NC0047384_Permit Modification_20101105

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 5, 2010
Mr. Allan Williams, Director of Water Resources
City of Greensboro
2199 White Street
Greensboro, NC 27405
Subject: Issuance of NPDES Permit Modifications
Permits NC0024325 and NC0047384
North Buffalo and T.Z. Osborne WWTPs
Guilford County
Dear Mr. Williams:
Consistent with the Director's October 1, 2009, letter of intent to modify NPDES permits affected by the
Jordan Reservoir Nutrient Management Strategy rules and Greensboro's subsequent request for further
permit modification, and in consideration of public comments on the draft permits, the Division is
forwarding herewith the revised NPDES permit for the North Buffalo and T.Z. Osborne WWTPs. This
permit modification 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 October 15, 2007.
The Division received no comments other than those provided by the City. The enclosed permits
include the following changes as proposed:
• Total Phosphorus (TP) Limits. Phosphorus limits have been removed from Condition A.(1.) of each
permit. A new Condition A.(2.) describes the combined TP limit for the two facilities and how it
will be administered. Other nutrient -related conditions of the permit have been modified as
necessary. Each facility will continue to monitor and report its nutrient discharges individually, and
we propose that the City report the combined load once each year, with the December monitoring
report for one plant. Phosphorus limits in the Jordan Lake watershed became effective January 1,
2010, according to the wastewater rule.
• Standard Permit Conditions. Several minor errors have been corrected, and all changes from Part
IV that are not supported by existing state or federal rules have been reversed.
• Treatment Process Description. The process descriptions on the Supplement to Cover Pages for
both plants have been modified as the City requested.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer
No ehCarolina
aturaI4y

Mr. Allan Williams, Director of Water Resources
Issuance of NPDES Permit Modifications
November 5, 2010
• Nitrogen Optimization. The previous draft permit included a new condition pertaining to nitrogen
optimization requirements from the wastewater rule. That compliance date has passed, and the
proposed condition has been deleted from the permit.
• Nutrient Re -opener. The nutrient monitoring re -opener from the previous permit pertained,to
monitoring in preparation for the Jordan Lake study. It is no longer necessary and has been deleted
from the permit.
• Total Residual Chlorine Footnote. A footnote has been added to Condition A.(1.) indicating that
-the Division considers the compliance level for TRC to be 50 ug/L. All lab values must still be
reported but, for compliance purposes, values below 50 ug/L meet the facility's TRC limit.
In the most recent review, the City noted an improper citation on page 16 of the standard conditions,
and that citation has also 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 a
demand is made, this permit shall be final and binding.
This permit is not transferable except after notice to the Division of Water Quality. 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, the
Division of Land Resources, the Coastal Area Management Act, or any other federal or local
governmental permit.
If you have any questions concerning this permit, please contact Mike Templeton at [phone] or at
[e-mail].
Sincerely,
Enclosure: Final permit modifications, NC0024325 and NC0047384
Copies: Chief, NPDES and Biosolids Permits Section, Region IV, EPA
Winston-Salem Regional Office, Surface Water Protection
Aquatic Toxicity Unit
NPDES Files
Central Files

Permit No. NC0047384
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 provisions 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
• City of Greensboro
is hereby authorized to discharge wastewater from a facility located at the
T.Z. Osborne WWTP
Huffine Mill Road west of McLeansville
Guilford County
to receiving waters designated as South Buffalo Creek in the Cape Fear 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, 2010.
This permit and authorization to discharge shall expire at midnight on June 30, 2011.
Signed this day November 5, 2010.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0047384
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 City of Greensboro
is hereby authorized to:
1. Continue to operate an existing 40.0 MGD activated sludge wastewater treatment facility located at
the T.Z. Osborne WWII' off Huffine Mill Road west of McLeansville in Guilford County. The
facility includes the following treatment components:
• Mechanical bar screen
• Influent pump station
• Stirred vortex grit removal
• Pre -aeration tank
• •Influent flow measurement
• Primary clarifiers
• Single stage activated sludge with nitrification
• Chemical addition for phosphorus removal
• Final clarifiers
• Tertiary effluent sand filters
• Chlorination
• Dechlorination
• Flow measurement and recording
• Cascade post aeration
• Sludge treatment units including sludge receiving tanks, gravity sludge thickeners, three
centrifuges, thickened sludge holding tanks, and sludge incinerator
• Odor control equipment
2. Discharge from said treatment works (via Outfall 001) into South Buffalo Creek, a class C-NSW
stream in the Cape Fear River Basin, at the location specified on the attached map.
•
ll

0
USGS Quad #: C20SW
Lat. 36° 05' 45" Long. -79° 41' 10"
N
SCALE
1:24,000
(1" = 2000')
City of Greensboro — T.Z. Osborne WWTP
NC0047384
County: Guilford
Receiving Stream: South Buffalo Creek
Stream Classification: C NSW
River Basin: Cape Fear
Sub -Basin #: 03-06-02
111

Permit No. NC0047384
A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Outfall 001
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
EFRUENT LIMITATIONS :
=
iMONITORINGl'REQUIREMENTS
EFFLUENT -
CHARACTERISTICS
Monthly ,
Average
.
Weekly.
Average
-Daily
Maximum
_ =,
:Measurement!
Frequencyi
j:
Sainpletype:: s
Sample Location
How
40.0 MGD
Continuous
Recording
Influent or Effluent
Total Monthly Flow (MG)
Monitor & Report
Monthly
Rec. or Calc.
Influent or Effluent
CBOD, 5-day, 20°C (Summer) 2
4.0 mg/L
6.0 mg/L
Daily
Composite
Influent & Effluent
CBOD, 5-day, 20°C (Winter) 2
8.0 mg/L
12.0 mg/L
Daily
Composite
Influent & Effluent
Total Suspended Solids 2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent & Effluent
NH3 as N (Summer)
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
NH3 as N (Winter)
4.0 mg/L
12.0 mg/L
Daily
Composite
Effluent
Fecal Coliform
(geometric mean)
200/100mL
400/100mL
Daily
Grab
Effluent
Dissolved Oxygen 3
Daily
Grab
Effluent
Temperature (°C) •
Daily
Grab
Effluent
pH 4
Daily
Grab
Effluent
Total Residual Chlorine 5
18.0 pg/L
Daily
Grab
Effluent
TKN
Monitor & Report (mg/L)
Weekly
Composite
Effluent
NO3-N + NO2-N
Monitor & Report (mg/L)
Weekly
Composite
Effluent
Total Nitrogen, TN 6
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TN Load'�8
Monitor & Report (Ib/mo)
Monitor & Report (Ib/yr)
Monthly
Annually
Calculated
Effluent
Total Phosphorus, TP
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TP Load's
Monitor & Report (Ib/mo)
Monitor & Report (Ib/yr)
Monthly
Annually
Calculated
Effluent
Total Cyanide 9
5.2 pg/L
22.0 pg/L
Weekly
Grab
Effluent
Total Mercury 10
0.012 pg/L
Weekly
Grab9
Effluent
Total Nickel*
91.0 pg/L
Weekly
Composite
Effluent
Fluoride*
1.9 mg/L
Weekly
Composite
Effluent
Total Cadmium
2.0 pg/L
Weekly
Composite
Effluent
Total Copper
2/Month
Composite
Effluent
Total Zinc
2/Month
Composite
Effluent
Chronic Toxicity11
Quarterly
Composite
Effluent
Effluent Pollutant Scan
See Special Condition A.(4.)
Annually
Grab/Comp.
Effluent
Dissolved Oxygen 12
12
Grab
U, D1, D2
Fecal Coliform 12
12
Grab
U, D1, D2
Temperature (°C) 12
12
Grab
U, Di, D2
Conductivity 12
12
Grab
U, Di, D2
All footnotes are listed on the following page.
PART I, Page 1 of 8

Permit No. NC0047384
Footnotes:
(Summer): April 1- October 31
(Winter): November 1- March 31
(Daily): every day on which a wastewater discharge occurs except Saturdays, Sundays, and legal holidays unless otherwise
specified by the Director.
1. U: Upstream at Old U.S. Highway 70. D1: Downstream at NCSR 2821 (Harvest Road). D2: Downstream at Huffine Farm
Road.
2. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the respective influent value (85%
removal).
3. The daily effluent dissolved oxygen concentration shall not be less than 6.0 mg/L.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. The Division shall consider all effluent TRC values reported below 50 ug/L to be in compliance with the permit.
However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory
(including field certified), even if these values fall below 50 ug/L.
6. TN is Total Nitrogen = TKN + NO3-N + NO2-N, where TKN is Total Kjeldahl Nitrogen, NO3-N and NO2-N are Nitrate
and Nitrite Nitrogen, respectively.
7. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See Special
Condition A.(7.), Calculation and Reporting of Nutrient Loads.
8. The facility is subject to nutrient limitations as specified in Special Condition A.(2.), Combined Limitations for Nutrients.
9. The quantitation limit for cyanide shall be 20 µg/L; levels reported below 20 µg/L shall be considered zero for
compliance purposes.
10. Effluent samples must be analyzed by an EPA -approved low level mercury analysis method.
11. Chronic Toxicity (Ceriodaphnia) at 90% with testing in January, April, July and October (see Special Condition A. (3.)).
12. Instream monitoring requirements are waived as long as facility retains membership in the UCFRBA. If membership is
cancelled, facility will monitor 3/Week (June -September) and 1/Week (October -May). Stream sampling may be
discontinued at such times as flow conditions in the receiving waters or extreme weather conditions will result in a
substantial risk of injury or death to persons collecting samples. Upon such discontinuance, stream sampling shall be
resumed at the first opportunity after the risk period has ceased.
* The limit might be removed if the facility submits 12 month of data that shows no reasonable potential to exceed the water
quality standard.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
PART I, Page 2 of 8

Permit No. NC0047384
A.(2.) COMBINED LIMITATIONS FOR NUTRIENTS - Outfall CO1
(a.) During the period beginning on the dates specified below and lasting until permit expiration, the
Permittee is further authorized to discharge Total Nitrogen and Total Phosphorus from the T.Z.
Osborne WWTP (NC0047384, Outfall 001) and the North Buffalo Creek WWTP (NC0024325,
Outfall 001) subject to the following combined, delivered load limitations:
Total Nitrogen,
Delivered (Ib/yr)1
Total .Phosphorus,
Delivered (Ib/yr)1
Permit
Facility
Active •
Allocations
Combined
Limit
Active'
Allocations
Combined
Limit
NC0047384
T.Z. Osborne WWTP
290,375
35,708
NC0024325
North Buffalo Creek WWTP
110,698
13,591
401,073
(effective 1/1/2016)
Footnote:
49,299
(effective 1/1/2010)
i Allocations and limits in this table are expressed as delivered loads. See Condition A.(7.) regarding
calculation of delivered loads from discharge loads.
(b.) Compliance with these limits shall be determined in accordance with Special Conditions A.(6.),
Annual Limits for Total Nitrogen and Total Phosphorus, and A.(7.), Calculation and Reporting of
Nutrient Loads.
(c.) Nutrient monitoring and reporting requirements are specified in Special Conditions A.(1.),
Effluent Limitations and Monitoring Requirements, and A.(7.), Calculation and Reporting of
Nutrient Loads.
(d.) Pursuant to N.C. General Statute Section 143-215.1 and the implementing rules found in Title 15A
of the North Carolina Administrative Code, specifically, 15A NCAC 02B.0270, and Part II,
Sections B-12 and B-13 of this permit, the Division of Water Quality (Division) may reopen the
permits listed above and establish more stringent nutrient limits upon finding that such limits are
necessary to prevent the discharges from causing localized water quality impacts in the receiving
streams.
(e.) The Permittee may request that its permits be modified to rescind these combined limits and
establish individual mass discharge limits for each facility. The Division may, after written
notification to the Permittee, rescind these combined limits and establish individual mass
discharge limits for each facility if it determines that the combined limits do not support the
objectives of the Jordan Lake Nutrient Management Strategy. The Division shall provide for
public review of the proposed permit modifications and include in the permit an appropriate
schedule of compliance for the proposed nutrient limits.
PART I, Page 3 of 8

Permit No. NC0047384
A.(3.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
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:
NCDENR/ DWQ/ 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.
PART I, Page 4 of 8

Permit No. NC0047384
A.(4.) EFFLUENT POLLUTANT SCAN
The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the attached
table (using a sufficiently sensitive detection level in accordance with 40 CFR Part 136). The Permittee
shall perform 3 Effluent Pollutant Scans prior to submitting the permit renewal application.
Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be analyzed as
"total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
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 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene
Benzene Base -neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis (2-chloroethoxy) methane
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. The report shall be submitted to the following address:
NCDENR/ DWQ/ Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
PART I, Page 5 of 8

Permit No. NC0047384
A.(5.) NUTRIENT ALLOCATIONS
(a.) The following table lists the Total Nitrogen (TN) and Total Phosphorus (TP) allocations assigned
to, acquired by, or transferred to the Permittee in accordance with the Jordan Lake nutrient
management rule (T15A NCAC 02B .0270) and the status of each as of permit issuance. For
compliance purposes, this table does not supersede any TN or TP limit established elsewhere in
this permit or in the NPDES permit of a compliance association of which the Permittee is a Co-
Permittee Member.
Total Nitrogen Allocation
ALLOCATION
TYPE
SOURCE
DATE, :
ALLOCATION AMOUNT 1
, .
STATUS
Delivered;
(Ib/yet
Discharge
'(lb"/yr)
Base
Assigned by Rule
(T15A NCAC 02B .0270)
8/11/09
289,618
643,595
Active
Supplemental
Connection of
Northeast M&HS WWTP,
NC0038156
608
1,351
Active
Supplemental
Connection of
McLeansville MS WWTP,
NC0038172
149
331
Active
TOTAL
290,375
645,277
Active
Footnote:
1 Nitrogen Transport Factor = 45%
Total Phosphorus Allocation
ALLOCATION
TYPE
. � SOURCE.
DATE"
ALLOCATION AMOUNT
e
- . � _'
.STATUS
•
N
De{ivered
(Ibtrl
�
'
Discharge
'(iontrl� ' '
Base
Assigned by Rule
(T15A NCAC 02B .0270)
8/11/09
35,595
80,899
Active
Supplemental
Connection of
Northeast M&HS WWTP,
NC0038156
90
205
Active
Supplemental
Connection of
McLeansville MS WWTP,
NC0038172
23
52
Active
TOTAL
35,708
81,156
Active
Footnote:
1 Phosphorus Transport Factor = 44%
(b.) Any addition, deletion, or modification of the active allocation(s) listed above (other than to
correct typographical errors) or any change of allocation to 'active' status shall be considered a
major modification of this permit and shall be subject to the public review process afforded such
modifications under state and federal rules.
PART I, Page 6 of 8

Permit No. NC0047384 •
A.(6.) ANNUAL LIMITS FOR TOTAL NITROGEN AND TOTAL PHOSPHORUS
(a.) Total Nitrogen (TN) and Total Phosphorus (TP) allocations and load limits for NPDES
dischargers in the Jordan Lake watershed are annual loads and apply on a calendar year basis.
(b.) For any given calendar year, the Permittee shall be in compliance with the annual TN (or TP)
Discharge Load limit in this Permit if:
(i.) the Permittee's annual TN (or TP) Discharge Load is not greater than the effective limit, or
(ii.) the Permittee is a Co-Permittee Member of a compliance association.
(c.) The TN (or TP) limit in this Permit may be modified as the result of allowable changes in the
Permittee's allocation.
(i.)
Allowable changes include those resulting from purchase of TN (or TP) allocation from an
authorized mitigation banker, the Ecosystem Enhancement Program, or other source
allowed under applicable regulations; purchase, sale, trade, or lease of allocation between
the Permittee and other dischargers; regionalization; and other transactions approved by
the Division.
The Permittee may request a modification of the TN (or TP) limit in this Permit to reflect
allowable changes in its allocation(s).
(A) Upon receipt of timely and proper application, the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Changes in TN (or TP) limits become effective on January 1 of the year following
permit modification. The Division must receive application no later than August 31
for changes proposed for the following calendar year.
Any requests for modification should be sent to:
NCDENR/ DWQ/ NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
(d.) If the Permittee is a member and co-permittee of an approved compliance association on January
1 of a given year, its TN and TP discharges during that year are governed by that association's
group NPDES permit and the limits therein.
The Permittee shall be considered a Co-Permittee Member for any given calendar year in
which it is identified as such in Appendix A of the association's group NPDES permit.
Association roster(s) and members' TN and TP allocations will be updated annually and in
accordance with state and federal program requirements.
If the Permittee intends to join or leave a compliance association, the Division must be
notified of the proposed action in accordance with the procedures defined in the
association's NPDES permit.
(A) Upon receipt of timely and proper notification, the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Membership changes in a compliance association become effective on January 1 of the
year following modification of the association's permit.
(e.) The TN and TP monitoring and reporting requirements in this Permit remain in effect
throughout the term of the Permit and are not affected by the Permittee's membership in a
compliance association.
PART I, Page 7 of 8

Permit No. NC0047384
A.(7.) CALCULATION AND REPORTING OF NUTRIENT LOADS
The Permittee shall calculate and report monthly and annual nutrient loads for the T.Z. Osborne
(NC0047384) and North Buffalo Creek (NC0025325) WWTPs as follows:
(a.) Calculation of Discharge Loads: The Permittee shall calculate monthly and annual discharge
loads for each facility as follows:
(i.)
Monthly Discharge Load (lb/mo, TN or TP) = TN (or TP) x TMF x 8.34
where:
TN (or TP) = the average Total Nitrogen (or Total Phosphorus) concentration
(mg/L) of the composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the
month (MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
(ii.) Annual Discharge Load (lb/yr, TN or TP) = Sum of the 12 Monthly TN (or TP) Loads for
the calendar year
Calculation of Delivered Loads:
(i.) The Permittee shall calculate delivered loads as follows:
(A) Individual, Annual Delivered Load (lb/yr, TN or TP) =
Annual Discharge Load (lb/yr, TN or TP) x TF
where TF = Transport Factor, as follows:
PERMIT
FACILITY
TFTM
TFTp
NC0047384
T.Z. Osborne WWTP
45%
44%
NC0024325
North Buffalo Creek WWTP
43%
42%
(B) Combined Annual Delivered Load (lb/ yr) = Sum of the facilities' Individual Annual
Delivered TN (or TP) Loads for the calendar year
(c.) Reporting of Nutrient Discharges: The Permittee shall report each facility's monthly TN and TP
discharge loads in that facility's discharge monitoring report.
(d.) Reporting of Combined Delivered Loads: The Permittee shall report each calendar year's
combined delivered loads with the T.Z. Osborne WWTP's December report for that year and
shall append the report with a summary of monthly loads and calculations.
PART I, Page 8 of 8

Final Permits, 11/5/2010
NCDENR
NOITfH CAROUNA DCPARTMCNr or
Er 1RONMCNT AND NAT1J AL RE ouI cES
AVM Fact Sheet - NPDES Permit
Jordan Lake NPDES Dischargers
4 NPDES Permits
PROPOSED PERMIT ACTION
The Division proposed to modify four (4) NPDES permits for municipal wastewater treatment
facilities in the Jordan Lake watershed of the Cape Fear, River Basin. The purpose of the
modifications is to set Total Phosphorus discharge limits in accordance with the Jordan Lake
Nutrient Management Strategy: Wastewater Discharge Requirements, T15A NCAC 02B .0270.
The Division first proposed related modifications for these permits in November 2009 and then
modified the draft permits in response to comments from the Permittees.
FACILITY INFORMATION
The affected facilities are as follows:
Permit
Owner
Facility
Receiving Stream
County
' NC0047384
City of Greensboro
T.Z. Osborne WWTP
South Buffalo Creek
Guilford
NC0024325
City of Greensboro
North Buffalo Creek WWTP
North Buffalo Creek
Guilford
NC0023868
City of Burlington
Eastside WWTP
Haw River
Alamance
NC0023876
City of Burlington
Southside WWTP
Big Alamance Creek
Alamance
TORDAN LAKE NUTRIENT MANAGEMENT STRATEGY
The Jordan Lake Nutrient Management Strategy is a comprehensive set of rules and Session
Law that became effective August 11, 2009. The Strategy aims to restore and maintain water
quality, protect the lake's classified uses, and maintain or enhance protections currently
implemented by local governments in existing water supply watersheds. The Strategy calls for
improvements in stormwater management (existing and new development), agricultural
practices, fertiliser application management, riparian buffers protection, and wastewater
treatment.
The Strategy establishes nitrogen and phosphorus allocations for all existing wastewater
dischargers that treat nutrient -bearing wastes. For point sources, it specifies that facilities with a
permitted flow of 0.1 MGD or greater must meet nutrient limits based on these allocations. The
limits for both nitrogen and phosphorus are to be given as annual mass limits. The phosphorus
limits become effective in CY2010, the nitrogen limits in CY2016.
The figure below shows the watershed and the three subwatersheds. The strategy sets nutrient
reduction targets for each subwatershed.
PROPOSED MODIFICATIONS
The Division proposes to incorporate the new phosphorus limits and related conditions into the
affected permits. It intends to add nitrogen limits during the 2011 permit renewals.
The proposed permit modifications go beyond adding the phosphorus limits, which were first
proposed for the Greensboro and Burlington facilities in November 2009. The revised draft

permits propose to apply combined TP limits for each City's wastewater facilities. In each case,
the combined limit equals the sum of the City's individual allocations. In order to account for
differences in transport losses in transit to Jordan Lake, the combined limits are expressed as
delivered (as opposed to discharge) loads. Other nutrient -related conditions in the permits have
been modified to reflect this arrangement.
The modifications include minor changes as well. Out-of-date Special Conditions (for example,
for requirements now completed) have been deleted.
PUBLIC COMMENTS
Greensboro noted one additional correction in the standard permit conditions, which was
corrected.
FINAL ACTION
The four permits are being issued as proposed, except for the one correction in the standard
conditions.
< end oftext >

IS
r
CASWELL \
I
Haw Suwatershed
B. EVERETT' JORDAN LAKE
WATERSHED
hfap Prepated November 8, 2005
/
WAKE
• , • .
1,4oweti NeW Hope
Sabinjatershed

NUTRIENT ALLOCATIONS - INITIAL ASSIGNMENTS
JORDAN RESERVOIR NUTRIENT MANAGEMENT STRATEGY
August 2009
TMDL Targets:
35% TN reduction
5% TP reduction
Transport
Allocations - TN
Allocations - TP
Permit
NC0047597
NC0025241
NC0026051
NC0056413
NC0051314
NC0043257
NC0042803
NC0074446
NC0048429
Owner
City of Durham
Orange Water & Sewer Authority
Durham County
Whippoorwill LLC
North Chatham Water & Sewer Company, LLC
Nature Trails Association, CLP
Birchwood Mobile Home Park
Hilltop Mobile Home Park
Cedar Village Apartments
Facility
South Durham WRF
Mason Farm WWTP
Triangle WWTP
Carolina Meadows WWTP
Qpmt
(MGD)
Cole Park Plaza
Nature Trails Mobile Home Park WWTP
Birchwood Mobile Home Park
Hilltop Mobile Home Park
Cedar Village Apartments
LOWER NEW HOPE ARM
Nutrient Reduction Targets:
Maintain 1997-2001 baseline loads for TN and TP _
(0% reduction required, 0% increase allowed).
20.0
14.5
12.0
0.35
0.050
0.040
0.018
0.012
0.005
46.98
TN TP
75% 67%
63% 47%
96% 97%
63% 47%
81% 84%
81% 84%
70% 64%
70% 64%
100% 100%
TN at EOP Avg Conc TN to Lake
(lb/yr) EOP (ng/L) (Ib/yr)
185,345
134,375
111,207
3,244
1,826
1,461
658
438
183
3.04
3.04
3.04
3.04
12.00
12.00
12.00
12.00
12.00
139,009
84,656
106,759
2,043
1,479
1,184
460
307
183
438,736 PS Alloc'n, lb/yr EOP
3.04 mg/LTN. Lg
12.00 mg/LTN. Sm
TP at EOP Avg Conc TP to Lake
(ib/yr) EOP (mg/L) (Ib/yr)
14,053
10,188
8,432
246
304
244
110
73
30
0.23
0.23
0.23
0.23
2.00
2.00
2.00
2.00
2.00
9,415
4,789
8,179
116
33,680 PS Alloc'n, lb/yr EOP
0.23 mg/LTP,Lg
2.00 mg/LTP, Sm
256
205
70
47
30
PS Alloc'n, Ib/yr at Lake: 336,079
lb/yr TN, Lg: 332,467
Ib/yr TN, Sm: 3,613
PS Alloc'n, Ib/yr at Lake: 23,106
Ib/yr TP, Lg: 22,498
lb/yr TP, Sm: 608
Calc'd redxn at Lake:
35.0°/a
Calc'd redxn at Lake:
5.0°/a
Transport
Allocations - TN
Allocations - TP
Permit
Owner
Facility
Qpmt
(Mm)
TN
TN at EOP
(Ib/yr)
Avg Conc
EOP(mg/L)
TN to Lake
(lb/yr)
TP at EOP
(Ib/yr)
Avg Conc
EOP(mg/L)
TP to Lake
(Ib/yr)
NC0043559
Fearrington Utilities, Inc.
Fearrington Utilities WWTP
0.5
84%
88%
8,138
5.35
6,836
566
0.37
498
0.5
8,138 PS Alloc'n, lb/yr EOP
5.35 mg/LTN, Lg
N/A mg/LIN, Sm
PS Alloc'n, Ib/yr at Lake: 6,836
lb/yr TN, Lg: 6,836
Ib/yr TN, Sm: N/A
566 PS Aloc'n,/yr EOP
0.37 mg/ L TP, Lg
N/A mg/ LTP, Sm
PS Alloc'n, Ib/yr at Lake: 498
lb/yrTP, Lg: 498
Ib/yrTP,Sm: N/A
Calc'd redxn at Lake: 0.0%
Calc'd redxn at Lake: 0.0%

HAW RIVER;ARM
Nutrient Reduction Targets:
8% TN reduction
5% TP reduction
Transport
Allocations - TN
Allocations - TP
Permit
Owner
Facility
QPrnt
(MGO)
TN
TN at EOP Avg Conc TN to Lake
(lb/yr) EOP (mg/L) (Ib/yr)
TP at EOP Avg Conc TP to Lake
(Ib/yr) EOP (mg/L) (lb/yr)
NC0047384
City of Greensboro
T.Z. Osborne WWTP
40.0
45% 44%
643,595 5.29 289,618
80,899 0.66 35,595
NC0024325
City of Greensboro
North Buffalo Creek WWTP
16.0
43% 42%
257,438 5.29 110,698
32,359 0.66 13,591
NC0023868
City of Burlington
Eastside WWTP
12.0
77% 69%
193,078 5.29 148,670
24,270 0.66 16,746
NC0023876
City of Burlington
Southside WWTP
12.0
80% 73%
193,078 5.29 154,463
24,270 0.66 17,717
NC0024881
City of Reidsville
Reidsville WWTP
7.5
66% 56%
120,674 5.29 79,645
15,169 0.66 8,494
NC0021211
City of Graham
Graham WWTP
3.5
81% 71%
56,315 5.29 45,615
7,079 0.66 5,026
NC0021474
City of Mebane
Mebane WWTP
2.5
56% 55%
40,225 5.29 22,526
5,056 0.66 2,781
NC0020354
Town of Pittsboro
Pittsboro WWTP
2.25
76% 82%
36,202 5.29 27,514
4,551 0.66 3,731
NC0066966
Quarterstone Farm Homeowners Assoc.
Quarterstone Farm WWTP
0.20
50% 43%
3,218 5.29 1,609
404 0.66 174
NC0003913
Glen Raven Inc
Altamahaw Division plant
0.15
58% 49%
2,413 5.29 1,400
303 0.66 149
NC0022691
Chateau Communities, Inc.
Autumn Forest Manuf. Home Community
0.082
52% 46%
2,995 12.00 1,558
499 2.00 230
NC0001210
Monarch Hosiery Mills Inc
Monarch Hosiery Mills Incorporated
0.050
58% 49%
1,826 12.00 1,059
304 2.00 149
NC0022675
Country Club Communities LLC
Birmingham Place
0.043
55% 52%
1,571 12.00 864
262 2.00 136
NC0042285
Trails Property Owners Assoc
Trails WWTP
0.040
84% 76%
1,461 12.00 1,227
244 2.00 185
NC0046043
Oak Ridge Military Academy
Oak Ridge Military Academy
0.040
46% 41%
1,461 12.00 672
244 2.00 100
NC0077968
Horners Mobile Home Park
Horners Mobile Home Park
0,040
58% 49%
1,461 12.00 847
244 2.00 119
NC0042528
B Everett Jordan & Son-1927 LLC
B Everett Jordan 1927 LLC
0.036
84% 76%
1,315 12.00 1,105
219 2.00 167
NC0038156
Guilford County Schools
Northeast Middle & Senior High WWTP
0.032
52% 46%
1,169 12.00 608
195 2.00 90
NC0073571
Mervyn R. IGng
Countryside Manor WWTP
0.030
42% 38%
1,096 12.00 460
183 2.00 69
NC0029726
NC Department of Correction
Guilford Correctional Center WWTP
0.025
36% 34%
913 12.00 329
152 2.00 52
NC0001384
Burlington Industries, Inc
Williamsburg plant
0.025
48% 47%
913 12.00 438
152 2.00 72
NC0035866
County of Chatham
Bynum WWTP
0.025
84% 76%
913 12.00 767
152 2.00 116
NC0065412
REA Enterprises, LLC
Pleasant Ridge WWTP
0.0235
51% 45%
858 12.00 438
143 2.00 64
NC0046809
Pentecostal Holiness Church
Pentecostal Holiness Church
0.020
46% 41%
731 12.00 336
122 2.00 50
NC0060259
Willow Oak Mobile Home Park
Willow Oak Mobile Home Park
0.0175
51% 45%
639 12.00 326
107 2.00 48
NC0031607
Alamance-Burlington School System
Western Alamance Middle School
0.015
64% 58%
548 12.00 351
91 2.00 53
NC0046019
Episcopal Diocese of North Carolina
The Summit WWTP
0.015
46% 41%
548 12.00 252
91 2.00 37
NC0045161
Alamance-Burlington School System
Altamahaw/Ossipee Elementary School
0.012
58% 49%
438 12.00 254
73 2.00 36
NC0045144
Alamance-Burlington School System
Western Alamance High School
0.0115
64% 58%
420 12.00 269
70 2.00 41
NC0038172
Guilford County Schools
McLeansville Middle School WWTP
0.0113
36% 34%
413 12.00 149
69 2.00 23
NC0022098
Cedar Valley Communities LLC
Cedar Valley WWTP
0.010
55% 52%
365 12.00 201
61 2.00 32
NC0045152
Alamance-Burlington School System
Jordan Elementary School
0.0075
84% 76%
274 12.00 230
46 2.00 35
NC0055271
Shields Mobile Home Park
Shields Mobile Home Park
0.006
64°/0 58%
219 12.00 140
37 2.00 21
NC0048241
Staley Hosiery Mills
Staley Hosiery Mills
0.005
74% 65%
183 12.00 135
30 2.00 20
NC0038164
Guilford County Schools
Nathanael Greene Elementary School WWTP
0.0045
75% 66%
164 12.00 123
27 2.00 18
NC0036994
Rockingham County Board of Education
Monroeton Elementary School
0.0042
42% 38%
153 ' 12.00 64
26 2.00 10
NC0066010
Rockingham County Board of Education
Williamsburg Elementary School
0.004
51% 45%
146 12.00 75
24 2.00 11
NC0045128
Alamance-Burlington School System
Sylvan Elementary School
0.003
84% 76%
110 12.00 92
18 2.00 14
96.74
1,569,542 PS Alloc'n, Ib/yr EOP
198,243 PS Alloc'n, Ib/yr EOP
5.29 mg/ L TN, Lg
0.66 mg/ L TP, Lg
12.00 mg/LTN, Sm
2.00 mg/LTP, Sm
PS Alloc'n, lb/yr at Lake: 895,127
PS Alloc'n, Ib/yr at Lake: 106,001
lb/yr TN, Lg: 881,757
Ib/yr TP, Lg: 104,001
lb/yr TN, Sm: 13,370
Ib/yr TP, Sm: 1,996
Calc'd redxn at Lake: 8.0% Calc'd redxn at Lake: 5.0%

City of Greensboro
L I North Carolina
October 1, 2010 [via email]
Mr. Mike Templeton
NCDENR- DWQ Point Source Branch
1617 Mail Service Center
Raleigh, N.C. 27699-1617
RE: Comments on NPDES Permit Modifications:
NC0024325 North Buffalo WWTP
NC0047384 T. Z. Osborne WWTP
Dear Mr. Templeton,
Water Resources Department
The City of Greensboro appreciates the opportunity to comment on the permit modifications to
the above listed NPDES permits. Page numbers and section citations are from the draft permits
provided via mail and dated 9-1-2010, including Standard Conditions version 7/23/2010.
Thank you for your time and effort in developing the combined total phosphorus limit for the
two Greensboro POTWs. This flexibility will allow the City to optimize current treatment
processes for the reduction of total phosphorus. It will also allow us to transfer additional flow
to the facility that provides the greatest incidental removal of total nitrogen.
The Industrial Waste Section reiterates our concerns regarding the North Carolina NPDES
Industrial Waste Survey language vs. the Federal language/requirements that were detailed in our
1-15-2010 correspondence to your office [Page 16, Section D. 2.] However, these concerns may
be more appropriately addressed through the North Carolina Water Quality Association, of
which we are a member.
We are also including a previous comment from 1-15-2010 about a confusing/incorrect citation:
• The requirement that, "The IWS submission shall include a summary of any
investigations conducted under paragraph B,2, c, of this Part" does not make sense and
evidently has an incorrect citation. There is no paragraph B. 2. c. in the old version or the
new version of the NPDES Standard Conditions [Page 16, Section D. 2.]
At a future date, we would very much like to discuss the option of a Group Compliance
Association, as mentioned in your cover letter. Greensboro has had preliminary discussions with
our fellow Haw River dischargers and several are interested in pursuing such an organization.
PO Box 3136 ' Greensboro, NC 27402-3136 • www.greensboro-nc.gov • 336-373-CITY (2489) • TTY # 333-6930

Letter to Mr. Mike Templeton re: NPDES Permit Modifications 10-1-2010 Page 2
If you have any questions or need additional information, please do not hesitate to contact me.
We look forward to receiving the final NPDES permit modification documents.
Sincerely,
Ma rti e grao' ei
Martie Groome
Laboratory and Industrial Waste Section Supervisor
cc: Allan Williams, Water Resources Director (via email)
Don Howard, Water Reclamation Manager (via email)
Walter Kling, Operations Superintendant (via email)
Ed Osborne, ORC North Buffalo POTW (via email)
Sharon Miller, Pretreatment Coordinator (via email)
Jeff Poupart, DWQ (via email)
Matt Matthews, DWQ (via email)

• Templeton, Mike
From: [e-mail]
Sent: Tuesday, September 28, 2010 2:42 PM
To: Templeton, Mike
Subject: NC0047384, T. Z. Osborne WWTP
EPA has no comments on this draft permit.
1

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
MEMORANDUM
To:
September 1, 2010
Lee Spencer
NC DENR / DEH / Public Water Supply Section Regional Engineer
Winston-Salem Regional Office
From: Mike Templeton
Point Source Branch/ NPDES
Subject: Review of Draft Permit NC0047384
Greensboro - T.Z. Osborne WWTP
Guilford County
RECI!!4` r
N.C. Garr -
SEP 0 72010
Regional o
��iCFI_
Dee Freeman
Secretary
SEP `�
+� �+ L U I %0t
O
.AW:'_.rl
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
October 4, 2010. If you have any questions on the draft permit, please contact me at 919-807-6402 or
[e-mail].
RESPONSE: (Check one)
******************************************************
Concurs 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 Date
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
?A -di 0
NorthCarolina •
Naturally

News & Record
Name
Published by
News & Record, Inc.
Greensboro, North Carolina
North Carolina, Guilford County
Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to
administer oaths, personally appeared the Publisher's Representative who being first duly sworn, deposed and says:
AFFIDAVIT OF
1. That he/she is the Publisher's Representative of the Greensboro News & Record, Inc. a corporation, engaged in the
publication of newspapers known as "News & Record", published, issued and entered as second class mail in the City of
Greensboro in said County and State.
2. That he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement,
a copy of which is attached hereto, was published in the News & Record on the dates listed below.
3. That the said newspaper (or newspapers) in which such notice, paper, document, or legal advertisement was published
was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of
Section 1-597 of the General Statutes of North C4ionrolinA an was a alified newspaper within the meaning of Sect1-591
of the General Statutes of North Carolina. ; I, ",��
Publisher's Representative ,C ik \ "Y
``��.0 PLANE°TA '161'
My Comm. Exp.
6/15/2014
vG PUBLIC
imc
''%, '?o ICO'i ��`�'
1'
Sworn to and subscribed before me, this
Notary Public
Ad # Date Edition
NCDENR DWQ NPDES 33968650 09/04/10 News & Record
day of Q-
Class PO Ad Copy
400 Jordan Lake PUBLIC NOTICESTATE OF NORTH CAROLIN

Ad ID
33968650
Date
09/02/2010
Time
12:24 PM
PUBLIC NOTCE
STATE OF NORTH CAROUNA
ENVIRONMENTAL MANAGEMENT
COMMISSION/ NPDES UNIT
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
NOTIFICATION OF INTENT TO MODFY
NPDES WASTEWATER PERMITS N
THE JORDAN LAKE WATERSHED
On the basis of through staff review
and application of NC General Statute
143.21, Public Law 92-500, and other
lawful standards and regulations, the
North Carolina Environrrental
Conmssion proposes to rnodiy
National Pollutant Dcharge
Eirniration System (NPDES)
wastewater discharge ppee mists to the
persons listed below effective 45 days
fromthe publish date of this notice.
The purpose of these modikatons 6
to set Total Phosphorus discharge
lirrits in accordance with the Jordan
Lake Nutrient Management Strategy:
Wastewater Discharge Requirerrents,
T15A NCAC 026.0270. The four (4)
affected faciities discharge treated
wastewater in the Jordan Lake
watershed of the Cape Fear River
Basin:
NPDES Perrrit No. NC0047384 City of
Greensboro -T.Z Osbome VWVTP,
dichargng to South Buffab Creek in
Guilford County,
NPDES Permit No. NC0024325, City of
Greensboro - North Buffab Creek
WWTP, discharging to North Buffalo
Creek n Guilford County,
NPDES Permit No. NC0023864 City of
Burlington - Eastside WWTP
dichargng to Haw River in Alamence
County,
NPDES Permit No. NC0023876, City of
Burlington-Southside WWTP,
discharging to Big Alarrence Creek in
Alamsance County,
Written convrents regarding the
proposed pem-rt wil be accepted
until 30 days after the pubish date of
this notice. All comments received
prior to that date are considered in
the final deterrrinations regarding
the proposed permits. The Director of
the NC Division of Water Quality rrey
decide to hold a public rreetnq for
the proposed permits should the
Division receive signdicantdegree of
public interest.
Copies of the draft pemit and other
supporting information on file used
to determine condtbns present in
the draft permits are avaailabb upon
request and payment of the costs of
reprodugton. Man com rrents andror
requests for infarnetion to the NC
Division of Water Quality at the
above address or call Ms Dina
Sprirkl at [phone]. Please
include the NPDES permit number
(attached) in any corrrnun'ration
Interested persons may also visit the
Division of Water Quality at 512 N.
Salsbury Street, Raleigh, NC
276041148 between the hours of
8:00am and 51J0pmto review
information on file.
Ad shown is not actual print size

WAT E R
Resources
...........
City of Greensboro
December 15, 2009 [Emailed: 12-15-09]
RECEIVED
DEC 2 3 2009
Certified Ma kill (�itt< /AtI�IY
Return Recei s'te
POINT SOURCE BRANCH
Mr. Michael E. Templeton
North Carolina Department of Environment and Natural Resources
Point Source Branch-NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699
Re: Comments on Draft Modification to NPDES Permit NC0047384
T. Z. Osborne WWTP-Guilford County
Dear Mr. Templeton,
This purpose of this correspondence is to document the City of Greensboro Water
Resources Department comments on the draft NPDES Permit for the T. Z. Osborne
Buffalo Water Reclamation Facility. The final corrected draft was received via email on
November 13, 2009. The City of Greensboro comments are as follows:
Part A. (1) Effluent Limitations and Monitoring Requirements
Total Phosphorus Annual Load: 81,156 pounds per year
As previously discussed with you, the City of Greensboro would like to request a total
phosphorus annual mass "bubble permit" for the two Greensboro facilities. This
approach is particularly appropriate since flow can be transferred from the North Buffalo
Plant to the T. Z. Osborne Plant. In your cover letter of November 4, 2009 you stated:
"The draft permits do not include (bubble permit) alternate limits; however, we are
considering the request and are willing to discuss the concept further." We are ready to
begin the discussions.
A.(5.)(d.) Annual Limits for Total Nitrogen or Total Phosphorus
The City of Greensboro would also like to explore the concept of an umbrella
permit/compliance association for several Haw River dischargers, but the current draft
NPDES permit language would preclude establishing such a compliance association this
year since a municipality would have to be a member on January 1 of the calendar year
per A.(5.)(d.). DWQ would not have time to issue such a permit and the municipalities
would not have time to form an association before January 1, 2010. We request that
DWQ allow a one-time extension of the January 1 date to allow several cities, along with
DWQ, to investigate the possibility of forming such an association during calendar year
2010. We would, of course, all agree to be held to our individual annual permitted

Letter to Mr. Michael E. Templeton re: NPDES Permit NC0047384- December 15, 2009
phosphorus loads prior to the formation of any compliance association and the applicable
CY 2010 phosphorus loads could be "prorated" if a compliance association were formed
during the year.
Supplement to Permit Cover Sheet - Treatment Component Updates
Please make the following changes to the T. Z. Osborne treatment components listed on
the Supplement To Permit Cover Sheet:
• "Aerated grit removal" should now say "Stirred vortex grit removal"
• "Belt filter presses" should be removed from the Sludge treatment units bullet as
these are no longer being used and have been demolished.
Clerical Addition
On the Effluent Limitations and Monitoring Requirements page A.(1.), the line between
Total Mercury and Total Nickel was omitted. Adding the line will make for easier
reading of the limits and monitoring requirements for those two parameters.
Clarification of definition of "Daily Maximum" (Page 2 of Standard Conditions)
Please clarify the following section/statement: Daily Maximum - The highest "daily
discharge" for conventional and other non -toxicant parameters. NOTE: Permittees may
not submit a "daily average" calculation [for determining compliance with permit limits]
for toxicants. See the relevant Federal effluent guideline[s] for the appropriate
calculation interval. The T. Z. Osborne NPDES permit contains a daily maximum
concentration limit for residual chlorine, total mercury and total cyanide, all of which
require grab sampling. Please confirm that this defmition/statement does not prevent us
from taking several grab samples in one day and averaging them for compliance with the
"daily maximum" limit for these parameters. The definition makes mention of the
"Federal effluent guidelines" which leads me to believe it is actually for parameters
regulated under Federal categorical standards. A review of the definition of "Daily
Discharge" merely confuses the issue further. We look forward to your response.
Thank you for the opportunity to comment on the draft T. Z. Osborne NPDES permit. If
you have any questions or need additional information, please do not hesitate to contact
me at 336-433-7229 or by email at [e-mail]
Sincerely,
Maefte' Qrooine' ActAZt
Martie Groome
cc: Allan Williams, Director of Water Resources [via email]
Don Howard, Water Reclamation Manager [via email]
Walter Kling, ORC-T. Z. Osborne POTW [via email]
Ed Osborne, ORC-North Buffalo POTW [via email]
Steve Tedder, Supervisor Winston-Salem DWQ Regional Office [via email]

AVA
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mitchell Johnson, City Manager
City of Greensboro
PO Box 3136
Greensboro, North Carolina 27402-3136
Dear Mr. Johnson:
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
October 1, 2009
Subject: Notification of Intent to Modify
NPDES Permits NC0047384 and NC0024325
to Incorporate Jordan Lake Nutrient Requirements
T.Z. Osborne and North Buffalo Creek WWTPs
Guilford County
Governor Bev Perdue recently signed legislation to complete passage of rules for the Jordan Lake
Nutrient Management Strategy. The Strategy includes a Wastewater Discharge rule (T15A NCAC 02B
.0270) that applies to your wastewater treatment facilities. Pursuant to Sub -Item (6)(d) of that rule, I am
writing to notify you of (1) the nutrient allocations assigned to your facilities and (2) the Division of
Water Quality's intent to modify the subject NPDES permits to include nutrient limits as provided in
the rule. I also wish to remind you of other provisions of the rule that require your prompt attention.
This letter addresses only certain provisions of the Jordan Lake Wastewater Discharge rule. I encourage
you to familiarize yourself with the remainder of the rule.
Nutrient Allocations. The Wastewater Discharge rule establishes the maximum loads of nitrogen and
phosphorus that can be released from wastewater treatment facilities into the Jordan Lake watershed.
The rule specifies that these wasteload allocations are to be divided among the existing facilities in
proportion to their 2001 permitted flows (with certain exceptions).
Your facilities have been assigned nitrogen and phosphorus allocations. The allocations are expressed
as annual mass loadings delivered to the lake. Due to foreseeable losses between the discharge point
and the lake, they are also expressed as the equivalent discharge loads at the point of discharge. The
delivered and the corresponding discharge allocations assigned to the City of Burlington are as follows:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service:1-877-623.6748
Internet: www.ncwaterquality.org
An Equal opportunity \ Affirmative Action Employer
NonrthCarolina
Naturally

..
Mitchell Johnson, City Manager
Notification of Intent to Modify
NPDES Permits NC0047384 and NC0024325
October 1, 2009
NC0047384 - T.Z. Osborne WWTP
NC0047384
Delivered Allocation
11 �(lb/ yr)
Transport
Factor (%)
Discharge Allocation
(lb/ yr)
Total Nitrogen
exo 289,618
45
$b I 643,595
Total Phosphorus
35,595
44
80,899
2001 Permitted Flow: 40 MGD (as defined in Wastewater Discharge rule)
NC0024325 - North Buffalo Creek WW'IP
NC0024325
Delivered Allocation
(lb/yr)
Transport
Factor (%)
Discharge Allocation
(lb/yr)
Total Nitrogen
110,698
43
257,438
Total Phosphorus
13,591
42
32,359
2001 Permitted Flow: 16 MGD
Intent to Modify Permit. The new rule specifies that facilities with permitted flows at or above 0.1
MGD, including yours, will be subject to effluent limits for nitrogen and phosphorus. The effluent
limits will equal the facility's discharge allocations. The new phosphorus limits become effective
beginning with calendar year 2010. Nitrogen limits become effective beginning with calendar year
2016.
It is the Division's intent to modify the affected permits by the end of 2009 to include the new
phosphorus limits. We will draft permit modifications for the affected facilities in the coming weeks.
As with any such permit action, the proposed modifications will be subject to public review, and we
will provide you with a copy of the draft permit at that time.
The Division will add nitrogen limits during the 2011 permit renewals, with a compliance date of 2016.
Process Optimization. The rule specifies that no later than six months after its effective date, each
discharger with a permitted flow greater than or equal to 0.5 MGD must "evaluate its treatment
facilities and operations and identify further opportunities to improve and minimize nitrogen
reduction in the existing facilities...; and submit a report to the Division documenting its findings,
proposing optimization measures, and describing expected results."
Please provide three copies of your report to the Division at the following address no later than
February 11, 2010:
Division of Water Quality
Surface Water Protection Section, Point Source Branch
Attn: Jordan Lake Coordinator
1617 Mail Service Center
Raleigh, NC 20699-1617
2

Mitchell Johnson, City Manager
Notification of Intent to Modify
NPDES Permits NC0047384 and NC0024325
October 1, 2009
Each discharger must implement the proposed measures no later than six months after the Division
accepts the report and continue until such time as the facility is upgraded for nitrogen removal. The
affected dischargers must also submit annual progress report to the Division for a period of five years.
If you have any questions regarding these requirements, please contact Mike Templeton at (919) 807-
6402 or at [e-mail].
Sincerely,
cc: Allan Williams, Director of Water Resources - 2199 White Street, Greensboro, NC 27405
Winston-Salem Regional Office
NDPES Files
Central Files
3