
To address concerns that copper and/or zinc are contributing toxicity to the effluent of
concern, the treatments noted above are applied to three unique composite effluent
samples collected over a period of several months. Untreated and treated samples are
analyzed for toxicity, hardness, total recoverable copper and zinc, and total dissolved
copper and zinc.
Reference
United States Environmental Protection Agency. Toxicity Identification Evaluation:
Characterization of Chronically Toxic Effluents, Phase I. EPA/600/6-91/005F. May
1992. EPA Office of Research and Development. Washington, D.C.

U7/UY!LUUJ J.J...r
J JUJY LJ.JLt
MERITECH, INC
ENVIRONMENTAL LABORATORIES
A Division of Water Technology and Controls, Inc.
Rutherfordton WWTP is required by the state of North Carolina to
demonstrate that its effluent's toxicity is rot caused by copper and zinc. Meritech
Inc., conducted this study on an effluent sample collected on August 20th, 2003.
The sample was first analyzed for metals. The results are presented. in
Attachment A.
The toxicity test was initiated on August 27th, 2003• The test consisted of a
control and five treatments, each with ten replicates. Rutherfordton's WWC of 71%
was the effluent concentration used in all of the treatments. The treatments were
as follows:
• Treatment #1: 71% effluent (used only to check toxicity)
• Treatment #2: 71°% effluent + 0.5 mg/L of EDTA
• Treatment #3: 71% effluent + 3.0 zing/L of EFTA
• Treatment #4: 71% effluent + 0.5 mg/L of sodium thiosulfate
• Treatment #5: 71.% effluent + 3.o mg/I, of sodium thiosulfate
Toxicity data is presented in Attachment B. In treatment #1, an i.8.oi%
reduction (from the control) in reproduction was observed. A similar reduction
of 18.97% was observed in toxicity test that was conducted on August 22nd, 2003
(Attachment C). In treatments #2 and #3, a 20.30% and 40.99% reduction (from
the control) in reproduction were observed, respectively. In treatments #4 and
#5, reductionsa in reproduction od the Rutherfordton dWWTP effluent indicates that zinc
Metalre noted.
analysis � L respectively.
and copper were present at concentrations of 30 µg/L and 6 µb/ res p y
The I.OEC values for these metals as cited in the EPA's Quality Criteria for Water
(1986) are 47 µg/L and 12 µg/L. Since the zinc and copper concentrations found
in the effluent sample are lower than the LOEC values, it is unlikely that these
metals caused any toxicity. Although the untreated effluent sample did show a
reduction in reproduction, it was not significant. Treatments #3 and #5 indicated
toxicity. However, this toxicity can be attributed to unbound EDTA and sodium
thiosulfate.
RECEIVED
SEP 1 2 2003
Environmental Sciences Branch
642 Tamco Road • P,O. Box 27 • Reidsville, NC 27320
[phone] • [phone] Fax

Sample Name: 082104 Ruthertordton Acquired: 08/21/2003 13:32:11
Method: IRIS REG 3 Mode: CONC Corr. Factor: 1.000000
User: adman Custom ID1: Custom ID2: Custom iD3:
Comment:
Type: Unk
Elem A13944 Sb2068 As1890 Ba4554 Be3131 B_2089 Cd2288 Cr2677
Units ppm ppm ppm ppm ppm ppm ppm ppm
Avg .0624 -.0006 .0073 .0124 .0000 .1372 -.0002 .0014
Stddev .0010 .0012 .0033 .0000 .0000 .0019 .0001 .0001
%RSD 1.641 217.2 44.90 .2187 73.97 1.350 60.87 9.344
#1 .0628 .0006 .0090 .0124 .0000 .1391 -.0002 .0013
#2 .0613 -.0019 .0035 .0123 .0001 .1369 -.0001 .0015
#3 .0632 -.0004 .0094 .0124 .0000 .1354 -.0003 .0013
Eiem Co2286 Cu3247 Fe2599 Pb2203 Mn2578 Mo2020 Ni2316 Se1960
Units PPm o.eo? ppm ppm PPm ppm ppm PPm PPm
Avg .0013 01', 1 ' .0062 .0639 -.0026 .0147 .0061 .0005 .0009
Stddev .0002 .0002 .0008 .0020 .0001 .0006 .0002 .0007
%RSD 12.18 2.449 1.213 76.44 .9481 9.261 36.85 72.74
Al__ _ .0015 - _ _ .0063 - ,0647 -.0004 .0146 .0054 .0007 .0005
#2 .0012 .0062 .0632 -.0042 .0146 .0062 .0004 .0006
#3 .0012 .0060 .0639 -.0033 .0148 .0065 .0004 .0017
Elem Ag3280 111908 Sn1899 113383 14_2924 Zn2138
Units PPm ppm PPm PPm PPm 0.010 PPm
Avg .0013 .0038 -.0025 .0027 .0024 mitt- .0297
Stddev .0008 .0014 .0021 .0001 .0006 .0001
%RSD 43.42 36.09 83.06 2.459 . 23.80 .4428
#1 .0013 .0039 -.0039 .0027 .0031 .0295
#2 .0019 .0052 -.0034 .0028 .0022 .0298
##3 .0007 .0024 -.0001 .0027 .0020 .0297
Int. Std. Sc2273 Sc3353
Units Cts/S Cts/S
Avg 22.154 543.44
Stddev .166 4.74
%RSD .74954 .87265
##1 21.970 537.97
#2 22.197 646.22
#3 22.294 548.14
RECEIVED
SEP 1 2 2003
ErnlronmenMal Sciences Branch
gePoirre b VA LEseS
Z7 30A'pi-
d ()e. 1010 t�tea "
� • 0 , E. C..wtcr� 19.1b
2 1-4-
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DES#:
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7
Total
?HrwFokb7Ai
1
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2
3.
M e.ritec h
Ceriodaphnia Chronic Reproduction Data Sheet
4
Start Date:
End Date:
Replicates
5
6
Time: ! s Ztc Ff"
Time: ; Sal
Reviewed by:
$ 9 10 %3rd Brood
511
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Total
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FaCility: RUTHSRPORDTON WWTP NPDES#=•NCO025902
Laboratory performing Test: MERITECH LASS, INC.
X
X
Ignature ot P re a. Yn Reepcns a arge
mature ot La
Work Order:
5upe=vsor
MA!L ORIGINAL TO:
North Carolina ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test
1 2 3 4 5 6 7 8 9 10 11 12
CONTROL ORGANISMS
# Young Produced
Adult (L) ive (D) ead
26
26
25
17
22
22
24
22
L
24
24
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 08/29/03
Pipe#: County: RUTHERFORD
Comments:
* PASSED: 18.974 Reduction *
Environmental Sciences Branch
Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Chronic Test Results
Calculated t 3.351
Tabular t = 2.552
t Reduction = 18.97
--Effluent Effluent % 711----- -- -
TREATMENT 2 ORGANISMS 1
# Young Produced
18
3
21
Adult (L) ive (D) ead
PH
1st sample
Control 8.01 8.00 8.00
Treatment 2 7.32 7.58 7.33
s
t
a
r
t
1st sample
D.O.
Control 7.71 7.11
Tretment 2 7.77 7.07
LC50/Acute Toxicity Test
L
21 16
L L
14
6 7 8 9---10 11.- 12
22
23 17
15
L D ID
21
1st sample 2nd sample
8.01
7.60
8.0018.00
7.34I7.57
s s
e t e t e
n a n
d a d r d
t
let sample 2nd sample
7.71 7.10
7.75 7.01
(Mortality
7.61
7.67
6.97
6.90
% Mortality
Avg.Reprod.
0.00
Control
23.20
Control
30.00
Treatment 2
18.80
Treatment 2
Control CV
11.458%
control Orgs
broducing 3rd
rood '
100%
PASS FAIL
X
check One
Complete This For Either Test
Test Start Date: 08/22/03
Collection (Start) Date
Sample 1: 08/19/03 Sample 2: / /
Sample Type/Duration
Sample 1
Sample 2
Grab
Comp.
Duration
24 hrs
hrs
D
I
L
T
2nd
let P/F
S S
A A
M M
P P
Hardness (mg/1) 46
Spec. Cond . (jhmhos) 188
Chlorine(mg/1)
Sample temp. at receipt(°C)
273
40.1
0.5
expressed as %, Combining replicates)
.% $
$I %
%I %
LC50 =
95% Continence Limits
Concentration
Mortality
Method of Determination
Moving Average Probit
Spearman Karber Other
rganism
Tested: Ceriodaphia dubia
start/end
Note: Please
Complete This
Section Also
Control
High
Conc.
PH
Duration (hrs) :
Copied from DWQ form AT-1 (3/87) rev. 11/95 (DUSIA ver. 4.41)
50/50 39Vd
HO31Ihl3W
ZZSZZ1E9EC
start/end
ED
SEP 1 2 2003
Envircomantal Sciences Branch
85:EZ 600Z/80/60

Rutherfordton
• • Subject: Rutherfordton
Date: Fri, 22 Aug 2003 15:21:57 -0400
From: Matt Matthews <[e-mail]>
To: Susan A Wilson <[e-mail]>
CC: Dave Goodrich <[e-mail]>, Kevin Bowden <[e-mail]>
Susan,
Kevin and I have reviewed Rutherfordton's letter and recommend we stick by our last extension date of
August 31 for submittal of TIE work. We have not received any data from the facility. According to our
action level policy, we should apply limits for copper and zinc to the new permit.
The facility initially became affected by the policy in April of 2001. Since that time, they have had ten
toxicity failures.
In a letter dated 1/30/02 representatives of the facility indicated that they would initiate TIE work when a
toxicity test results in a failure. There have been six such failures since that time, including three in the first
three months of this year. Still, we have not seen any results from TIE work.
As you can imagine, our level of frustration with this facility is quite high. We feel we've already been
highly flexible about this. Our perception is that the facility did not want to spend any money on this issue
and were hoping it would go away.
I believe there is also a fairness issue here. A good number of operators have buckled down and done the
appropriate work to address this issue and have either taken a limit when appropriate or submitted the data
necessary to avoid a limit. I hope we don't end up giving Rutherfordton a free ride.
Matt Matthews
NC DENR/Division of Water
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina
Quality
27699-1621
v-[phone]
f-[phone]
MailTo:[e-mail]
http://www.esb.enr.state.nc.us
1 of I 8/22/03 3:53 PM

TOWN OF RUTHERFORDTON
"The clie.a41 of the Theunal &II"
Town Hall • 129 North Main Street
Rutherfordton, NC 28139
828/287-3520, • FAX [phone]
August 13, 2003
Sally Lesher
MAYOR
Christy Bare
Jimmy G. Dancy
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin. Librarian
CERTIFIED MAIL/RETURN RECEIPT REQUESTED
Ms. Susan Wilson
DWQ/NPDES Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Rutherfordton
NPDES Permit No. NC0025909
Dear Ms. Wilson:
£OOZ 5 t 9nb
On June 23, 2003, the Town received a letter from Mr. Matt Matthews granting the
Town an extension to conduct Toxicity Identification Evaluation. The Town appreciates
the Division's decision to extend the due date of the TIE report to August 31, 2003.
Since my last letter to you, the Town has been impacted by the closing of a major
portion of the Broyhill operation, our largest industrial wastewater customer. The
portion of the industry that closed represented approximately 12.62% of the Town's
wastewater revenue.
As you are aware, the Town of Rutherfordton was given specific options to demonstrate
that copper and zinc were not the cause of our toxicity failures. These options were:
1. Instream measurements of dissolved metal during low flow conditions that
demonstrate compliance with the Action Level standard.
2. A revision of the prospective permit limit using improved inputs that in
concert with existing or additional monitoring data demonstrates
compliance with the Action Level standard.
3. Toxicity Identification Evaluation (TIE) results that definitively rule out
copper and/or zinc as causes of effluent toxicity.
4. Demonstration by an alternative method approved by the Division and
EPA that copper and/or zinc is not the cause of toxicity.

Page 2
Ms. Susan Wilson
August 13, 2003
As you are aware, the first two options can only be done when Cleghom Creek is at its
point of low flows. Option 3 could feasibly cost the Town over $10,000.00. Therefore,
the Town committed to Option 4, conducting a Toxicity Identification Evaluation by using
EDTA and sodium thiosulfate additions to the treated samples. Cooper is indicated if
toxicity is reduced by addition of EDTA and sodium thiosulfate and Zinc is evident if
toxicity is reduced by the addition of EDTA. The Town has spent approximately
$10,000.00 to try to meet the Division's requirements. None of the test results
conclusively demonstrated that copper and zinc were not the cause of the toxicity
failures. In addition, this testing can only be conducted on effluent that is toxic. As
noted in our previous letter, the Town does not have a history of consistently failing its
toxicity test.
The Division informed the Town that an alternative option would be acceptable due to
the inconsistent toxicity failures by spiking known concentrations of copper and zinc into
the effluent. The Town received a price quote of over $9,000.00 to conduct this testing.
The Town has consulted with B. P. Barber Associates, Inc. to assist the Town in
evaluating any necessary modification to its wastewater treatment plant. B.P. Barber
has advised the Town to modify the wastewater treatment plant by downsizing the
aeration basin at the plant. This project will cost the Town approximately $350,000. We
hope to initiate this project as soon as possible. Upon completion of the modification
the Town believes it will be able to consistently meet all of its NPDES Permit limits
including toxicity. Due to the current oversizing of the wastewater treatment plant, the
Town has operational challenges that adversely affect our ability to maintain a good
MLSS, the nitrification/denitrification process, and solids management.
The Town is proceeding with the TIE study and is anticipating results by the week of
August 25. The Town is again requesting additional time to conduct two additional tests
as required by the DWQ Copper and Zinc Action Level Policy. The Town is faced with
some significant financial constraints and decisions that will affect all of its citizens. The
Town of Rutherfordton is a small community of approximately 4,200 people. Our
industrial base consists of a minimal number of small businesses of which only one of
the businesses is a Significant Industrial User. The inclusion of copper and zinc limits
will significantly affect our Pretreatment Program and ability to attract large industrial
customers because of the low copper and zinc limits that we will have available to
allocate to them.

Page 3
Ms. Susan Wilson
August 13, 2003
Again, the Town respectfully requests the Division to grant the Town more time to
conduct the TIE Study. As noted previously, the Town did not anticipate the closing of
one of its major financial wastewater contributors when the Town previously requested
an extension for the Study period. In addition, the Town would appreciate any cost-free
assistance or technical support in resolving this matter. I would like to thank you in
advance for your consideration in this matter; we anxiously await your reply. If you
require additional information, please advise.
Sincerely,
TOWN OF RUTHERFORDTON
7.,te.t./1,,;"
Karen E. Andrews
Town Manager
cc: Gary Stainback, Hydro Management
Paul Rhodes, Hydro Management
Robert Whitaker, B P Barber
Louis Nanney, Town Attorney

TOWN OF RUTHERFORDTON
.41
"The ew�t e fthe Thvzonal Belt"
Town Hall • 129 North Main Street
Rutherfordton, NC 28139
828/287-3520 • FAX [phone]
June 18, 2003
Sally Lesher
MAYOR
Christy Bare
Jimmy G. Dancy
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver. Finance Ofticer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin, Librarian
CERTIFIED MAIL/RETURN RECEIPT REQUESTED
Mr. Charles Weaver
DWQ Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit No. NC0025909
Rutherford County
Dear Mr. Weaver:
JUN 1 9 2003
This correspondence is in reference to our NPDES Permit Renewal Application
submitted to your office on January 17, 2003. Since the submittal of the Application, the
Town was notified that one of our larger industrial users will be going out of business.
This industry represents approximately 12.62 percent of the revenue in the Town's
sewer enterprise budget and approximately 5% of the wastewater treatment plant's flow
volume. In June 1999, the Town of Rutherfordton upgraded the wastewater treatment
plant from a 1.0 MGD lagoon treatment facility to a 3.0 MGD activated sludge treatment
facility. This upgrade to the plant was implemented to accommodate the request of a
textile industrial user that was to discharge over 1.0 MGD of process wastewater. The
textile industrial user was unable to demonstrate to the Town that their discharge would
not cause toxicity failures at the Town's wastewater treatment plant. As a result, the
industry did not move to Rutherfordton and the Town is not receiving the anticipated 1.0
MGD of industrial process wastewater. Currently, the average effluent discharge from
the Rutherfordton WWTP is 0.5 MGD.
We are requesting modifications to our NPDES permit based on the changes in our
industrial customers. First, we are requesting a tiered permit which would include
sampling and monitoring at a permitted flow of 1.0 MGD, 2.0 MGD, and 3.0 MGD.
Second, we are requesting that the following parameters be deleted from our permit:
Chloride, Sodium, and Sulfate. Lastly we are requesting relief from having to use EPA
1631 test method for Mercury testing.

Mr. Charles Weaver
June 18, 2003
Page 2
Our current permit is based on the Town discharging 3.0 MGD. As noted above, the
Town discharges on a monthly average approximately 0.500 MGD of wastewater. With
a tiered permit, at 1.0 MGD, the Town could be classified as a Modified Pretreatment
Program and subsequently be relieved of the costly Headworks Analysis sampling and
monitoring. In addition, the Town is hoping the effluent parameter limitations would be
based on the instream waste concentration (IWC) to Cleghorn Creek for each of the
permitted flow levels. Currently, the permit indicates that at a permitted flow of 3.0
MGD, the IWC is 71%. The Town would expect the IWC to be less than 71% if the
permitted flow was 1.0 MGD or 2.0 MGD.
It is our understanding that Chloride, Sodium and Sulfate were included in the NPDES
Permit based on the potential discharge from the textile industrial user. Since the
industrial user is not discharging to the treatment plant, the Town is requesting these
parameters be deleted from the permit. The Town does not expect to receive any
textile industrial wastewater in the near future.
In reference to Mercury, a review of our effluent data since January 2000 indicates that
Mercury is not present in the discharge. All of the mercury values have been reported
as less than 0.0002 mg/I. In addition, the NPDES Permit does not contain a permit
limitation for Mercury. By requiring the Town to sample using test method 1631, our
cost for mercury testing will increase from $60.00/month to $500.00/month. We are
requesting approval to continue testing Mercury in accordance with EPA test Method
245.1.
The Town of Rutherfordton, as many other North Carolina municipalities, is facing
serious financial challenges. We are respectfully requesting the North Carolina Division
of Water Quality to consider our requests. The Town of Rutherfordton is committed to
environmental compliance and protection of the receiving waters. We are requesting
relief from any unnecessary sampling and monitoring.
If you require additional information or form(s) to be completed please contact me at the
above address or by phone [phone] ext 1213. Thank you.
Sincerely,
TOWN OF RUTHERFORDTON
Karen E. Andrews
Town Manager
KEA/nb
cc: Roger Edwards, DWQ-Ashville Regional Office
Gary Stainback, Hydro Management Services
Paul Rhodes, ORC W tNTP

TOWN OF RUTHERFORDTON
"Tile Gllecatie j ate Theizo ,l belt"
Town Hall • 129 North Main Street
Rutherfordton, NC'28139
828/287-3520 • FAX [phone]
May 12, 2003
Sally Lesher
MAYOR
Christy Bare
Jimmy G. Dancy
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, 'Town Clerk/Tax Collector
Randall M. Greenway, Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin, Librarian
CERTIFIED MAIURETURN RECEIPT REQUESTED
Ms. Susan Wilson
DWQ/NPDES Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Rutherfordton
NPDES Permit No. NC0025909
Dear Ms. Wilson:
MAY 1 3 2003
In reference to my letter dated April 23, 2003, the Town of Rutherfordton would like to
readdress those issues. Last week the Town was notified that our largest industrial
sewer user would be closing at the end of June 2003. With the closing of this industry,
this leaves no industrial sewer user on the Town's collection system and a very large
loss of revenue in our Sewer Enterprise Fund.
We respectfully request some time to assess our options concerning the sewer plant
operation and a delay in the Toxicity Identification Evaluation (TIE) testing concerning
Toxicity, Copper and Zinc. If possible we request a delay in the testing until fall 2003,
perhaps October 2003.
Please advise us at your earliest convenience if this is acceptable with your unit. We
thank you for understanding how the Toss of this flow and revenue will adversely affect
the Town and its sewer operation.
Sincerely,
TOWN OF RUTHERFORDTON
Karen E. Andrews
Town Manager
KEA/em
cc: Nadine Blackwell
Paul Rhodes

Re: Town of Rutherfordton NC0025909
•
.
;> ,r•,. :.;......:ter: <. ,..
.....:.....
............:::.:.
ordtonk .
To: Roger Edwards <Roger.Edwardsncmail.net>, Charles Weaver <Charles.Weaver
CC: Forrest Westall <[e-mail]>
Roger, thanks for keeping me in the loop. I did not know about the renewal,
but Charles, I will send you a completed Pretreatment Information form
today.
Roger is correct that there is only one SIU, a small metal finisher called
Color Works. The Town had originally expanded the plant to 3.5 MGD to be
able to handle a large 1.5 MGD textile dyeing operation, but they never did
move in the dyeing. Next, the textile company talked about moving in a 0.4
MGD bleaching operation, but even that never happened. They did move in a
weaving operation (no process discharge, so not an SIU), and I assume that
is the operation Roger is saying will now close.
Please cc: me on the draft permit. Thanks!
Roger Edwards wrote:
> Charles,
> The Town of Rutherfordton NPDES permit is up for renewal and you should
> have the staff report from ARO. I have some new information that should
> be considered in the permit renewal. The Town is going to lose an
> industry the employees 500 people my mid July 2003. This is domestic
> flow only but will have an effect on the WWTP. Can we do a tiered
> permit, on the order of the Town of Spi ndal e, begin the permitted flow
> at 1.0 MGD to 3.0 MGD. The Town has a pretreatment program for a very
> small categorical industry that is still in business at this time. If
> we can do this tiered permit the monitoring will remain a 3 times per
> week instead of going to daily. If you have any questions let me know.
> Thanks,
> R. Edwards
> --
> Roger Edwards - [e-mail]
> North Carolina Dept. of Environment and Natural Resources
> Asheville Regional Office
> Division of Water Quality - Water Quality Section
> 59 Woodfin Place
> Asheville, NC 28801
> Tel: [phone]
> Fax: [phone]
1 of 1 5/12/2003 6:04 AM

[Fwd: Town of Rutherfordton NC0025909]
. •
oms�•ne `
To: Charles Weaver <[e-mail]>
CC: Roger Edwards <[e-mail]>
Charles, Just to echo Roger's request, this town has taken some real
hits lately and anything we can do within reason to keep the impacts
down on a town losing industries left and right would be a help. Thanks
for the consideration. Forrest
Original Message
Subject: Town of Rutherfordton NC0025909
Date: Thu, 08 May 2003 06:09:45 -0400
From: Roger Edwards <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Charles Weaver <[e-mail]>,Dana Folley
<[e-mail]>
CC: Forrest Westall <[e-mail]>
Charles,
The Town of Rutherfordton NPDES permit is up for renewal and you should
have the staff report from ARO. I have some new information that should
be considered in the permit renewal. The Town is going to lose an
industry the employees 500 people my mid July 2003. This is domestic
flow only but will have an effect on the WWTP. Can we do a tiered
permit, on the order of the Town of Spindale, begin the permitted flow
at 1.0 MGD to 3.0 MGD. The Town has a pretreatment program for a very
small categorical industry that is still in business at this time. If
we can do this tiered permit the monitoring will remain a 3 times per
week instead of going to daily. If you have any questions let me know.
Thanks,
R. Edwards
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
1 of 1 5/12/2003 6:01 AM

Contact
NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form
NPDES OR NONDISC.HARGE PERMITTING UNIT COMPLETES THIS PART:
Date of Request 5 16
Facility
g_k 41.4 ey-CL r ci - r to
Permit #
i'I LO G i s 9 69 .
Region
Requester
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Pretreatment A_D Towns )
E-L Towns- Deborah Gore (ext 593)
-R Town— s-Dana F011ey(ext-523)->
S-Z Towns 92)
1-0
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PRETREATMENT UNIT COMPLETES THIS PART:
Status of Pretreatment Program (circle all that apply)
1) the facility has no SIU's and does have a Division approved Pretreatment Program that is INACTIVE
2 the facility has no SIU's and does not have a Division approved Pretreatment Program
3) the facility has (or is developing) a Pretreatment Pro r
3a) is Full Program with LTMP or 3b) is Modified Program with STMP
the facility MUST develop a Pretreatment Program - Full Modified
5) additional conditions regarding Pretreatment attached or listed below
Flow Permitted Actual
% Industrial D, 046 0.010
STMP time frame:
most recent
next cycle
% Domestic O , 4 55 Ai
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MP
Pollutant
Check List
POC due to
NPDES/Non-
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Site specific POC (Provide Explanation'•
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"Only in the LTMP if the POTW land appres sludge
--' Only in LTMP while the SIU is connected to the POTW
••" Only in LTMP when the pollutant is a specific concern to the POTW (ex -Chlorides for a POTW who accepts Textile waste)
Q. Quarterly
M=Monthly _ n l /
Comments: - c c K e i\iA--ekpeA- 51 Lt 431 t,LLe iDi ' 5 + s Et f #e s ne.re v- movvo{
ci ye. tom, 0 n!, ,�-tx o y., •-fv i'o w 't
version 8/23/00
N PDES_Pretrealment. request.lorm.010613
Revised: August 4. 2000

TOWN OF RUTHERFORDTON
"The me o ate Theirsial Belt
Town Hall • 129 North Main Street
Rutherfordton, NC 28139
828/287-3520 • FAX [phone]
April 23, 2003
Ms. Susan Wilson
DWQ/NPDES Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Rutherfordton
NPDES Permit No. NC0025909
Dear Ms. Wilson:
Sally Lesher
MAYOR
Christy Bare
Jimmy G. Dancv
Ron Giles
Bobby E. Jones
COUNCIL MEMBERS
Karen E. Andrews, Town Manager
Tamara C. Weaver, Finance Officer
Jennifer D. Armstrong, Town Clerk/Tax Collector
Randall M. Greenway. Police Chief
Hal Davis, Public Works Superintendent
C. Thomas Blanton, Fire Chief
Pat A. Hardin. Librarian
This correspondence is in regard to Matt Matthews Memorandum to Dave Goodrich
dated March 7, 2002, requesting our permit be reopened and include limits for copper
and zinc. We are requesting the Division to afford the Town additional time to
demonstrate that Copper and Zinc are not the causative of toxicity.
When the Town was notified of the Division's policy concerning Toxicity, Copper and
Zinc, the Town committed to conducting a Toxicity Identification Evaluation by using
EDTA and sodium thiosulfate additions to the treated samples. Copper is indicated if
toxicity is reduced by addition of EDTA and sodium thiosulfate and Zinc is evident if
toxicity is reduced by the addition of EDTA. EPA recommends this test method. It is
our understanding that these test methods should be conducted on a sample that
exhibits toxicity. The Town of Rutherfordton has a history of inconsistent toxicity results
as shown in Attachment I. The Town did not experience continuous toxicity failures until
July and August 2002. During the month of August, the TIE study was implemented.
Unfortunately, the results were inconclusive due to the low hardness in the sample,
which caused interference in the study. During the months of January, February and
March 2003 the effluent exhibited toxicity and the TIE study was conducted during the
month of March. The results will be submitted to the Division under separate cover.
It is our understanding the intent of the Division's policy was to demonstrate whether or
not copper and/or zinc are the causative of toxicity failures at the Rutherfordton
Wastewater Treatment Plant. The Town is requesting additional time to conclusively
demonstrate that Copper and/or Zinc are not the cause of our toxicity failures. Now that
the Town is aware that tests can be conducted on non -toxic samples, we will proceed

with "spiking" the samples with none concentrations of copper and zinc. In addition,
should the test indicate toxicity, the Town will proceed with the addition of the EDTA and
sodium thiosulfate. We propose to conduct toxicity testing for the next three months.
With these two procedures in place, the Town should have some reliable results by July
2003. I have attached a letter from our toxicity consultant, which further outlines the
Town's proposal for the toxicity study.
Again, the Town respectfully requests the Division to allow the Town additional time to
definitely demonstrate that copper and/or zinc are not the cause of toxicity. We would
prefer to utilize the Town funds to support the cost incurred for the study than the
adjudicating the permit modification to exclude the copper and zinc limits.
Thanking you in advance for your consideration in this matter, we anxiously await your
reply. If you require additional information, please advise.
Sincerely,
TOWN OF RUTHERFORDTON
.?Ae.ityl- Adcadr4---
Karen E. Andrews
Town Manager
cc: Gary Stainback
Paul Rhodes

ATTACHMENT I
TOXICITY TEST RESULTS
Sample Date
Test Result
Pass/Fail
o
Chronic Value, /o
1/22/2001
Fail
2/12/2001
<25%
4/16/2001
Pass
7/9/2001
Fail
8/13/2001
<60%
9/12/2001
<60%
9/19/2001
<60%
10/1/2001
Pass
1/14/2002
Pass
4/8/2002
Fail
5/13/2002
92.2
6/10/2002
>100
7/17/2002
Fail
8/12/2002
25.3
9/16/2002
>100
10/2002
Lab Error
11 /11 /2002
Pass
1/13/2003
Fail
2/10/2003
50.2
3/24/2003
50.2

Aquatic Sciences Consulting
Rd
15751 Bushy Park
Woodbine, Maryland 21797
[phone] — phone
[phone] — fax
April 16, 2003
Ms. Nadine Blackwell
Hydro Management Services
2554 Lewisville-Clemmons Rd
Suite 304
Clemmons, NC 27012
Re: Contribution of Copper and Zinc to Effluent Toxicity at the Town of Rutherfordton
(NC0025909)
Dear Ms. Blackwell:
As discussed, Aquatic Sciences Consulting (ASC) recommends advising the Division of Water
Quality (DWQ) that the town is proceeding with its evaluation of the potential for copper and
zinc to cause instream toxicity. This work is proceeding in spite of DWQ's intention to develop
copper and zinc limits for the town's wastewater treatment plant (WWTP). ASC believes that
the results of the planned tests will be critical in determining the actual effects of copper and
zinc on the town's effluent quality. Although DWQ is proceeding with copper and zinc limits,
the planned testing may indicate no reasonable potential for metals toxicity. On the other hand,
if a reasonable potential is indicated, the testing will provide data to show the actual
concentrations of copper and zinc that cause toxicity. These data should be used to derive
realistic limits, instead of limits based on assumed toxicity. Therefore, ASC recommends that
the town request a delay in the limits development until the planned testing is complete.
This letter includes a plan and schedule for the copper and zinc evaluation. ASC understands
that the tests must be completed in a timely manner to ensure proper consideration by DWQ. In
that respect, ASC will soon be forwarding the results of the recently completed first test.
Background
According to DWQ's Implementation of Action Levels for Copper and Zinc in NPDES Permits
(2000), permittees, who consistently fail their whole effluent toxicity (WET) limits and
discharge copper and zinc concentrations that may cause North Carolina's instream action level
standards to be exceeded, must evaluate the potential for copper and zinc to cause instream
toxicity. As a result of two successive WET failures in July and August 2002, the town of
Rutherfordton conducted a test to evaluate the contribution of copper and zinc to the town's

Town of Rutherfordton
NC0025909
Page 2
April 16, 2003
effluent toxicity. The results were inconclusive because the low effluent hardness caused the
test reagents to be toxic.
DWQ advised the town that additional testing was required to confirm the presence or absence
of copper and zinc toxicity (letter dated October 23, 2002). Unfortunately, this additional testing
was not carried out due to miscommunication. DWQ subsequently advised the town that it
would proceed with establishing copper and zinc effluent limits.
It is important to note that the town has made changes in WWTP treatment chemicals that may
be affecting effluent toxicity. The town previously used lime for alkalinity control of the
activated sludge nitrification process. More recently, sodium hydroxide is being used. Effluent
toxicity was not observed as frequently during lime addition as now. Lime provides hardness
that can ameliorate the toxicity of many metals. Therefore, the town is considering using lime
again for alkalinity control. During the period of increased effluent toxicity, the town also began
using an emulsion polymer to assist in clarifying suspended solids after activated sludge
treatment. Many emulsion polymers contain wetting agents that can be toxic. Therefore, the
town is in the process of evaluating an alternative polymer.
Lime may have a significant effect on copper and zinc toxicity in the town's effluent. Therefore,
ASC proposes to focus on the results of tests to be performed once lime addition is reinstituted.
It is anticipated that lime addition will be started up in late April in time for the next required
toxicity compliance test.
Test Plan
ASC recommends a series of effluent tests that will quickly gather the information needed to
assess copper and zinc toxicity and, if such toxicity is observed, provide data to DWQ to derive
technically defensible limits.
The type of test will depend on the presence or absence of effluent toxicity as measured with the
town's permit test species, Ceriodaphnia dubia. For example, in March when toxicity was
observed, ASC and SIMALABS performed a recommended Toxicity Identification Evaluation
(TIE) test, using the same procedures practiced on the August 2002 effluent sample (see ASC
letter dated October 15, 2002). TIE testing involves adding EDTA and sodium thiosulfate,
which bind metals, to sample aliquots and comparing the resulting toxicity to the original
(untreated) effluent sample toxicity (EPA 1992). The relative success of the EDTA and
thiosulfate treatments provides evidence for the presence or absence of copper and/or zinc
toxicity as noted in Figure 1.
C:1Documents and Settings\K.aren Andrews\Local Settings\Temporary Internet Files\Content.IE5169VWP4V11Toxicity Letter About Proposed
Copper & Zinc Limits.doc
04/23/03 3:21 PM

Town of Rutherfordton
NC0025909
Page 3
April 16, 2003
If the effluent samples are nontoxic, an effluent spiking approach will be used as described in
DWQ's letter to the town dated October 23, 2002. ASC proposes to spike aliquots of these
samples with a series of copper concentrations and determine the effect on effluent toxicity. A
second series of sample aliquots will be spiked with zinc and tested for toxicity. Results will be
interpreted to determine the concentrations that cause effluent toxicity.
As noted, ASC proposes to focus on the results of tests to be performed once lime addition is
reinstituted. ASC invites DWQ comments on this approach.
ASC proposes to conduct the appropriate test each month through June 2003. The test results
will provide evidence for (1) the presence or absence of copper and/or zinc toxicity and (2) the
concentrations at which copper and zinc become toxic in the effluent. These results will be used
to derive a toxicity threshold level that can then be used as a basis for setting permit limits.
Please contact me at [phone], if you have questions or comments about this plan.
Respectfully,
John A. Botts
Principal Scientist
c.c.: Rick Diehl, SIMALABS International
C:\Documents and Settings\Karen Andrews1Loca1 Settings\Temporary Internet Files\Content.IE5\69VWP4VI\Toxicity Letter About Proposed
Copper & Zinc Limits.doc
04/23/03 3:21 PM

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Copper Chloride
Cadmium Chloride
Mercuric Chloride
Zinc Chloride
Manganese Chloride
Lead Nitrate
Nickel Chloride
No
Silver Chloride
Sodium Selenate
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SOC PRIORITY PROJECT: No
IF YES, SOC NUMBER
TO: NPDES UNIT
WATER QUALITY SECTION
ATTENTION: Charles Weaver
DATE: March 24, 2003
NPDES STAFF REPORT AND RECOMMENDATION
RUTHERFORD COUNTY
PERMIT NUMBER NC0025909
PART I - GENERAL INFORMATION
1. Facility and Address: 1021 South Main Street
Mailing: Post Office Box 1925
Rutherfordton, NC 28139
2. Date of Investigation: February 3, 2003
3. Report Prepared By: Roger C. Edwards
4. Persons Contacted and Telephone Number: Paul Rhodes, ORC
828-287-2141
5. Directions to Site: From Asheville take Hwy. I-26E to Hwy. 74E to
Hwy. 221 exit turn left travel through second traffic light turn
right at first road to right. (approx. 200 feet after traffic light)
6. Discharge Point(s), List for all discharge points:
Latitude: 35 55' 92" Longitude: 82 04' 46"
Attach a USGS map extract and indicate treatment facility site and
discharge point on map.
U.S.G.S. Quad No. U.S.G.S. Quad Name Rutherford South
7. Site size and expansion area consistent with application?
X Yes No If No, explain:
8. Topography (relationship to flood plain included):
Above 100 year flood plain
9. Location of nearest dwelling: approximately 200 yards
10. Receiving stream or affected surface waters:
-1-

a. Classification: C
b. River Basin and Subbasin No.: Broad River Basin
c. Describe receiving stream features and pertinent downstream
uses: typical upper piedmont stream; wildlife corridor,
wildlife propagation, rural, agriculture
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted 3.0 MGD (Ultimate
Design Capacity)
b. What is the current permitted capacity of the Wastewater
Treatment facility? 3.0 MGD
c. Actual treatment capacity of the current facility (current
design capacity 3.0 MGD
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two years:
N/A
e. Please provide a description of existing or substantially
constructed wastewater treatment facilities: See attached
f. Please provide a description of proposed wastewater treatment
facilities: N/A
g. Possible toxic impacts to surface waters: Expected possible
toxic impacts of domestic & industrial wastewater.
h. Pretreatment Program (POTWs only):
in development approved X
should be required not needed
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DWQ Permit
Number
Residuals Contractor
Telephone Number
b. Residuals stabilization: PSRP PFRP OTHER
C. Landfill:
d. Other disposal/utilization scheme (Specify): At present Town of
Rutherfordton has agreement with Town of Forest City to process
-2-

sludge through Town of Forest City dryer. The Town of
Rutherfordton should peruse a land application permit for their
sludge.
3. Treatment plant classification (attach completed rating sheet):
Grade III
4. SIC Codes (s) : 4952
Primary 01 Secondary
Main Treatment Unit Code: 050-7
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or
are any public monies involved. (municipals only)? N/A
2. Special monitoring or limitations (including toxicity) requests: No
3. Important SOC, JOC, or Compliance Schedule dates: (Please
indicate) N/A
Submission of Plans and Specifications
Begin Construction
Complete Construction
Date
4. Alternative Analysis Evaluation: Has the facility evaluated all of
the non -discharge options available. Please provide regional
perspective for each option evaluated. N/A
Spray Irrigation:
Connection to Regional Sewer System:
Subsurface:
Other disposal options:
5. Other Special Items:
-3-

PART IV - EVALUATION AND RECOMMENDATIONS
The Town of Rutherfordton should peruse a final disposal method for the
sludge generated by the WWTP, other than hauling to Town of Forest City.
The Town of Rutherfordton has received many civil assessments for violation
of NPDES Permit limited parameters, primarily BOD and NH3. The plant has
temporary modifications to the wastewater treatment plant design. These
modifications are, using the design digester as the aeration basin and the
design aeration basin as flow equalization. The permit should include
language that requires the town to submit a schedule for permanent
modification to the treatment plant. This schedule should include a time
line for request of an A to C for the modifications.
The town is under a moratorium due to the number of permit violations
received since the new plant was placed on line in June 1999. The regional
office has suggested an SOC however the Town has not pursued the SOC.
I suggest the permit be renewed with the above requirement.
S
gn
o� �. Ldlvn.�do /%43
ture of Report Preparer
Writer Quality Regional Supervisor
3/3//°3
Date
-4-

Rutherfordton Aeration Basin Chemistry
• Subject: Rutherfordton Aeration Basin Chemistry
Date: Tue, 11 Mar 2003 14:49:30 -0500
From: Matt Matthews <[e-mail]>
To: Larry Ausley <[e-mail]>
CC: Kevin Bowden <[e-mail]>, Susan A Wilson <[e-mail]>,
Keith Haynes <Keith.Haynes @ncmail.net>, Jimmie Overton <Jimmie.Overton @ncmail.net>
Larry,
Thanks for the heads -up on the Rutherfordton aeration basin data showing
copper at 2300 ug/L and zinc at 7200 ug/L.
Last week Kevin requested that the facility's permit be re -opened and
modified to implement Cu and Zn limits. We had recommended limits
through the action level process, primarily based on continued WET
violations and lack of action on the facility's part regarding TIE work.
Matt Matthews
NC DENR/Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
v-[phone]
f-[phone]
MailTo:[e-mail]
A few observations and much reasoning lead to error;
many observations and a little reasoning to truth.
--Alexis Carrel
1 of 1 3/17/03 9:59 AM

DIVISION OF WATER QUALITY
March 7, 2003
MEMORANDUM
To: Dave Goodrich £007, L ` I
Through: Matt Matthews 00\
From: Kevin Bowden J15
Subject: REQUEST TO REOPEN NPDES PERMIT AND INCORPORATE EFFLUENT
LIMITATIONS FOR COPPER AND ZINC
DWQ's Copper and Zinc Action Level Policy
Town of Rutherfordton WWTP
NPDES No. NC0025909
Rutherford County
Our office requests that the Town's NPDES Permit be reopened and effluent limitations for
copper and zinc be applied. Our recommendation is based on the following events.
The Town was notified that it had reasonable potential to violate instream action levels.ro.,., for
copper and zinc by NOVs dated 4/2/01 and 4/24/01 for WET permit limit violations occurring in January
and February, 2001, respectively. The 4/24/01 correspondence cited prospective copper and zinc permit
limits of 25 ug/L and 216 ug/L, respectively, with a final report due by 1/24/02.
The Town was required to notify our office of its decision to accept the prospective permit limits
by 5/24/01. On 5/22/01, two days prior to the notification deadline, our office received correspondence
from the Town indicating its choice to conduct "a form of a Toxicity Identification Evaluation..." On
9/18/01, our office received a fax from the Town's contractor, Hydro Management Services, Inc.
transmitting a proposed test method to rule out copper and zinc as causative effluent toxicants. On
9/25/01, the Town's contractor contacted our office and was informed that the information contained in
their submittal met the minimum requirements. A letter dated 9/26/01 from this office to the Town
acknowledged receipt of the 9/18/01 fax. On 1/24/02, our office received a phone call from Hydro
Management requesting additional time to submit the final report due to inclement weather. The fmal
report deadline was administratively extended until 2/1/02.
On 1/30/02 our office received the Town's Toxicity Identification Evaluation. The Town states
that the study was "inconclusive because the treatment plant passed the toxicity tests conducted after
receiving approval of the test method." The evaluation mentioned that the Town instructed SIMALABS
to implement TIE testing in the event that a toxicity test does not achieve compliance with the toxicity
permit limit. Our office reviewed the Town's proposal and responded with a memo dated 2/14/02 that
contained the following statement, "By copy of this letter the Town is notified that they are subject to the
provisions of DWO's Copper and Zinc Action Level Policy should additional effluent toxicity violations
occur in the future. Also, the facility has the option to conduct metal "spiking" of non -toxic samples and
to submit the data for review."
On 10/23/02, the Town was sent another NOV that placed the Town under DWQ's Copper and
Zinc Action Level Policy with the final report due 7/23/03. The Town was required to respond to our
office in writing by 11/22/02 with their choice of Option 1-4. Our office never received written
notification from the Town regarding the Town's option selection. Language in the 10/23/02 NOV
states, "...failure to notify DWQ of your option selection ...within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate."

Page 2
Town of Rutherfordton
March 7, 2003
The facility conducted TIE manipulations on a toxic effluent sample collected during August
2002. The August 2002 TIE results were transmitted to our office by cover letter dated 11/18/02. A
12/20/02 letter from our office to the Town acknowledged receipt of the TIE evaluation. Study results
indicated that concentrations of EDTA and sodium thiosulfate were too high to accurately evaluate
metals toxicity. Our office reviewed the Town's proposal and responded with a memo dated 1/23/03
that contained the following statement, "If future TIE test results are inconclusive, identify copper or zinc
as causes of toxicity, or if TIE work is not conducted on a sample which fails to achieve compliance with
the permit limit for toxicity, then our office will recommend the NPDES Permit be reopened to
incorporate copper and zinc permit limits." Our final statement read, "In summary, our office is
anticipating TIE testing to commence upon the next toxicity test failure."
On 3/4/03 our office received a call from Hydro Management Services, Inc. indicating that
toxicity test failures occurred during January and February 2003; however, no additional TIE testing was
performed. Since issuance of the 4/2/01 and 4/24/01 NOVs (for the January and February 2001 WET
test failures), the Town submitted WET test results that did not achieve compliance with the 71% chronic
permit limit for the following months: July, August and September 2001; April, July and August 2002;
January and February (verbal) 2003. The Town's initial evaluation was reported as inconclusive due to
"passing" test results obtained after approval of the test method. TIE study results conducted on the
August 2002 effluent sample were also reported as inconclusive.
The Town has not taken advantage of TIE testing opportunities whenever toxicity test results did
not achieve compliance with the toxicity permit limit. Written notification was sent from this office
clearly stating the consequence(s) of failing to perform TIE testing on effluent samples which did not
achieve compliance with the permit limit. No data have been submitted that definitively rules out either
copper or zinc as causes of effluent toxicity. We believe that our office has been extremely flexible in
this situation and we must be consistent in this response at it relates to decisions concerning this issue
applied to other facilities. We recommend the NPDES Permit for the Town be reopened to incorporate
numeric copper and zinc permit limitations.
Please feel free to contact me or Matt at 733-2136 if you have questions.
cc: Forrest Westall-Asheville Regional Office
Keith Haynes -Asheville Regional Office
Susan Wilson-NPDES Unit
Pretreatment Unit-DWQ
Jimmie Overton-ESB
Karen Andrews, Town of Rutherfordton, 134 N. Washington Street, Rutherfordton, NC 28139
Madolyn Dominy, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta, Georgia
30303
Aquatic Toxicology Unit Files
Central Files

Process Flow Design and Schematic
The Town of Rutherfordton owns and operates a 3.0 MGD design activated
sludge wastewater treatment plant, which includes a mechanical bar screen and
grit removal. The activated sludge process is provided by an aerated lagoon with
mixing and aeration provided by high speed floating mechanical aerators. Two
secondary clarifiers are provided with associated return sludge pumps. The
secondary effluent is disinfected by use of Chlorine gas. Dechlorination will be
provided by Sulfur Dioxide. The treated effluent if discharged into Cleghorn
Creek, which is in the Broad River Basin.

Rutherfordton Wastewater Treatment Plant
Aeration Lagoon
Influent
Domestic
CTeghorn
Cree
Lagoon Effluent
4" Flexible Pipe
Lagoon Effluent &
Return Sludge Well
MLSS from top
of Aeration Basin
to Clarifier
6" PVC Pipe•:
Conveying MLSS � ��:::::;•.... \�rel.........
To Splitter Box 1 ::::
:...:........ MLSS from bottom
of Aeration Basin
to Clarifier
Sludge Loading Station
Temporary Aeration Basin
and
Sludge
Digester
Volume
,.//)
441,645 Gal.
Effluent
to Stream

•
DIVISION OF WATER QUALITY
January 23, 2003
MEMORANDUM
To: Dave Goodrich � 2p03
JAN 2
Through: Matt Matthews'OPP—
From: Kevin Bowden ff6
Subject: Evaluation of Copper and Zinc per DWQ's Copper and Zinc Action Level Policy
August 12-13 and 15-16, 2002 Effluent Sample
Town of Rutherfordton WWTP
NPDES No. NC0025909
Rutherford County
This office has completed a review of the subject document prepared by the Town with
assistance from Aquatic Sciences Consulting dated October 15, 2002. An evaluation of
reasonable potential to violate instream action levelsTo«i for these parameters was conducted by
the NPDES Unit because the facility failed toxicity tests during January and February, 2001.
The analysis. indicated that reasonable potential existed and the facility was sent a NOV dated
April 2, 2001, containing prospective copper and zinc permit limits of 25 ug/L and 216 ug/L,
respectively.
The Town chose to conduct a TIE (Option 3) to rule out copper and/or zinc as causative
effluent toxicants. The Town submitted correspondence dated 1/30/02 to our office indicating
that the initial copper and zinc study was "inconclusive" because the WWTP achieved
compliance with its WET chronic toxicity permit limit "after receiving approval of the test
method" on September 26 2001. The City's correspondence stated, "We have instructed our
contract laboratory to implement the TIE testing when a toxicity test results in a failure." Our
office responded back to the Town with a letter dated 2/14/02 indicating our expectations of TIE
work to be completed if toxicity non-compliance recurs. We are not sure why the facility did not
conduct TIE testing in April or July 2002 upon experiencing toxicity test failures.
The Town's 11/18/02 letter transmitting the subject report again indicates that additional
TIE studies will be performed if future toxicity test results do not achieve compliance with the
NPDES chronic toxicity permit limit. We recognize that technical issues with the TIE
manipulations conducted in August 2002 prevented clear interpretation of the results. Our office
expects TIE work to be conducted with any effluent toxicity sample which does not meet
compliance with the NPDES Permit Limit. If future TIE test results are inconclusive, identify
copper or zinc as causes of toxicity, or if TIE work is not conducted on a sample which fails to
achieve compliance with the permit limit for toxicity. then our office will recommend the
NPDES Permit be reopened to incorporate copper and zinc permit limits.
Effluent samples were collected on August 12-13 and 15-16 for use in EDTA and sodium
thiosulfate TIE manipulations. Based on actual test data/results submitted with the report, we
believe that the 8 mg/L EDTA and 10 mg/L sodium thiosulfate concentrations cited in Table 1,
page 6 should read 6 mg/L EDTA and 12.5 mg/L sodium thiosulfate. Test results in Table 1
indicate that toxicity increased with increasing EDTA and sodium thiosulfate concentrations.

Town of Rutherfordton
January 23, 2003
Page 2
Corresponding IC25 values measured 42.8, 12.7, 69.9 and 39.2, respectively. While
EDTA toxicity is slightly hardness dependant, we agree with the Town's suggestion that 3 mg/L
of EDTA should not have resulted in effluent toxicity in the August 12-13 sample and we agree
that hardness measurements may overestimate the actual hardness in solution due to WWTP
polymer usage.
Sodium thiosulfate, like EDTA, is slightly hardness dependent in soft to very soft waters.
If polymer usage lowered the actual effluent hardness, then is it reasonable that sodium
thiosulfate toxicity could be overestimated. We point out that polymer usage/dosage at the
Town's WWTP is an issue that we would expect to have been addressed by this stage of the
investigation.
Test results suggest that EDTA and sodium thiosulfate additions were too high to
evaluate potential toxicity from copper and/or zinc. Soluble copper and zinc concentrations in
the August sample measured 6.8 and 32 ug/L, respectively, below the North Carolina Action
Level Standards of 7 and 50 ug/L, respectively. While the progress report cites soluble metal
concentrations, reasonable potential evaluations are based on total metals concentration.
failure.
In summary, our office is anticipating TIE testing to commence upon the next toxicity test
Please contact me or Matt at [phone] if you have any questions.
cc: Forrest Westall-Asheville Regional Office
Dave Goodrich-NPDES Unit
Susan Wilson-NPDES Unit
Dana Folley-Pretreatment
Marshall Hyatt, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta, Georgia 30303
Karen Andrews, Town of Rutherfordton, 134 N. Washington St., Rutherfordton, NC
28139
Aquatic Toxicology Unit Files
Central Files

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
3800 Barrett Drive Raleigh, North Carolina 27609
CERTIFIED MAIL
RETURN RECENT REQUESTED
Mr. A. Terry Rolan `
City of Durham-Northside WRF
101 City Hall Plaza
Durham, North Carolina 27701
SUBJECT:
Dear Mr. Rolan:
December 20, 2002
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0023841
City of Durham WWTP
Durham County
JAN 2 7 2003
This is to inform you that a review of your toxicity self -monitoring report form for the month of
October 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition, this correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by two or more toxicity limit violations that occur during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations during a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

2
The Division has evaluated your copper and/or zinc monitoring data. The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the
copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
zinc permit limit is 135 pg/L.
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide DWQ with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
OR
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation.
'Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your: final report
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity: or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more tonicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.

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

NORTH CAROLINA ACTION LEVEL WATER QUALITY
STANDARDS BRIEF
In 1984, North Carolina adopted Action
Level water quality standards for copper,
zinc, iron, and silver. These standards were
developed to prevent the State from having
to adopt the EPA criteria for metals, which
at the time were overly restrictive.
Action Level water quality standards are
a special category of surface water quality
standards, which are flexible, instream
criteria established for certain substances
that meet the following conditions:
• The chemical must be non-
bioaccumulative (BCF<100);
• The chemical must have variable
toxicity due to its chemical form,
solubility, affinity for other ligands,
or other characteristics; and
• The aquatic species used for whole
effluent toxicity (WET) testing must
be among the most sensitive biota to
that particular chemical, based on
available toxicity data.
In the early 1980's EPA was just
discovering the mechanisms that made these
metals toxic. One of the things that was
clear was that, in most waters, only a portion
of the total metal concentration is
bioavailable. At the time, the best method
for determining the bioavailable portion of
the metal was WET testing. Thus the
standard was written to allow a facility to
calculate a more site -specific metals limit
using a measure of bioavailability and was
implemented using WET testing.
Under the Clean Water Act, EPA must
approve all state standards and
reclassifications. In 1985, 1986 and 1990
when EPA reviewed the action level water
quality standards they only conditionally
approved them. They had concerns related
to the fate and transport of the metals in
natural systems. In order to get the
conditional approval, which prevented EPA
from promulgating standards for North
Carolina, the Division committed to
conducting fate and transport studies on
selected metals, including copper and zinc,
contingent on adequate funding. Several
study plans were developed and presented to
EPA for funding. No funding was made
available.
When these standards were adopted,
EPA requested information on how the
Action Level standards would be
implemented. The implementation
procedure presented to EPA involved
establishing WET testing limits and
monitoring for discharges with copper or
zinc in their effluent. No permit limits for
the metals were to be given if the facility
continued to pass their WET limits or if
upon failure of the WET testing an action
level parameter was not found to be a
causative factor.
EPA was uncomfortable with this
process and, when other states began asking
about using a similar approach, they became
even more uncomfortable.
While North Carolina was using its
action level standards, EPA was grappling
with metals criteria. The original national
criteria were so low that some pristine
streams had higher background
concentrations of copper and/or zinc and
would have been considered impaired. In
recent years, EPA has developed equations
and procedures for determining site -specific
metals criteria and for measuring more
precisely the bioavailable metals.
During the last Triennial Review, North
Carolina agreed to modify the action level
language to reference EPA's guidance on
developing site -specific metals criteria and
to provide a detailed Implementation
Procedure for action level standards. Had
North Carolina not taken these actions, EPA
was ready to promulgate straight standards
for metals for North Carolina based on
perceived successes in other states. This
action would have resulted in permit limits
for copper and zinc in most NPDES permits.
The Implementation Procedure that the
Division is beginning to implement was
reviewed by EPA and reworked by the
Division several times during 1999 and 2000
before EPA finally approved it in October

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Karen E. Andrews
Town of Rutherfordton
134 North Washington Street
Rutherfordton, North Carolina 28139
SUBJECT:
Dear Ms. Andrews:
. October 23, 2002
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0025909
Town of Rutherfordton WWTP
Rutherford County
This is to inform you that a review of your toxicity self -monitoring report form for the month of
August 2002 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper and
Zinc Action Level Policy. The correspondence included prospective permit limits for copper and/or zinc and
stated that the trigger for implementing the policy would be two or more WET limit violations which occur
during a toxicity testing calendar quarter. Please note that the second WET permit limit violation within a
toxicity testing calendar quarter specified by the NPDES Permit has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and/or zinc
permit limit. Notification is due by November 22, 2002.
OR
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by
November 22, 2002. DWQ approval of options 1-3 (below) is not necessary as the Division
expects work to rule out copper and/or zinc as causative effluent toxicants to begin immediately
upon the second WET permit limit violation.
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with existing
or additional monitoring data demonstrates compliance with the Action Level standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc as
causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

2
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Lsj
OCT 2 4 2002
c .a - WKfER aUPLITY
f ..:, iT SOURCE BRMiiCH
Please note that if you choose item b) above, you will be given nine months to submit documentation
that eliminates copper and/or zinc as causative effluent toxicants. Your final report should be comprehensive
and include all data used to support your conclusion. The report is due on or before July 23, 2003.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify DWQ of
your option selection or failure to make acceptable demonstration to DWQ that copper and/or zinc are not
causative effluent toxicants within the stated time frames will result in reopening of the NPDES Permit to
include copper and/or zinc numeric limitations, as appropriate.
If the effluent is toxic, then we expect work to commence immediately with toxic effluent samples.
Failure to initiate work with toxic effluent samples during the study period is unacceptable and will be
considered a failure to make acceptable demonstration as cited above. We recommend a minimum of three
separate sampling events during the nine month period to definitively rule out copper and/or zinc as causative
effluent toxicants.
Should the effluent be non -toxic for the remainder of the nine month period, then the facility may
consider "spiking" of a non -toxic effluent sample with aliquots of copper and zinc to determine threshold
concentrations at which copper and zinc would be toxic. Again, three separate sample events must be
conducted. The "spiking" of non -toxic samples during the nine month study period is appropriate and
recommended in the absence of effluent toxicity, but not required.
Additional information regarding the Division's copper and/or zinc action level policy can be found at
the following web site - http:/ /www.esb.enr.state.nc.us/. Click on the Aquatic Toxicology Unit and go to
the prompt "DOWNLOADS" located at the bottom of the page.
If you have any questions concerning this correspondence, please contact me at [phone] or
Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
fi
Forres estall
Regional Water Quality Supervisor
cc: Asheville Regional Office
Susan Wilson-NPDES Unit
Tom Poe -Pretreatment
Madolyn Dominy-USEPA Region IV, Atlanta Federal Center, .61 Forsyth St., SW,
Atlanta, GA 30303 (no attachments)
Central Files
Aquatic Toxicology Unit Files

DIVISION OF WATER QUALITY
February 14, 2002
MEMORANDUM
To:
Through:
From:
S ubject:
Dave Goodrich
Matt Matthews (61w
Kevin Bowden 63
Evaluation of Copper and Zinc per DWQ
Town of Rutherfordton WWTP
NPDES No. NC0025909
Rutherford County
DENR - WATER QUALITY
POINT SOURCE BRANCH
's Copper and Zinc Action Level Policy
This office has completed a review of the subject document prepared by the Town and
SIMALABS, Inc. dated January 30, 2002. The Town requested an additional one week time
extension to complete the final Copper and Zinc Action Level report. The extension was granted
and the final report was received by our office on February 1, 2002. The Town was issued
NOVs for the January and February 2001 effluent toxicity permit limit failures. An evaluation of
reasonable potential to violate instream action levelsTotai for these parameters was conducted by
the NPDES Unit. The analysis indicated that reasonable potential existed and the facility was
sent a NOV dated April 2, 2001, containing prospective copper and zinc permit limits of 25 ug/L
and 216 ug/L, respectively.
The Town chose to conduct a TIE (Option 3) to disprove copper and/or zinc as causative
effluent toxicants. The town indicates that the TIE test method was approved by DWQ on
September 26, 2001.
The WWTP was upgraded from 1.0 MGD to 3.0 MGD to accommodate additional
industrial user flow of 1.0 MGD or greater. The current plant is undersized to handle the 0.5
MGD influent flow and the Town has experienced problems with maintaining a viable biomass.
The report notes that during the nine month study period, six (6) NPDES effluent compliance
toxicity tests were conducted. Four (4) of the six (6) toxicity tests did not achieve compliance
with the Town's 71% chronic permit limit and were performed prior to the Town receiving
approval for the selected study method. The Town contends that the study was "inconclusive"
and could not be conducted because of "pass" test results that were obtained after DWQ approval
of the study plan. The Town has instructed its biological testing laboratory to initiate TIE testing
upon receiving effluent sample(s) which do not achieve compliance with the Town's 71% permit
limit.
We are disappointed with the amount of time that elapsed after receipt of the second
WET Copper/Zinc Notice of Violation by the Town (April 24, 2001) until the time the Town
notified DWQ of its selected treatment option (September 18, 2001). EPA Phase I TIE
treatments targeting metals as potential effluent toxicants are well documented and available.

Page 2
Town of Rutherfordton Copper and Zinc Final Report
February 14, 2002
We recall speaking with the facility's toxicity consultant (September 2001) regarding
"spiking" of effluent samples in the absence of a toxic effluent. A mutual agreement was
reached that our office would prefer TIE treatments be conducted on samples which were toxic
versus TIE treatments on non -toxic samples "spiked" with copper and zinc. After this issue was
brought to our attention, discussions concerning the "spiking" of a non -toxic sample occurred
among DWQ staff and EPA and a decision was made to accept "spiked" sample(s) data in the
absence of effluent toxicity.
In the future, we will indicate to permittees and their consultants that metal "spiking" of
non -toxic samples during the nine month study period is appropriate and recommended, but not
required. Since this information was not available to the Town until after they submitted Option
3 to DWQ for review, we believe it is fair to provide additional time to complete the study.rBv
copy of this letter the Town is notified that they are subject to the provisions of DWQ's Copper
and Zinc Action Level Policy should additional effluent toxicity violations occur in the future.
Also. the facility has the option to conduct metal "spiking" of non -toxic samples and to submit
the data for review.
Please contact me or Matt at [phone] if you have any questions.
cc: Forrest Westall-Asheville Regional Office
Dave Goodrich-NPDES Unit
Susan Wilson-NPDES Unit
Bill Reid -Point Source Branch
Tom Poe -Pretreatment
Lisa Spurlin, US EPA Region IV, Water Mgt. Div., 61 Forsyth St., SW, Atlanta, Georgia 30303
Karen Andrews, Town of Rutherfordton, 134 N. Washington St., Rutherfordton, NC 28139
Aquatic Toxicology Unit Files
Central Files

•
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
CERT1k1ED MAIL
RETURN RECEIPT REQUESTED
Ms. Karen E. Andrews
Town of Rutherfordton
134 North Washington Street
Rutherfordton, North Carolina 28139
SUBJECT:
Dear Ms. Andrews:
April 24, 2001
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0025909
Town of Rutherfordton WWTP
Rutherford County
•
This is to inform you that a review of your toxicity self -monitoring report form for the month of
February 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit. You
should undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper
and Zinc Action Level Policy. The correspondence included prospective permit limits for copper and/or
zinc and stated that the trigger for implementing the policy would be two or more WET limit violations
which occur during a toxicity testing calendar quarter. Please note that the second WET limit violation
has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and/or
zinc permit limit. Notification is due by May 24, 2001.
OR
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by
May 24, 2001.
1. Instream measurements of dissolved metal during low. flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or
zinc as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

•
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion. The report is due by
January 24, 2002.
Three copies of the fmal report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify DWQ
of your option selection or failure to make acceptable demonstration to DWQ that copper and/or zinc are
not causative effluent toxicants within the stated time frames will result in reopening of the NPDES
Permit to include copper and/or zinc numeric limitations, as appropriate.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http: / /www.esb.enr.state.nc.us/. Click on the Aquatic Toxicology
Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
orrest Westall
Regional Water Quality Supervisor
cc: Asheville Regional Office
Susan Wilson-NPDES Unit
Lydia Mayo-USEPA Region TV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
Central Files
Aquatic Toxicology Unit Files

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Karen E. Andrews
Town of Rutherfordton
134 North Washington Street
Rutherfordton, North Carolina 28139
SUBJECT:
Dear Ms. Andrews:
April 2, 2001
NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NC0025909
Town of Rutherfordton WWTP
Rutherford County
t5
APR 2 5 2001
DENR - WATER QUALITY
POINT SOURCE BRANCH
This is to inform you that a review of your toxicity self -monitoring report form for the month of
January 2001 indicates a violation of the toxicity limitation specified in your NPDES Permit. You should
undertake necessary actions to eliminate or reduce effluent toxicity to acceptable levels.
In addition, this correspondence contains important information on the Division's Copper and
Zinc Action Level Policy which is triggered by failure of two or more toxicity limit violations during
the toxicity testing calendar quarter specified by the toxicity testing special condition of your NPDES
Permit. Attachments addressing policy implementation and a copy of the Division's Toxicity Reduction
Guidance have been included with this Notice of Violation.
You should initiate follow-up toxicity testing upon a single WET test failure which occurs
during the toxicity testing calendar quarter.
Your facility is currently monitoring for copper and/or zinc and is exceeding the action level for
these parameters. The policy states that whenever a facility experiences two or more toxicity limit
violations during a toxicity testing calendar quarter, the NPDES Permit will be modified to include
numeric limits for copper and/or zinc UNLESS the permittee provides one or more of the following:
1. Instream measurements of dissolved metal during low flow conditions that demonstrate
compliance with the Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with
existing or additional monitoring data demonstrates compliance with the Action Level
standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and/or zinc
as causes of effluent toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper
and/or zinc is not the cause of toxicity

2
The Division has evaluated your copper and/or zinc monitoring data. The Division has also
developed a prospective NPDES permit limit based on your facility's instream waste concentration, the
copper and/or zinc action level criterion and a translator procedure. Based on this data your prospective
copper permit limit is 25 pg/L and prospective zinc permit limit is 216 pg/L.
The permittee, upon experiencing two or more toxicity limit violations during a toxicity
testing calendar quarter must either provide DWQ with:
a) Written notification indicating acceptance of the prospective copper
and/or zinc permit limit. Notification is due within 30 days after the date of
the second WET Notice of Violation.
OR
b) Written notification indicating your choice of option(s) as noted on page
one of this correspondence. Notification is due within 30 days after the date
of the second WET Notice of Violation.
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit
documentation that eliminates copper and/or zinc as causative effluent toxicants. Your final report
should be comprehensive and include all data used to support your conclusion(s). Should the data
indicate copper and/or zinc as the source of effluent toxicity or if the data are inconclusive as to copper
and/or zinc's role as a toxicity source, then the NPDES Permit will be reopened and the metal limits
specified above will be applied to the permit. The report is due nine months after the date of the second
WET Notice of Violation.
Three copies of the final report shall be submitted to:.
North Carolina Division of Water Quality
Environmental Sciences Branch
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
You should consider submitting the above correspondence certified mail.
Failure to notify DWQ of your acceptance of a copper and/or zinc limit, failure to notify
DWQ of your option selection or failure to make acceptable demonstration to DWQ that copper
and/or zinc are not causative effluent toxicants within the stated time frames will result in
reopening of the NPDES Permit to include copper and/or zinc numeric limitations, as appropriate.
Please note that your actions to notify DWQ of prospective limit acceptance or to notify DWQ
of plan option(s) and subsequent submission of a plan are contingent upon two or more toxicity NPDES
permit limit violations occurring during a toxicity testing calendar quarter.

3
Also note that the WET limit will remain in your NPDES permit regardless of whether metals
are the source of effluent toxicity. The data resulting from your actions to disprove copper and/or zinc as
sources of effluent toxicity will determine whether NPDES Permit limits will be assigned for these
parameters. You are responsible for initiating actions to address these issues.
You may consider entering into a Special Order by Consent (SOC) with DWQ. A SOC provides
regulatory relief for specific NPDES permit limit violations and, if signed, will contain a requirement to
conduct a Toxicity Reduction Evaluation. The SOC will contain a compliance schedule, stipulated
penalties for failing to meet milestone activity dates and may contain upfront penalties to settle past
permit limit violations.
Additional information regarding the Division's copper and/or zinc action level policy can be
found at the following web site - http://www.esb.enr.state.nc.us. Click on the "Aquatic
Toxicology" Unit and go to the prompt "AT Downloadable Files" located at the bottom of the page.
This web site also contains EPA's "Toxicity Reduction Evaluation Guidance for Municipal Wastewater
Treatment Plants." Section 4 of this document contains pertinent information on Toxicity Identification
Evaluations.
If you have any questions concerning this correspondence, please contact me at [phone]
or Mr. Matt Matthews, Supervisor of the Aquatic Toxicology Unit at [phone].
Sincerely,
&rest Wes . 1
Regional Water Quality Supervisor
ATTACHMENTS
cc: Asheville Regional Office (no attachments)
Susan Wilson-NPDES Unit (no attachments) L./-
Lydia Mayo-USEPA Region IV, Atlanta Federal Center, 61 Forsyth St., SW, Atlanta, GA 30303
(no attachments)
Central Files (no attachments)
Aquatic Toxicology Unit Files (no attachments)