NC0024911_Permit (Issuance)_20060927

NPDES DOCUMENT SCANNIN`: COVER :SHEET
NPDES Permit:
NC0024911
MSD Buncombe County WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 27, 2006
This document is printed on rewse paper - ignore any -
cork -bent on the rezrerise side

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 27, 2006
Mr. Tom Hartye
MSD of Buncombe County
2028 Riverside Drive
Asheville, North Carolina 28804
Subject: Issuance of NPDES Permit
NC0024911
French Broad River WRF
Buncombe County
Dear Mr. Hartye:
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,1.994 (or
as subsequently amended).
This final permit contains the following significant changes from the draft you were sent on February
13, 2006:
> An 18-month compliance schedule has been placed in effect for the 22 pg/L daily maximum
cyanide limit. This limit will take effect on May 1, 2008.
> Groundwater monitoring will be required three times per year in order to be consistent with
existing requirements.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such
demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Toya Fields at telephone
number [phone], extension 551.
Sincerely,
Alan W. Klimek, P.E.
cc: Central Files
Asheville Regional Office/Surface Water Protection
NPDES Unit
PERCS Unit
Aquatic Toxicology
Marshall Hyatt, EPA Region IV
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http://h2o.enr.state.nc.us/
An Equal Opportunity/Affirmative Action Employer
Noe
rthCarolina
2aturally

7
Permit NC0024911
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
Metropolitan Sewerage District of Buncombe County
is hereby authorized to discharge wastewater from a facility located at the
French Broad River WRF
NC Highway 251
North of Asheville
Buncombe County
' to receiving waters designated as French Broad River in the French 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 November 1, 2006.
This permit and authorization to discharge shall expire at midnight on December 31, 2010.
Signed this day September 27, 2006.
fps - Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0024911
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of
this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements,
terms, and provisions included herein.
The Metropolitan Sewerage District of Buncombe County
is hereby authorized to:
1. Continue to operate an existing 40 MGD wastewater treatment system consisting
of a Rotating Biological Contactor (RBC) system with the following components:
• Two mechanical bar screens
• Three aerated grit chambers with grease removal
• Three influent pumps with capacity of 35 MGD each.
• Instrumental flow measurement
• Seven 250-micron primary microscreens (currently not in service)
• Eighteen 27-micron secondary microscreens
• lst, 2nd, and 3rd stage RBCs (150 total)
• Three intermediate pumps
• Four intermediate clarifier cells
• Effluent chlorination (sodium hypochlorite)
• Two gravity sludge thickeners. •
• Four gravity belt thickeners (currently not in service)
• Two anaerobic digesters (currently not in service)
• Two 2.5-meter belt filter presses
• Fluidized bed incinerator
• Alkaline stabilization facility
• 2 MW back-up; generator (diesel)
♦ Two 450 KW gas generators
• Three 850 KW hydro turbines
♦ 17-acre ash storage lagoon
The facility is located north of Asheville at the MSD Buncombe County WRF on
NC Highway 251 in Buncombe County;
2. Discharge from said treatment works at the location specified on the attached
map into the French Broad River, classified B waters in the French Broad Basin.

NC00024911 - MSD Buncombe County
Latitude:
Longitude:
Ouad #:
Stream Class:
Receiving Stream:
Pemiitted Flow:
35°39'02"
82°35'54"
EBNE/Weaverville
B
French Broad River
40.0 MGD
Sub -Basin:
04-03-02
North
Metropolitan Sewerage District of Buncombe County
NC0024911
MSD - Buncombe WWTP

Permit NC0024911
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge 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
40 MGD
Continuous
Recording
I or E
CBOD, 5-day (20°C)2
25.0 mg/L
40.0 mg/L
Daily
Composite
I & E
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Daily
Composite
I & E
NH3 as N
Daily
Composite
E
Dissolved Oxygen3
Daily
Grab
E, U & D
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
E, U & D
Total Residual Chlorines
28 pg/L
Daily
Grab
E
Temperature (°C)
Daily
Grab
E, U & D
Total Nitrogen
(NOz+NO3+TKN)
Quarterly
Composite
E
Total Phosphorus
Quarterly
Composite
E
Conductivity
-
Daily
Grab
E, U & D
Cyanide4
22 pg/L
Weekly
Grab
E
Copper
2/Month
Composite
E
Zinc
2/Month
Composite
E
Silver
2/Month
Composite
E
pH
Between 6.0 and 9.0 s.u.
Daily
Grab
E
Chronic Toxicity6
Quarterly
Composite
E
Annual Pollutant Scan7
Annual
Grab
E
Footnotes:
1. I= Influent, E= Effluent, U= Upstream at dam discharge to fish ladder adjacent to intake flume to the
hydroelectric plant (Location is approximately 2700 feet upstream of the hydroelectric plant). D = Downstream
at Ledges Park. Upstream and downstream samples shall be grab samples. Stream samples shall be collected
three times per week during June, July, August and September then once per week in the remaining months of
the year.
2. The monthly average effluent CBOD5 and Total Suspended Solids concentrations shall not exceed 20% of the
respective influent value (80% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 5.0mg/L.
4. See special condition A(3).
5. TRC limit takes effect May 1, 2008. Limit and monitoring requirement only apply if chlorine is used for
disinfection.
6. Whole effluent toxicity will be monitored using the Pass/Fail Chronic Toxicity test with Ceriodaphnia at 12%.
Samples shall be taken in February, May, August & November; see A. (2.).
7. See special condition A(7).
There shall be no discharge of floating solids or visible foam in other than trace amounts

i r
Permit NC0024911
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) •
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 12%.
The permit holder shall perform at a minimum, auarterIu 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
February, May, August and November. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes. -
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be 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 Section
1621 Mail Service Center
Raleigh, North Carolina 27699.-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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 Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality .indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be completed
no later than the last day of the month following the month of the initial monitoring.

0
Permit NC0024911
A. (3) CYANIDE SPECIAL CONDITION
The cyanide limit shall take effect May 1, 2008, however the weekly monitoring requirement applies
as of the effective date of this final permit. The quantitation limit for cyanide shall be 10 ug/L (10
ppb) . Levels reported at less than 10 ug/L shall be considered zero for compliance purposes. The
Division will review the cyanide limit, upon request, after twelve months of data have been collected.
A. (4.) PRETREATMENT MONITORING CLARIFICATION
Ground Water remediation sites discharging to MSD Buncombe WRF with locally issued permits
shall be considered as Non -Significant Industrial Users and shall have no specific requirements for
parameter limits or monitoring frequency if they do not discharge more than 25,000 gallons of
industrial process wastewater per day, they do not discharge more than 5 % of the Maximum
Allowable Headwbrks Loading (MAHL) of any pollutant to the MSD Buncombe WRF, they are not a 40
CFR regulated Categorical Industry, or they do not in the opinion of the Director of MSD Buncombe
have the potential to upset or interfere with the operation of the WRF. The Director of MSD WRF
shall enforce the Sewer Use Ordinance, permit, limit, monitor, and inspect all dischargers to his WRF
as needed to assure proper operation and compliance with all NPDES effluent limits including Whole
Effluent
A. (5.) GROUNDWATER REQUIREMENTS
I. Monitoring Requirements
a. The existing monitoring wells MW1, MW2, MW3, and MW4 shall be sampled three
times per year for the following parameters:
➢ Arsenic ➢ Nitrogen, Nitrate Total (as N)
➢ Barium ➢ pH
➢ TOC ➢ Silver
➢ Chlorides ➢ TDS
➢ Chromium ➢ Volatile Organic Compounds (Sample
> Fecal conform annually in the last quarterly sampling
> Lead month only)
> Mercury > Water level
> Nitrogen, Ammonia Total (as N)
The measurement of water level and then pH must be taker prior to sampling the
remaining parameters. The depth to water in each well shall be measured from the
surveyed point on the top of the casing. The measuring points (top of well casing) of
all monitoring wells shall be surveyed to provide the relative elevation of the
measuring point for each well. •
b. Analyses of the required parameters must be conducted by a laboratory certified by
the DWQ Laboratory Certification Unit for those analyses.
c. Volatile Organic Compounds (VOCs). Samples collected for VOCs must be analyzed
using one of the following methods:
Standard Method 6230D
Standard Method 6210D
EPA Method 8021, Low Concentration
EPA Method 8260, Low Concentration
Another method, with prior approval by the Aquifer Protection Section Chief
Any method used to analyze VOCs must include, at a minimum, all constituents listed
in Table VIII of Standard Method 6230D. Any method used must provide a Practical
Quantitation Limit (PQL) of 0.5 ug/L or less, which must be supported by laboratory
proficiency studies as required by the DWQ Laboratory Certification Unit. Any
constituents detected above the Method Detection Limit (MDL) but below the PQL of
0.5 ug/L must be qualified (estimated) and reported.

Permit NC0024911
d. The Division may require additional .groundwater monitoring it deems necessary to
determine compliance with Groundwater Quality Standards .and other applicable laws
and regulations.
II. Reporting Requirements
a. The Permittee shall prepare groundwater monitoring reports for each sampling period
using current versions of Form GW-59 (Groundwater Quality Monitoring: Compliance
Report Form) and Form GW-59A (Compliance Report Form) and shall include copies of
the laboratory report(s) with each report.
b. The Permittee shall submit: three (3) copies of its reports to the following address,
postmarked no later than the 28th day of the month following the sampling period:
Division of Water Quality
Attn: Information Processing Unit
1617 Mail Service Center
Raleigh, NC .27699-1617
c. Copies of current forms may be downloaded from the Division of Water Quality website
at http://h2o.enr.state.nc.us/ans/gpu/forms.htm or requested from the address
above.
III. Applicable Boundaries
a. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary
for the disposal system individually permitted prior to December 30, 1983 is
established at either 500 feet from the waste disposal area, or at the property
boundary, whichever is closest to the waste disposal area. An exceedance of •
Groundwater Quality Standards at or beyond the Compliance Boundary is subject to
remedial action according to 15A NCAC 2L .0106(d)(2).
b. The REVIEW BOUNDARY is. established around the disposal system midway between
the Compliance Boundary and the perimeter of the waste disposal area. Any
exceedance of standards at the Review Boundary shall require action in accordance
with 15A NCAC 2L .0106(d)(1). •
A. (6.) ASH STORAGE LAGOON
MSD Buncombe is permitted to operate a.17-acre lagoon for the purpose of storing incinerator ash.
Effluent from this lagoon is sent to the head of the plant for treatment. No other materials may be
stored in the lagoon without prior Division .notification.

Permit NC0024911
A. (7.) EFFLUENT POLLUTANT SCAN
The permittee shall perform an annual effluent pollutant scan for all parameters listed in the table
below (in accordance with 40 CFR Part 136), The annual effluent pollutant scan samples shall
represent seasonal (summer, winter, fall, spring) variations over the 5-year permit cycle. Unless
otherwise indicated, metals shall be analyzed as "total recoverable." Additionally, the method
detection level and the minimum level shall be the most sensitive as provided by the appropriate
analytical procedure.
Ammonia (as N)
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate/Nitrite
Total Kjeldahl nitrogen
Oil and grease
Total Phosphorus
Total dissolved solids
Hardness
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total phenolic compounds
Volatile organic compounds:
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1, 1-dichloroethane
1,2-dichloroethane
Trans-1,2-dichloroethylene
. 1,1-dichloroethylene
1,2-dichloropropane
1,3-dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-trichloroethane
1,1,2-trichloroethane
Trichloroethylene
Vinyl chloride
Acid -extractable compounds:
P-chloro-m-cresol
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophenol
Phenol
2 , 4, 6-trichloroph enol
Base -neutral compounds:
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4 benzofluoranthene
Benzo(ghOperylene
Benzo(k)fluoranthene
Bis (2-chloroethoxy) methane
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
2-chloronaphthalene
4-chlorophenyl phenyl ether
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate .
Dibenzo(a,h)anthracene
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
1,2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclo-pentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-trichlorobenzene
Test results shall be reported to the Division in DWQ Form- DMR-PPA1 or in a form approved by the
Director, within 90 days of sampling. A copy of the report shall be submitted to Central Files to the
following address: Division of Water Quality, Water Quality Section, 1617 Mail Service Center,
Raleigh, North Carolina 27699-1617.

NCDENR/DWQ
FACT SHEET AMENDMENT
Metropolitan Sewerage District of Buncombe County
NC0024911
Facility Information
(1.) Facility Name: j French Broad River WRF
(2.) Permitted Flow MGD):
40 MGD
(6.) County: 1 Buncombe
(3.) Facility Class:
Iv
(7.) Regional Office: 1 Asheville
(4.) Pretreatment Program:
Full
(8.) USGS Topo Quad: 1 Weaverville
(5.) Permit Status: Existing/renewal (9.) USGS Quad Name: E8NE
Stream Characteristics
(1.) Receiving Stream:
(2.) Sub -basin:
French Broad River
04-03-02
(7.) Drainage Area (mi2): ! 966
(8.) Summer 7Q10 (cfs):;, 466
(3.) Stream Index Number:
6-(54.5)
(9.) Winter 7Q10 (cfs): 595
(4.) Stream Classification:
B
Not listed
(10.) 30Q2 (cfs):
(11.) Average Flow (cfs):
' 882
2140
_._._
(5.) 303(d) Status:
(6.) 305(b) Status:
-
(12.) IWC %:
12
1.0 Proposed Changes Incorporated Into Permit Renewal
o The stream class has been corrected to class B.
o Betty Wilcox with the Groundwater Protection unit has indicated that groundwater
monitoring should be required three times per year, rather than quarterly.
o The facility will be given an 18-month compliance schedule on the 22 pg/L cyanide limit
in order to voluntarily perform a site specific study. The study will attempt to determine
whether the facility is experiencing false positives and /or matrix interference with
respect to observed cyanide values.

NCDENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Metropolitan Sewerage District of Buncombe County
NC0024911
..M ^S S....M. .>*- '..+ T. p. ' t
La- ,, i; di 1t1n � � � � ' , = 3
(1.) Facility Name:
French Broad River WRF
(2.) Permitted Flow MGD):
40 MGD
IV
(6.) County
(7.) Regional Office:
Buncombe
Asheville
(3.) Facility Class:
(4.) Pretreatment Program:
Full
(8.) USGS Topo Quad:
Weaverville
(5.) Permit Status:s
Existing/renewal
! (9.) USGS Quad Name:
ERNE
k ZY� 1 ♦
..�Ar+.a����Y■ ��A� rs�Y� �,�]y)-
+.Haifa.-+r.� � ..
f ,'
. _. „'
_^l
(1.) Receiving Stream:
1 French Broad River
(7.) Drainage Area (mi2):
966
(2.) Sub -basin:
04-03-02
(8.) Summer 7Q10 (cfs):
466
(3.) Stream Index Number:
; (9.) Winter 7Q10 (cfs):
595
(4.) Stream Classification: T
C 1 (10.) 30Q2 (cfs):
882
(5.) 303(d) Status: i Not Not listed ! (11.) Average Flow (cfs):
(6.) 305(b) Status: - 1 (12.) IWC %:
2140
12
1.0 Proposed Changes Incorporated Into Permit Renewal
> Add 28 pg/L TRC limit with 18 month compliance schedule
> Add annual PPA scan.
> Monitoring for cadmium and chromium will be removed from the permit as they show
no reasonable potential to cause an exceedance of water quality standards. These
parameters will continue to be monitored through the facility's pretreatment program.
> Cyanide limits will be added to this permit based on the acute water quality standard of 22
pg/L.
> Add groundwater monitoring requirements.
> Add special condition for operation of lagoon.
2.0 Summary
The Metropolitan Sewerage District of Buncombe County (MSD) services an area that includes
Asheville, Black Mountain, Montreat, Woodfin, Biltmore forest, and Weaverville. The facility
also processes wastewater from 23 SIUs currently accounting for 2.94 MGD of the wasteflow.
This segment of the French Broad River is not listed on the draft 2002 or 2004 303(d) lists,
however the draft 2005 French Broad Basin Plan states the following. "The French broad River
[AU#6-(54.5)d and e] is impaired in the aquatic life category due to a Fair bioclassification at site
B-3. Craggy Dam is a run -of -river dam that could potentially slow the flow of the river during
drought conditions, consequently impacting the benthic community downstream."
Based on an email from Dave Goodrich, MSD appears to maintain an unpermitted 17-acre sludge
lagoon. At one point this lagoon was been used to store ash (from an onsite incinerator), grit, line
cleanouts, grease, and site stormwater. The outfall from the lagoon returns to the head of the
plant. Based on discussions with MSD, the Asheville Regional office, and Shannon Thornburg in

NPDES Permit Fact Sheet - 02/ 13/06 MSD-Buncombe WWTP
Page 2
NC004911
the non -discharge unit, MSD has agreed to several improved waste handling procedures. A
septage receiving station has been built for the vacuum truck debris and other some site
management procedures were (according to a July 2003 letter) implemented in Fall 2003.
Therefore grease, grit, and line cleanouts are no longer stored in the lagoon. The regional office
indicates that the facility will continue to use the lagoon for ash storage and the treatment unit
should be permitted. Therefore a special condition will be added to the permit allowing the use
of the lagoon for ash storage.
The permit will also include a special condition restating the facility's existing groundwater
monitoring requirements.
3.0 Compliance Summary
DMR Data Review
Monthly average DMRs were reviewed for the period of January 2003 through December 2005.
Monthly average flows during this time period averaged 22.68 MGD (57% capacity) with a
maximum monthly average of 35 MGD (88% capacity). The facility does not have dechlorination
installed and TRC levels are very high with an average of 650 }ig/L. The permit will receive a
TRC limit of 28 pg/L, effective 18 months from the effective date of the final permit. Monthly
average DMR data is summarized in the following table.
Table 1: 2003-2005 Monthly Average DMR Data
Flow
(MGD)
Temp.
(deg C)
TRC
(ug/L)
BOD
(mg/L)
NH3-N
(mg/L) ;
TSS
(mg/L)
D.O.
(mg/L)
TN (mg/L)
TP
(mg/L)
Conductance
pH
Avg
22.7
18.6
650.31
14.54
9.44
17.23
8.13
18.09
3.18
726.07
7.30
Max
35.12
23.04
1511.43
19.14
14.19
27.87
9.19
23.60
4.75
975.04
7.47
Min
19
13.16
10.15
3.47
11.76
6.99
12.00
0.33
528.28
7.06
Instream Data
Instream data was reviewed for the period of November 2005 through January 2004.
Conductivity levels appear slightly higher downstream, howevever other than that there do not
appear to be any significant adverse effects.
RPA Analysis
RPAs were performed for cadmium, cyanide, chromium, copper, zinc, and silver based on data
collected as part of MSD's previous permit requirements. RPAs were also performed on arsenic,
beryllium, lead, mercury, and nickel based on LTMP data.
Arsenic, beryllium, lead, mercury, and nickel will continue to be monitored as part of the
facility's pretreatment program. There was no reasonable potential for these parameters to cause
an exceedance of water quality standards.
Monitoring for cadmium and chromium will be removed from the permit as they show no
reasonable potential to cause an exceedance of water quality standards. These parameters will
continue to be monitored through the facility's pretreatment program.

APR-20-2006 10:57 FROM:WAT 8282964663 TO:919197330719 P:2'3
..
NPDES Permit Fact Sheet — 04/ 18/06 MSD-Buncombe WWTP
Page 3
NC00491 I
Copper, zinc and silver monitoring will continue in this permit. The maximum predicted
concentration for these parameters was above the allowable concentration, however these are
action level parameters. If required due to consecutive WET failures, limits would be determined
based on the Copper and Zinc Action Level. Policy.
Cyanide limits will be added to this permit based on the acute water quality standard of 22 µg/L.
Data from the facility showed two values of 130 pg/L in 2005.
WET Test .ReRults
MSD Buncombe has a 12% chronic WET testing requirement.17 of 20 tests administered since
January 2002. The three failures were January 2002, January 2003, and April 2003.
Correspondence File Revicw/Compliance History
The facility appears to be well operated and maintained.
4.0 Proposed Schedule for Permit Issuance
Draft Permit to Public Notice: February 15, 2006
Permit Scheduled to Issue: April 1, 2006
5.0 State Contact Information,
If you have any questions on any of the above information or on the attached permit, please
contact Toya Fields at [phone], extension 551.
Copies of the following are attached to provide further information on the permit development:
• Draft permit
NPDES Recommendation by:
Signature Date
Regional Office Comments:
ARO has no issue with draft permit and recommends that the draft be issued as the final. MSD iq
concerned with the addition of a Cyanide permit limit, monitoring only would have been
preferred. MSD will likely present request a permit modification regarding Cn, in the next year.
They will only do so after presenting data that they will compile.
Regional Recommendation by:
Signature Date
9 AR/9 6

APR-20-2006 10:58 FROM:WAT 8282964663
TO:919197330719 P:3'3
NPDES Permit Fact Sheet — 04/ 18/06
Page 4
Reviewed and accepted by:
MSD-Buncombc WWTP
NC004911
Regional Supervisor:
Signature iv C
Date Wil/pg,
NPDES Unit Supervisor:
Signature
Date

r I
REASONABLE POTENTIAL ANALYSIS
MSD Buncombe
NC0024911
Time Period 2003-2005
Ow (MGD) 40
7010S (ds) 466
7010W (cfs) 595
3002 (cfs) 882
Avg. Stream Flow, QA (ds) 2140
Reeving Stream French Broad River
WWTPCIass IV
/WC (%) ® 7010S 11.742
7010W 9.4368
® 3002 6.5678
® QA 2.8156
Stream Class C
Outfall 001
Ow = 40 MGD
PARAMETER
TYPE
n1
STANDARDS &
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
h"CWOS/ liiAV/
Chronic Acute
n 01kt lifexPredCw Alowrebl.Co
Arsenic
C
50
ug/L
32 1
9.0
Acute: WA
_ _
Chroni776_M c--1,ax_
_ _ _
predicted _«stow_able----------------
Monitored through LIMP
Berytilum
C
6.5
ug/L
8 0
Note: n<12
Limited data
0.5
set
Acute: WA
_ _ -_ __
" Chronic: 231
__—_— _ —_—_—_—_—_—_—_—_—_—
No detec_tions
Monitored through LTMP
Cadmium
NC
2 15
ug/L
40 0
0.5
Acute: 15
_ _ -____—
Chronic: 17
_ _ _ _ _ —_—_—_—_—_---_---
Max predicted «stowable
Remove monitoring
Chromium
NC
50 1,022
ug/L
36 28
87.5
Acute: 1,022
_ _ ___ _ _
Chronic: 426
__ _ ___ —_—_—_—_—_---_—_—
Max predicted « atiowable
Remove monitoring
Copper
NC
7 AL 7.3
ug/L
75 75
63.8
Acute: 7
_ _-____—_
Chronic: 60
_ _ _ _ __—_—_—_—_—_—_—_—_—
Max predicted > atlawabte
Action level parameter. Retain monitoring..
Cyanide
NC
5 N 22
10
ug/L
74 42
312.0
Acute: 22
_ _--___—_
Chronic: 43
_ _ _ _ _ _—_—_—_—_—_—_—__
Max predicted» atiowabta
Ada limit
Lead
NC
25 N 33.8
ug/L
32 7
13.0
Acute: 34
_ _ -_ _ __
Chronic: 213
_ _ _ _ _ _ _ — _ —__—_—_—_—
Max predicted «atiowaMe
Monitored through LTMP
Mercury
NC
12
ng/L
29 29
46.3
Acute: N/A
_
' chronic: — 12 --
_ —_—_—_—_—_—_—_—
Max predicted <a stowable
Monitored through LTMP
Nickel
NC
88 261
ug/L
33 24
34.7400
Acute: 261
_ _ __ _ __
' Chronic: 749
_ _ _ __ _ —_—_—_—_—_—_—_—_—
Max predicted «aUowabte
Monitored through LIMP
Silver
NC
0.06 AL 1.23
ug/L
75 59
47.0
Acute: 1
_ _ _—___—
Chronic: 1
___ _ ___ _ —_—_—_—_—_—_—_—_—
Max predicted » stowable
Action level parametr. Retain monitoring
Zinc
NC
50 AL 67
ug/L
75 75
305.9
Acute: 67
_ _ _ _ _
Chronic' -- 426
_ _ _ _ _ _
Max predicted > acute. --------------_-----
Retain monitoring
0 0
N/A
Acute: N/A
__ ____
Chronic: Error O Type-------------------------------
0 0
N/A
Acute: WA
__ __
Chronic: irror Q Type
------ —.—.—.—.--------- -------
0 0
N/A
Acute: WA
__ ___
Chronic: error Q.Type
.
_--.—_—.-------_—_-- ` ------.—.—
0 0
N/A
Acute: N/A
_ _roerror A _ ill -Type
Ch
--------------------------------
' Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
" Freshwater Discharge
24911_rpa.xls, rpa
2/13/2006

REASONABLE POTENTIAL ANALYSIS
Arsenic
Beryllium
Date Data BDL=1/2DL Results
1 Nov-05 < 5 2.5 Std Dev. 0.7071
2 Oct-05 < 5 2.5 Mean 2.6250
3 Sep-05 < 5 2.5 C.V. 0.2694
4 < 5 2.5 n 32
5 5 2.5
6 5 2.5 MultFactor= 1.3800
7 < 5 2.5 Max. Value 6.5 ug/L
8 Jul-05 < 5 2.5 Max. Pred Cw 9.0 ug/L
9 May-05 < 5 2.5
10 < 5 2.5
11 Apr-05 < 5 2.5
12 Mar-05 < 5 2.5
13 Feb-05 < 5 2.5
14 Jan-05 < 5 2.5
15 Dec-04 < 5 2.5
16 Nov-04 < 5 2.5
17 Oct-04 < 5 2.5
18 Sep-04 < 5 2.5
19 Aug-04 < 5 2.5
20 Jul-04 < 5 2.5
21 Jun-04 < 5 2.5
22 May-04 < 5 2.5
23 Apr-04 6.5 6.5
24 Mar-04 < 5 2.5
25 Feb-04 < 5 2.5
26 Jan-04 < 5 2.5
27 Dec-03 < 5 2.5
28 Nov-03 < 5 2.5
29 Oct-03 < 5 2.5
30 Sep-03 < 5 2.5
31 Aug-03 < 5 2.5
32 Jul-03 < 5 2.5
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Date Data BDL=1/2DL Results
1 Nov-05 < 1 0.5 Std Dev. 0.0000
2 Oct-05 < 1 0.5 Mean 0.5000
3 Sep-05 < 1 0.5 C.V. 0.0000
4 < 1 0.5 n 8
5 < 1 0.5
6 < 1 0.5 Mult Factor = 1.0000
7 < 1 0.5 Max. Value 0.5 ug/L
8 Jul-05 < 1 0.5 Max. Pred Cw 0.5 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
24911_rpa.xls, data
- 1 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
Cadmium
Chromium
Date Data BDL=1/2DL Results
1 1/15/2003 < 1 0.5 Std Dev. 0.0000
2 2/5/2003 < 1 0.5 Mean 0.5000
3 3/7/2003 < 1 0.5 C.V. 0.0000
4 4/10/2003 < 1 0.5 n 40
5 5/15/2003 < 1 0.5
6 6/4/2003 < 1 0.5 Mult Factor= 1.0000
7 7/9/2003 < 1 0.5 Max. Value 0.5 ug/L
8 8/14/2003 < 1 0.5 Max. Pred Cw 0.5 ug/L
9 9/18/2003 < 1 0.50
10 10/16/2003 < 1 0.50
11 11/13/2003 < 1 0.50
12 12/11/2003 < 1 0.50
13 1/6/2004'`< 1 0.50
14 2/18/2004 < 1 0.50
15 3/17/2004 < 1 0.50
16 4/14/2004 < 1 0.50
17 5/5/2004 < 1 0.50
18 6/3/2004 < 1 0.50
19 7/8/2004 < 1 0.50
20 8/5/2004 < 1 0.50
21 9/2/2004 < 1 0.50
22 10/14/2004 < 1 0.50
23 11/11/2004 < 1 0.50
24 12/9/2004 < 1 0.50
25 1/13/2005 < 1 0.50
26 2/17/2005. < 1 0.50
27 3/10/2005 < 1 0.50
28 4/7/2005 < 1 0.50
29 5/19/2005 < 1 0.50
30 5/26/2005 < 1 0.50
31 6/16/2005 < 1 0.50
32 7/22/2005 < 1 0.50
33 8/11/2005 ?< 1 0.50
34 9/12/2005 < 1 0.50
35 9/13/2005 < 1 0.50
36 9/14/2005 < 1 0.50
37 9/15/2005 < 1 0.50
38 9/16/2005 < 1 0.50
39 10/27/2005 < 1 0.50
40 11/23/2005 < 1 0.50
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Date Data BDL=1/2DL Results
1 1/15/2003 < 5.0 2.5 Std Dev. 5.8346
2 2/5/2003 17.0 17.0 Mean 5.7000
3 3/7/2003 15.0 15.0 C.V. 1.0236
4 4/10/2003 < • 5.0 2.5 n 36
5 5/15/2003 < 5.0 2.5
6 6/4/2003 ": 4 6.2 6.2 Mult Factor = 2.6500
7 7/9/2003 33.0 33.0 Max. Value 33.0 ug/L
8 8/14/2003 3.9 3.9 Max. Pred Cw 87.5 ug/L
9 9/18/2003 5.6 5.6
10 10/16/2003 "'': 5.5 5.5
11 11/13/2003 + 9.6 9.6
12 12/11/2003 7.2 7.2
13 1/6/2004 '`' 4.6 4.6
14 2/18/2004 3.2 3.2
15 3/17/2004 7.8 7.8
16 4/14/2004 is 5.0 5.0
17 5/5/2004 3.7 3.7
18 6/3/2004 2.0 2.0
19 7/8/2004 'i# 2.4 2.4
20 8/5/2004 5.1 5.1
21 9/2/2004 8.8 8.8
22 10/14/2004 4.8 4.8
23 11/11/2004 ' 2.5 2.5
24 12/9/2004 5.1 5.1
25 1/13/2005 4.8 4.8
26 2/17/2005 "i+ 7.9 7.9
27 3/10/2005 4.6 4.6
28 4/7/2005 <e 5.0 2.5
29 5/19/2005 < 5.0 2.5
30 5/26/2005 5.9 5.9
31 6/16/2005 2.0 2.0
32 7/22/2005 < 5.0 2.5
33 8/11/2005 <' 5.0 2.5
34 9/12/2005 < 5.0 2.5
35 9/13/2005 2.0 2.0
36 9/14/2005 0.0 0.0
37 9/15/2005
38 9/16/2005
39 10/27/2005
40 11/23/2005
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
24911_rpa.xls, data
- 2 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
Copper
Cyanide
Date Data BDL=1/2DL Results
1 1/8/2003 30 30.0 Std Dev. 6.8511
2 1/15/2003 18 18.0 Mean 23.0427
3 2/5/2003 24 24.0 C.V. 0.2973
4 2/7/2003 19 19.0 n 75
5 3/5/2003 20 20.0
6 3/7/2003 18 18.0 Mult Factor = 1.2500
7 4/9/2003 16 16.0 Max. Value 51.0 ug/L
8 4/10/2003 15 15.0 Max. Pred Cw 63.8 ug/L
9 5/14/2003 9 9.3
10 5/15/2003 23 23.0
11 6/3/2003 22 22.0
12 6/4/2003 ` 22 22.0
13 7/8/2003 19 19.0
14 7/9/2003 19 19.0
15 8/13/2003 25 25.0
16 8/14/2003 26 26.0
17 9/17/2003 21 21.0
18 9/18/2003 22 22.0
19 10/15/2003 23 23.0
20 10/16/2003 34 34.0
21 11/12/2003 23 23.0
22 11/13/2003 18 18.0
23 12/10/2003 25 25.0
24 12/11/2003 21 21.0
25 1/5/2004 43 43.0
26 1/6/2004 11 11.0
27 2/18/2004 24 24.0
28 2/19/2004 24 24.0
29 3/16/2004 22 22.0
30 3/17/2004 23 23.0
31 4/14/2004 18 18.0
32 4/15/2004 19 19.0
33 5/5/2004 30 30.0
34 5/6/2004. 25 25.0
35 6/2/2004 15 15.0
36 6/3/2004 18 18.0
37 7/7/2004 30 30.0
38 7/8/2004 30 30.0
39 8/5/2004 30 30.0
40 8/6/2004 20 20.0
41 9/2/2004 22 22.0
42 9/20/2004 23 23.0
43 10/12/2004 23 23.0
44 10/14/2004 21 21.0
45 11/9/2004 19 19.0
46 11/11/2004 51 51.0
47 12/8/2004 22 22.0
48 12/9/2004 32 32.0
49 1/12/2005 18 18.0
50 1/13/2005 24 24.0
51 2/16/2005 16 16.0
52 2/17/2005 23 23.0
53 3/9/2005 20 20.0
54 3/10/2005 18 18.0
55 4/6/2005 22 22.0
56 4/7/2005 30 30.0
57 5/11/2005 39 39.0
58 5/19/2005 9 8.9
59 5/26/2005 28 28.0
60 6/16/2005 29 29.0
61 6/20/2005 22 22.0
62 7/21/2005 28 28.0
63 7/22/2005 25 25.0
64 8/10/2005 20 20.0
65 8/11/2005 15 15.0
66 9/7/2005 13 13.0
67 9/12/2005 16 16.0
68 9/13/2005 30 30.0
69 9/14/2005 24 24.0
1
2
3
_ 4
5
6
7
8
9
10
11
12
13
14
15
16
17
18 9/18/2003
19 10/15/2003
20 10/16/2003
21 11/12/2003
22 11/13/2003
23 12/9/2003
24 12/10/2003
25 1/5/2004'
26 1/6/2004
27 2/18/2004
28 2/19/2004
29 3/16/2004
30 3/17/2004
31 4/14/2004
32 4/15/2004
33 5/5/2004
34 5/6/2004
35 6/2/2004
36 6/3/2004
37 7/7/2004
38 7/8/2004
39 8/5/2004
40 8/6/2004
41 9/2/2004
42 9/20/2004
43 10/12/2004
44 10/14/2004
45 11/9/2004
46 11/11/2004
47 12/8/2004'
48 12/9/2004
49 1/12/2005
50 1/13/2005
51 2/16/2005
52 2/17/2005
53 3/9/2005
54 3/10/2005
55 4/6/2005
56 4/7/2005
57 5/11/2005
58 5/19/2005
59 6/16/2005
60 6/20/2005
61 7/21/2005
62 7/22/2005
63 8/10/2005
64 8/11/2005
65 9/7/2005
66 9/12/2005
67 9/13/2005
68 9/14/2005
69 9/15/2005
Date
1/8/2003
1/15/2003
2/5/2003
2/7/2003
3/5/2003
3/7/2003
4/9/2003
4/10/2003
5/14/2003
5/15/2003
6/3/2003
6/4/2003
7/8/2003
7/9/2003
8/13/2003
8/14/2003
9/17/2003 <
Data BDL=1/2DL Results
3.9 5.0 Std Dev. 21.9515
< 2 5.0 Mean 13.5135
< 2 5.0 C.V. 1.6244
29 29.0 n 74
4 5.0
2 5.0 Mult Factor= 2.4000
2 5.0 Max. Value 130.0 ug/L
< 2 5.0 Max. Pred Cw 312.0 ug/L
2.4 5.000
3.4 5.000
• 2 5.000
4 5.000
6.8 5.000
3.4 5.0
3.3 5.0
2.3 5.0
2 5.0
< 2 5.0
< 2 5.0
• 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
<' 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
6 5.0
33 33.0
5 5.0
9 5.0
< 2 5.0
34 34.0
21 21.0
6 5.0
< 2 5.0
c 2 5.0
17 17.0
8 5.0
20 20.0
15 15.0
28 28.0
12 12.0
22 22.0
19 19.0
9 5.0
< 2 5.0
5 5.0
• 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
< 2 5.0
5 5.0
25 25.0
36 36.0
130 130.0
10 10.0
44 44.0
35 35.0
<' 2 5.0
6 5.0
24911_rpa.xls, data
- 3 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
70 9/15/2005 27 27.0
71 9/16/2005 27 27.0
72 10/26/2005 20 20.0
73 10/27/2005 28 28.0
74 11/22/2005 28 28.0
75 11/23/2005 22 22.0
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
70 9/16/2005 38 38.0
71 10/26/2005 130 130.0
72 10/27/2005 < 2 5.0
73 11/22/2005 14 14.0
74 11/23/2005, 23 23.0
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
24911_rpa.xls, data
- 9 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
Lead
Mercury
Date Data BDL=1/2DL Results
1 Nov-2005 <: 5 2.5 Std Dev. 1.6167
2 Oct-2005 5.6 5.6 Mean 3.3281
3 Sep•2005 { 5 2.5 C.V. 0.4858
4 7.4 7.4 n 32
5 < 5 2.5
6 <`' 5 2.5 Mult Factor = 1.7500
7 <; 5 2.5 Max. Value 7.4 ug/L
8 Aug-2005 Max. Pred Cw 13.0 ug/L
9 Jul-2005 < 5 2.5
10 Jun-2005
11 May-2005 < 5 2.5
12 Apr-2005 < 5 2.5
13 Mar-2005 < 5 2.5
14 Feb-2005 < 5 • 2.5
15 Jan-2005 < 5 2.5
16 Dec-2004 < 5 2.5
17 Nov-2004 7 6.6
18 Oct-2004 < 5 2.5
19 Sep-2004 < 5 2.5
20 Aug-2004 < 5 2.5
21 Jul-2004 5 5.4
22 Jun-2004 6 6.3
23 May-2004 < 5 2.5
24 Apr-2004 7 6.5
25 Mar-2004 <' 5 2.5
26 Feb-2004 6 6.2
27 Jan-2004 < 5 2.5
28 Dec-2003 < 5 2.5
29 Nov-2003 < 5 2.5
30 Oct-2003 < 5 2.5
31 Sep-2003 < 5 2.5
32 Aug-2003 <' 5 2.5
33 Jul-2003 < 5 2.5
34 Jun-2003 < 5 2.5
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Date Data BDL=1/2DL Results
1 Nov-2005 33.3 33.3 Std Dev. 4.8501
2 Oct-2005 31.1 31.1 Mean 25.1897
3 Sep-2005 17.2 17.2 C.V. 0.1925
4 21.9 21.9 n 29
5 25 25.0
6 26.3 26.3 Mult Factor = 1.2800
7 28.1 28.1 Max. Value 36.2 ng/L
8 Aug-2005 Max. Pred Cw 46.3 ng/L
9 Jul-2005 23 22.9
10 Jun-2005
11 May-2005 20 19.7
12 Apr-2005 31 30.5
13 Mar-2005 29 28.9
14 Feb-2005 25 25.4
15 Jan-2005 21 21.3
16 Dec-2004 26 26.4
17 Nov-2004 30 29.9
18 Oct-2004 21 21.3
19 Sep-2004 28 27.5
20 Aug-2004 19 18.5
21 Jul-2004 25 24.6
22 Jun-2004 25 25.1
23 May-2004 20 19.8
24 Apr-2004 24 23.9
25 Mar-2004 20 20.3
26 Feb-2004 22 21.7
27 Jan-2004 21 21.0
28 Dec-2003 34 34.3
29 Nov-2003 36 36.2
30 Oct-2003 25 25.0
31 Sep-2003 23 23.4
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
24911_rpa.xls, data
- 4 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
Nickel
Silver
Date Data BDL=1/2DL Results
1 Nov-2005 7.1 7.1 Std Dev.
2 Oct-2005 5.2 5.2 Mean
3 Sep-2005 11 11.0 C.V.
4 9 9.0 n
5 5.4 5.4
6 5.4 5.4 Mull Factor =
7 < 5 2.5 Max. Value
8 Aug-2005 Max. Pred Cw
9 Jul-2005 < 5.0 2.5
10 Jun-2005
11 May-2005 < 5.0 2.5
12 Apr-2005 6.6 6.6
13 Mar-2005 9.0 9.0
14 Feb-2005 5.1 5.1
15 Jan-2005 5.3 5.3
16 Dec-2004 < 5.0 2.5
17 Nov-2004 < 5.0 2.5
18 Oct-2004 < 5.0 2.5
19 Sep-2004 7.7 7.7
20 Aug-2004 3.2 3.2
21 2.5 2.5
22 Jul-2004 8.6 8.6
23 Jun-2004 < 5.0 2.5
24 May-2004 5.4 5.4
25 Apr-2004 8.2 8.2
26 Mar-2004 < 5.0 2.5
27 Feb-2004 6.3 6.3
28 Jan-2004 < 5.0 2.5
29 Dec-2003 8.0 8.0
30 Nov-2003 14.0 14.0
31 Oct-2003 18.0 18.0
32 Sep-2003 9.9 9.9
33 Aug-2003 6.6 6.6
34 Jul-2003 5.6 5.6
35 Jun-2003 6.8 6.8
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Date Data BDL=1/2DL Results
3.6241 1 1/8/2003 4.9 4.9 Std Dev. 2.86
6.1333 2 1/15/2003 3.9 3.9 Mean 2.91
0.5909 3 2/5/2003 3.2 3.2 C.V. 0.98
33 4 2/7/2003 < 2.0 1.0 n 75
5 3/5/2003 3.7 3.7
1.93 6 3/7/2003 < 2.0 1.0 Mult Factor = 1.8800
18.0 ug/L 7 4/9/2003 < 2.0 1.0 Max. Value 25.0 ug/L
34.7 ug/L 8 4/10/2003 2.0 2.0 Max. Pred Cw 47.0 ug/L
9 5/14/2003 < 2.0 1.0
10 5/15/2003 < 2.0 1.0
11 6/3/2003 3.1 3.1
12 6/4/2003 - 3.0 3.0
13 7/8/2003 2.8 2.8
14 7/9/2003 3.7 3.7
15 8/13/2003 3.7 3.7
16 8/14/2003 3.3 3.3
17 9/17/2003 2.0 2.0
18 9/18/2003 2.5 2.5
19 10/15/2003 3.5 3.5
20 10/16/2003 3.6 3.6
21 11/12/2003 3.1 3.1
22 11/13/2003 3.0 3.0
23 12/10/2003 3.4 3.4
24 12/11/2003 3.2 3.2
25 1/5/2004 3.2 3.2
26 1/6/2004 2.1 2.1
27 2/18/2004 2.4 2.4
28 2/19/2004 3.3 3.3
29 3/16/2004 7.4 7.4
30 3/17/2004 3.6 3.6
31 4/14/2004 2.5 2.5
32 4/15/2004 2.5 2.5
33 5/5/2004 2.5 2.5
34 5/6/2004 3.0 3.0
35 6/2/2004 2.4 2.4
36 6/3/2004 3.1 3.1
37 7/7/2004 < 2.0 1.0
38 7/8/2004 2.7 2.7
39 8/5/2004 3.2 3.2
40 8/6/2004 2.5 2.5
41 9/2/2004 2.5 2.5
42 9/20/2004 3.1 3.1
43 10/12/2004 3.5 3.5
44 10/14/2004 2.0 2.0
45 11/9/2004 2.6 2.6
46 11/11/2004 2.4 2.4
47 12/8/2004 2.6 2.6
48 12/9/2004 2.3 2.3
49 1/12/2005 3.2 3.2
50 1/13/2005 2.4 2.4
51 2/16/2005 2.3 2.3
52 2/17/2005 2.8 2.8
53 3/9/2005 3.2 3.2
54 3/10/2005 4.6 4.6
55 4/6/2005 3.6 3.6
56 4/7/2005 2.7 2.7
57 5/11/2005 25.0 25.0
58 5/19/2005 < 2.0 1.0
59 5/26/2005 6.8 6.8
60 6/16/2005 2.6 2.6
61 6/20/2005 < 2.0 1.0
62 7/21/2005 2.2 2.2
63 7/22/2005 2.1 2.1
64 8/10/2005 < 2.0 1.0
65 8/11/2005 < 2.0 1.0
66 9/7/2005 < 2.0 1.0
67 9/12/2005 < 2.0 1.0
68 9/13/2005 < 2.0 1.0
69 9/14/2005 2.5 2.5
24911_rpa.xls, data
- 5 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
70 9/15/2005 < 2.0 1.0
71 9/16/2005 2.6 2.6
72 10/26/2005 ' 2.0 2.0
73 10/27/2005 2.6 2.6
74 11/22/2005 < 2.0 1.0
75 11/23/2005 < 2.0 1.0
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102 3�
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118�.
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
24911_rpa.xls, data
- 11 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
Zinc
0
Date Data BDL=1/2DL Results
1 1/8/2003 93 93.0 Std Dev. 32.5619
2 1/15/2003 `. 74 74.0 Mean 84.0933
3 2/5/2003 88 88.0 C.V. 0.3872
4 2/7/2003 94 94.0 n 75
5 3/5/2003 86 86.0
6 3/7/2003 78 78.0 Mult Factor = 1.3300
7 4/9/2003 63 63.0 Max. Value 230.0 ug/L
8 4/10/2003 60 60.0 Max. Pred Cw 305.9 ug/L
9 5/14/2003 70 70.0
10 5/15/2003 84 84.0
11 6/3/2003 `''' 84 84.0
12 6/4/2003 80 80.0
13 7/8/2003 61 61.0
14 7/9/2003 63 63.0
15 8/13/2003 77 77.0
16 8/14/2003 73 73.0
17 9/17/2003 78 78.0
18 9/18/2003 74 74.0
19 10/15/2003 84 84.0
20 10/16/2003 110 110.0
21 11/12/2003. 95 95.0
22 11/13/2003 94 94.0
23 12/10/2003 91 91.0
24 12/11/2003 94 94.0
25 1/5/2004 `' 230 230.0
26 1/6/2004 67 67.0
27 2/18/2004':',. - 160 160.0
28 2/19/2004 150 150.0
29 3/16/2004 78 78.0
30 3/17/2004 92 92.0
31 4/14/2004 96 96.0
32 4/15/2004 66 66.0
33 5/5/2004 60 60.0
34 5/6/2004 64 64.0
35 6/2/2004 47 47.0
36 6/3/2004 70 70.0
37 7/7/2004 70 70.0
38 7/8/2004 110 110.0
39 8/5/2004 89 89.0
40 8/6/2004 74 74.0
41 9/2/2004 110 110.0
42 9/20/2004 76 76.0
43 10/12/2004 71 71.0
44 10/14/2004 61 61.0
45 11/9/2004 77 77.0
46 11/11/2004 99 99.0
47 12/8/2004 72 72.0
48 12/9/2004 78 78.0
49 1/12/2005 > 73 73.0
50 1/13/2005 82 82.0
51 2/16/2005 92 92.0
52 2/17/2005 91 91.0
53 3/9/2005 99 99.0
54 3/10/2005 87 87.0
55 4/6/2005 100 100.0
56 4/7/2005 77 77.0
57 5/11/2005 120 120.0
58 5/19/2005 37 37.0
59 5/26/2005 76 76.0
60 6/16/2005 71 71.0
61 6/20/2005 52 52.0
62 7/21/2005 74 74.0
63 7/22/2005 51 51.0
64 8/10/2005 59 59.0
65 8/11/2005 52 52.0
66 9/7/2005 52 52.0
67 9/12/2005 55 55.0
68 9/13/2005 230 230.0
69 9/14/2005 65 65.0
Date Data BDL=1/2DL Results
Std Dev. NO DATA
Mean NO DATA
C.V. NO DATA
n 0
Mull Factor = N/A
Max. Value 0.0 0
Max. Pred Cw N/A 0
24911_rpa.xls, data
- 6 - 2/13/2006

REASONABLE POTENTIAL ANALYSIS
70 9/15/2005 53 53.0
71 9/16/2005 62 62.0
72 10/26/2005 67 67.0
73 10/27/2005 140 140.0
74 11/22/2005 91 91.0
75 11/23/2005 84 84.0
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
24911_rpa.xls, data
- 12 - 2/13/2006

NPDES/Non-Discharge Permitting Unit Pretreatment Information Request Form
NPDES OR NONDISCHARGE PERMITTING UNIT COMPLETES THIS PART:
Date of Request 1/24/2006
Facility
MSD Buncombe
Permit #
NC0024911
Region
Asheville
Requestor
Toya Fields
Pretreatment A-F Towns- Dana Folley (ext. 523)
Contact G-M Towns- Jon Risgaard (ext. 580)
N-Z Towns- Deborah Gore (ext. 593)
COMMENTS TO PRETREATMENT UNIT:
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 Program
I 3a) is Full Program with LTMP I or 3b) is Modified Program with STMP
4) the facility MUST develop a Pretreatment Program - Full Modified
5) additional conditions regarding Pretreatment attached or listed below
Flow Permitted MGD Actual MGD
Industrial 2.94 2.3
STMP time frame:
most recent
Domestic NA 19.06
next cycle
L
(S)
T
MP
Pollutant
Check List
POC due to
NPDES/Non-
Discharge
Permit Limit
Required
by EPA*
Required by
503 Sludge**
POC due to SIU"•
Site specific POC (Provide Explanation)****
STMP
Frequency at
effluent
LTMP
Frequency at
effluent
4
BOD
4
Q
II
TSS
4
Q
NH3
4
Q M
/�1
.7
Arsenic
4
Q
Cadmium
4
Q
Chromium
.
4
4
Q
Copper
q
«1
4
Q
'I
Cyanide
4
Q
A
Lead
-1
-V
4
Q
A-
Mercury
4
Q
Molybdenum
4
Q M
-4-
Nickel
4
4
4
Q
-Ni
Silver
4
Q
Selenium
4
Q M
A-
Zinc
I/
-4
4
Q
1NH4
4
Q
4
% Solids
4
Q
Beryllium
4
Q
Il
Flow
4
Q
1
C-BOD
4
Q
'Always in the LTMP
"Only in the LTMP if the POTW land applies sludge
***Only in LTMP while the SLU is connected to the POTW
-- Only in LTMP when the pollutant is a specific concem to the POTW (ex -Chlorides for a POTW who accepts Textile waste)
all LTMP/STMP effluent data
on DMRs?
Yes
0= Quarterly
M=Monthly
h d tt o aacata
N( )
Comments: check bims ansd or
available in spreadsheet?
Yes No
r
version 10/8/03
L
Copy of NPDES_Pretreatment.request.form.031008.xls
Revised: August 4, 2000

Current Status
Hominy Creek, from the source to Moore Creek (16.1 miles), is Supporting due to a Good -Fair
bioclassification at SB-39 and F-4 and a Good bioclassification at site SB-38. Hominy Creek,
from Moore Creek to the French Broad River (7.8 miles), however, is currently Impaired due to
a Fair bioclassification at site B-8. This site is near the community of Enka, downstream of the
BASF discharge. Conductivity was much higher below the discharge, and there were many
pollution tolerant macroinvertebrates collected, which suggests that this portion of Hominy
Creek may be impacted by toxicity. The stream also has showed evidence of severe habitat
degradation including bank erosion and poor riparian buffers. The downstream portion of
Hominy Creek is urbanized. A special study found that many of the problems facing Hominy
Creek may be attributed to development directly next to the stream (NCDENR-DWQ, 2002a).
2005 Recommendations
DWQ will continue to monitor water quality in Hominy Creek and work with other local
agencies to study the toxic impacts affecting this stream. BASF is no longer discharging to
Hominy Creek, which may result in a higher bioclassification rating during the next sampling
cycle. It is recommended that local agencies work with landowners to install BMPs to improve
the riparian zone and complete stream restoration activities. These practices will improve habitat
and stabilize eroding banks. In addition, care should be taken during development to minimize
erosion and sedimentation of the stream, and an area of natural vegetation should be maintained
adjacent to the stream. It is recommended that local efforts work together and focus on this
watershed for water quality improvement.
Water Quality Initiatives
Through the NC Agriculture Cost Share Program (NCACSP) and Agriculture Sediment
Initiative, the Buncombe County Soil and Water Conservation District (BCSWCD) was provided
$35,000 in cost share funding for BMPs in the Hominy Creek watershed. Implementation of
several BMPs is currently underway. For more information on either of these programs, refer to
Chapter 11.
Because of the water quality impairment noted above, Hominy Creek has been identified by
NCEEP as one of 28 local watersheds in the basin with the greatest need and opportunity for
stream and wetland restoration efforts. This watershed will be given higher priority than
nontargeted watersheds for implementation of NCEEP restoration projects.
2.3.3 French Broad River [AU# 6-(54.5)b, d and e]
Current Status
The French Broad River [AU# 6-(54.5)b], from Mud Creek to NC 146 (8.2 miles), is Supporting
in the aquatic life category due to a Good -Fair bioclassification at site B-1. This same segment,
however, is Impaired in the recreation category due to a standards violation for fecal coliform
bacteria. During annual screening in 2002, the ambient monitoring station (A-5) at Glenn Bridge
Road (SR 3495) near Skyland exceeded the water quality screening criteria for fecal coliform
bacteria. Subsequent monitoring of five samples in 30 days is required by DWQ assessment
methodology to confirm the fecal coliform levels and determine if it exceeds the state standard.
This additional monitoring reported fecal coliform bacteria levels above the standard. Excessive
rainfall in the two years of monitoring (Fall 2002 through 2003) caused extremely high flows in
Chapter 2 — French Broad River Subbasin 04-03-02 24

the French Broad River. The associated nonpoint runoff from the precipitation events may have
caused the higher than normal bacteria levels.
Regional DWQ staff and the Buncombe County Metropolitan Sewerage District — Water
Reclamation Facility (MSD-WRF) are working to identify possible sources of the elevated fecal
coliform bacteria. The specific source has not been identified; however, the regional staff and
MSD-WRF were able to eliminate an MSD-WRF pump station as a potential source. This pump
station force main crosses the French Broad River, and no leaks or damage was found in the line.
Given that land use in this segment of the river is dominated by agricultural pastureland, it is
likely that the potential source of fecal coliform bacteria is associated with nonpoint source
runoff during heavy rain events.
From NC 146 to Craggy Dam (17.9 miles), the French Broad River [AU# 6-(54.5)c] is
Supporting in the aquatic life category due to a Good bioclassification at site B-2. No standards
violations were reported for fecal coliform bacteria at the ambient monitoring station A-9;
therefore, this segment is also Supporting in the recreation category. This site has been sampled
seven times since 1983 and has steadily increased from Fair (1983 and 1985) to Good -Fair
(1987, 1992 and 1997) to the most recent Good (2002) bioclassification. Like much of the
French Broad River, this section receives runoff from both point and nonpoint sources including
the City of Asheville and surrounding agricultural land. Substrate was a good mix of boulders
and rubble, and the macroinvertebrate community has been fairly stable since 1992.
rThe French Broad River [AU# 6-(54.5)d and e], from Craggy Dam to Sandymush Creek (10.3
miles), is Impaired in the aquatic life category due to a Fair bioclassification at site B-3. Craggy
Dam (Section 14.2) is a "run -of -river" dam that could potentially slow the flow of the river
during drought conditions, consequently impacting the benthic community downstream.
Specific conductivity was slightly higher at this site than at the upstream site B-2 (-90
µmhos/cm compared to —50 µmhos/cm). The stream substrate was a good mix of boulders and
rubble.
Like much of the river, this section is impacted by runoff from both point and nonpoint sources
(i.e., agriculture, stormwater, etc.) and has historically received Fair (1990 and 1992) and/or
Good -Fair (1997) bioclassifications. The improvement to Good -Fair in 1997 was most likely
associated with treatment and operation upgrades at MSD-WRF. No violations of the discharge
permit were reported from 2000 to 2002, and information provided by MSD-WRF shows that
instream waste concentration of the discharge was less than 5% of the river's flow during July
2002. This section of the river also receives water from Newfound Creek and Reems Creek.
Both of these watersheds have historically been impacted by both urban and agricultural runoff.
For more information on either of these watersheds, refer to Sections 2.3.5 and 2.4.1,
respectively.
Overall, the aquatic community in this stretch of the river has historically received low (Fair)
and/or marginal (Good -Fair) bioclassifications. Based on these low and marginal
bioclassifications, this segment is considered Impaired based on the most recent sampling data.
DWQ will continue to monitor this segment of the French Broad River and continue to work
with the City of Asheville as they develop a Phase II stormwater program to minimize impacts
from both point and nonpoint sources.
Chapter 2 — French Broad River Subbasin 04-03-02 25

2005 Recommendations
A total maximum daily load (TMDL) should be developed to identify and address the elevated
fecal coliform bacteria levels found in the river from Mud Creek to NC 146 (8.2 miles). It is
recommended that the adjacent segments of the French Broad River be included in this TMDL
so that the source of the fecal coliform can be identified and targeted for reduction. Prior to
scheduling and developing a TMDL, DWQ staff will continue to work with other agencies and
organizations to attempt to track and remedy sources of bacteria. Continued follow-up
monitoring is being conducted in this more normal flow year of 2004 to assess the persistence of
fecal coliform bacteria.
DWQ will also continue to monitor benthic macroinvertebrates along the entire mainstem of the
French Broad River and work with local agencies to identify impacts from point and nonpoint
sources.
Water Quality Initiatives
MSD-WRF is continually investing funds into its aggressive sewer rehabilitation program and
has completed several projects throughout the county. The results have reduced the amount of
sanitary sewer overflows, and no permit violations were reported from 2000 to 2002. For more
information about MSD-WRF, visit their website at www.msdbc.ore.
2.3.4 Swannanoa River [AU# 6-78a and c]
2000 Recommendations
Swannanoa River was not Impaired, but impacts to water quality are evident along the entire
length of the river. DWQ recommends a strategy of monitoring the river to identify sources of
sediment. Sediment controls should be enhanced and in accordance with regulations or
ordinances to prevent further impacts to habitat and water quality along the Swannanoa River.
Current Status
The Swannanoa River, from source to the North Fork Swannanoa River (7.0 miles), is currently
Impaired because of Fair bioclassification at site SB-49. The river is also Impaired from Beetree
Creek to Bull Creek (2.6 miles) due to a Fair bioclassification at site B-10.
Segments of the Swannanoa River, from the North Fork of the Swannanoa River to Beetree
Creek (4.6 miles) and from Bull Creek to the French Broad River (11.5 miles), are currently
Supporting because of Good -Fair bioclassification at sites B-11, SB-48 and SB-50 and a Good
bioclassification at site F-6.
Much of the data collected in this watershed during the assessment period was part of special
study to prioritize projects for conservation and restoration (NCDENR-DWQ, January 2003). All
of the sample sites on the Swannanoa River indicate water quality problems. These include:
habitat degradation; poor riparian buffer zones; nutrient enrichment; sedimentation;
channelization; and toxicity. Many of these problems may be attributed to urban/residential
runoff and development. The lower portion of the river (near Biltmore Forest) has improved
over time, progressing from Poor or Fair in the 1980s to Good -Fair in the 1990s. The middle
section, however, still has a Fair bioclassification, and there are indications of water quality
decline over time.
Chapter 2 — French Broad River Subbasin 04-03-02 26

RE: MSD permit
Subject: RE: MSD permit
From: "John Kiviniemi" <[e-mail]>
Date: Mon, 18 Sep 2006 17:43:36 -0400
To: "'Susan Wilson" <[e-mail]>
CC: "'Toya Fields' <[e-mail]>
Thanks - we are having a collective meeting of the MSD minds (including Gary McGill & Forrest
Westall) Wednesday afternoon. We are truly concerned that we are chasing "ghosts" with respect
to Cn and accepting a limit, even with a gracious "compliance period" may prove ultimately
damaging to MSD with respect to permit compliance/enforcement; not to mention the potential
for 3rd party litigation. I would welcome talking with you though prior to/after the Wednesday
meeeting, as MSD would like to reach an amenable solution for all concerned, as adjudication is
not exactly our "desired" route. I am free tomorrow (Tuesday - 9/19) between 10am - 2pm and
after 3pm. Call me on my cellular if I'm not in the office (828-768-0216). Thanks. JK
Original Message
From: Susan Wilson[mailto:[e-mail]]
Sent: Monday, September 18, 2006 10:37 AM
To: [e-mail]
Cc: Toya Fields
Subject: MSD permit
John,
Toya let me know of your concerns. We have not issued the permit yet and I hope to
call you today or tomorrow. Thanks.
Susan
Susan A. Wilson, P.E.
Supervisor, Western NPDES Program
(919) 733 - 5083, ext. 510
1617 Mail Service Center
Raleigh, NC 27699-1617
1 of 1
9/19/2006 8:48 AM

[Fwd: NPDES Permit]
Subject: [Fwd: NPDES Permit]
From: Toya Fields <[e-mail]>
Date: Mon, 18 Sep 2006 10:19:08 -0400
To: Susan Wilson <[e-mail]>
Original Message
Subject: NPDES Permit
Date: Fri, 15 Sep 2006 11:22:52 -0400
From: John Kiviniemi <[e-mail]>
Reply -To: <[e-mail]>
Organization: MSD of Buncombe County, NC
To: 'Toya Fields' <[e-mail]>
Good morning Toya - I hope this e-mail finds you well. Per a previous e-mail, I
would again ask that you NOT formally issue the permit just yet. MSD is meeting next
Wednesday to decide on our final course of action with respect to the CN issue. We
are concerned that the 18 months may not produce the "smoking gun" and we will be
facing non compliance with a limit we cannot meet. We also are concerned that
accepting the 18 months will eliminate our right to an ajudicatory hearing on the
matter if necessary. We are meeting with Gary McGill, Forrest Westall and our legal
counsel next Wednesday as indicated to further discuss the matter and develop a final
strategy. As mentioned previously we have been actively sampling for Cn with no
major finds to date. We are hopeful that a continued collaborative effort with
NCDENR can ultimately resolve this issue. I anticipate a formal letter outlining our
final position on the matter will result from Wednesday's meeting. Delaying formal
issuance of the permit until NCDENR has received/reviewed this correspondence would
likely be prudent. JK
John Kiviniemi
Director - Water Reclamation
MSD
Toya Fields - [e-mail]
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: [phone] x 551
Fax: [phone]
1 of 1 9 / 19 / 2006 8:49 AM

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[Fwd: Npdes Permit]
paNe 922' ZZs s223
Subject: [Fwd: Npdes Permit]
From: Toya Fields <[e-mail]>
Date: Thu, 14 Sep 2006 14:02:53 -0400
To: Susan Wilson <[e-mail]>
Original Message
Subject: Npdes Permit
Date: Thu, 14 Sep 2006 14:05:58 -0400
From: John Kiviniemi <[e-mail]>
Reply -To: <[e-mail]>
Organization: MSD of Buncombe County, NC
To: 'Toya Fields' <[e-mail]>
Thanks for returning my telephone messages concerning a few outstanding items related
to our NPDES permit. We've asked Forrest Westall w/McGill Associates to comment on
the pros/cons of how to best deal with the 18 month compliance window (i.e. reference
vs. special condition). We also are evaluating how accepting the permit now relates
to future adjudicatory "rights" down the road if we cannot find the source of our
episodic Cn blips and/or have no viable control options in this regard. In addition
we would like the Cn limit derivation protocol you referenced - you can fax it to me
@ 828-251-4767. We want to further evaluate this as it relates to our position that
our site specific limit should be 42 ug/1 - which is derived utilizing the 5 ug/1 WQ
std. and our 40 MGD design flow @ 12% IWC. I know you mentioned that you were
looking to issue the permit in the coming days - I would greatly appreciate you
holding off formally issuing the permit until closer to the end of the month such
that we have time to decide on our final course of action; specifically the
adjudicatory route. JK
John Kiviniemi
Director - Water Reclamation
MSD
Toya Fields - [e-mail]
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: [phone] x 551
Fax: [phone]
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9 / 19 / 2006 8:49 AM

Re: NPDES Permit Renewal
Subject: Re: NPDES Permit Renewal
From: Toya Fields <[e-mail]>
Date: Fri, 08 Sep 2006 11:52:15 -0400
To: [e-mail], Susan Wilson <[e-mail]>
John,
Please consider this a formal response to your letter dated March 13, 2006 and May 9, 2006.
The issues mentioned in the March 13th letter were as follows:
Increase in groundwater monitoring requirements. This was an error in the draft NPDES permit. We
did not intend to increase MSD's existing groundwater monitoring requirements. I spoke with Betty .
Wilcox in the Groundwater Protection Unit and she indicated their program typically requires
monitoring 3 times per year. The NPDES permit will reflect those requirements.
Supplement to permit cover page. The primary microscreens and gravity belt thickeners will be noted as
"currently out of service".
Stream class. The stream class for the French Broad River will be corrected to class B.
Nomenclature. We will change references to the facility as a "water reclamation facility" or WRF.
The remainder and bulk of the letter concerns cyanide. Several theories are posed as to why cyanide is
being detected in the effluent but does not seem to exist in the influent. Our position is that we will
allow MSD a reasonable period of time to demonstrate that the facility is experiencing "false positives"
or "matrix interferences", but we will not assume that this is the case as a default. Several facilities in
the state have attempted to perform site -specific cyanide studies but only one has been successful in
demonstrating that they are in fact experiencing interference. Also, as we discussed in our meeting, we
would be happy to review any proposed study plan, however NPDES staff is not qualified to give
specific guidance on exactly how to go about performing a demonstration. Therefore I can't comment
on some of the specific theories posed in your comment letter.
As far as the calculation of the cyanide limit: MSD's January 5, 2001 permit also included a daily
maximum cyanide limit of 22 µg/L. It appears that a modification was issued in February 2001 which
re-evaluated (and removed) the limit based on more recent data. In this cycle we will be reinstating the
22 µg/L daily maximum cyanide limit, which is based on acute criteria and is consistent with Division
procedure.
As far as the compliance period, again, we feel that 18 months is more than adequate. In November
2000, MSD submitted comments on a proposed NPDES permit where MSD argued that the facility was
experiencing "analytic anomalies" and "false positives" with respect to cyanide. Therefore MSD has
known about this issue for more than 6 years. Furthermore, the draft permit was mailed in February of
this year, and since that time you have been aware that current cyanide values were a concern at the
facility. Also, if MSD has been actively sampling and developing the draft study since we last met, then
that is at least 6 months of preparation that has already gone into this issue. Therefore we feel that an
additional 18 months is more than reasonable.
1 of 2 9/8/2006 1:33 PM

Re: NPDES Permit Renewal
Thank you for your comments.
Toya Fields
John Kiviniemi wrote:
It appears we have both been waiting for the other to respond. We have
developed a study plan but were waiting to heare back from you prior to
sending it for "review". The attached letter sent to NCDENR requested a
written response to our March 13, 2006 letter concerning our draft NPDES
permit. There were numerous issues addressed in that letter which MSD
request response to; specifically options for dealing with the cyanide
issue. I can forward you the study plan for your comments. We have been
actively sampling at the treatment plant since our May meeting - we've yet
to find the "needle in the haystack" and renew our stance that these
episodic blips are analytical anomolies. While we are appreciative of the
noted 18 months, we would prefer 24 months. As mentioned in our May meeting
we want to fully assess seasonal variations as well as potential impacts of
lost industrial flows. We also renew our concern about the proposed limit
of 22 ug/1 - the previous limit was 43 ug/1 and is consist with the limits
calculation model based on the NCWQ std. If a limit is to take affect after
18 months it appears it should be 43 ug/1. I would like to discuss this
further when you have time before you issue the permit. JK
Original Message
From: Toya Fields [mailto:[e-mail]]
Sent: Thursday, September 07, 2006 5:13 PM
To: [e-mail]
Subject: NPDES Permit Renewal
Hi John,
After our meeting in May, you sent us a letter stating that Buncombe MSD
would be developing plans for a site specific cyanide study and would
forward a copy of the study plan to our office. We haven't yet received
anything and at this point (since its been so long) we would like to
move ahead with the permit issuance. As we stated in the meeting, we
still don't think its appropriate to give a 3 year compliance schedule
on this. The cyanide limit will take effect 18 months after the
effective date of the final permit. I'll try to get the permit out
within the next few days and it would be effective October 1st.
Thanks,
Toya
Toya Fields - [e-mail]
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: [phone] x 551
Fax: [phone]
2 of 2 9/8/2006 1:33 PM

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
AUG o 7 2006
Ms. LeToya Fields
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Draft NPDES Permit
MSD Buncombe County WWTP
Permit No. NC0024911
Dear Ms. Fields:
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit referenced above. Contingent on the permit having 85% removal requirements for 5-day
carbonaceous biochemical oxygen demand and total suspended solids, we have no comments.
We request that we be afforded an additional review opportunity only if significant changes are
made to the draft permit prior to issuance or if significant comments objecting to the draft permit
are received. Otherwise, please send us one copy of the final permit when issued.
Based on the above, EPA's March 20, 2006 interim objection is withdrawn.
Sincerely,
i 0 2006 ._`
Df.NR • 4':A;ER QUALITY
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsurner)

Draft NPDES Permit NC0024911
Subject: Draft NPDES Permit NC0024911
From: Betty Wilcox <Betty.Wilcox C ncmail.net>
Date: Thu, 29 Jun 2006 15:42:02 -0400
To: Toya Fields <[e-mail]>
CC: Debra Watts <debra.watts C ncmail.net>
Toya,
Draft NPDES permit NC0024911 was forwarded to me to review Groundwater Requirements. I offer
the folloj Ong recommendations for Section (A)(4) I Monitoring Requirements:
ge NH3 to Nitrogen, Ammonia Total (as N)
hange Total nitrogen to Nitrogen, Nitrate Total (as N)
Mange Volatile Organic Compounds toVolatile Organic Compounds (Sample annually in the last
quarter] sampling month only.)
orrection: Standard Method 6210D
Call me at 715-6169 if you have questions.
Betty Wilcox
1 of 1 9/8/2006 2:31 PM

09-May-2006
NC-DENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: LeToya Fields and Susan Wilson (Western NPDES Program)
Ms. Fields & Ms. Wilson:
I want to thank you both for the time afforded to MSD last week to discuss our draft NPDES permit,
specifically the issues related to the proposed cyanide limitation. As we discussed, MSD will develop a site
specific cyanide study for its treatment plant in the coming weeks. A copy of this study plan will be
forwarded to NCDENR for review — this is to insure that we don't overlook something that NCDENR
would want included in the study. While it was apparent that MSD will not be afforded the entire permit
cycle to conduct this study, we renew our request to have up to three (3) years. It is important to fully
assess seasonal variations and the potential impacts to our incoming waste load associated with the
impending departure of much of our significant industrial user base.
We would request a formal response to this request and the others outlined in our March 13, 2006 letter to
NCDENR prior to the issuance of our NPDES permit.
Again - thank you for your time, as I know that you are both extremely busy. Please don't hesitate to
contact me if you have any questions.
Sincerely,
John Kiviniemi
Director — Water Reclamation
MSD
(828-225-8223) office #
cc: Gary McGill
Forrest Westall
Tom Hartye

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Metropolitan Sewerage District
OF BUNCOMBE COUNTY, NORTH CAROLINA
LeToya Fields
Western NPDES Program
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Ms. Fields:
MAR 2 0 2006
March 13;-2006----
Thank you for your letter dated February 13, 2006 concerning the draft NPDES permit (#NC0024911) for
the Metropolitan Sewerage District of Buncombe County, NC (MSD) — French Broad River Water
Reclamation Facility. The District appreciates the opportunity to review the draft and present to you our
comments. As I'm sure you know, MSD is committed to full compliance with all environmental
requirements for our facilities and programs. We consider the NDPES permit for our water reclamation
facility to be an essential component and guideline for our compliance efforts. As a result of this
commitment, we share DWQ's objective of providing a permit that properly reflects water quality
requirements and the necessary management and operation of the treatment plant.
Following the specific notations in your letter of the "significant changes" proposed for the permit, we
would make the following general comments and would follow those with more detailed information:
9 The TRC limit of 28µg/L proposed has been noted. MSD will undertake the design of the
necessary treatment modifications to meet this limit and secure approval for the authorization to
construct the modifications within the 18 months compliance period proposed.
➢ MSD will implement the annual pollutant scan included in this draft to be implemented as soon as
the permit is finalized.
➢ MSD is certainly aware that our monitoring data has from time to time shown detectable levels of
cyanide (CN) in the plant's effluent. However, we are convinced that based on a complete
evaluation of the available data, a review of where the samples were taken, considering the
chemical analysis procedures used to develop this data, and the importance of securing more
appropriate data over the next permit cycle, that a CN limit is not appropriate at this time. More
detailed comments are provided below.
➢ MSD appreciates DWQ's review of our cadmium and chromium and the elimination of the
monitoring for these parameters under the NDPES permit. We concur that our pretreatment
monitoring program is adequate to evaluate these parameters.
➢ The inclusion of the groundwater monitoring requirements already being met by MSD is an
appropriate action by the State to properly reflect ongoing compliance demonstration efforts,
however we would request that DWQ retain existing monitoring frequencies. Groundwater
monitoring data collected to date does not indicate elevated levels of any pollutant parameter
included in this requirement. An increase in the monitoring frequency at this time doesn't seem
appropriate Atte ja Cit 11/01tuG ..
•
-Protecting Our Natural Resources-
2028 RIVERSIDE DRIVE, ASHEVILLE, NORTH CAROLINA 28804 TELEPHONE: [phone] FAX: [phone] WEBSITE: www.msdbc.org

t
> Specifically including the existing lagoon in this permit for ash storage from the incinerator is an
appropriate action and reflects the agency's past actions that approved the lagoon for this activity
under an A to C.
In addition to the points provided in your letter, MSD has identified a few additional areas of the permit we
would request that you consider modifying:
> We have noted several items on the supplement to the permit cover page that should be revised to
reflect the current status of various plant process equipment; specifically the primary micro -
screens and gravity belt thickeners should be noted as "currently not in service." These facilities
have consistently been evaluated by DWQ's inspections and their "not in service" status is not a
compliance issue.
> The stream classification listed for the French Broad River is class C waters. We believe that the
current classification is B.
> With respect to consistency of nomenclature, MSD would request that its facility be referenced as
a water reclamation facility and all acronym references noted as WRF.
As noted above, a daily maximum cyanide limit has been proposed in the permit. While this decision is
clearly based on data submitted by the MSD, a complete look at the data in context raises some real doubts
as to the need for a CN limit. As the Division is aware, problems related to "false positives" and "matrix
interferences" with respect to the cyanide sample analysis procedures plague numerous facilities
throughout the country. Many studies have been conducted in this regard in an attempt to get to the bottom
of why cyanide is being detected in treatment plant effluents when there are no corollary findings in
treatment plant influents. In addition, successful IW-pretreatment programs have successfully regulated
metal finishing industry processes that traditionally have been identifiable sources of cyanide. A critical
question in this regard is: "If cyanide is not being detected in treatment plant influent, how is it being
detected in the effluent?" There is no conceivable manner nor known information that would support a
conclusion that treatment plants are producing cyanide. Review of DMR and plant process CN data at
MSD's WRF supports the above concerns. MSD offers the following comments in this regard:
• Elevated CN levels (at a concentration above the calculated IWC) in the treatment plant effluent
have only been recorded episodically.
• Elevated CN levels are not detected in the treatment plant influent.
• Treatment plant performance has been maintained (i.e. no interference) consistently throughout
time; even when elevated effluent CN values have been recorded. Taking into account recorded
%-removal for CN, back calculations of potential influent CN values based on recorded effluent
CN values would have resulted in plant process interference (as noted this did not occur).
• The treatment plant has consistently passed effluent toxicity testing; no cyanide toxicity
correlation has been established for this specific effluent discharge.
• MSD maintains an active and successful IW-Pretreatment Program. There are only a few indirect
dischargers which conduct metal finishing operations which utilize CN; of which all
routine/monthly monitoring data indicate consistent compliance and no measurable levels of CN .
Many have gone to zero discharge of all CN bearing waste streams.
• MSD incorporates fluidized bed incineration as its primary bio-solids management option, with
alkaline stabilization as it back-up. Neither unit process has been adversely affected due to CN
levels.
• Since the WRF effluent contains residual ammonia, the resulting chlorinated final effluent
contributes to potential "false positives" and/or "matrix interferences" for the CN analysis.
In addition to these site specific considerations, much is being done nationally to look at CN within
municipal treatment systems.; The Water Environment Research Foundation (WERF) completed a
comprehensive study in 2003 concerning the on -going concerns surrounding CN. Some of the pertinent
findings of that Study include the following:
Page 2 of 4

• The presence of organocyanide compounds in wastewater could potentially contribute to
elevated cyanide levels in chlorinated WWTP effluents.
• The presence of thiocyanate (a cyanide precursor) can cause significant positive error in the
conventional total cyanide analysis.
• The chlorination of WWTP effluents containing residual ammonia can lead to chloramination
of organic compounds and the resulting production of cyanogens chloride and free cyanide.
• US EPA considers cyanide to be a method define analyte, thus the availability of analytical
methods of distinguishing among cyanide chemical species at environmentally relevant
concentrations is an essential part of the development of water quality criteria that are based
on the differential toxicity of cyanide chemical species. This is consistent with US EPA's
stated intention to affirm the distinction between toxic and comparatively non -toxic forms of
cyanide.
Based on all the above consideration, MSD believes that the current information on CN in its effluent is
inconclusive in warranting a permit limitation. We would request the opportunity to collect more
comprehensive data carefully evaluate this situation. MSD would propose the following course of action in
this regard and would ask that the draft permit be revised to reflect these actions:
• A CN limit should not be included in the permit at this time.
• The permit should require MSD to develop, submit to DWQ for approval, and initiate a
comprehensive cyanide identification evaluation process over this permit cycle ; this
monitoring would also include parameters which have commonly been identified as potential
sources of analytical interference (i.e. chloramines, nitrates, sulfates, etc.)
• Since MSD has a draft TRC requirement and it has been demonstrated that dechlorination can
often lead to a reduction in the amount of CN being detected with current analytical
procedures, it is essential for the comprehensive evaluation to include monitoring results
following implementation of dechlorination activities. Because the noted TRC requirement
does not take effect for 18 months from the effective date of the final reissued permit, it is
reasonable for the evaluation to extend over the entire permit cycle.
• Following the completion of the comprehensive CN evaluation, these results would be
submitted as part of the next permit renewal package for consideration at that time.
In addition to the above identified components of a comprehensive evaluation, MSD would request that
DWQ consider the following points as components of this work:
• The utilization of an alternative approved CN detection method; such as the available cyanide
method (US EPA Method OIA-1677) or other available methods that provide an accurate
measurement of more toxic species of CN.
• Consider a CN translator, much in the manner done for various metals — this could more
appropriately represent the toxic (or presumed bio-available) form of CN.
• Increase the method detection level to 24ug/l. This would be consistent with other treatment
plants that have experienced similar CN related anomalies; specifically the City of Winston
Salem and the City of Greensboro. Both have shown that CN analysis of wastewater below
this noted detection level is often inherently unreliable.
MSD is not the only utility in North Carolina, or nationally for that matter, to experience the identification
of CN as a potential effluent limit. Much CN data and research already exists which shed light on potential
cause and remedies; consistent with those noted above. MSD considers the quality of its effluent its
highest priority and the CN limit an important issue to us and to our whole team. The current knowledge of
the presence or absence of CN within its treatment system is not sufficient to establish a limit as this point.
We would welcome the opportunity to work with DWQ to fashion a CN permit condition which reflects
our commitment to properly evaluate this issue and, if necessary, to establish an effluent limit. MSD would
request a meeting with you to review and discuss this permit prior to its finalization.
Page 3 of 4

Again, thank you for the opportunity to review this permit. MSD has and continues to maintain a strong
commitment to environmental stewardship. We note with some pride that MSD is a registered ISO 14001
organization. MSD continues to make every effort to insure that its facilities provide excellent protection
of the environment and the French Broad River.
Once you have had an opportunity to review and consider our comments, we believe that an open and frank
discussion of these issues between MSD and DWQ is an appropriate next step. Please contact me at 828-
225-8223 or email sewerman @ msdbc.org to schedule this meeting.
Sincerely,
John Kiviniemi
Director — Water Reclamation
Metropolitan Sewerage District — Buncombe County, NC
Cc: Tom Hartye, MSD - General Manager
Susan Wilson, Western NPDES Program Supervisor
Gary McGill , McGill Associates & MSD-Engineering of Record
Forrest Westall, McGill Associates
Page 4 of 4

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 appli
cation of NC General
Statute 143.21, Public
law 92-500 and other
lawful standards and
regulations, the North
Carolina • Environmen
tal Management Com
mission proposes to is
sue a Notional 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 • re
garding• the proposed
permit will be accepted
until 30 days after the
publish . dote of this. no.
tice. All comments. re
ceived prior to that date
are considered in the fi
nal determinations re
garding the proposed
permit. The Director of
the NC Division of Wa
ter Quality may decide
to hold o public meeting
for the proposed permit
should the Division re'
'ceive a significant de
gree of public interest.
Copies of the draft per
mit and other support
Ina information on file
used to determine con
ditions • present in the
draft • permit are avail
able' upon request and
payment of the costs of
reproduction. Mail com
ments and/orrequests
for information to the
NC Division of •Water
Quality at the above ad
dress or call the Point
Source Branch at (919)
733-5083, extension 520
'or 363. Please include
the NPDES permit
number (attached) • in
any communication.. In
terested persons may
also visit the Division of
Water Quality at 512 N.
Salisbury Street, Ra
leigh, NC 27604-1148 be
tween the hours of 8:00
a.m. and 5:00 p.m. to re
view information on
file.
NPDES Permit Num
ber' NC0021946, Town of
Rosman, Transylvania
County, has applied for
a flow extension of its
permit for a facility dis
charging treated „ do
mestic wastewater to
the French Broad River
in the French Broad
River Basin. Currently
fecal coliform and total
residual chlorine are
water quality limited.
'This discharge may of
feet future allocations
In this portion of the re
ceiving stream.
MSD . of Buncombe
County (2028 Riverside
Drive, Asheville, NC
28804) has applied for
renewal of NPDES per
mit NC0024911 for the
`French Broad River
WRF in Buncombe
County. This permitted
facility discharges 40
MGD treated wastewa
ter to the French Broad
River in the French
Broad River Basin. Cur
rently total residual
chlorine and —cyanide
are water quality lim
ited. This • discharge
may affect future alto
cations in this portion of
the French Broad River
Basin.
March 24, 2006
(2165)
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified and
authorized by law to administer oaths, personally
appeared Velene Fagan, who, being first duly
sworn, deposes and says: that she is the Legal
Billing Clerk of The Asheville Citizen -Times,
engaged in publication of a newspaper known as
The Asheville Citizen -Times, published, issued,
and entered as second class mail in the City of
Asheville, in said County and State; that she is
authorized to make this affidavit and sworn
statement; that the notice or other legal
advertisement, a true copy of which is attached
hereto, was published in The Asheville Citizen -
Times on the following date: March 24th , 2006.
And that the said newspaper in which said notice,
paper, document or legal advertisement was
published was, at the time of each and every
publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of
the General Statues of North Carolina and was a
qualified newspaper within the meaning of Section
1-597 of the General Statues of North Carolina.
Sirthis day of March, 2006
U\ 11
(Srgnature of person
Sworn to and
March,ll00
(Notary Putjlic)
My C
2008.
ng affidavit)
subscribe • befo e me the 24t11 day of
mission expires the 3rd day
N�Nlu*g*****
-yFA"

comments on NC0024911, French Broad River WRF
Subject: comments on NC0024911, French Broad River WRF
From: [e-mail]
Date: Thu, 02 Mar 2006 11:24:27 -0500
To: [e-mail]
sorry for the delay in getting these to you. will you be able to reply
by Mar 10?
1. The fact sheet needs to contain the standard language that the
County will continue to implement the existing pretreatment program at
this facility.
2. The draft permit contains an 80% removal requirement for CBOD and )1-L
TSS, but the fact sheet provides no rationale. It is interesting that AlDe'°,S146V\pr''
the previous permit required 85% removal. To justify this waiver from y
secondary treatment, the fact sheet must be revised to provide a
rationale based on one of the factors at 40 CFR Part 133.103 based on �\ �1? M1n�
documentation provided by the permittee. I would like to review any \"�j Imo`
revision. W/o an adequate justification, keeping the 80% removal limits yQ
will result in an objection. will be glad to discuss with you if '1
needed. If more time is needed to resolve this, let me know and I'll
send an interim objection letter.
3. The metals should be expressed as "total".
1 of 1 10/12/2006 9:29 AM

Re: [Fwd: NPDES Permit # NC0024911 - MSD BC]
Subject: Re: [Fwd: NPDES Permit # NC0024911 - MSD BC]
From: Larry Frost <[e-mail]>
Date: Thu, 09 Feb 2006 08:24:19 -0500
To: Toya Fields <toya.fields @ ncmail.net>
CC: Roger Edwards <[e-mail]>
Toya
I have not done a staff report on MSD.
The grease and debris no longer is an issue, they constructed new facilities for this. All I we need to do,
in my opinion, is recognize in the permit that the lagoon exists.
Larry
Toya Fields wrote:
Thanks Larry,
Do you have a staff report for this facility? I don't have anyting in the file. It looks like at some
point there was a concern about the facility placing grease and other debris in the lagoon and there
was mention of giving them some special conditions for a grease/debris management plan so that
they would cease placing the material in the lagoon. Is this still taking place? Do you feel this
language would be necessary? All the correspondence I have is from 2003 so it might be a bit
dated.
Toya
Larry Frost wrote:
Toya
All we want in the permit is that " the lagoon is in use, for the disposal of incinerator ash".
Larry
Toya Fields wrote:
Hi Larry,
What exactly needs to be done during this renewal with respect to the lagoon? I have some
letters in the file stating that the lagoon is currently unpermitted, but I'm not clear whether
they are planning on changing anything or if they just want it added to the permit.
Thanks,
Toya
Larry Frost wrote:
1 of 4 2/13/2006 3:10 PM

Re: MSD-Buncombe NC0024911
Subject: Re: MSD-Buncombe NC0024911
From: Toya Fields <[e-mail]>
Date: Thu, 02 Feb 2006 15:15:01 -0500
To: Shannon Mohr Thornburg <[e-mail]>
I have an email from Dave written shortly before he left (about 3 weeks ago) that mentions the groundwater
monitoring and a requirement for a *closure* plan as well as an ash contingency plan. But based on other
information in the file it doesn't appear that MSD intends to close the lagoon. It appears that they want to
continue using it for ash storage. There is a letter from Forrest written in 2003 discussing the lagoon and
some proposed permit conditions. It mentions:
- A schedule for removal of vacuum truck debris
- Grease management plan
- Physical modification of lagoon
- Site management issues (vegetative control, etc.)
However, according to MSD's permit application, a number of these concerns have been resolved. For example, a
septage receiving station has already been built for the vacuum truck debris. Some site management procedures
were (according to a July 2003 letter) scheduled to be implemented in Fall 2003. So it isn't clear what the
outstanding issues are at this point. I thought I'd contact you and the region to get more information. I
asked Sergei if he has any correspondence concerning this facility. He said the worked with you on another
permit (unpermitted lagoon in the Winston Salem office) but not this one. Natalie Sierra was the former
permit writer for this so perhaps she was involved in the discussions.
Also- groundwater monitoring has been added. NPDES now has a list of facilities that need to have these
requirements in their permits and Buncombe MSD was on the list. I think Mike Templeton was developing
language with Debra Watts.
Essentially, I understand there were a cache of conditions which needed to be placed in the permit. But the
records I have concerning this issue are from 2003 and I need a quick idea of what the current outstanding
issues are in order to move forward with this. Still waiting to hear back from Larry Frost, perhaps he'll
have some input as well.
Toya
Shannon Mohr Thornburg wrote:
It is not an lagoon, rather it is a surface impoundment where the ash from the sludge incinerator is
quenched and stored. There is alot more that needs to be added to the permit in addition to a simple
change to the system description. Specifically, a whole cache of conditions related to the
operation/maintenance of the surface disposal unit including groundwater monitoring well requirements needs
to be in the permit. We advocated for a separate non -discharge permit to be issued for this activity, but
we were overruled by the Permittee and NPDES in favor of incorporating conditions into the NPDES permit.
There should be an e-mail from me to Dave G. and (I think) Sergei from a long time ago somewhere in your
files that listed all of the conditions that needed to be added with the renewal of the NPDES permit. If
not, I suppose that I have to recreate them. Let me know.
Shannon
Toya Fields wrote:
Hi Shannon,
I'm working on the renewal for the French Broad River WRF and there are several letters in the file
concerning the permitting of an existing lagoon. It is my understandig that all that needs to be done
at this point is to list the lagoon as one of the treatment plant components. As far as you're
concerned, would this be satisfactory?
Thanks,
Toya
Shannon Mohr Thornburg, Environmental Engineer ,_.Mailing Address_:
Land Application
Unit
Service Center
Aquifer Protection Section
Raleigh, NC 27699-1636
NCDENR-DWQ
Physical Address_:
Telephone: [phone]
2728 Capital Boulevard, Room No. 1C 130
Fax: (919)
715-0588
1636 Mail
1 of 2 2/13/2006 3:09 PM

Buncombe County MSD Renewal
Subject: Buncombe County MSD Renewal
From: Dave Goodrich <[e-mail]>
Date: Mon, 09 Jan 2006 12:22:57 -0500
To: Toya Fields <[e-mail]>, Susan Wilson <[e-mail]>
Toya -
A couple of years ago, Shannon Thornburg brought up the fact that MSD had a sludge
lagoon that was not permitted by either the Non -Discharge Unit or the NPDES Unit.
She was inspecting their alkaline sludge stabilization process with the ARO and found
a drain that goes to a lagoon. The lagoon has 2 or 3 activities going on that are
inappropriate.
The lagoon was built in the 1960's as a sludge lagoon. Ash does go into the lagoon
today (I'm sorry that I can't remember where the ash comes from based on my memory
and notes). They have also disposed of grit, line cleanouts, grease, and site
stormwater in the past. The outfall from the lagoon returns to the head of the
plant.
MSD said they will landfill the lagoon. They will move future gravel and grit
disposal to their septage facility, and could landfill some of this deposited or new
material if they move past the problem of solidifying it.
We tentatively agreed to handle this by modifying the NPDES permit to include a
special condition for the Lagoon, which should include:
* A requirement for a closure plan (including timeframes and steps
towards abandonment)
* A schedule to remove grit and any other undesirable material (line
cleanout, grease, gravel) from the lagoon
* An ash disposal contingency plan (if problems or capacity issues)
*.
I agree with the first two bullets, but am unsure that we need an ash disposal
contingency plan. I'll leave that to Susan's and your discretion. Also, I think
it's fine to let the MSD know that the GW monitoring will be reviewed upon each
renewal, but I don't think we need to include as part of a special condition. To
give you both some idea of the size of this lagoon, Shannon said that it was 17
acres!
Dave
1 of 1 1 /31 /2006 11:59 AM

Metropolitan Sewerage District
OF BUNCOMBE COUNTY, NORTH CAROLINA
3-June-2005
NC-DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Mrs. Valery Stephens
Re: NPDES Permit # NC0024911 Renewal Application Submittal
Mrs. Stephens:
Enclosed herewith is the subject NPDES permit renewal application for the Metropolitan
Sewerage District of Buncombe County, North Carolina (MSD) — French Broad River
Water Reclamation Facility. MSD owns/operates the subject reclamation facility located at
2225 Riverside Drive, Asheville, NC 28804. The facility is a 40MGD plant that incorporates
a secondary treatment, fixed film design. The current permit expires on December 31, 2005
and MSD does hereby request renewal with this application submittal. Enclosed with the
application is all of the requested supportive documentation about the facility.
If there is any additional information needed to process this renewal request, please do not
hesitate to contact me or the reclamation facility director (John Kiviniemi) at 828-254-9646
or 828-225-8223 respectively.
Sincerely,
Thomas E. Hartye,
General Manager,
Cc: John Kiviniemi — Director, Water Reclamation
File
;^n. �:;. r,.y.,t..q .ng4-.14Im; .
, l
JUN 7 2 25
C, :t - w OUALtTY
FuolT Sl;:kCE BRANCH
-Protecting Our Natural Resources-
2028 RIVERSIDE DRIVE, ASHEVILLE, NORTH CAROLINA 28804 TELEPHONE: [phone] FAX: [phone] WEBSITE: www.msdbc.org

NPDES RENEWAL
2005
Facility Description:
The present reclamation facility is a 40MGD secondary plant serving Buncombe County
(specifically — Asheville, Biltmore Forest, Black Mountain, Montreat, Weaverville, Woodfin
and Buncombe County at large). The facility treats a current average daily flow of 22-23
MGD. The reclamation facility is an attached growth design, comprised of 152 rotating
biological contactors (RBC's). These RBC's provide 450-500 acres (3+ acres each unit) of
surface area for biological growth. It has been said that MSD's facility is the largest RBC
plant in the world. The plant consists of:
Pre
nary Treatment Components
arscreens (2 units) w/screenings compactor and shaftless screw conveyer
nt Pumps (3 units) — 35 MGD rated capacity each
rated Grit Chambers (3 units) w/associated grease removal
Primary Treatment Components
-I ri1mary Microscreens (7 units) — 250 micron screens
Secondary Treatment Components
t4s( Stage RBC's (44 units)
and Stage RBC's (72 units)
Vr tage RBC's (36 units)
termediate Pumps (3 units) — pump water to clarifier from 3rd RBC stage
(Jnttrmediate Clarifier (4 cells — total volume 2 MG)
(condary Microscreens (18 units) — 27 micron screens
Disinfection Components
ki uid Chlorine (Sodium Hypochlorite) — average feed 500-600 lbs./day
Residuals Handling Components
£avity Thickeners (2 units) —100 foot diameter each
vity Belt Thickeners (4 units) — (mothballed - no longer in service)
1pAIeter Belt Presses (2 units)
Vna robic Digesters (2 units) —100 foot diameter each — (mothballed — no longer in service)
(FlUidized Bed Incinerator (40DT/day rated)
tiklaline Stabilization Facility (40DT/day rated)
Energy Manatement Components
2 Megawatt Diesel Generator (full back-up/emergency power for WWTP)
450 Kilowatt Gas Generators (2 units) — operate on natural, digester or landfill gas
850 Kilowatt Hydro Turbines (3 units) — induction units (French Broad River source)
Automation Components
Distributed Control System — full automated control of WWTP

The reclamation facility is permitted for up to 40 MGD, with discharge limits of 25mg/1
CBOD (monthly average) and 30mg/1 TSS (monthly average). The current average removal
efficiency for these two parameters is in excess of 90%, compliance has been consistent.
Since the last permit renewal application, the plant has undergone several improvements.
WWTP Improvements
Fluidized Bed Incinerator — new refractory lining, heat exchanger and duct
Sludge Dewatering Equipment — new 2.5 meter belt filter presses (2 units)
Secondary Micro -screens — SIGNIFICANT rehabilitation efforts on this unit process
Conversion to Liquid Chlorine (Sodium Hypochlorite)
New Septage Receiving Station (adjacent to WRF — 24 hour access)
New (progressive cavity) Thickened Sludge Pumps (replaced aging lobe pumps)
New Variable Frequency Drives for Raw Sewage Pumps (2 of 3 — 3rd scheduled for 2005)
In addition to the items listed above, numerous operational modifications have been made
to improve the overall efficiency of the treatment operation. All of which have significantly
improved the quality of the plant effluent.
It should also be noted that MSD achieved ISO-14001 certification since the last permit
renewal; becoming the 3rd (and largest) utility organization in North Carolina to achieve
this certification.
MSD also maintains an excellent web site, which includes a tour of the treatment facility —
access the site via www.msdbc.org

Sludge Management Plan
MSD utilizes its fluidized bed incinerator as its primary residuals management option, with
alkaline stabilization as a secondary management option — as well as maintains an
arrangement with the Buncombe County landfill (lined) for emergencies. Presently the
facility is managing approx. 16 DT's per day of residuals. The facilities are designed for
40DT's per day. Due to the lack of true primary clarifiers, most of the sludge generated at
the facility is secondary in nature (i.e. sloughings from the RBC's). Sludge is thickened in
on -site gravity thickeners to a consistency of 2-5% solids at which time it is then pumped to
the 2.5-meter belt presses. These units dewater the sludge to 24+% solids and then it is
pumped to the incinerator. The facility maintains gravity belt thickeners and anaerobic
digesters, however these units are presently not being utilized. Air emissions from the
incinerator are of excellent quality. Recent air emissions testing place removal efficiency of
the air scrubbers at 99+% for regulated parameters. Incinerator ash is thickened on -site
via a gravity ash thickener and then pumped to an on -site lagoon. Groundwater is
monitored in accordance with NCDENR requirements (up & down gradient). When
alkaline stabilization operations are activated, a class A product is produced and
distributed to the public. The alkaline add -mixtures utilized in the process are cement kiln
dust (CKD) and lime kiln dust (LKD). The process incorporates the use of the "N-Viro"
process when these alkaline products are utilized in accordance with the patented mix
recipe. Due to the fact that the incinerator operations provide much more cost effective
management, it is utilized as the primary option. Supplementary fuel is still necessary in
most cases, both natural gas & landfill gas, as well as #2 fuel oil, are available for use in this
regard.

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aye :0941UNTY111:11:°*k‘.11'
G�o
Qo\S.�p,N SEWEge,. Qi•
2231, cp a LKOLO
PITSCar
FRENCH BROAD RIVER
MSD WASTEWATER TREATMENT PLANT SITE

SOLIDS STORAGE LAGOON
OVERFLOW
INCINERATOR
BELT FILTER
PRESSES
GRAVITY BELT
THICKENER
PARALLEL ASH/SOLIDS
TO SOLIDS STORAGE LAGOON
GRAVITY BELT THICKE ED Bl0 SOLIDS
TRUCKED TO ALKALINE
B1� 5011105 TRU`17 AT1C.N
CONSTANT PRESSURE
PUMPS
1NTERMED
PUMP BUILDING
TREAiaMENT putter ADMIN.
THICKENER
! K ER OVERFLOW
TEMPORARY PRIMARY
9ACKWASH
FLUENT RFT
SCHEMATIC OF TREATMENT PLANT WASTEWATER FLOW

e
DATE Flow (MGD)
Jan-00 19.6
Feb-00 20.9
Mar-00
Apr-00
May-00
Jun-00
Jul-00
Aug-00
Sep-00
Oct-00
Nov-00
Dec-00
Avg.
LIMITS
22.6
23.8
20.2
19.5
18.9
19.1
18.7
17.8
18.7
18.5
19.9
40.0
DATE pH (min.)
Jan-00 6.8
Feb-00 6.9
Mar-00 7.1
Apr-00 7.1
May-00 7.0
Jun-00 7.1
Jul-00 6.9
Aug-00 7.1
Sep-00 7.2
Oct-00 7.1
Nov-00 7.3
Dec-00 7.0
Avg. 7.1
LIMITS 6.0
INF CBOD
303.6
155.5
119.4
154.9
144.8
124.5
144.3
150.4
174.5
178.2
161.0
249.7
171.7
pH (max.)
7.5
7.4
7.7
8.1
7.5
7.7
7.8
7.6
7.9
7.5
7.6
7.5
7.7
9.0
EFF CBOD
12.6
11.4
13.2
16.7
14.0
12.5
11.7
13.9
11.9
14.1
11.8
11.9
13.0
25.0
Temp. (C)
15.9
15.0
16.4
17.2
20.0
22.5
23.4
24.1
23.2
22.1
19.6
15.7
19.6
% Removal
96%
93%
89%
89%
90%
90%
92%
91%
93%
92%
93%
95%
92%
80%
Conductivity
654.7
683.9
773.6
759.3
680.0
741.4
723.6
802.0
815.9
815.6
848.5
748.7
753.9
INF TSS
266.1
184.4
141.8
142.3
226.8
251.5
193.3
167.1
213.2
201.1
205.4
325.0
209.8
Fecal Coliform
4.3
3.8
14.8
12.6
8.0
6.1
6.7
12.0
15.9
7.0
4.8
2.9
8.2
200.0
EFF TSS
13.3
14.0
14.5
14.8
14.6
15.2
14.0
14.2
12.9
13.1
11.5
13.7
13.8
30.0
% Removal
95%
92%
90%
90%
94%
94%
93%
92%
94%
93%
94%
96%
93%
80%
Cyanide Total N
<10.0
<10.0 18.0
<10.0
<10.0 11.0
<10.0
<10.0
<10.0
<10.0 16.0 4.3
<10.0
<10.0
<10.0
<10.0 22.0 4.8
<10.0 16.8 3.8
EFF NH3-N
6.3
4.7
4.9
16.9
7.7
8.4
9.9
9.3
7.5
10.2
7.7
9.4
8.6
Total P
3.2
2.9
Chronic TOX Dissolved 02
8.90
8.81
PASS-24% 8.30
PASS - 24% 8.25
PASS - 48% 7.96
7.33
7.14
PASS-24% 6.68
6.88
7.28
PASS-24% 7.78
8.67
7.83
PASS-12% >5.0
Residual Cl2
1.29
1.06
0.67
1.00
0.96
1.26
1.11
0.98
1.13
1.53
1.31
1.62
1.16

•
0,
DATE Flow (MGD) INF CBOD EFF CBOD % Removal INF TSS EFF TSS % Removal EFF NH3-N Chronic TOX Dissolved 02
Jan-01 19.3 209.1 13.8 93% 233.1 12.3 95% 9.5 9.14
Feb-01 20.4 217.3 13.7 94% 286.6 12.8 96% 9.0 PASS-12% 8.04
Mar-01 22.5 193.0 16.7 91% 228.8 17.2 92% 8.5 8.85
Apr-01 20.7 258.3 12.9 95% 294.9 12.6 96% 8.4 8.15
May-01 19.3 206.4 10.5 95% 226.9 12.0 95% 5.2 PASS-24% 8.44
Jun-01 19.3 196.2 10.9 94% 248.5 13.7 94% 4.4 8.70
Jul-01 19.7 190.5 10.2 95% 231.1 12.3 95% 8.5 8.24
Aug-01 19.7 184.2 8.7 95% 289.7 14.2 95% 8.5 PASS 8.18
Sep-01 19.0 168.7 6.4 96% 284.1 11.5 96% 5.0 7.89
0ct-01 18.2 157.5 9.3 94% 272.5 11.8 96% 6.8 7.61
Nov-01 18.2 203.9 10.9 95% 323.7 13.4 96% 8.1 PASS 7.64
Dec-01 18.2 105.9 7.0 93% 217.8 13.4 94% 8.6 7.97
Avg. 19.5 190.9 10.9 94% 261.5 13.1 95% 7.5 8.24
LIMITS 40.0 25.0 80% 30.0 80% PASS >5.0
DATE pH (min.) pH (max.) Temp. (C) Conductivity Fecal Coliform Cyanide Total N Total P Residual Cl2
Jan-01 6.6 7.6 13.8 760.8 1.8 <10.0 1.43
Feb-01 7.1 7.4 15.2 788.9 5.0 <10.0 13.0 3.5 1.13
Mar-01 6.6 7.3 15.1 695.8 4.0 <10.0 1.13
Apr-01 6.9 7.5 17.1 705.6 3.1 <10.0 1.51
May-01 7.1 7.5 19.6 794.9 3.7 <10.0 15.0 4.2 1.35
Jun-01 7.1 7.4 21.8 786.4 4.0 <10.0 1.55
Jul-01 6.5 7.6 23.0 735.7 5.1 <10.0 1.65
Aug-01 7.4 7.6 24.3 807.9 7.7 <10.0 19.0 4.0 1.48
Sep-01 7.1 7.5 24.0 761.3 7.2 8.5 1.23
0ct-01 7.1 7.6 21.3 783.0 6.0 <10.0 1.34
Nov-01 6.5 7.7 19.9 843.8 4.2 <10.0 20.0 4.5 1.42
Dec-01 7.1 7.6 18.0 730.5 2.6 10.5 1.67
Avg. 6.9 7.5 19.4 766.2 4.5 <10.0 16.8 4.1 1.41
LIMITS 6.0 9.0 200.0
Note: NC-DENR issued new NPDES permit for WWTP in February 2001. New permit left CBOD & TSS effluent limits unchanged, however
modified %-removal requirement for each to 80%, changed instream monitoring locations (upstream in river adjacent to flume wall at the
fish ladder & downstream to Ledges Park) and removed the numeric limit for cyanide & reduced cyanide monitoring to 2/month.

It
•
0.
DATE Flow (MGD)
Jan-03 19.5
Feb-03 22.9
Mar-03
Apr-03
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-03
Dec-03
Avg.
LIMITS
24.2
26.2
28.6
23.0
23.8
22.8
20.5
20.6
23.1
21.6
23.1
40.0
INF CBOD EFF CBOD
299.5 16.3
244.5 10.2
201.0 10.2
166.5 15.8
137.2 17.2
148.5 15.2
175.1 15.6
149.4 13.0
191.6 14.0
190.5 13.2
168.1 12.9
189.0 12.7
188.4 13.9
25.0
DATE pH (min.) pH (max.) Temp. (C)
Jan-03 6.8 7.7 13.9
Feb-03 7.3 7.6 13.5
Mar-03 7.2 7.7 14.9
Apr-03 6.9 7.7 16.5
May-03 6.9 7.5 18.6
Jun-03 7.2 7.5 20.3
Jul-03 7.2 7.5 22.1
Aug-03 6.9 7.5 23.0
Sep-03 7.1 7.6 22.9
Oct-03 7.2 7.7 21.3
Nov-03 6.7 7.5 18.6
Dec-03 6.9 7.5 15.7
Avg. 7.0 7.6 18.4
LIMITS 6.0 9.0
% Removal
95%
96%
95%
91%
87%
90%
91%
91%
93%
93%
92%
93%
92%
80%
Conductivity
685.5
624.8
639.6
626.5
670.5
697.7
736.8
780.9
895.4
975.0
895.8
712.9
745.1
INF TSS
310.9
226.5
178.0
209.7
257.5
193.3
206.6
170.9
235.7
211.3
176.4
166.7
212.0
Fecal Coliform
4.2
4.8
4.9
5.2
5.5
2.5
6.7
16.8
4.9
3.6
11.3
4.3
6.2
200.0
EFF TSS
12.6
15.8
20.2
18.3
23.0
19.5
21.4
20.9
17.1
15.2
19.5
15.4
18.2
30.0
Cyanide
<10.0
15.5
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
% Removal
96%
93%
89%
91%
91%
90%
90%
88%
93%
93%
89%
91%
91%
80%
Total N
16.0
15.0
19.0
23.6
18.4
EFF NH3-N
5.0
5.0
5.4
6.8
6.5
9.9
10.5
10.6
8.1
10.7
6.6
4.2
7.4
Total P
4.1
2.5
4.8
3.1
3.6
Chronic TOX Dissolved 02
8.66
10.4% * 8.81
17% * 8.86
7.3% * 8.31
24% 8.13
7.52
7.34
36% 7.76
7.72
7.96
36% 8.98
8.81
8.24
PASS >5.0
Residual Cl2
0.64
1.08
1.32
1.09
0.79
0.67
0.57
0.43
0.72
0.54
0.37
0.59
0.73
Note: NC-DENR issued new NPDES permit for WWTP in February 2001. New permit left CBOD & TSS effluent limits unchanged, however
modified %-removal requirement for each to 80%, changed instream monitoring locations (upstream in river adjacent to flume wall at the
fish ladder & downstream to Ledges Park) and removed the numeric limit for cyanide & reduced cyanide monitoring to 2/month.
* Note - Geometric Mean of February, March & April 2003 chronic toxicity test result > 12% (compliant)

DATE Flow (MGD)
Jan-04 19.7
Feb-04 24.3
Mar-04 21.1
Apr-04 22.6
May-04 21.1
Jun-04 21.6
Jul-04 20.0
Aug-04 20.1
Sep-04 35.1
Oct-04 20.8
Nov-04 24.5
Dec-04 24.1
Avg. 22.9
LIMITS 40.0
DATE pH (min.)
Jan-04 6.8
Feb-04 7.1
Mar-04 7.1
Apr-04 7.0
May-04 7.3
Jun-04 7.2
Jul-04 7.3
Aug-04 7.6
Sep-04 6.4
Oct-04 7.1
Nov-04 7.1
Dec-04 6.9
Avg. 7.1
LIMITS 6.0
INF CBOD EFF CBOD
170.4 16.7
154.0 13.8
228.4 13.6
215.2 15.0
169.6 18.1
177.2 16.8
241.4 19.1
276.7 14.4
108.3 12.6
129.4 10.4
188.0 15.8
181.4 14.6
186.7 15.1
25.0
pH (max.) Temp. (C)
7.5 14.1
7.6 13.2
7.5 15.1
8.2 16.1
7.5 18.7
7.8 21.0
7.7 22.4
7.2 22.7
7.5 21.2
7.6 21.1
7.4 19.7
7.5 16.2
7.6 18.5
9.0
% Removal
90%
91%
94%
93%
89%
91%
92%
95%
88%
92%
92%
92%
92%
80%
Conductivity
732.5
666.7
735.9
717.6
858.0
782.9
914.4
774.1
528.3
782.8
732.7
572.8
733.2
INF TSS
156.6
154.8
190.9
164.8
177.0
180.8
225.6
238.1
180.5
126.3
110.9
126.5
169.4
Fecal Coliform
2.9
2.0
2.5
5.1
3.3
8.7
6.6
11.0
22.0
4.2
10.0
5.5
7.0
200.0
EFF TSS % Removal EFF NH3-N
14.2
8.9
12.2
12.0
13.9
12.0
10.7
12.5
3.5
3.9
8.7
11.0
10.3
12.2 92%
13.5 91%
16.2 92%
14.9 91%
14.1 92%
14.5 92%
12.7 94%
14.1 94%
27.9 85%
16.4 87%
17.7 84%
16.1 87%
15.9 90%
30.0 80%
Cyanide Total N Total P
<10.0 19.0 2.2
<10.0
<10.0
<10.0
<10.0
19.5
<10.0
19.5
13.5
<5.0
12.5
17.5
<10.0
12.0
21.0
15.0
16.8
1.8
4.0
3.3
2.8
Chronic TOX Dissolved 02
9.19
24% 8.98
8.60
8.33
36% 7.91
7.90
7.43
36% 7.15
7.67
7.90
24% 7.51
8.41
8.08
12% >5.0
Residual Cl2
0.51
0.76
0.77
0.51
0.39
0.46
0.51
0.24
0.35
0.47
0.49
0.44
0.49
Note: NC-DENR issued new NPDES permit for WWTP in February 2001. New permit left CBOD & TSS effluent limits unchanged, however
modified %-removal requirement for each to 80%, changed instream monitoring locations (upstream in river adjacent to flume wall at the
fish ladder & downstream to Ledges Park) and removed the numeric limit for cyanide & reduced cyanide monitoring to 2/month.
Cn reported as ug/I - all other parameters reported as mg/I (except TOX = %IWC pH = standard units and fecal coliform = colonies/100m1)

DATE Flow (MGD)
Jan-05 23.0
Feb-05 21.6
Mar-05 22.4
Apr-05 23.1
May-05
Jun-05
JuI-05
Aug-05
Sep-05
Oct-05
Nov-05
Dec-05
Avg.
LIMITS
INF CBOD EFF CBOD
184.9 15.9
173.5 17.3
156.5 15.1
138.0 12.7
% Removal
91%
90%
90%
91%
22.5 163.2 15.3 91
40.0 25.0 80%
DATE pH (min.)
Jan-05 7.0
Feb-05 7.0
Mar-05 6.9
Apr-05 6.9
May-05
Jun-05
Jul-05
Aug-05
Sep-05
Oct-05
Nov-05
Dec-05
Avg. 7.0
LIMITS 6.0
pH (max.) Temp. (C) Conductivity
7.5 15.6 670.7
7.5 14.8 647.2
7.5 14.6 655.9
7.3 16.1 669.7
7.5 15.3 660.9
INF TSS
133.0
140.7
163.5
123.1
EFF TSS % Removal EFF NH3-N Chronic TOX Dissolved 02
17.4 87% 10.7 8.89
20.4 86% 11.7 36% 8.80
17.9 89% 8.9 8.86
18.1 85% 10.2 8.82
140.1 18.5 87% 10.4
30.0 80%
Fecal Coliform Cyanide Total N Total P
4.0 20.0 22.0 4.1
2.0 20.5
3.1 <10.0
1.3 <10.0
Residual Cl2
0.47
0.75
0.87
1.46
2.6 <10.0 22.0 4.1 0.89
9.0 200.0
Note: NC-DENR issued new NPDES permit for VVWTP in February 2001. New permit left CBOD & TSS effluent limits unchanged, however
modified %-removal requirement for each to 80%, changed instream monitoring locations (upstream in river adjacent to flume wall at the
fish ladder & downstream to Ledges Park) and removed the numeric limit for cyanide & reduced cyanide monitoring to 2/month.
Cn reported as ug/l
8.84
>5.0