NC0041696_Permit Issuance_20061115

NPDES DOCUMENT SCANNING COVER SHEET
NC0041696
Valdese — Lake Rhodhiss WWTP
NPDES Permit:
Document Type:
Permit Issuance x_
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Compliance
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 15, 2006
Thies document iu printed on reunite paper - ignore any
content on the reiterate aide

Mr. Jeffrey V. Morse
Town Manager
P.O. Box 339
Valdese, North Carolina
Dear Mr. Morse:
28690
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
November 15, 2006
Subject: Issuance of NPDES Permit
NC0041696
Lake Rhodhiss WWTP
Burke County
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, 1994 (or
as subsequently amended).
This final permit contains the following changes from the draft you were sent on September 25, 2006:
➢ Division staff noted that the weekly average ammonia limit at 10.5 MGD had been
incorrectly calculated. The correct limit is 12 mg/L. This error has been corrected.
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
WOES Unit
Marshall Hyatt, EPA Region IV
Deborah Gore, PERCS Unit
•
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
No hCarolina
7atura!!y

,
NC0041696
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,
Town of Valdese
is hereby authorized to discharge wastewater from a facility located at
Lake Rhodhiss Wastewater Treatment Plant
on Lake Rhodhiss Drive
North of Valdese
Burke County
to receiving waters designated as Lake Rhodhiss (Catawba River) in the Catawba River
Basin in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2006.
This permit and authorization to discharge shall expire at midnight on February 28, 2010.
Signed this day November 15, 2006.
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

NC0041696
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.
Town of Valdese is hereby authorized to:
1. Continue to operate a 7.5 MGD wastewater treatment facility consisting of the
following components:
• Influent pump station,
• Bar screen,
• Grit removal,
• Primary clarifiers,
• Aeration basins,
• Secondary clarifiers,
• Chlorination,
• Dechlorination
• Gravity sludge
• Thickeners,
• Residual centrifuges,
• Residuals composting operation
• SCADA system
The facility is located at Valdese Wastewater Treatment Plant, on Lake Rhodhiss Drive,
north of Valdese, Burke County.
2. After receiving an Authorization to Construct from the Division of Water Quality,
construct and operate additional wastewater treatment facilities and upgrade the
existing influent pumping, aeration equipment, plant outfall, and residuals
management facilities. The ultimate design capacity after expansion and
modification to existing facilities shall be 10.5 MGD.
3. Discharge from said treatment works at the location specified on the attached map
into the Lake Rhodhiss (Catawba River), which is classified WS-IV & B CA waters in
the Catawba River Basin.

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Lake Rhodhiss WWTP — NC0041696
USGS Quad Name: Drexel
Receiving Stream: Catawba River
Stream Class: WS-IV & B CA
Subbasin: Catawba — 03 08 31
Lat.: 35°46'41"
Long.: 81°32'25"
Not to SCALE

NC0041696
A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expansion to 10.5 MGD
or expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
7.5 MGD
Continuous
Recording
I or E
BOD52
30.0 mg/L
45.0 mg/L
Daily
Composite
E,I
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Daily
Composite
E,I
NI-I3 as N
Weekly
Composite
E
Dissolved Oxygen
Daily
Grab
E
Dissolved Oxygen
(June 1 through September 30)
3/Week
Grab
U,D
Dissolved Oxygen
(October 1 through May 31)
Weekly
Grab
U,D
Fecal Coliform
(geometric mean)
200/100 mL
400/100 mL
Daily
Grab
E
pH
Between 6.0 and 9.0 s.u.
Daily
Grab
E
Phenols
21 pg/L
Weekly
Grab
E
Total Residual Chlorine'
28 pg/L
Daily
Grab
E
Temperature
(June 1 through September 30)
3/Week
Grab
U,D
Temperature
(October 1 through May 31)
Weekly
Grab
U,D
Total Nitrogen
(NO2 + NO3 + TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicity'
Quarterly
Composite
E
Priority Pollutant Analysis'
Annual
Grab
E
Notes:
1. Sample Locations: E - Effluent, I - Influent , U - Upstream at least 100 feet, D - Downstream 1 mile below
discharge at SR 1001. Upstream and downstream samples shall be grab samples. Stream samples shall be
collected three times per week during June, July, August, and September and once per week during the
remaining months of the year.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The TRC limit shall take effect September 1, 2007.
4. Chronic Toxicity (Ceriodaphnia) P/F ® 4.8%; January, April, July, October. See Special Conditions of the
Supplement to Effluent Limitations A (4).
5. See Special Conditions of the Supplement to Effluent Limitations A(5).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NC0041696
A (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon expansion to 10.5 MGD and lasting until expiration, the Permittee is
authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
10.5 MGD
Continuous
Recording
I or E
BOD52
15.0 mg/L
22.5 mg/L
Daily
Composite
E,I
Total Suspended Solids'
30.0 mg/L
45.0 mg/L
Daily
Composite
E,I
NH3-N
4.0 mg/L
12.0 mg/L
Weekly
Composite
E
Dissolved Oxygen
Daily
Grab
E
Dissolved Oxygen
(June 1 through September 30)
3/Week
Grab
U,D
Dissolved Oxygen
(October 1 through May 31)
Weekly
Grab
U,D
Fecal Coliform
(geometric mean)
200/100mL
400/100 mL
Daily
Grab
E
pH
Between 6.0 and 9.0 s.u.
Daily
Grab
E
Phenols
15 µg/L
Weekly
Grab
E
Total Residual Chlorine
28 µg/L
Daily
Grab
E
Temperature
(June 1 through September 30)
3/Week
Grab
U,D
Temperature
(October 1 through May 31)
Weekly
Grab
U,D
Total Nitrogen
(NO2 + NO3 + TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicity'
Quarterly
Composite
E
Priority Pollutant Analysis5
Annual
Grab
E
Notes:
1. Sample Locations: E - Effluent, I - Influent , U - Upstream at least 100 feet, D -Downstream 1 mile below
discharge at SR 1001. Upstream and downstream samples shall be grab samples. Stream samples shall be
collected three times per week during June, July, August, and September and once per week during the
remaining months of the year.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentrations shall not be less than 5 mg/1.
4. Chronic Toxicity (Ceriodaphnia) P/F @ 6.6%; January, April, July, October. See Special Conditions of the
Supplement to Effluent Limitations A (5).
5. See Special Conditions of the Supplement to Effluent Limitations A(5).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NC0041696
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
A (3). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) © 7.5 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 4.8 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then
multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: Environmental Sciences Section
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Branch at the address cited above.
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.

NC0041696
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
A (4). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) © 10.5 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia
dubia at an effluent concentration of 6.6%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the
NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then
multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B
for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: Environmental Sciences Section
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response
data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the
form. The report shall be submitted to the Environmental Sciences Branch at the address cited above.
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.

NC0041696
A. (5) 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)
Trans-1,2-dichloroethylene
I,1-dichloroethylene
Bis (2-chloroethyt) ether
Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Total Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Total Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1, I,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,I,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno( I ,2,3-cd)pyrene
Benzene Base -neutral compounds: Isophorone
B romoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3.4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1, I -dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis (2-chloroethoxy) methane
Test results shall be reported to the Division in DWQ Form- DIM-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
AMENDED FACT SHEET FOR PERMIT MODIFICATION
Town of Valdese
NC0041696
Facility Information
Facility Name:
Town of Valdese WWTP
_(1.)
(2.) Permitted Flow (MGD):
7.5 MGD; 10.5 MGD
(6.) County: I Burke
(3.) Facility Class:
IV
(7.) Regional Office: ' Asheville
(4.) Pretreatment Program:
Full LTMP
(8.) USGS Topo Quad:
U12S1,
(5.) Permit Status:
Existing (9.) USGS Quad Name:
Stream Characteristics
(1.) Receiving Stream:
Lake Rhodhiss
(Catawba River)
(7.) Drainage Area (mi2):
Lake
(2.) Sub -basin:
03-08-31
(8.) Summer 7Q10 (cfs):
228.7 (min release)
(3.) Stream Index Number:
(9.) Winter 7Q10 (cfs):
-
(4.) Stream Classification:
WS-N & B CA
(10.) 30Q2 (cfs):
-
(5.) 303(d) Status:
Not listed
(11.) Average Flow (cfs):
-
(6.) 305(b) Status:
-
(12.) IWC %:
4.8
1.0 Proposed Changes Incorporated Into Permit Modification
➢ Remove monitoring for mercury, silver, cyanide, and copper. These parameters should
continue to be monitored as part of the facility's LTMP.
2.0 Summary
The Town of Valdese has requested a permit modification to review the possibility of removing or
reducing monitoring for silver, cyanide, mercury, and phenols. Monitoring and limits for several of
these parameters were added during the last renewal based on limited data from the LTMP. In order
to evaluate the necessity of these limits, an updated RPA was performed for these four parameters.
Copper was also re-evaluated since additional data has been collected for that parameter as well.
All RPAs were performed with the most recent year of data: May 2005 - June 2006.
Based on this data, monitoring may be removed for silver, copper, mercury and cyanide. There were
no detections of silver or mercury during the review period, and values of copper and cyanide did
not show reasonable potential to cause an exceedance of water quality standards.
The phenol limit and monitoring requirements will remain in the permit based on reasonable
potential for levels of this parameter to cause an exceedance of water quality criteria.

REASONABLE POTENTIAL ANALYSIS
Lake Rhodhiss WWTP
NC0041696
Time Period July 2004-June 2006
Ow (MGD) 7.5
7010S (cis) 228.7
7010W (cis) 228.7
3002 (cls) 228.7
Avg. Stream Flow, OA (cls) 228.7
Recving Stream Catawba River
WWTP Class IV
!WC (°o) ' 7010S 4.8372
7010W 4.8372
0 3002 4.8372
0 OA 4.8372
Stream Class WS-IV 8, B CA
Outfall 001
Qw = 7.5 MGD
PARAMETER
TYPE
(11
STANDARDS 8
CRITERIA (2)
POL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC Wo$/ 'S FAY
Chronic Arore
n XOtt. Max Prod Cw Allowable Cw
Cyanide
NC
N 22
10
ug/L
24 5
5.0
Acute: 22
_ _ __ _
Chronic: 103
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Max predicted « allowable.
Monitor through LTMP
Mercury
NC
1:'0
ngiL
22 0
160.0
Acute: N/A
_ _ ___ _ ___
Chronic: 248
No detections
Monitor Through LTMP
Phenols
A
ug/L
56 15
69.2
Acute: N/A
_
C Chronic: _--21---
Max predicted,.allowable.
Retain limit, monitoring
Sliver
NC
i1..
ug/L
9 0
Note: nct2
Limited data
Acute: I
5.9 _ _ --- ---
I Chronic: 1
set
_ _ _ _ ------------ --- --
No detections-- —
Remove monitoring
Copper
NC
,?:. .'i
ug4
71 29
1074
Acute: 7
Chronic: 145
Max predicted e allowable.
Monitor through LTMP
0
WA
Acute: N/A
__ ____
Chronic: irror0Type
----'----------- ---_.. _.._.---.—--
0
N/A
Acute: WA
Chronic: rror 0 Type
-------------—'—•—'-----'-----.
0 0
WA
Acute: WA
_ _ __ ___
Chronic: irror 0 Type
_—_—_—__--__-_____-___-_-_-_--_—
0
WA
Acute: WA
Chronk: rror @ Type
0
WA
Acute: WA
Chronic: Error IS Type
-------'------_._.__---'_______
0
N/A
Mule: WA
Chronic::rror ® Type
---'---.—__.—_—_—_—'-------^'—
0
N/A
Mute: WA
Chronlc: rror ® Type
-----'---'—'---•-----•—•—'—•—'—
0
WA
Acute: N/A
Chronic::nor ®-Type
—'------'---'—'-----'—_---_—
Mute: WA
Chronic: !nor 0 Type
0
N/A
Acute: WA
___-_-______--_____-_-_-_-_-__—
Chronic: Error 0 Type
I
'Legend.•
C = Carcinogenic
NC = Non -carcinogenic
A = Aest/retfc
Freshwater Discharge
41696_ rpa_amend.xls. rpa
9/21/2006

[Fwd: Fw: overview update - re NC0041696 - Lake Rhodhiss WWTP...
Subject: [Fwd: Fw: overview update - re NC0041696 - Lake Rhodhiss WWTP mod]
From: Toya Fields <[e-mail]>
Date: Wed, 15 Nov 2006 10:30:10 -0500
To: Charles Weaver <Charles. Weaverncmail.net>
Original Message
Subject: Fw: overview update - re NC0041696 - Lake Rhodhiss WWTP mod
Date: Wed, 04 Oct 2006 16:48:06 -0400
From: [e-mail]
To: [e-mail]
Forwarded by Marshall Hyatt/R4/USEPA/US on 10/04/2006 04:47 PM
Marshall
Hyatt/R4/USEPA/U
S To
susan wilson, gil vinzani,
10/04/2006 10:35 [e-mail]
AM cc
Subject
overview update
we just had a staff mtg here. Ro told us that we will soon be sending
a letter to the states, indicating which permits we will overview this
fiscal year. I believe he had sent you an email recently that said
that. Until that list goes out, we were told not to overview anything
that comes here after Oct 1. wanted you to know about this as soon as
I did. if you have any questions, call me.
Toya Fields - [e-mail]
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: [phone] x 551
Fax: [phone]
1 of 1 11/16/2006 6:42 AM

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
MEMORANDUM
To:
From:
Subject
September 27, 2006
James Adams
NC DENR / DEH / Regional Engineer
Asheville Regional Office
Toya Fields
Western Division
Review of Draft NPDES Permit NC0041696
Lake Rhodhiss WWTP
Burke County
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
kPec'd 9/29006
Rev,ca'ed 10 jiio jot.
to]zolotr
Please indicate below your agency's position or viewpoint on the draft permit and return this form by October 27,
2006. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address
listed at the bottom of this page.
RESPONSE: (Check one)
X
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits
are met prior to discharge, and the discharge does not contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signed Pa•ti 7/1& Da : / Date f00�06
Pbtf6s /4-020
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
VISIT us ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES
919 733-5083, extension 363 (fax) 919 733-0719
[e-mail]

NPDES. information
ubject: NPDES information
From: "Jerry.R Freeman" <[e-mail]>
Date: Fri, 22 Sep 2006 12:30:02 -0400
To: [e-mail], [e-mail]
Jim; Angela;
Here are three letters (PDF) for Jessica's signature. Also, one system
information data is included. The two others were sent by courier prior to my
knowledge. You will have them in a couple of days.
Jerry Freeman
Jerry Freeman -
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office Division of Environmental Health - Public Water Supply
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone] Ext4583
Fax: [phone]
Jerry.R Freeman <[e-mail]>
NC DENR - Asheville Regional Office
Division of Environmental Health - Public Water Supply
NPDES Permit info.PDF
Content -Type: application/pdf
Content -Encoding: base64
I of 1
9/26/2006 2:38 PM

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NORTH CAROLINA
BURKE COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of Catawba County,
North Carolina, duly commissioned, qualified, and authorized
by law, to administer oaths, in said County and State; that he/
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 News Herald
on the follo 'ng dates:
/01,11vt J a9, -019(.,
and that the said newspaper in which such notice,
or legal advertisement was published, was a newspaper
meeting all of the requirements and qualifications of Section
1-597 ' f the General Statutes of North Carolina.
Assi.tant Bookkeeper
Sworn to and subscribed before me, this
43/14- day of
ublic
My Commission Expires
, 2006
/0
PUBLIC NOTICE
STATE OF
NORTH CAROLINA
ENVIRONMENTAL
MANAGEMENT
COMMISSION /
NPDES UNIT
1617 MAIL SERVICE
CENTER
RALEIGH, NC 27699-1617
NOTIFICATION OF
INTENT TO ISSUE A
NPDES WASTEWATER
PERMIT
One the basis of thor-
ough staff review and
application of NC Gener-
al Statute 143.21 Public
law 92-500 and other
lawful standards and
regulations, the North
Carolina Environmental
Management Commis-
sion proposes to issue, a
National Pollutant Dis-
charge Elimination Sys-
tem (NPDES) wastewater
discharge permit to the
person(s) listed below
efthe pubtishctive 5days date offrotn
this
notice.
Wcomments
gardingritten the proposedre-
permit will be accepted
until 30 days after the
publish date of this no-
tice. All comments re-
ceived prior to that date
are considered in the fi-
gal rd npthe e ations re-
prroposed
permit. The Director of
the NC Division of Water
Quality maydecide to
hold a public meeting
for the proposed, permit
should the Division re-
ceive a significant de-
gree of public interest.
Copies of the draft per-
mit andother supporting
information on file used
to determine conditions
present In the draft per-
mit are available upon
request and payment, of
the cost of reproduction.
Mail comments and/or
requests for information
to the NC Division of Wa-
ter Quality at the above
or allPoint
Source address Branch tat (919)
733-5083, extension 363.
Comments can also be
emailed to
Carolyn.Bryant@ncmai I.
net. Please include the
NPDES permit number
(attached) in any
communication. Interest-
ed persons may also •visit
the Division of Water
Quality at 512 N: Salis-
bury Street, Raleigh, NC
27604-1148 between the
hours of 8:00 a.m. and
5:00 p.m. to review infor-
mation on file.
The Town of Valdese
(P.O. Box 339, Valdese,
NC 28690) has requested
a modification of NPDES
permit NC0041696 for the
Lake Rhodhiss WWTP in
Burke County. This per-
mitted facility dis-
charges 7.5 MGD of
treated wastewater tot
. he Catawba River in the
Catawba River Basin.
Currently phenols and
total residual chlorine
are water quality limited.
This discharge may af-
fect future allocations in
the portion of the Cataw-
ba River Basin.
Publish:
September 29.2006.

Re: NPDES Permit Modification
Subject: Re: NPDES Permit Modification
From: Toya Fields <[e-mail]>
Date: Thu, 21 Sep 2006 14:00:19 -0400
To: "Padgett, Greg" <[e-mail]>
CC: Larry Frost <[e-mail]>
Hi Greg,
Just a heads up that your draft modification will go out next week. It will have to
go through a 30-day comment period and be reviewed by EPA. Also, based on further
review we have also decided that removal of the mercury limit based on your most
recent 12 months of data would be appropriate. So the draft permit proposes that
mercury, cyanide, copper, and silver be monitored through the LTMP. The permit will
still contain a phenol limit. Again, this is a proposed draft and everything will
need to be approved by EPA before it becomes final.
Toya
Padgett, Greg wrote:
Toya,
Thanks for getting back to me so soon. I do appreciate the
clarification. Where do I need to submit the $860 fee?
Regards,
Greg Padgett
Original Message
From: Toya Fields [mailto:[e-mail]] Sent: Thursday, August 10, 2006
11:50 AM
To: Padgett, Greg
Cc: [e-mail]; [e-mail];
[e-mail]
Subject: Re: NPDES Permit Modification
Greg,
When we look at data we review a minimum of 8-12 data points over a minimum of two
years of data. So if you had quarterly monitoring, then over two years we would
only be looking at 8 data points. However if you have weekly or monthly
monitoring then we are looking at a lot more. We don't simply grab the most
recent 12 data points, that would not necessarily be representative of your
discharge.
In this case I added the most recent few months of data to what we had already
received on your DMRs. So I reviewed the most recent two years of data for all of
the parameters that you asked for us to look at, plus
copper. There is no inconsistency, all of the parameters were treated exactly the
same. The data set I used was July 2004 through June 2006. I used the same data
period for all of the parameters. But there were high values of mercury and
phenols reported during that time frame. Thats why we cannot remove the limits.
It looks like the problematic mercury result was recorded in February 2005. Thats
too recent (and it was very high) for us to disregard it at
this point. As far as phenols your reported values are very close to the permit
I of 3 9/21/2006 2:14 PM

Re: NPDES Permit Modification
limit of 21 ug/L. You reported a value of 18 in May.
continue to be reasonable potential for phenol values
water quality standards. If the reported values stay
should expect for the limit to remain in the permit.
require that class
It looks like there will
to cause an exceedance of
in this range I think you
Also, our regulations
IV facilities receive weekly monitoring for parameters with limits.
You don't need to submit a permit application. These emails will serve as your
"request", but we do have a fee for major modifications.
Toya
Padgett, Greg wrote:
be
Toya,
Thanks for getting back to me on this matter. I am sure that they keep
you busy out in Raleigh. I may have misunderstood but I was under the
impression that only twelve data points was needed to request a
modification, thus the request for Mercury and Phenol. There seems to
some inconsistency in the time requirements. At what level would it
become possible for Phenols to be reduced to 2/month or LTMP in the
future? In addition, Mercury what has to happen in order to get Mercury
changed to LTMP?
In regards to permit modification, will I need to submit a complete
permit application along with the fee? Can I just resubmit the most
recent application?
Greg Padgett
Original Message
From: Toya Fields [mailto:toya [e-mail]] Sent: Wednesday, August
2006 5:28 PM
To: Padgett, Greg
Cc: [e-mail]; [e-mail];
[e-mail]
Subject: Re: NPDES Permit Modification
09,
Hi Greg, based on your data from the past two years, we can propose to remove
silver, copper, and cyanide. They would continue to be required as part of your
LTMP. However the limits and monitoring requirements
for
mercury and phenols would have to remain as -is.
These changes would constitute a major permit modification,
so we would
Ineed you to submit the fee of $860. Also, the permit would need to go through
the 30 day public notice and would need to be approved by EPA
01 9/21 /2006 2:14 PM

Re: NPDES Permit Modification
again.
If you have any questions, let me know.
Toya
Padgett, Greg wrote:
Good Morning Susan,
In the hope of speeding things along, I am including the current data on the
limits that we are seeking modification. The data is from March
- June DMRs.
Mercury: 18 samples have been taken all 'non -detect' i.e. <.0001 ug/l.
Phenols: 18 samples taken 14 'non -detect', remaining four '13 ug/1, 17
ug/1, 18 ug/1, 14 ug/1'.
Cyanide: 18 samples taken, all 'non -detect'.
Silver: 4 samples taken all 'non -detect'.
Regards,
Greg Padgett
Toya Fields - toya.fieldsgncmail.net
Environmental Engineer I
Western NPDES Program
Division of Water Quality
Tel: [phone] x 551
Fax: [phone]
3 of 3 9/21/2006 2:14 PM

NPPES Per at Modification
Subject: NPDES Permit Modification
From: "Padgett, Greg" <[e-mail]>
Date: Wed, 19 Jul 2006 10:10:15 -0400
To: <[e-mail]>
CC: <[e-mail]>
Good Morning Toya,
/347.4%-y nr —
(M;. ;.s4M)
The Town of Valdese is going to request a minor permit modification for Mercury, Silver, Cyanide,
and Phenols. Before moving forward, I would like to consider what affect adding a lower flow tier
(4.0 MGD) would have to the above -mentioned limits. If the effect is enough I may need only
request the modification for a lower tier, the 4.0 MGD. I guess what I need from you is some
indication of exactly what the plant's limits would be at 4.0 MGD. It is imperative that I address
this situation as we lost approximately 1.0 MGD flow as I alluded to in the follow up to the Draft
Permit. That equates to roughly $30,000 in lost sewer revenue annually. Then on top of that, the
new permit increased our sampling cost in excess of $5500 per year. Larry Frost , our inspector
out of the Asheville office, actually suggested that I seek a 3.5 MGD permit. If you could email me,
what limits the plant would have at 3.5 and 4.0 MGD I should be able to decide what direction to
take from there. You can reach me at 828-879-2131 if there are any questions, thank you for your
time.
Regards,
Greg Padgett
Padgett, Greg <[e-mail]>
1 of 1 7/20/20064:21 PM

From: "Padgett, Greg" <[e-mail]>
Date: Wed, 2 Aug 2006 11:19:51 -0400
To: <[e-mail]>
CC: <[e-mail]>
Toya,
Please disregard the question about seeking a lower flow tier. The staff and I have reviewed our current and
potential future growth. Based on this I feel that it would not be in the best interest of The Town to request the
lower flow tier at this time. We would however like to pursue changes in the existing 7.5 MGD permit based on
current data we have collected. What steps do I need to take in order to request a permit modification for the
following?
1. Silver
2. Cyanide
3. Mercury
4. Phenols
1. Silver: We would request that Silver be changed to Long Term Monitoring Program (LTMP) as it was on
the previous NPDES.
2. Cyanide: We would request that Cyanide be modified to LTMP as it was on the previous NPDES.
3. Mercury: We would request the Mercury be changed to LTMP as it was on the previous NPDES.
4. Phenols: We would request that Phenols be changed to 2/Month
I do appreciate your time on this matter. If there are any questions, please call me at 828-879-2131.
Regards
Greg Padgett
Padgett, Greg <[e-mail]>
1 of 1 8/7/2006 5:18 PM

NPDES Permit Modification
Subject: NPDES Permit Modification
From: "Padgett, Greg" <[e-mail]>
Date: Wed, 9 Aug 2006 09:51:28 -0400
To: <[e-mail]>
CC: <[e-mail]>, <[e-mail]>, <[e-mail]>
Good Morning Susan,
In the hope of speeding things along, I am including the current data on the limits that we are seeking
modification. The data is from March — June DMRs.
Mercury: 18 samples have been taken all 'non -detect' i.e. <.0001 ug/l.
Phenols: 18 samples taken 14 'non -detect', remaining four '13 ug/I, 17 ug/I, 18 ug/I, 14 ug/I'.
Cyanide: 18 samples taken, all 'non -detect'.
Silver: 4 samples taken all 'non -detect'.
Regards,
Greg Padgett
Padgett, Greg <[e-mail]>
1 of 1 8/9/2006 1 1:33 AM

February 23, 2006
Mrs. LeToya Fields
Western NPDES Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mrs. Fields
Town of Valdese
LAKE RHODHISS WWTP
2100 Lake Rhodhiss
P.O. Box 339
Valdese, N.C. 28690
(828) 879 - 2131
Subject:
NPDES Permit
Permit NC0041696
Lake Rhodhiss WWTP
Town of Valdese
After reviewing the NPDES Permit, I am somewhat shocked and disturbed. The
new permit changed drastically from what was on the draft and not for the better either.
I am looking at approximately $5500 a year in increased testing and monitoring for to
meet the requirements of this permit. That may not seem like much, but when faced
with the possibility of losing the majority of our flow due to closing of Textile Mills every
dollar has to be accounted for more so than normal. One of the town's largest Textile
Mills will be closing their doors in two months. They account for 1MGD of the flow. The
average plant flow for 2005 was 4.02 MGD. The plant will be lucky to average 3 MGD
for 2006.
I question the reasoning behind the plant receiving a Mercury limit. The draft
also seemed a bit over the top but only required 2/Month monitoring of Mercury. What
changed to cause Mercury to become limited instead of just monitored? It is my
contention that Mercury should continue to be part of the Long Term Monitoring
Program (LTMP) and not limited.
I would like some clarification on some of the Monitoring Frequency and Sample
Type data. For Phenols, there is a discrepancy between draft and permit. Should the
frequency of Phenols be Weekly or 2/Month? Copper and Silver are both listed as a grab
on the draft but as a composite on the final. Which is correct, should they be composite
or grab samples? Silver also went from being 2/Month on the draft to Monthly on the
final. Should Silver be Monthly? Cyanide is listed a composite on the final and as a grab
on the draft. I believe this should be a grab.
I strongly feel that Silver should still be under the LTMP as it has in the past.
Silver has never been an issue at this plant.
Because of the increased amount of Phenol hits on our last permit, we chose to
change labs. Since changing labs, we have not had any Phenol samples above our limit.
It is my staffs and my contention that the former lab we were using returned some
suspect numbers from time to time. Some of which we did contest or had the sample
reran when possible. Based on this we feel it might be quite possible that some other
results were suspect.

I would also like to ask the State/EPA to reconsider the flow number that they
are currently using for Lake Rhohiss. At present, the NCDENR is using 228.7cfs as our
7Q10. Based on data that I have found I would like to request that our 7Q10 revisited.
Duke Power has the 7Q10 for Lake Rhodhiss at 364cfs. Duke's number comes from
data collected over 71 years (1929 - 2001). The discrepancy between the two numbers
is great enough to warrant some attention.
If any other information is needed please call me, Greg Padgett at 828-879-2131.
I will be glad to make my staff or myself available to answer any questions or clarify any
comments about the Draft NPDES.
Thank you for assistance in this matter.
Regards,
Greg Padgett, Superintendent/ORC
Cc: Mr. Jeff Morse, Town Manager of Valdese