NC0047384_Permit Issuance_20140606

Aria
✓ 1 •
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 6, 2014
Mr. Steve Drew, Water Resources Director
City of Greensboro
Box 3136
Greensboro, North Carolina 27402 -3136
Subject: Issuance of NPDES Permit NC0047384
Renewal and Expansion
T.Z. Osborne WWTP
Guilford County .
Facility Class IV
Dear Mr. Drew:
Division personnel have reviewed and approved your application for expansion and 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 October 15, 2007 (or as subsequently amended).
Please note that the receiving stream is listed as an impaired waterbody on the North
Carolina 2012 303(d) Impaired Waters List for copper and zinc. Addressing impaired waters
is a high priority with the Division, and instream data will continue to be evaluated. If there
is noncompliance with permitted effluent limits and stream impairment can be attributed to
your facility, then mitigative measures may be required.
The following items are in response to the comment letter received from the City of
Greensboro on March 21, 2014.
• The Cyanide limitation and footnote were removed from this permit since the
effluent from the T.Z. Osborne WWTP did not show reasonable potential to violate
state Water Quality Standards (WQS). However, the Division recognizes that the
City of Greensboro's effluent quantitation limit for cyanide shall be 20 µg/L and
levels reported below 20 µg/L shall be considered zero for Pretreatment Long Term
Monitoring Program purposes.
• The Fact Sheet was revised to include the nutrient calculations used for the modified
allocations.
• Condition A.(3) in the permit has been modified to clarify that the TN and TP combined
delivered load limits will apply to the T.Z. Osborne WWTP at a permitted flow of 40 MGD
once the North Buffalo Creek WWTP permit is rescinded and until the expansion is
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone]Internet: Nv v w.ncwaterquality.org
An Equal Opportu.'ty 1 A.ffirmntive Action Employe - Made part by recycled oa;.er

Mr. Steve Drew, Water Resources Director
June 6, 2014
Page 2 of 4
completed. Additionally, paragraph (a.) under Section A.(1.) has been revised to reference
condition A.(3.) where the combined delivered limitations for TN and TP are described.
• Per the City's request footnote #4 was added under Section A.(2.) to state that the ammonia -
nitrogen limitations do not become effective until the average plant flow for the calendar
year is greater than or equal to 36 MGD. The footnote was modified to include a statement
that when the City of Greensboro reports that the annual average flow is greater than or
equal to 36 MGD with their December DMR, the City shall include a cover letter with the
report stating that the ammonia -nitrogen limits in Section A.(2.) are now effective.
The following item was added to the permit in response to comments from DWR
Public Water Supply Regional and Central Office staff.
• A special condition was added under Section A. (13.) stating that this permit may be
reopened and modified in the future to include 1,4-dioxane monitoring and/or
reduction measures, if the wastewater discharge is identified as contributing to
violations of surface water quality standards.
As identified previously, the renewal permit contains the following significant changes from
your current permit:
• The permit expiration date has been changed to June 30, 2019 to allow five years before
permit renewal. The Division may change the expiration renewal to coincide with Basin
renewals when staffing workloads allow for shorter renewal periods.
• The City of Greensboro's request for Monitoring Frequency Reductions for fecal coliform,
total suspended solids, CBOD5, and ammonia -nitrogen was reviewed. Reduced monitoring
frequencies for fecal coliform, total suspended solids, and CBOD5 were permitted and a
reduction from daily monitoring to twice per week was made for all three parameters in
Section A.(1.). Upon expansion, the City of Greensboro will sample these parameters daily
and may revert back to twice per week sampling for the parameters for which no permit
limit violation occurs. See Section A.(2.) and footnote #13. Ammonia -nitrogen effluent
sampling results did not meet the Guidance requirements to allow for a sampling reduction.
• The requirement to begin reporting discharge monitoring data electronically, no later than
March 30, 2015 (within 270 days of the NPDES Permit effective date), using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been
added to your final NPDES permit. [See Special Condition A.(12.)] For information on
eDMR, registering for eDMR and obtaining an eDMR user account, please visit the
following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the
following web site:
http://www2.epa.gov/compliance/proposed-npdes-electronic-reporting-rule
• The Jordan Lake Nutrient Management Strategy rules adopted in Aug. 2009 prompted a
stream reclassification for South Buffalo Creek from C; NSW to WS-V; NSW. See the
Supplement to Permit Cover Sheet.

Mr. Steve Drew, Water Resources Director
June 6, 2014
Page 3 of 4
• Cyanide, cadmium, nickel, and fluoride effluent sampling results did not show reasonable
potential to violate Water Quality Standards. Limits and monitoring requirements for all
four parameters were removed from the permit.
• Effluent sampling data for selenium showed reasonable potential to violate Water Quality
Standards. Monthly monitoring and limitations for selenium were added to the permit.
• Copper and zinc sampling results showed reasonable potential to violate WQS, however,
they are action level parameters and monitoring is set in conjunction with toxicity test
results. T.Z. Osborne is passing its toxicity tests so limits are not necessary. Both
parameters remain in the permit and sampling was reduced from monthly to quarterly in
accordance with the NPDES Monitoring Frequency memo dated July 15, 2010.
• In accordance with the 2012 Statewide Mercury TMDL, the requirement to perform a
Mercury Minimization Plan (MMP) was added to the permit. See MMP Special Condition
A.(11.). Please note that the MMP shall be developed by December 29, 2014 (within 180
days of the NPDES Permit effective date). A sample MMP was developed through a
stakeholder review process and has been placed on the Division website for guidance at:
http://portal.ncdenr.org/web/wq/swp/ps/npdes.
• Five years of mercury data was reviewed and all the annual averages were less than the
WQBEL and the TBEL. The mercury limitation was removed and monitoring shall continue
as part of the City's Effluent Pollutant Scans.
• Section A.(2.) was added to include limitations and monitoring requirements when T.Z.
Osborne WWTP is expanded to 56 MGD.
• Footnote number 2 in Section A.(3) was revised to recognize Session Laws 2011-394
(HB 119) and 2013-395 (SB515) which extends the compliance date to 2021 if an
ATC is acquired before December 31, 2019 for upgrades needed to meet the TN
allocation.
• In accordance with Federal Regulations 40 CFR 122 a Total Nitrogen Reduction
Schedule containing annual milestones outlining the steps the City of Greensboro
will take to comply with the Jordan Lake Wastewater Discharge Rule (15A NCAC
02B .0270), as modified by North Carolina Session Laws 2011-394 (HB 119) and
2013-395 (SB515), was added under Special Condition A.(4.).
• Revisions were made to Sections A.(7.) and A.(9.) to recognize nutrient allocation
and loading calculation changes required with the expansion. Please review these
Sections carefully. Note the numbers in the allocation Tables in Section A.(7.) have
been rounded and the Totals were determined using additional significant digits. All
delivered loads were converted to discharge loads using T.Z. Osborne's transport
factors.
• Some of the wording has changed in Section A. (5.), Chronic Toxicity Permit Limit,
please review each paragraph carefully.
• Section A. (6.) on the Effluent Pollutant Scan now designates the three years in which the
scans are to be performed — 2016, 2017, and 2018. Please review this condition.
• Section A. (10.) Nitrogen Optimization Plan was added to confirm that the City of
Greensboro will continue to evaluate its treatment facilities and operational processes to

Mr. Steve Drew, Water Resources Director
June 6, 2014
Page 4 of 4
make reasonable efforts to reduce nitrogen discharges until process improvements are
completed as stated in its nitrogen optimization plan dated 2/11/2010.
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
Resources 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 Julie Grzyb by email
([e-mail]) or phone at [phone].
Sincerely,
ehomas A. Reeder, Director
'''Division of Water Resources, NCDENR
Enclosure: NPDES Permit NC0047384
cc: NPDES Unit
Central Files
Winston-Salem Regional Office / Surface Water Protection Section
e-copy:
EPA Region 4
PERCS Unit
Winston-Salem Regional Office / Surface Water Protection Section
Winston-Salem Regional Office /DWR/Regional Engineer, Eric Hudson
ESS/ Aquatic Toxicity Unit, Susan Meadows
ESS/ Ecosystems Unit
Wastewater Operator Certification Group, Steve Reid
Martie Groome, Laboratory and Industrial Waste Section Supervisor, Water Resources Dept.
City of Greensboro

Permit No. NC0047384
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
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
2350 Huffine Mi11 Road •
McLeansville, North Carolina
Guilford County
to receiving waters designated as South Buffalo Creekin.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 July 1, 2014...
This permit and authorization to discharge shall expire at midnight -op June 30, 2019.
. Signed this day June 6, 2014.
omas A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
PART I, Page 1 of 18

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 WWTP 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 fluidized bed sludge incinerator
• Odor control equipment
2. Upon receipt -of one or more Authorizations to Construct from the Division of Water:Resources;
construct 'aid' operate facilities giving the system an ultimate treatment capacity of 56 MGD which
is to be complete in conjunction with the connection and transfer of all wastewaters from North
Buffalo Creek WWTP to.the T.Z. Osborne WWTP and the rescission of the North Buffalo Creek -
WWTP permit NC0024325 (a 16 MGD NPDES permitted facility); and,
3. Discharge from said treatment works (via Outfall 001) into South Buffalo Creek, a class WS-V,
NSW stream in the. Cape Fear River Basin, at the location specified on the attached map.
PART I, Page 2 of 18

r • , Permit No. NC0047384
Footnotes:
1. No later March 30, 2015, begin submitting discharge monitoring reports electronically using NC
DWR's eDMR application system. See Special Condition A. (12.).
2. U: Upstream at Old U.S. Highway 70. DI: Downstream at NCSR 2821 (Harvest Road). D2:
Downstream at Huffine Farm Road.
3. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the
respective influent value (85% removal).
4. The daily effluent dissolved oxygen concentration shall not be less than 6.0 mg/L.
5. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
6. 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.
7. 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.
8.. .TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period
. of time. See Special Condition A.(9.), Calculation and Reporting of Nutrient Loads.
:.. 9.: The facility is subject to nutrient limitations as specified in Special Condition A.(3.), Combined
Limitations for Nutrients and the TN compliance schedule outlined in Special Condition A.(4.).
10. Chronic Toxicity (Ceriodaphnia) at 90% with testing in January, April, July and October (see Special
Condition A. (5.)): TOXICITY MONITORING SHALL COINCIDE WITH METALS
MONITORING.
11..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
. irk thereceiving 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.
There shall benodischarge of floating solids or visible foam in other than trace amounts.
PART I, Page 4 of 18

Permit No. NC0047384 ,
PART 1
A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Outfall 001
a. During the period beginning on the effective date of this permit and lasting until expiration or
expansion to 56 MGD, the Permittee is authorized to discharge treated wastewater from Outfall 001.
Such discharges shall be limited and monitored1 by the Permittee as specified below and in
condition A. (3.) of this permit.
• • , •; • -
: • EFFLUENT • •
• CHARACTERISTICS
•"„ . EFFLUENT LIMITATIONS
• .
MONITORING REQUIREMENTS •
.: Monthly
Average.
Weekly
Average .
Daily
Maximum
Measurement
• Frequency
Sample Type
•
2
Sample Location .1
•
Flow
40.0 MGD
Continuous
Recording
Influent or Effluent '
Total Monthly How (MG)
Monitor & Report
Monthly
Rec. or Calc.
Influent.or Effluent
CBOD, 5-day, 20°C (Summer) 3
4.0•mg/L
6.0 mg/L
2/Week
Composite
Influent & Effluent •
CBOD, 5-day, 20°C (Winter) 3
8;0 mg/L"
110 mg/L
2/Week
Composite
Influent & Effluent •
Total Suspended Solids 3 -
30;0 mg/L. -
45.0 mg/L. •
2/Week
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
2/Week:
Grab
.
Effluent =
Dissolved Oxygen 4
Daily •
Grab
Effluent • •
Temperature (°C)
Daily
Grab
Effluent
pH 5
• .
Daily
Grab
Effluent •
Total Residual Chlorine 6
18.0 pg/L
• ' Daily •
Grab
• Effluent •
TKN
Monitor & Report (rig/L) . •
• Weekly
Composite
Effluent
NO3-N + NO2-N .
Monitor & Report (mg/L)
Weekly
Composite
Effluent
Total Nitrogen, TN '
Monitor & Report (mg/L)
Weekly,
Composite
• Effluent
TN Load 8,9
• - Monitor & Report (Ib/mo)
• • Monitor & Report -(Ib/yr)
Monthly
Annually
. Calculated
.Effluent
Total Phosphorus, TP
. Monitor & Report .(mg/L) •
Weekly •
Composite
Effluent
TP Load 8,9
• " Monitor & Report (Ib/mo) .
'Monitor .&•Report (lb/yr) • • •
Monthly- .
* ' Annually •
Calculated
.
.
Effluent .
Selenium
5.2 Ng/L .
- • .•. -
- 57.6-pg/L.
::.. -. Monthly- _ •
Composite
Effluent -
Total Copper
. • .....: .
.. • . . .
.... Quarterly
Composite
Effluent •
Total Zinc
• .- • .
• - : :. • •
: •; = : • • • :
. :Quarterly'
Composite
Effluent •
Chronic Toxicity 1°
. ":- - •
•
• ' 7Quarterly-
Composite
Effluent
Effluent Pollutant Scan
Monitor &.Report .'. •• - ` • ' • - '
" See Special Condition A.(6.)
Effluent
Dissolved Oxygen 11
See footnote 11
Grab
U, D1, D2
Fecal Coiiform 11
-
..: , - ..:::.:See
footnote 11
Grab
U, D1, D2
Temperature (°C) 11
. •.
::See footnote 11
Grab
U, D1, D2
Conductivity 11
.. . •
:. See footnote 11
Grab
'U, Di, D2
(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.
All footnotes are listed on the following page.
PART I, Page 3 of 18

Permit No. NC0047384
A.(2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Outfall 001
a. Beginning upon expansion to 56 MGD expansion and lasting until permit expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and
monitored' by the Permittee as specified below:
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS y',
EFFLUENT
CHARACTERISTICS
Monthly :
Average
Weekly ,
Average
Daily
Maximum
Measurement
' . Freguencf '
Sample
Type
Sainple,Location2 =.
Flow
56.0 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) 3
4.0 mg/L
6.0 mg/L
Twice per week°
Composite
Influent & Effluent
CBOD, 5-day, 20°C (Winter) 3
8.0 mg/L
12.0 mg/L
Twice per week
Composite
Influent & Effluent
Total Suspended Solids 3
30.0 mg/L
45.0 mg/L
Twice per week
Composite
Influent & Effluent
NH3 as N (Summer)4
0.82 mg/L
2.46 mg/L
Daily
Composite
Effluent
NH3 as N (Winter) 4
1.64 mg/L
4.92 mg/L
Daily
Composite
Effluent
Fecal Conform
(geometric mean)
200/100mL
400/100mL
Twice per week°
Grab
Effluent
Dissolved Oxygen 5
Daily
• Grab
Effluent
Temperature (°C)
Daily
Grab
Effluent
pH 6
Daily
Grab
Effluent
Total Residual Chlorine'
17.0 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 8
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TN Load 9
Monitor & Report (lb/mo)
891,272 lb/yr (effective 1/1/2019)10
Monthly •
Annually
Calculated
Effluent
Total Phosphorus, TP
Monitor & Report (mg/L)
Weekly
Composite
Effluent
TP Load9
Monitor & Report (Ib/mo)
112,044 Ib/yr
Monthly
Annually
Calculated
Effluent
Selenium
5.1 pg/L
57.1 pg/L
Monthly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Chronic Toxicityit
Quarterly
Composite
Effluent
Effluent Pollutant Scan
Monitor & Report
See Special Condition A.(6.)
Effluent
Dissolved Oxygen 12
12
Grab
U, D1, D2
Fecal Coliform 12
12
Grab
U, D1, D2
Temperature (°C) 12
12
Grab
U, D1, D2
Conductivity 12
12
Grab
U, D1, D2
(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.
All footnotes are listed on the following page.
PART I, Page 5 of 18

Permit No. NC0047384
•
Footnotes:
1. No later than March 30, 2015, begin submitting discharge monitoring reports electronically using
NC DWR's eDMR application system. See Special Condition A. (12.).
2. U: Upstream at Old U.S. Highway 70. D1: Downstream at NCSR 2821 (Harvest Road). •
D2: Downstream at Huffine Farm Road.
3. The monthly average effluent CBOD5 and TSS concentrations shall not exceed 15% of the
respective influent value (85% removal).
4. These limitations do not become effective until the average plant flow for the calendar year is
greater than or equal to 36 MGD. In the meantime, the ammonia -nitrogen limitations in Section
A.(1.) will remain in effect. When the City of Greensboro reports that the annual average flow is
greater than or equal to 36 MGD with their December DMR, the City shall state in a cover letter
with the report that the ammonia -nitrogen limits in Section A.(2.) are now effective.
5. The daily effluent dissolved oxygen concentration shall not be less than 6.0 mg/L.
6. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
7. 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.
8. 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.
9. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period
of time. See Special Condition A.(9.), Calculation and Reporting of Nutrient Loads.
10. Per the Jordan Lake Wastewater Discharge Rule (15A NCAC 02B .0270) as modified by North
Carolina Session Laws 2011-394 (HB119) and 2013-395 (SB515), the annual mass Total Nitrogen
limit shall be effective beginning with calendar year 2019, unless the discharger has received by
December 31, 2019, an authorization -to -construct permit for construction, installation, or alteration
of the treatment works for purposes of complying with this limit, in which case the limit shall be
effective beginning with calendar year 2021. This facility is subject to a TN reduction schedule
outlined in Special Condition A. (4.).
11. Chronic Toxicity (Ceriodaphnia) at 90% with testing in January, April, July and October (see Special
Condition A. (5.)). TOXICITY MONITORING SHALL COINCIDE WITH METALS
MONITORING.
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.
13. Upon expansion, the City of Greensboro will sample these parameters daily. However, after 6
months of daily sampling, the Permittee may revert back to twice per week sampling for the
parameters for which no permit limit violation occurred.
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
c. Expansion to a permitted flow of 56 MGD at the T.Z. Osborne WWTP is contingent upon
connection and transfer of all wastewaters received at the North Buffalo Creek WWTP to the
T.Z. Osborne WWTP, cessation of the discharge from the North Buffalo WWTP, and rescission
of permit NC0024325.
PART I, Page 6 of 18

• , Permit No. NC0047384
A.(3.) COMBINED LIMITATIONS FOR NUTRIENTS — Outfall CO1
(a.) During the period beginning on the effective date of this permit, and lasting until expansion to 56
MGD or permit expiration, whichever is sooner, the Permittee is 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; except that upon rescission of the N. Buffalo WWTP permit, the
Permittee is authorized to discharge solely from the T.Z. Osborne WWTP subject to the combined
delivered load limitations.
Total Nitrogen,
Delivered (Ib/yr)1
Total Phosphorus,
Delivered (Ib/yr)1
Permit
Facility
Active
Allocations
Combined
Limit
Active
Allocations
Conibioed
Limit
NC0047384
T.Z. Osborne WWTP
290,375
35,708
NC0024325
North Buffalo Creek WWTP
110,698
13,591
Combined
Delivered
Load
Limitations
401,073
(effective
1/1/2019) 2
• 49299
Footnotes:
1 Allocations and limits in this table are expressed as delivered loads. See Condition A.(8.) regarding
calculation of delivered loads from discharge loads.
2 Per the Jordan Lake Wastewater Discharge Rule (15A NCAC 02B .0270) as modified by North Carolina
Session Laws 2011-394 (HB119) and 2013-395 (SB515), the annual mass Total Nitrogen limit shall be
effective beginning with calendar year 2019, unless the discharger has received by December 31, 2019, an
authorization -to -construct permit for construction, installation, or alteration of the treatment works for
purposes of complying with this limit, in which case the limit shall be effective beginning with calendar
year 2021.
(b.) Compliance with these limits shall be determined in accordance with Special Conditions A.(8.),
Annual Limits for Total Nitrogen and Total Phosphorus, and A.(9.), 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.(9.), 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 Resources (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 7 of 18

Permit No. NC0047384 , ,
A.(4) Total Nitrogen Reduction Schedule
In accordance with Federal Regulations 40 CFR 122 a schedule containing annual milestones outlining
the steps the City of Greensboro will take to comply with the Jordan Lake Wastewater Discharge Rule
(15A NCAC 02B .0270), as modified by North Carolina Session Laws 2011-394 (HB119) and 2013-395
(SB515), are listed below. Revisions to this schedule may be considered and made provided that by
December 31, 2019, the City of Greensboro shall receive an Authorization -to -Construct permit from
DWR for construction, installation, or alteration of the treatment works for purposes of complying
with the TN permit limitation; and, by December 31, 2021 the City of Greensboro shall comply with the
annual total nitrogen targets listed in NPDES Permit NC0047384. All construction contract Packages
are required to obtain an approved ATC in accordance with DWR regulations.
2014 -Begin 1 year study (12 consecutive months with 2 sampling events per month) on Jordan Lake Haw
River Arm
By December 31, 2014 submit report to DWR on progress of the Jordan Lake Haw River Arm study
2015 -Compile, review and analyze data from Jordan Lake Haw River Arm study and develop draft
written report
Bid Package 1 of the T. Z. Osborne BNR Project
By December 31, 2015 submit report to DWR on results of both activities (including final Jordan
Lake study report)
2016 -Award construction contract for Package 1 of the T. Z. Osborne BNR Project
Bid construction contract for Packages 2 and 3 of the T. Z. Osborne BNR Project
By December 31, 2016 submit report to DWR on activities relating to Packages 1, 2 and 3 of the
T. Z. Osborne BNR project
2017- Award construction contract for Packages 2 and 3 of the T. Z. Osborne BNR Project
Bid construction project for Package 4 of the T. Z. Osborne BNR Project
By December 31, 2017 submit report on activities relating to Packages 1, 2, 3 and 4 of the T. Z.
Osborne BNR Project
2018 -Complete Package 1 construction of the T. Z. Osborne BNR Project
Continue construction on Packages 2 and 3 of the T. Z. Osborne BNR Project
Award construction contract for Package 4 of the T. Z. Osborne BNR Project
By December 31, 2018 submit report on activities relating to Packages 1, 2, 3 and 4 of the T. Z.
Osborne BNR Project
2019 -Continue construction on Packages 2, 3 and 4 of the T. Z. Osborne BNR Project
By December 31, 2019 received an Authorization -to -Construct permit for construction,
installation, or alteration of the treatment works for purposes of complying with the TN permit
limitation. By December 31, 2019 submit report on activities relating to Packages 2 and 3 of the
T. Z. Osborne BNR Project
2020 -Complete construction of Packages 2, 3 and 4 (complete BNR facility) and conduct BNR
Optimization of the T. Z. Osborne BNR Project
By December 31, 2020 submit written report to DWR on completion and optimization of
Packages 2, 3 and 4 of the T. Z. Osborne BNR Project
2021-By December 31, 2021 comply with annual total nitrogen targets listed in NPDES Permit NC0047384
All submissions shall be sent to:
NCDENR/ DWR/ NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
PART I, Page 8 of 18

Permit No. NC0047384
A.(5.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality
to Ceriodaphnia dubia at an effluent concentration of 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 December 2010, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December
2010) or subsequent versions. The tests will be performed during the months of January, April, July, and
October. These months signify the first month of each three month toxicity testing quarter assigned to the
facility. Effluent sampling for this testing must be obtained during representative effluent discharge and
shall be performed at the NPDES permittedfinal 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 -December 2010) or subsequentversions.
•
•
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, DWR Form AT-3 (original) is to be •
sent to the following address:. :. .
Attention: North Carolina Division of Water Resources
Water sciences Section
1621 Mail Service Center
Raleigh; North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water -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, andbe certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorineiof'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, arid. 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 Water
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. Assessment of: toxicity compliance is based on the toxicity
testing quarter, which is the three month time interval that begins:on the first day of the month in which
toxicity testing is required by this permit and continues until the final, day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources 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 9 of 18

Permit No. NC0047384
A.(6.) EFFLUENT POLLUTANT SCAN
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below. One scan
must be performed in each of the following years: 2016, 2017, and 2018. Analytical methods shall be in
accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether parameters are present
in concentrations greater than applicable standards and criteria. Samples should be collected with one quarterly
toxicity test each year, and must represent seasonal variation [i.e., do not sample in the same quarter every year].
Unless otherwise indicated, metals shall be analyzed as "total recoverable."
Ammonia (as N)
Chlorine (total residual, TRC)
Dissolved oxygen
Nitrate/Nitrite
Total Kjeldahl nitrogen
Oil and grease
Total Phosphorus
• - Total dissolved solids
Hardness
Antimony
Arsenic .
Beryllium
' _ Cadmium
Chromium
• Copper.
Lead
Mercury (EPA Method 1631E)
.. Nickel
Selenium
Silver
Thallium
Zinc
Cyanide
Total phenolic compounds
: Volatile organic compounds:
Aczolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride •
Chiorobenzene
Chloro dibroanomethane
Chloroethane
2-chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1,1-dichloroethane
1,2 dichloroethane
Trans-1,2-dichloroethylene
1,1-dichloroethylene
1,2-dichloropropane
1,3-dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-trichloroethane
1,1,2 trichloroethane
TrichloroethyIene
Vinyl chloride
Acid -extractable compounds:
P-chloro-m-cresol
2 chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophenol
Phenol
2,4,6-trichlorophenol
Base -neutral compounds:
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4, benzofluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Bis (2-chloroethoxy) methane
Bis (2 chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2 ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
2-chloronaphthalene
4-chlorophenyl phenyl ether
Chrysene •
Di-n-butyl phthalate
Din-octyl phthalate
Dibenzo (a,h) anthracene
1,2 dichlorobenzene .
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,4-dinitrotoluene
2,6-dinitrotoluene
1,2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexaclilorocyclo-pentadiene •
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone,
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine .
N-nitrosodimethylamine
N nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-trichlorobenzene
Reporting: Test results shall be reported on DWR Form -A MR PPA1(or in a form approved by the
Director) by December 31st of each designated sampling year. The report shall be submitted to the
following address: NC DENR/ DWR/ Central Files, 1617 Mail Service Center, Raleigh, North
Carolina 27699-1617.
PART I, Page 10 of 18 ,

Permit No. NC0047384
A.(7.) 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/yr)
Discharge
(Ib/yr)
Base
Assigned by Rule . ..8/11/09
(T15A NCAC 02B .0270)
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
. +S.
,''T
?"ALLOCATION
• :- TYPE':: '• ;
.-
SOURCE
DATE
•
.. . •
' •• ALLOCATION AMOUNT 1
•.
• ;•
'STATUS
Delivered
. . (Ib/yr)
Discharge
(IbIyr.)
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%
PART I, Page 11 of 18

Permit No. NC0047384 •
(b.) Upon receipt of the Engineer's Certification after completion of the 56 MGD expansion and upon
rescission of the North Buffallo Creek Wastewater Treatment Plant permit (NC0024325), the
allocations for the T.Z. Osborne WWTP shall be as follows:
Total Nitrogen Allocation
ALLOCATION
TYPE
SO RCE
.
DATE
ALLOCATION AMOUNT
STATUS
Delivered
(Ib/yr)
Discharge
(Ib/yr)
Base
(TZ Osborne)
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
• •NC0038172
Connection of
Mcleansville MS WWTP,
149
"
331
Active
Supplemental
Connection of N. Buffalo
WWTP (NC0024325)
110,698
.
245,996
•
Active
TOTAL
401,072
891,272
Active
Footnote:
1 Nitrogen Transport Factor = 45%
Total Phosphorus Allocation
:: ,
;ALLOCA`IOEI
T1fPE .
r: ,
SOURCE. %.
t •. .
DATE
. • • •
ALLOCATION AMOUNT
STATUS•
:Delivered
(Ib/yr)
1 ',..
Discharge•
(Ib/yr)
Base :
(lZ Osborne)
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
Supplemental
Connection of N. Buffalo
WWTP (NC0024325)
13,591
30,889 .
..:Active
Total
49,299
112,044
Active
Footnote:
1 Phosphorus Transport Factor = 44%
(c.) 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 12 of 18

Permit No. NC0047384
A.(8.) 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 inits'allocation(s).
(A) Upon receipt of timely and proper application, the Division will modify the permit as
appropriate andin 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/ DWR/ NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
. Raleigh, NC ..27699-1617
(d.) If the Permittee is a mennber 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.
(i.) The Permittee shall be.considered a Co-Permittee Member for any given calendar year in
which it is identified,assuch in Appendix A of the association's group NPDES permit.
(ii.) Association roster(s) arid; members' TN and TP allocations will be updated annually and in
accordance with state 'and federal program requirements.
(iii.) If the Permittee intends tojoin 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 13 of 18

Permit No. NC0047384
A.(9.) 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 (NC0024325) WWTPs as follows:
(a.) Calculation of Discharge Loads: The Permittee shall calculate monthly and annual discharge
loads for each facility as follows:
(b.)
(i.)
Monthly Discharge Load (ib/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.)
When necessary to satisfy conditions A.(1,) and A.(3.) of this permit, 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
TFTN
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 Monthly Discharge Load: The Permittee shall report each facility's monthly TN and
TP discharge loads in that facility's discharge monitoring, report.
(d.) - (i) • Reporting of Annual Combined Delivered Loads: In any calendar year in which conditions
. A.(1.) and A.(3.) of this permiit apply, the Permittee shall report the 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. The
reported annual and monthly Combined Delivered Loads should be labeled
appropriately.
Reporting of Annual Discharge Loads: Beginning with the first full calendar year in which
condition A.(2.) of this permit becomes effective, the Permittee shall report each calendar
year's discharge loads with its December report for that year and shall append the report
with a summary of monthly loads and calculations. The reported annual and monthly
Discharge Loads should be labeled appropriately.
(u)
PART I, Page 14 of 18

Permit No. NC0047384
A.(10.) NITROGEN OPTIMIZATION PLAN
On February 17, 2010 the City of Greensboro submitted a plan to optimize the reduction of nitrogen in
its wasterwater discharges. It is expected that the City of Greensboro will implement these measures
and continue to evaluate its treatment facilities and operational processes to make reasonable efforts to
reduce nitrogen discharges until process improvements are completed.
A.(11.) MERCURY MINIMIZATION PLAN (MMP)
The permittee shall develop and implement a Mercury Minimization Plan (MMP) during this permit
term. The MMP shall be developed by December 29, 2014 , and shall be available for inspection on -site.
A sample MMP was developed through a stakeholder review process and has been placed on the
Division website for guidance (http:/ /portal.ncdenr.org/web/wq/swp/ps/npdes, under Model
Mercury Minimization Plan). The MMP should place emphasis onidentification of mercury
contributors and goals for reduction. Results shall be summarized and submitted with the next permit
renewal.
A.(12.) ELECTRONIC. REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees must
submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates
that these regulations will be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.)Signatory Requirements
O Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting [Supersedes Section D.:(2.) and. Section-E.. (5.) (a)] - - -
Beginning no later than March 30; 2015, the permittee shall begin reporting discharge monitoring data
electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet
application. -
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. TheeDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically, using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR),
permittees will be required to submit all discharge monitoring data to the state electronically using
eDMR and will be required to complete the eDMR submission by printing, signing, and submitting
one signed original and a copy of the computer printed eDMR to the following address:
NC DENR / DWR / Information Processing Unit
A t;NTION: Central Files / eDMR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
PART I, Page 15 of 18

Permit No. NC0047384
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1,1.1, 2, 3) or alternative
forms approved by the Director. Duplicate signed copies shall be submitted tto the mailing address
above.
Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted
in writing to the Division for written approval at least sixty (60) days prior to the date the facility
would be required under this permit to begin using eDMR. Temporary waivers shall be valid for
twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically
to the Division unless the permittee re -applies for and is granted a new temporary waiver by the
Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http: / /portal. nc denr. org/web/ wq/ admin/bog/ipu/ a dmr
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)]
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.) (a) or by a duly authorized representative of that person as described in Part II, Section
B. (11.)(b). A person, and not a position, must be delegated signatory authority‘for eDMR reporting •
purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user.
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following
web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certifij, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted. Based on my inquiry of the person or persons who manage the system, or those
persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting
false information, including the possibility of fines and imprisonment for knowing violations."
3. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
This period may be extended by request of the Director at any time [40 CFR 122.41].
PART I, Page 16 of 18

Permit No. NC0047384
A. (13.) REOPENER FOR 1,4-DIOXANE
This permit may be reopened and modified in the future to include 1,4-dioxane monitoring and/or
reduction measures, if the wastewater discharge is identified as contributing to violations of surface
water quality standards.
PART I, Page 17 of 18

Permit No. NC0047384
0
USGS Quad #: C20SW
Lat. 36° 05' 45" Long. -79° 41' 10"
City of Greensboro — T.Z. Osborne WWTP
NC0047384
County:
Receiving Stream:
Stream Classification:
River Basin:
Sub-Basin/8-Digit HUC #:
Guilford
South Buffalo Creek
WS-V; NSW
Cape Fear
03-06-02 /03030002
PART I, Page 18 of 18

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne
Page 7 NPDES No. NC0047384
Addendum to fact sheet 6-2-2014:
Below are the NPDES responses to the comments received from the City of Greensboro on their draft
permit dated March 21, 2014. The comments are briefly noted first with NPDES responses in italics. The
comment letter from the City is attached to the Fact Sheet.
1. The footnote documenting the City's authority to use 20 ug/L as the POTW's specific analytical
limit was removed from the permit. The City requested that the footnote be inserted back into
the effluent pages.
Cyanide effluent monitoring and limitations were removed since no reasonable potential was
shown for cyanide to violate state Water Quality Standards. Since the footnote would not
reference anything in the permit, the POTW's specific analytical limit for cyanide will be
recognized in the cover letter.
2. The City of Greensboro requested that the raw data used to determine the TN and TP
calculations in the permit be provided in the fact sheet.
An explanation of how the allocations were determined is provided below:
Calculation of combined nutrient limits for Greensboro WWTPs
The City has two WWTPs and N & P allocations for each. Two schools have also connected to the TZO
plant, and their allocations were transferred to TZO in accordance with the Jordan Lake WW rule.
A few key considerations in combining allocations to set limits
Nutrient reduction targets in the Jordan Lake strategy — the resulting nutrient limits in NPDES
wastewater permits — are ultimately concerned with controlling the amounts of nitrogen and
phosphorus delivered to the lake.
Some portion of the nitrogen and the phosphorus discharged upstream of the lake is lost in transit to
the lake. The amounts of nutrients lost increase with travel time. Transport factors are an estimate
of the losses and are used to convert nutrient loads, allocations, or limits from 'discharge' to
'delivered' values and back.
Transport factors in the Jordan Lake watersheds vary from one facility to the next. Thus, all transfers
of allocation must be conducted in terms of 'delivered' loads in order to ensure that the aims of the
strategy are met. The resulting 'delivered' allocations can then be converted back to the
corresponding 'discharge' or 'end -of -pipe' loads, if necessary.
The City's combined limits for TN and TP are the sums of the delivered allocations held by the TZO and
NBC plants.
• The NBC plant's allocations are the plant's base allocations under the Jordan WW rule.
NBC's TN allocation (delivered) = 110,698 lb/yr
NBC's TP allocation (delivered) = 13,591 lb/yr
Page 7
Version: June, 2014

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne' '
Page 8 NPDES No. NC0047384
• The TZO plant's allocations include the plant's base allocations and those of the two schools that have
connected to the City's collection system, as follows:
TZO's TN allocation (delivered) = 289,618 Ib/yr (individual allocations are as originally
608 assigned under the Jordan WW rule.)
149
TZO's TP allocation (delivered) =
290,374 lb/yr delivered load
35,595 lb/yr (Individual allocations are as originally
90 assigned under the Jordan WW rule.)
23
35,708 lb/yr delivered load
(Allocations are not rounded but are displayed to the nearest 1 lb/yr. Sums are based on the actual, not
the displayed, allocations and may appear to be in error due to differences between the displayed and
true values.)
Again, the combined delivered allocations for the two plants are the sums of these delivered allocations:
Combined TN allocation/limit =
Combined TP allocation/ limit =
290,374 lb/yr TZO
110,698 NBC
401,072 lb/yr TN
35,708 Ib/yr TZO
13,591 NBC
49,299 lb/yr TP
The component and combined allocations are summarized here:
Transport
Factors
Allocations - TN
Allocations - TP
TN
TP
TN at EOP
(Ib/yr)
TN to Lake
(Ib/yr)
TP at EOP
(Ib/yr)
TP to Lake
(Ib/yr)
T.Z. Osborne WWTP
45%
44%
643,595
289,618
80,899
35,595
Northeast MS&HS
608
90
McLeansville MS
149
23
290,374
35,708
North Buffalo Creek
43%
42%
257,438
110,698
32,359
13,591
Combined ("bubble")
401,072
49,299
Page 8
Version: June 2, 20I4

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne
Page 9 NPDES No. NC0047384
3. The City requested that the permit address TN and TP allocations during the period of time
when the N. Buffalo Creek WWTP is off-line (and rescission of the NBC permit has occurred) and
all wastewaters are being treated at the T.Z. Osborne WWTP but the expansion has not been
completed.
Condition A.(3) in the permit has been modified to clarify that the TN and TP combined delivered
load limit will apply to T.Z. Osborne at a permitted flow of 40 MGD once the NBC permit is
rescinded and until the expansion is completed. Additionally, paragraph (a.) under Section A.(1.)
has been revised to reference condition A.(3.). where the combined delivered limitations for TN
and TP are described.
In addition, the following item was added to the final permit in response to comments from
DWR Public Water Supply Regional and Central Office staff.
• A special condition was added under Section A. (13.) stating that this permit may be reopened
and modified in the future to include 1,4-dioxane monitoring and/or reduction measures, if the
wastewater discharge is identified as contributing to violations of surface water quality
standards
Page 9
Version: June 2, 2014

NCDENR / DWQ
FACT SHEET
NPDES PERMIT RENEWAL AND EXPANSION
City of Greensboro/T.Z. Osborne WWTP
NPDES No. NC0047384
Facility Name:
T.Z. Osborne WWTP (South Buffalo Creek)
Permitted Flow, MGD:
40 mgd renewal and
expansion to 56 MGD
County:
Guilford
Facility Class:
4
Regional Office:
Winston Salem
Facility Status:
Existing
USGS Topo Quad:
C20SW
(McLeansville)
Permit Status:
Renewal and Expansion
Stream Ch ,
--
Receiving Stream:
South Buffalo Creek
Drainage Area (mi2):
41
Subbasin/ 8 Digit
HUC:
030602/03030002
Summer 7Q10 (cfs)
2.1
Index No.:
16-11-14-2C
Winter 7Q10 (cfs):
4.7
Stream Class:
WS-V, NSW
30Q2 (cfs):
6.5
303(d) Listed:
YES, for Cu and Zn
Average Flow (cfs):
46
Use Support:
Impaired
IWC (%) at 40 and 56 MGD:
96.7% / 97.6%
SUMMARY
This facility is a major municipal treatment plant operating in Guilford County. The City of Greensboro
operates the TZ Osborne WWTP and this permit application was originally submitted on Jan. 4, 2011 for
a permit renewal at the current plant design flow of 40 MGD. On Feb. 22, 2013 the City submitted a
revised renewal application to include an expansion modification from 40 MGD to 56 MGD. In addition,
on April 25, 2013 the City of Greensboro submitted data requesting monitoring frequency reductions for
fecal coliform, total suspended solids, CBOD5, and ammonia -nitrogen. Additional information was
requested and received on May 1, 2013. The permit was than redrafted but put on hold pending proposed
changes to the Jordan Lake rules in state legislation. In 2013 the Jordan Lake Wastewater Discharge Rule
was modified by Session Laws 2011-394 (HB119) and 2013-395 (SB515). This permit was then re-
drafted to include these modifications and a Total Nitrogen reduction schedule outlining the actions the
City will take to comply with annual total nitrogen targets listed in NPDES Permit NC0047384.
BACKGROUND
The City of Greensboro currently operates both the T. Z. Osborne WWTP with a permitted discharge of
40 MGD and the North Buffalo Creek WWTP with a permitted discharge of 16 MGD. As part of the B.
Everett Jordan Reservoir Nutrient Management Strategy and TMDL adopted in August 2009 the City of
Greensboro assessed alternatives for the two WWTP's to meet TMDL nutrient limitations. The most
feasible and cost effective alternative determined was to expand and upgrade the T.Z. Osborne WWTP to
a combined permitted discharge of 56 MGD and to rescind the NPDES permit for the North Buffalo
Creek WWTP.
In 2010, the City requested and received speculative limits for a combined discharge of 56 MGD from
the T.Z. Osborne facility to South Buffalo Creek. In February 2012, The City of Greensboro submitted a
SEPA Environmental Assessment on the proposed expansion and on October 9, 2012, a Finding of No
Significant Impact was issued. As stated above, the City than resubmitted its permit renewal application
which included the expansion to 56 MGD. The proposed project will not increase the total wastewater
treatment capacity for the City and the geographical service area will not be increased beyond the current
plannning limits.

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne "
Page 2 NPDES No. NC0047384
For the past 3 years, the T.Z. Osborne WWTP has discharged an average flow of 23 MGD into South
Buffalo Creek. The City has a separate sewer collection system. The City of Greensboro has 34
Significant Industrial Users (SIUs) and a full-scale pretreatment program. SIUs include metal finishers
and electroplaters, organic chemical manufacturing, centralized waste treatment, electrical and electronic
component manufacturing, textile manufacturers, one tobacco company, and two pharmaceutical
companies. Twenty-nine SIUs discharge directly to the T.Z. Osborne WWTP and five SIUs send their
effluent to the North Buffalo Creek WWTP. A portion of the wastewaters received at the N. Buffalo •
WWTP are currently diverted to the T.Z. Osborne WWTP and treated. In 2010, the total average daily
flow to the North Buffalo Creek WWTP was 15.4 MGD. Approximately 6 MGD was treated and
discharged to North Buffalo Creek, and 9.4 mgd was transferred to the T.Z. Osborne WWTP for
treatment and discharge.
The WWTPs, T.Z. Osborne and North Buffalo, ultimately discharge to the Haw River arm of Jordan Lake.
The T.Z. Osborne WWTP discharges to South Buffalo Creek, which then discharges to Buffalo
Creek>Reedy Fork>Haw River>Jordan Lake. South Buffalo Creek is an effluent -dominated stream, with
the Greensboro discharge representing 96.7% of the in -stream waste concentration (IWC) at 40 mgd and
97.6% IWC at 56 mgd. South Buffalo Creek is listed on the 2012 303(d) list for Cu and Zn impairments.
With the adoption of the Jordan Lake Nutrient Management Strategy and TMDL in Aug. 2009, the City
of Greenboro will have to control nitrogen to meet the following annual TN mass loadings:.
Jordan Lake Rules End -of -Pipe Target TN Annual Mass Loadings
POTW
Permitted Flow
Annual Mass Load
Concentration
North Buffalo
16.0 MGD
257,438 pounds
—5.3 mg/L
T.Z. Osborne
40.0 MGD
643,595 pounds
—5.3 mg/L
The permit was modified in 2010 to reflect the Jordan Lake Nutrient Management Strategy and TMDL
and this permit includes additional modifications made to the rule as modified by North Carolina Session
Laws 2011-394 (HB119) and 2013-395 (SB515). These modifications extend compliance with the TN
Combined Limit to 2019; however, if an ATC is acquired for purposes of complying with the allocation
prior to Dec. 31, 2019, the annual mass Total Nitrogen limit shall be effective beginning with calendar
year 2021.
As part of the Management Strategy, South Buffalo Creek was reclassified as a WS-V stream. The
closest downstream intake on the Haw River is the Town of Pittsboro's which is approximately 65 river
miles below the T.Z. Osborne outfall. On July 16, 2012 the NC Governor signed Senate Bill 810 which
included the following clarification on WS-V waters:
SECTION 12.1. Rules adopted by the Environmental Management Commission
pursuant to S.L. 2009-216 and S.L. 2009-486 to implement nutrient management strategies for
the B. Everett Jordan Reservoir and the Falls of the Neuse Reservoir watersheds shall not be
interpreted to apply surface water quality standards set out in 15A NCAC 2B .0218(3)(e)
through (3)(h) to waters designated in the nutrient management rules as WS-V except where:
(i) the designation of WS-V is associated with a water supply intake used by an industry to
supply drinking water for their employees; or (ii) standards set out in 15A NCAC 02B
.0218(3)(e) through (3)(h) are violated at the upstream boundary of waters within those
watersheds that are classified as WS-II, WS-III, or WS-IV. This section shall not be construed
to alter the nutrient reduction requirements set out in 15A NCAC 2B .0262(5) or 15A NCAC
2B .0275(3).
As a result, effluent sampling data for pollutants of concern were compared to Human Health standards
pertaining to organism consumption and Aquatic Life freshwater, Water Quality Standards (WQS).
Surface water quality standards found under 15A NCAC 2B .0218(3)(e) through (3) (h) were not applied.
Page 2
Version: June 2, 2014

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne
Page 3 NPDES No. NC0047384
PERMIT LIMIT DEVELOPMENT
AMMONIA -NITROGEN
Note that the BOD ultimate loading at 40 MGD for the TZ Osborne WWTP was frozen to determine the
CBOD5 limits for the 56 MGD expansion. As a result, the ammonia -nitrogen limit was lowered to 0.82
mg/L as a summer monthly average and 1.64 mg/L as a winter monthly average at 56 MGD. The eF/i.eevl
=rW"' DO s rrdinrd-is to be maintained at above 6 mg/L.
/rw,; (-
REASONABLE POTENTIAL ANALYSIS
Reasonable potential analyses were conducted for As, Cu, F, Pb, Ni, Se, and Zn (see RPA attached). All
other toxicants reported samples at levels below detection — Be, Cd, Cr, CN, and Ag.
Effluent sampling data for Arsenic, Fluoride, Lead, and Nickel showed no reasonable potential to violate
Water Quality Standards.
Effluent sampling data for Selenium, Copper and Zinc showed reasonable potential to violate Water
Quality Standards. Recommendations:
• Monthly monitoring and limitations for Selenium were added to the permit.
• Copper and Zinc are action level standards and are reviewed in conjunction with toxicity
testing. Copper and Zinc monitoring will remain in the permit at a reduced frequency of
quarterly. The City has passed 21 out of 22 Whole Effluent Toxicity Tests between 2009
and 2013. Copper and Zinc limitations are not considered necessary for this discharge.
All the metals will continue to be monitored as part of the City's Pretreatment Program.
MERCURY LIMITATION REVIEW:
Effluent Mercury Data — T.Z. Osborne
Year
2009
2010
2011
2012
2013
# of Samples
52
51
52
52
44
Annual Average, ng/L
6.2
5.4
3.8
3.9
3.7
Maximum Value, ng/L
13.60
19.70
11.10
11.90
9.30
TBEL, ng/L
47
WQBEL, ng/L
12.4
Per the Division guidelines for implementing the mercury TMDL, five years of mercury effluent data
was evaluated. Annual averages for all five years were less than the allowable Water Quality Based
Effluent Limitation of 12.4 ng/L and the Technology Based Effluent Limitation (TBEL) of 47 ng/L. In
accordance with the implementation of the 2012 Statewide Mercury TMDL, the City is required to
develop and implement a Mercury Minimization Plan and continue to monitor for mercury as part of its
Effluent Pollutant Scans.
TOXICITY TESTING:
Type of Toxicity Test:
Existing Limit:
Recommended Limit:
Monitoring Schedule:
Chronic P/F
001: Chronic P/F @ 90%
001: Chronic P/F @ 90%
January, April, July, and October
The facility has been consistently passing its WET tests. During the period from 2009 through 2013 it
has passed 21 out of 22 toxicity tests. Second species tests were performed and passed as well.
Page 3
Version: June 2, 2014

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne " '
Page 4 NPDES No. NC0047384
COMPLIANCE SUMMARY:
DMRs have been reviewed for the period January 2009 through December 2013. The facility received
five Notices of Violation (NOVs) during that time period. The NOV's issued cited exceedances for the
following parameters during the months listed: Hg in 2/2009, Hg in 12/2009, Hg in 2/2010, ammonia -
nitrogen and CBOD5 in 4/2011, and CBOD5 in 7/2012. No permit limit violations occurred in 2013.
The last routine compliance evaluation inspection was conducted on March 12, 2012 and the facility
evaluation rating was extremely reliable. The last routine pretreatment compliance evaluation inspection
was conducted on August 24, 2012 and the facility evaluation rating was extremely reliable.
INSTREAM MONITORING:
Instream monitoring is required for temperature, dissolved oxygen, fecal coliform, and conductivity. The
facility is a member of the Upper Cape Fear Monitoring Coalition, and all their instream monitoring is
conditionally waived for the duration of their membership in the Coalition.
The 2005 Cape Fear River Basin Plan recommends that the City of Greensboro continue to monitor water
quality on S. Buffalo Creek and continue to work with DWR to identify measures that can be used to
reduce stormwater impacts to the creek. In 2002, Greensboro received a $570,000 CWMTF grant to
construct a 20-acre stormwater wetland along South Buffalo Creek treating runoff from 13 square miles
of urban land.
All three segments of S. Buffalo Creek remain on the 2012 303(d) list showing aquatic life impairments.
TMDLs are expected to be developed for identified stressors within 8-13 years of listing.
NUTRIENTS:
TN and TP Limits: Total Nitrogen and Total Phosphorus limits were determined as part of the Jordan
Lake Nutrient Management Strategy which includes a Wastewater Discharge rule (T1SA NCAC 02B
.0270) that established maximum loads of nitrogen and phosphorus that can be released from wastewater
treatment facilities into the Jordan Lake watershed. The rule specifies that the wasteload allocations are
to be divided among the existing facilities in proportion to their 2001 permitted flows (with certain
exceptions).
SEPA/FONSI DETERMINATION:
The proposed expansion was subject to review by governmental agencies under the State of North
Carolina Environmental Policy Act (SEPA EA), and DWR has concluded that the proposed project will
not result in significant impacts to the environment. A Finding of No Significant Impact (FONSI) was
issued on October 9, 2012 and is available for inspection at the State Clearinghouse.
ANTIDEGRADATION REVIEW:
Per NC Antidegradation Policy (15A NCAC 2B.0201), each applicant for an NPDES permit expansion
must document an effort to consider non -discharge alternatives pursuant to 15A NCAC 2H.0105(c)(2).
This alternatives evaluation was submitted as part of the SEPA EA document, and resubmitted with the
permit renewal and expansion. It is important to note that the proposed project will not increase the total
wastewater treatment capacity for the City and the geographical service area will not be increased beyond
the current plannning limits. DWR staff reviewed both the previous flow justification for the City's
service area as well as the alternatives analysis to meet the nutrient TMDL standards. DWR staff
concurred with the projected flow needs based on a 20-year planning horizon. The service area
population is expected to increase from 269,666 (in 2010) to 429,841 (in 2035). The main four
alternative discharge options considered and their corresponding comparative costs included:
1) Nutrient Removal Upgrades to existing surface water discharges — North Buffalo Creek and T.Z.
Osborne WWTPs at a 20-year Total Present Worth cost of $150,700,000
2) Land Application with a 60-day storage pond at a 20-year Total Present Worth cost of $573,700,000.
Page 4
Version: June 2, 2014

' NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne
Page 5 NPDES No. NC0047384
3) Reuse Spray Irrigation using approximately 6,400 acres at a 20-year Total Present Worth cost of
$573,700,000.
4) Upgrades at T.Z. Osborne to treat 56 MGD and decommissioning the N. Buffalo Creek WWTP,
transferring all the City's permitted flow to one facility and complying with TMDL nutrient standards, at
a 20-year Total Present Worth cost of $133,200,000.
DWR concurred with the alternatives analysis conclusion that the upgrade and expansion of the T.Z.
Osborne facility(option number 4 above) with a direct discharge to South Buffalo Creek is the most
environmentally sound alternative from all reasonably cost-effective options (per 15A NCAC 2H.0105).
MONITORING FREQUENCY REDUCTION EVALUATION:
• On April 25, 2013 the City of Greensboro submitted data requesting monitoring frequency reductions
for fecal coliform, total suspended solids, CBOD5, and ammonia -nitrogen. Additional information
was requested and received on May 1, 2013. Three years of effluent data were reviewed (2011-2013)
for each parameter and a summary on the analysis is attached and titled - Effluent Analysis
Summary. Reduced monitoring frequencies for fecal coliform, total suspended solids, and CBOD5
were granted based on long-term treatment performance at levels consistently below effluent
limitations (<50%). Ammonia -nitrogen effluent sampling results did not meet the Guidance
requirements to allow for a sampling reduction.
PROPOSED CHANGES:
• . Change the permit expiration date to June 30, 2019 to allow five years before permit renewal.
• Reduce monitoring frequencies for fecal coliform, total suspended solids, and CBOD5 from daily
monitoring to twice per week.
• Cyanide, cadmium, nickel, and fluoride effluent sampling results did not show reasonable potential
to violate Water Quality Standards (WQS). Limits and monitoring requirements for all four
parameters were removed from the permit.
• Effluent sampling data for selenium showed reasonable potential to violate Water Quality Standards.
Monthly monitoring and limitations for selenium were added to the permit.
• Copper and zinc sampling results showed reasonable potential to violate WQS, however, they are
action level parameters and limits are set in conjuction with toxicity test results. T.Z. Osborne is
passing its toxicity tests so limits are not necessary. Both parameters remain in the permit and
sampling was reduced from monthly to quarterly in accordance with the NPDES Monitoring
Frequency memo dated July 15, 2010.
• Mercury annual averages were Tess than the WQBEL and the TBEL of 47 ng/L. In accordance with
the 2012 Statewide Mercury TMDL and NPDES Permitting Implementation the mercury limitation
was removed. The facility will be required to implement a Mercury Minimization Plan and continue
monitoring mercury as part of their Effluent Pollutant Scans.
• Section A.(2.) was added to include limitations and monitoring requirements when T.Z. Osborne
WWTP is expanded to 56 MGD. Changes in the Total Residual Chlorine and Selenium limitations
are based on the increased lnstream Waste Concentration (IWC) at 56 MGD.
• Footnote #2 in Section A.(3.) was revised to recognize North Carolina Session Laws 2011-394
(HB119) and 2013-395 (SB5 15) which extends the compliance date to 2021 if an ATC is acquired
before Dec. 31, 2019 for upgrades needed to meet the TN allocation.
• In accordance with Federal Regulations 40 CFR 122 a schedule containing annual milestones
outlining the steps the City of Greensboro will take to comply with the Jordan Lake Wastewater
Discharge Rule (15A NCAC 02B .0270), as modified by North Carolina Session Laws 2011-394
(HBI 19) and 2013-395 (SB515), was added under Special Condition A.(4.).
Page 5
Version: June 2, 2014

NPDES PERMIT FACT SHEET City of Greensboro- T.Z. Osborne'
Page 6 NPDES No. NC0047384
• Section A. (6.) on the Effluent Pollutant Scan now designates the three years in which the scans are
to be performed.
• Sections A.(7.) and A.(9.) were revised to include TN and TP allocations and load calculation
changes when T.Z. Osborne is expanded to 56 mgd and N. Buffalo is closed.
• Section A. (10.) Nitrogen Optimization Plan was added to confirm that the City of Greensboro will
continue to evaluate its treatment facilities and operational processes to make reasonable efforts to
reduce nitrogen discharges until process improvements are completed as stated in its nitrogen
optimization plan dated 2/11/2010.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: Feb. 12, 2014 (est.)
Permit Scheduled to Issue: April 7, 2014 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Julie
Grzyb at [phone].
NAME:
kLati d/711(
REGIONAL COMMENTS:
No additional comments received from the Region.
EPA COMMENTS:
No comments received from EPA.
NC WRC COMMENTS:
DATE: V " —
See attached memorandum dated 2-19-2014.
Comment 1. NC WRC was pleased to see that the ammonia -nitrogen speculative limits were included in
the permit. Comment 2. NC WRC recommends UV or ozone disinfection systems over chlorine contact
tanks due to aquatics toxicity caused by chlorine and associated compounds.
Page 6
Version: June 2, 2014

Guilford WWTP
NC0047384
2013 Freshwater RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
Qw (MGD) = 40.00
IQIOS(cfs)= 1.76
7Q1OS (cfs) = 2.10
7QIOW(cfs)= 4.70
30Q2 (cfs) = 6.50
Avg. Stream Flow, QA (cfs) = 46.00
Receiving Stream: South Buffalo Creek
WWTP/WTP Class: IV
IWC @ 1QIOS = 97.24%
IWC @ 7QIOS = 96.72%
IWC @ 7QI OW = 92.95%
IWC@30Q2= 90.51%
IWC @ QA = 57.41%
Stream Class: WS
Outfall
Qw=40 MGD
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
PQL l
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS /
Chronic
Applied
Standard
%2 FAV /
Acute
n
u Det Max Pred Allowable Cw
Cw
Arsenic
Arsenic
C
C
50
10
FW(7Q10s)
FIFI/WS(Qavg)
tie./I.
ug/L
17
17
3
3
13.3
13.3
Acute: NO WQS
_ _-- _ _----------------------------
---
Chronic: -- 51.7
N_ o value > Allow_a_ble C_w _
Chronic: 17.4
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _
No RP , Predicted Max >_ 50% of Allowable Cw -
defer to LTMP
Beryllium
NC
6.5
FW(7Q10s)
tie../1.
0
0
N/A
Acute: NO WQS
_ _ -----6.7 _ ---
Chronic:
al samples < 5 ug/L
----------------------------
Cadmium
NC
2
FW(7Q10s)
15
ug/L
0
0
N/A
Acute: 15.4
_ _ _ ---- _ ----------------------------
Chronic:—2.1
all samples < 2 ug/L
---
Chromium
NC
50
FW(7Q1Os)
1022
ug/L
58
0
2.5
Acute: 1,051.0
---- --
Chronic: 51.7
No value > Allowable Cw
all samples < 5 ugfL
----------------------------
Copper (AL)
NC
7
FW(7Q10s)
7.3
us,/I.
58
56
13.0
Acute: 7.5
Chronic:-----7.2 -------------------------------
1 I value(s)> Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Cyanide
NC
5
FW(7Q10s)
22
10
wail..
0
0
N/A
Acute: 22.6
------------------------------------
Chronic:5.2
all sample < 20 ug/L
Fluoride
NC
1800
FW(7Q10s)
uJl.
58
58
1,300.0
Acute: NO WQS
_ _____ _ __
Chronic: 1,861.0
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ ____
No RP , Predicted Max a 50% of Allowable Cw -
defer to LTMP
Lead
NC
25
FW(7Q10s)
; `
ul 'I
55
5
16.0
Acute: 34.8
Chronic---- 25.8---
No value> Allowable Cw
No RP , Predicted Max i 50% of Allowable Cw -
defer to LTMP
----------------------------
Nickel
NC
88
FW(7Q10s)
261
u:1 1.
58
58
42.0
Acute: 268.4
Chronic----- 91.0---
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
---------------------------
Page 1 of 2
NC0047384 9595 FRESHWATER RPA@40MGD 2014.xlsm, rpa
2/10/2014

Guilford WWTP
NC0047384
2013 Freshwater RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
Outfall 1
Qw = 40 MGD
Selenium
NC
5
FW(7Q10s)
56
uwL
22
2
34.8
Acute: 57.6
_ _ _ _____ ____
Chronic: 5.2
1 value(s) > Allowable Cw
RP for non -AL - apply Monthly Monitoring with Limit
____________________________
Silver(AL)
NC
0.06
FW(7Q10s)
1.23
uo/L
0
0
N/A
Acute: 1.265
_ _ _____ _ __
Chronic: 0.062
all samples < 5 ug/L
_____________________
Zinc (AL)
NC
50
FW(7Q10s)
67
unll.
58
58
144.0
Acute: 68.9
_ _ __ _ _
Chronic: 51.7
52 value(s) > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe.CI) - apply Quarterly
Monitoring in conjunction with TOX Test
NC0047384 9595 FRESHWATER RPA(@40MGD 2014.xlsm, r�pa
Page 2 of 2 2/10/2014

Guilford WWTP
NC0047384
2013 Freshwater RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
Qw (MGD) = 56.00
IQ10S(cfs)= 1.76
7Q1OS(cfs)= 2.10
7QIOW (cfs)= 4.70
30Q2 (cfs) = 6.50
Avg. Stream Flow, QA (cfs) = 46.00
Receiving Stream: South Buffalo Creek
W WTP/WTP Class: IV
IWC tn3 IQ1OS = 98.01%
IWC c 7QIOS = 97.64%
IWC tQ 7Q10W = 94.86%
IWC Q 30Q2 = 93.03%
IWC Qu QA = 65.36%
Stream Class: WS
Outfall 1
Qw = 56 MGD
PARAMETER
TYPE
(1)
STANDARDS & CRITERIA (2)
PQL
UNITS
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS /
Chronic
Applied
Standard
% FAV /
Acute
Il
Max Pred
# Det. Cw Allowable Cw
Arsenic
Arsenic
C
C
50
10
FW(7Q10s)
HH/WS(Qavg)
ug/I,
ug/I.
17
17
3
3
13.3
13.3
Acute: NO WQS
_ __—__ ____—__________________________
Chronic: 51.2
No o value > Allowable Cw__
Chronic: 15.3
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _
No RP , Predicted Max >_ 50% of Allowable Cw -
defer to LTMP
Beryllium
NC
6.5
FW(7Q10s)
ug/L
0
0
N/A
Acute: NO WQS
_ _ _
Chronic------6.7 ---
al samples < 5 ugIL
----------------------------
Cadmium
NC
2
FW(7QIOs)
15
ug/I.
0
0
N/A
Acute: 15.3
_ _—_—__ __—
Chronic: 2.0
all samples < 2 ug/L
________________________—__
Chromium
NC
50
FW(7Q10s)
1022
ue/1.
58
0
2.5
Acute: 1,042.8
_ _—_—______—___________________________
Chronic: 51.2
No value > Allowable Cw
all samples < 5 ug/L
Copper (AL)
NC
7
FW(7Q10s)
7.3
ug/I.
58
56
13.0
Acute: 7.4
------------------------------------
Chronic:72
II value(s) > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Cyanide
NC
5
FW(7Q10s)
22
10
ugll.
0
N
N/A
Acute: 22.4
Chronic: 5.1 ---
all sample < 20 ug/L
----------------------------
Fluoride
NC
1800
FW(7Q10s)
ug/l.
58
58
1,300.0
Acute: NO WQS
_
Chronic: 1,843.5
No value > Allowable Cw
No RP , Predicted Max z 50% of Allowable Cw -
defer to LTMP
Lead
NC
25
FW(7Q10s)
33.8
ug/I.
58
5
16.0
Acute: 34.5
Chronic25.6---
No value > Allowable Cw
No RP , Predicted Max >_ 50% of Allowable Cw -
defer to LTMP
----------------------------
Nickel
NC
88
FW(7Q10s)
261
ug/l,
58
58
42.0
Acute: 266.3
_ _ _ _
Chronic: 90.1
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required _ _ _ _ _ _ _ _
Page 1 of 2
9595 FRESHWATER RPA2013 (2).xlsm, rpa
1/24/2014

Guilford WWTP
NC0047384
2013 Freshwater RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
Outfall 1
Qw = 56 MGD
Selenium
NC
5
FW(7Q10s)
56
ueJL
22
2
34.8
Acute. 57.1
Chronic: 5. I
l value(s) > Allowable Cw
RP for non -AL - apply Monthly Monitoring with Limit
Silver (AL)
NC
0.06
FW(7Q10s)
1.23
ug/L
0
0
N/A
Acute: 1.255
—_ _ _ __
- Chronic: 0.061
all samples < 5 ug/L
______________________---- _
Zinc (AL)
NC
50
FW(7Q10s)
67
ug/L
58
58
144.0
Acute: 68.4
_ _ _ _
Chronic: 51.2
52 value(s) > Allowable Cw
RP for AL(Cu,Zn,Ag,Fe,CI) - apply Quarterly
Monitoring in conjunction with TOX Test
Page 2 of 2
9595 FRESHWATER RPA2013 (2).xlsm, rpa
1/24/2014

REASONABLE POTENTIAL ANALYSIS
1
Arsenic - FW Standard
Date
1 9/15/2010
2 12/29/2010
3 3/9/2011
4 6/8/2011
5 9/14/2011
6 12/14/2011
7 3/14/2012
8 6/20/2012
9 9/12/2012
10 12/11/2012
11 3/13/2013
12 9/18/2013
13 10/28/2013
14 10/29/2013
15 10/30/2013
16 10/31/2013
17 11/26/2013
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Data
BDL=1/2DL Results
10 5 Std Dev.
10 5 Mean
10 5 C.V.
10 5 n
11 11
8 8 Mult Factor =
4 4 Max. Value
10 5 Max. Pred Cw
10 5
10 5
10 5
10 5
10 5
10 5
10 5
10 5
10 5
Use "PASTE
SPECIAL -Values"
then "COPY"
Maximum data
Points = 58
8
Chromium
1.6247
5.4706
0.2970
17
1.21
11.0 ug/L
13.3 ug/L
Date
1 11/1/2013
2
3
4
5
6 10/1/2013
7
8
9
10
11
12
13
14 9/1/2013
15
16
17
18 8/1/2013
19
20
21
22 7/1/2013
23
24
25
26
27 5/1/2013
28
29
30
31
32 4/1/2013
33
34
35
36 3/1/2013
37
38
39
40 2/1/2013
41
42
43
44 1/1/2013
45
46
47
48
49 10/24/2012
50 10/31/2012
51 11/7/2012
52 11/14/2012
53 11/21/2012
54 11/28/2012
55 12/5/2012
56 12/11/2012
57 12/19/2012
58 12/26/2012
I`
I
si
<I
Data
c 5
< 5
5
5
5
5
5
BDL=1/2DL Results
2.5 Std Dev.
2.5 Mean
2.5 C.V.
2.5 n
2.5
2.5 Mult Factor =
2.5 Max. Value
5 2.5 Max. Pred Cw
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
0.0000
2.5000
0.0000
58
1.00
2.5 ug/L
2.5 ug/L
-1-
NC0047384 9595 FRESHWATER RPA@4OMGD 2014.xlsm, data
2/10/2014

REASONABLE POTENTIAL ANALYSIS
9
Copper (AL)
Date
1 11/21/2012
2 11/28/2012
3 12/5/2012
4 12/11/2012
5 12/19/2012
6 12/26/2012
7 1/2/2013
8 1/9/2013
9 1/16/2013
10 1/23/2013
11 1/29/2013
12 2/6/2013
13 2/13/2013
14 2/20/2013
15 2/26/2013
16 3/6/2013
17 3/13/2013
18 3/20/2013
19 3/26/2013
20 4/3/2013
21 4/10/2013
22 4/17/2013
23 4/23/2013
24 5/1/2013
25 5/8/2013
26 5/15/2013
27 5/22/2013
28 5/29/2013
29 6/5/2013
30 6/12/2013
31 6/19/2013
32 6/26/2013
33 7/3/2013
34 7/10/2013
35 7/17/2013
36 7/23/2013
37 7/31/2013
38 8/7/2013
39 8/14/2013
40 8/21/2013
41 8/28/2013
42 9/4/2013
43 9/11/2013
44 9/18/2013
45 9/25/2013
46 10/2/2013
47 10/9/2013
48 10/16/2013
49 10/23/2013
50 10/28/2013
51 10/29/2013
52 10/30/2013
53 10/31/2013
54 11/1/2013
55 11/6/2013
56 11/13/2013
57 11/20/2013
58 11/26/2013
Data
BDL=112DL Results
9 9 Std Dev.
8 8 Mean
6 6 C.V.
7 7 n
7 7
7 7 Mult Factor =
7 7 Max. Value
7 7 Max. Pred Cw
9 9
6 6
11 11
6 6
7 7
7 7
8 8
7 7
10 10
4 4
7 7
5 5
7 7
9 9
7 7
6 6
11 11
8 8
5 5
5 5
7 7
13 13
5 5
7 7
8 8
2 1
5 5
6 6
5 5
6 6
5 5
7 7
7 7
6 6
7 7
5 5
4 4
7 7
6 6
7 7
4 4
4 4
4 4
5 5
7 7
7 7
7 7
7 7
6 6
7 3.5
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
11
Fluoride
1.9686
6.5776
0.2993
58
1.00
13.0 ug/L
13.0 ug/L
Use "PASTE SPECIAL
Values" then "COPY"
Maximum data
points = 58
Date Data BDL=1/2DL Results
1 10/24/2012 I 1 600 600 Std Dev. 251.9855
2 10/31/2012 I 1100 1100 Mean 803.4483
3 11/7/2012 900 900 C.V. 0.3136
4 11/14/2012 1000 1000 n 58
5 11/21/2012 1000 1000
6 11/28/2012 600 600 Mult Factor= 1.00
7 12/5/2012 500 500 Max. Value 1300.0 ug/L
8 12/11/2012 1000 1000 Max. Pred Cw 1300.0 ug1L
9 12/19/2012 1000 1000
10 12/26/2012 1100 1100
11 1/2/2013 500 500
12 1/9/2013 700 700
13 1/16/2013 200 200
14 1/23/2013 500 500
15 1/29/2013 900 900
16 2/6/2013 1000 1000
17 2/13/2013 600 600
18 2/20/2013 600 600
19 2/27/2013 600 600
20 3/6/2013 700 700
21 3/13/2013 600 600
22 3/20/2013 500 500
23 3/27/2013 500 500
24 4/3/2013 500 500
25 4/10/2013 400 400
26 4/17/2013 700 700
27 4/24/2013 500 500
28 5/1/2013 600 600
29 5/8/2013 700 700
30 5/15/2013 600 600
31 5/22/2013 500 500
32 5/29/2013 500 500
33 6/5/2013 800 800
34 6/12/2013 700 700
35 6/19/2013 1100 1100
36 6/26/2013 900 900
37 7/3/2013 i 1200 1200
38 7/10/2013 800 800
39 7/17/2013 1200 1200
40 7/24/2013 900 900
41 7/31/2013 800 800
42 8/7/2013 800 800
43 8/14/2013 700 700
44 8/21/2013 1000 1000
45 8/28/2013 900 900
46 9/4/2013 700 700
47 9/11/2013 800 800
48 9/18/2013 700 700
49 9/25/2013 900 900
50 10/2/2013 900 900
51 10/9/2013 1100 1100
52 10/16/2013 1100 1100
53 10/23/2013 1300 1300
54 10/30/2013 1100 1100
55 11/6/2013 1000 1000
56 11/13/2013 1100 1100
57 11/20/2013 1300 1300
58 11/26/2013 1100 1100
-1-
NC0047384 9595 FRESHWATER RPA©40MGD 2014.xlsm, data
2/10/2014

REASONABLE POTENTIAL ANALYSIS
12
Lead
Use"PASTE SPECIAL -
Values" then "COPY"
Maximum data points
50
Date Data BDL=112DL Results
1 11/1/2013 10 5 Std Dev. 2.0938
2 10 5 Mean 5.6034
3 <: 10 5 C.V. 0.3737
4 10 5 n 58
5 S 10 5
6 10/1/2013
10 5 Mult Factor 1.00
7 5; 10 5 Max. Value 16.0 ug/L
8 10 5 Max. Pred Cw 16.0 ug/L
9 u 10 5
10 10 5
11 10 5
12 10 5
13 10 5
14 9/1/2013 10 5
15<, 10 5
16 10 5
17 10 5
18 8/1/2013 10 5
19 E, 10 5
20 a 10 5
21 10 5
22 7/1/2013 c 10 5
23 10 5
24 10 5
25 ; 10 5
26 10 5
27 5/1/2013 10 5
28 10 5
29 4 10 5
30 16 16
31 10 5
32 4/1/2013 10 5
33 `ty 10 5
34 b: 10 5
35 10 5
36 3/1/2013 10 5
37 p-. 10 5
38 10 5
39 10 5
40 2/1/2013 10 5
41 13 13
42 <' 10 5
43 * 10 5
44 1/1/2013 10 10
45 10 10
46 < 10 5
47 10 5
48 10 5
49 10/24/2012 10 5
50 10/31/2012 10 5
51 11/7/2012 ' = 10 5
52 11/14/2012 10 5
53 11/21/2012 S 10 5
54 11/28/2012 10 5
55 12/5/2012 10 5
56 12/11/2012 ', 11 11
57 12/19/2012 �'< 10 5
58 12/26/2012 < 10 5
15
Nickel
Date Data BDL=1/2DL Results
1 9/5/2012 14.0 14 Std Dev.
2 9/12/2012 13.0 13 Mean
3 9/26/2012 21.0 21 C.V.
4 11/7/2012 42.0 42 n
5 11/14/2012 34.0 34
6 11/21/2012 24.0 24 MultFactor =
7 11/28/2012 13.0 13 Max. Value
8 12/5/2012 21.0 21 Max. Pred Cw
9 12/11/2012 31.0 31
10 12/19/2012 27.0 27
11 1/2/2013 15.0 15
12 1/9/2013 21.0 21
13 1/16/2013 24.0 24
14 1/23/2013 28.0 28
15 1/29/2013 17.0 17
16 2/6/2013 18.0 18
17 2/13/2013 12.0 12
18 2/20/2013 14.0 14
19 2/26/2013 13.0 13
20 3/13/2013 10.0 10
21 3/26/2013 40.0 40
22 4/3/2013 16.0 16
23 4/10/2013 20.0 20
24 4/17/2013 15.0 15
25 4/23/2013 15.0 15
26 5/15/2013 38.0 38
27 5/22/2013 40.0 40
28 5/29/2013 19.0 19
29 6/5/2013 17.0 17
30 6/12/2013 13.0 13
31 6/19/2013 26.0 26
32 6/26/2013 17.0 17
33 7/3/2013 20.0 20
34 7/10/2013 11.0 11
35 7/17/2013 16.0 16
36 7/23/2013 14.0 14
37 7/31/2013 20.0 20
38 8/7/2013 24.0 24
39 8/14/2013 15.0 15
40 8/21/2013 13.0 13
41 8/28/2013 32.0 32
42 9/4/2013 12.0 12
43 9/11/2013 19.0 19
44 9/18/2013 18.0 18
45 9/25/2013 29.0 29
46 10/2/2013 14.0 14
47 10/9/2013 28.0 28
48 10/16/2013 14.0 14
49 10/23/2013 13.0 13
50 10/28/2013 18.0 18
51 10/29/2013 14.0 14
52 10/30/2013 13.0 13
53 10/31/2013 17.0 17
54 11/1/2013 19.0 19
55 11/6/2013 14.0 14
56 11/13/2013 14.0 14
57 11/20/2013 17.0 17
58 11/26/2013 14.0 14
Use "PASTE SPECIAL,
Values" limn "COPY" .
Maximum data points
= 58
7.9197
19.6552
0.4029
58
1.00
42.0 ug/L
42.0 ug/L
NC0047384 9595 FRESHWATER RPA©40MGD 2014.xlsm, data
- 1 - 2/10/2014

REASONABLE POTENTIAL ANALYSIS
16
Selenium
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
=68
Date Data BDL=1/2DL Results
1 11/1/2013 IF 10 5 Std Dev. 4.2795
2 I 10 5 Mean 5.8636
3 10/1/2013 .. 10 5 C.V. 0.7298
4 r 10 5 n 22
5 10 5
6 10 5 Mult Factor = 1.39
7 9/1/2013 10 5 Max. Value 25.0 ug/L
8 3/1/2013 ' 10 5 Max. Pred Cw 34.8 ug/L
9 1/26/2010 . 10 5
10 3/10/2010 -z 10 5
11 4/27/2010 ' 10 5
12 6/16/2010 10 5
13 9/15/2010 -. 10 5
14 12/29/2010 '" . 10 5
15 3/9/2011 10 5
16 6/8/2011 10 5
17 9/14/2011 10 5
18 12/14/2011 a:, 25 25
19 3/14/2012 4 4
20 6/20/2012 10 5
21 9/12/2012 ' Y 10 5
22 12/11/2012 "!' 10 5
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52 icy
53 I' ;
54
55
56 t'
57
58
18
Zinc (AL)
Date
1 11/21/2012
2 11/28/2012
3 12/5/2012
4 12/11/2012
5 12/19/2012
6 12/26/2012
7 1/2/2013
8 1/9/2013
9 1/16/2013
10 1/23/2013
11 1/29/2013
12 2/6/2013
13 2/13/2013
14 2/20/2013
15 2/26/2013
16 3/6/2013
17 3/13/2013
18 3/20/2013
19 3/26/2013
20 4/3/2013
21 4/10/2013
22 4/17/2013
23 4/23/2013
24 5/1/2013
25 5/8/2013
26 5/15/2013
27 5/22/2013
28 5/29/2013
29 6/5/2013
30 6/12/2013
31 6/19/2013
32 6/26/2013
33 7/3/2013
34 7/10/2013
35 7/17/2013
36 7/23/2013
37 7/31/2013
38 8/7/2013
39 8/14/2013
40 8/21/2013
41 8/28/2013
42 9/4/2013
43 9/11/2013
44 9/18/2013
45 9/25/2013
46 10/2/2013
47 10/9/2013
48 10/16/2013
49 10/23/2013
50 10/28/2013
51 10/29/2013
52 10/30/2013
53 10/31/2013
54 11/1/2013
55 11/6/2013
56 11/13/2013
57 11/20/2013
58 11/26/2013
Data
BDL=1l2DL Results
82 82 Std Dev. 24.4843
60 60 Mean 79.4483
74 74 C.V. 0.3082
100 100 n 58
79 79
60 60 Mult Factor =
96 96 Max. Value
105 105 Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
P.Q1P.ts = 68
109 109
105 105
77 77
97 97
92 92
105 105
100 100
53 53
90 90
79 79
67 67
63 63
104 104
83 83
82 82
107 107
61 61
35 35
27 27
33 33
37 37
60 60
52 52
83 83
46 46
56 56
113 113
144 144
104 104
117 117
65 65
103 103
110 110
88 88
104 104
74 74
99 99
84 84
70 70
37 37
83 83
91 91
78 78
61 61
77 77
90 90
53 53
55 55
58 58
91 91
1.00
144.0 ug/L
144.0 ug/L
-1-
NC0047384 9595 FRESHWATER RPA@40MGD 2014.xism, data
2/10/2014

EFFLUENT ANALYSIS SUMMARY
NC0047384
Fecal Coliform (2011-2013)
1) 9.53 geo avg
< 100/100mL or 50 % of the monthly permit limit
2) 200% of 400/100 mL weekly avg limit = 800/100mL
2011 5 2012 0 2013 1
6 daily samples > 200% of permit limit
< 20 daily samples exceeded 200% of the 400/100 mL permit limit
3) no more than two weekly average limit violations in 2013 (none on record)
Reduce monitoring Frequency for fecal coliform to 2/week
CBOD (2011-2013)
1) 7/12*4 mg/L + 5/12*8 mg/L = 5.67 mg/L weighted, annual monthly average
2.83 = 50% of wt. annual monthly average
2.7658551 2.77 three-year average is < 50% of the weighted annual monthly average limit
2) 200% of summer monthly avg. limit = 8 mi summer values > 8
2011 5 2012 3 2013 1
9 daily samples exceeded 200% of the monthly average summer limit
200% of winter monthly permit limit = 16 r winter values > 16
2011 0 2012 0 2013 0
no daily samples exceeded 200% of monthly average winter limit
only 15 exceedances allowed - 9 accounted for
3) no more than two weekly average limit violations in 2013 (none on record)
Reduce Monitoring Frequency for CBOD5 to 2/week
TSS • (2011-2013)
1) 30 mg/L monthly average permit limit
15 = 50% of monthly average permit limit
5.18 three-year average is < 50% of the monthly average permit limit
2) 200% of monthly average permit limit= 60 mg/L
2011 0 2012 1 2013 0
1 daily sample exceeded 200% of the monthly average limit
3) no more than two weekly average limit violations in 2013 (none on record)
Reduce Monitoring Frequency for TSS to 2/week
NH3-N (2011-2013)
1) 7/12*2 mg/L + 5/12*4 mg/L = 2.83 mg/L weighted, annual monthly average
1.42 = 50% of wt. annual monthly average
0.56 three-year average is < 50% of the weighted annual monthly average limit
2) 200% of summer monthly avg. limit = 4 mg/L summer values > 4
2011 10 2012 1 2013 0
11 daily samples exceeded 200% of the monthly average summer limit
13) no more than two weekly average limit violations in 2013 (none on record)
200% of winter monthly permit limit = 8 mg/L winter values > 8
2011 7 2012 0 2013 0
0 0 0
7 daily samples exceeded 200% of monthly average winter limit
Total -18 samples exceeded 200% of the monthly summer and winter averages (15 allowed)
Monitoring Frequency for NH3-N remains the same

City of Greensboro T. Z. Osborne [NC0047384] Reduced Monitoring Request
The City of Greensboro hereby requests designation as an'Exceptional Performing Facility"
and reduced monitoring for the following parameters listed as daily monitoring in the current T.
Z. Osborne. NPDES permit: CBOD5, TSS, NH3-N, and fecal coliform. A spreadsheet
summarizing the applicable data is also part of this submittal.
[Language from 4ctober22, 2012 DWQ Guidance Regarding the Reduction of Monitoring
Frequencies in NPDES Permits for Exceptionally Performing Facilities] •
individual NPDES facilities shalt submit a written request to modify their NPDES permit
specifying which parameters are to. be; considered for teqfrced monitoring . Permit holders
must include with. their requests sufficient data, statistical analyses, and, other information to
support the justification for reduced monitoring. ,NPDES permit staff shall ieview the application
and pupporting information. Approval of reduced monitoring frequency shone granted if all the
criteria below are met:
• The facility has no more than one civil penalty assessrnent for permit limit violations for each
target parameter during the previous three years.
o During CY 2010 to 2012, the T. Z. Osborne POTW was assessed the
following civil penalties for the four target parameters:
■ March 2011: $2599.62 for one MA NH3-N limit violation
• Neither the permittee nor any of its employees have been convicted of criminal violations of
the Clean Water Act within the previous five years.
o No City of Greensboro employees have been convicted of criminal
violations of the Clean Water Act within the previous five calendar years
(2008-2412)
• The facility is not currently under an SOC for target parameter effluent limit noncompliance.
o The T. Z. Osborne POTW Is not currently under an SOC for CBOD5, TSS,
NH3-N, or fecal coliform violations.
• The facility is not on EPA's Quarterly Noncompliance Report for target parameter limit
violations.
o The City of Greensboro has not been notified that the T. Z. Osborne POTW
is on EPA's Quarterly Noncompliance Report for CBOD5, NH3-N, TSS'or
fecal coliform violations.
• For BODE CBOD5, TSS, NH3-N and TSS, the three year arithmetic mean of effluent data
must be less than fifty percent of the monthly average permit limit For fecal coliform or
enterococci, the three year geometric mean must be less than 5Q percent of the monthly
average permit limit. For parameters with summer and winter limits, an annual arithmetic
mean of the seasonal limits may be used in the calculation.
o The T. Z. Osborne CY2010-2012 effluent concentrations are less than 50%
• .of the NPDES monthly average limits as follows [see attached data
spreadsheet]:
City of Greensboro 7. Z. Osborne NC0047384 Reduced Monitoring Request Submittal; April 2013 Page 1

Grzyb, Julie
From: Godreau, Jessica
Sent: Friday, May 30, 2014 1:23 PM
To: Belnick, Tom; Matthews, Matt
Cc: Berry, Ron; Grzyb, Julie; Poupart, Jeff; Frick, Jay; Sadosky, Rebecca
Subject: RE: NPDES/Bromide/Dioxane
Yes. If the local bromide work stops however, my understanding is that the division is ready to do more before the next
permit cycle if needed (pending our own investigations). I'm ok leaving it out of the actual permits at this time because
of the state and local actions occurring. Indications are positive with the study being done by NCSU.
Thanks
Ms. Jessica C. Godreau, PE, BCEE, Chief
NC Public Water Supply Section
1634 Mail Service Center
Raleigh NC 27699-1634
512 N Salisbury St, Raleigh 27604-1170
919-707-9100 switchboard
919-707-9078 direct
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Belnick, Tom
Sent: Thursday, May 29, 2014 2:20 PM
To: Godreau, Jessica; Matthews, Matt
Cc: Berry, Ron; Grzyb, Julie; Poupart, Jeff
Subject: NPDES/Bromide/Dioxane
Jessica/Matt: Just want to make sure everyone is on same page....
1. Bromide. PWS submitted comments regarding bromide in Draft permits for Greensboro TZ Osborne and
Burlington Southside&Eastside. In response, a proposed bromide study to be concLucted by Permittees outside
of NPDES permits will be undertaken. Pro p oJQol
2. 1,4-Dioxane. PWS submitted comments regarding 1,4-dioxane in Draft permit for Greensboro TZ Osborne. In
response, the following proposed Reopener Condition will be added to Greensboro Final:
A(x) Reopener for 1,4-Dioxane
This permit may be reopened and modified in the future to include 1,4-dioxane monitoring and/or reduction measures,
if the wastewater discharge is identified as contributing to violations of surface water quality standards.
Let me know if I missed anything. I'd like to reissue these permits next FridayJune 6, as they have been on our backlog
list for >2 years and we have committed to EPA to reissue during current FY. Thanks all.
1

Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDWR/Water Quality Programs
919-807-6390
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
2

•
ra
City of Greensboro
North Carolina
May 12, 2014 [via email]
Mr. Matt Matthews
NC Department of Environment and Natural Resources
Division of Water Resources
1617 Mail Service Center
Raleigh NC 27699-1617
Water Resources Department
RE: Special Bromide Monitoring Study by City of Greensboro and Fayetteville Public Works Commission
Urban Water Consortium Cape Fear River Basin 1,4-Dioxane Study
Dear Matt,
This correspondence is in response to our conference call of May 6, 2014 and will outline the special
bromide monitoring study to be conducted by the City of Greensboro and Fayetteville Public Works
Commission on the Haw River and Cape Fear River.
1. All surface water samples will be collected by Meritech, Inc., a North Carolina certified
commercial laboratory. EPA Method 200.8 will be used for the bromide analyses.
2. All of the initial sample locations are currently part of the Upper Cape Fear or Middle Cape Fear
Basin Monitoring Program and most are on the main stem of the Haw River/Cape Fear River.
Bromide sampling and analyses will be added to the existing twice per month sampling
frequency.
3. The City of Greensboro will pay for all bromide analyses in the Upper Cape Fear basin.
4. The Middle Cape Fear Basin Association will pay for all bromide analyses in the Middle Cape
Fear basin.
5. Bromide sampling and analyses are scheduled to begin in May 2014.
6. After two months of sampling has been conducted and the results made available, the City of
Greensboro, Fayetteville Public Works Commission and Division of Water Resources will meet to
review the data and decide on the next steps to be taken.
The sampling locations chosen for the bromide special study are as follows:
Upper Cape Fear River Basin Bromide Sampling Sites [7 sitesi
B0540050 North Buffalo Creek at 2770 Huffine Mill Road
B0670000 South Buffalo Creek at SR 3000 McConnell Road
B1020000 Haw River at SR 1700 [lower Hopedale Road]
B1440000 Haw River at SR 2158 Swepsonville Road
B1200000 Haw River at NC 54
B2100000 Haw River at SR1713 hear Bynum
B4080000 Haw River at SR 1011 Old US 1

Moy 12, 2014 Letter from COG and PWC to Matt Matthews re: Bromide Study page 2
Middle Cape Fear River Basin Bromide Sampling Sites 14 sites'
B6160000 Cape Fear River at NC 42
B6370000 Cape Fear River at US 401
B8290000 Cape Fear River above Lock & Dam #3
B8349000 Cape Fear River above Lock & Dam #1
We also wanted you to be aware that the Urban Water Consortium (UWC) recently approved funding
for a 1,4-dioxane research project in the Cape Fear River Basin. The purpose of the study, which will
begin in June 2014, is to quantify levels of 1,4-dioxane in the Cape Fear River and identify the sources.
Both the City of Greensboro and Fayetteville Public Works Commission are members of the UWC.
If you have any questions or need additional information, please do not hesitate to contact either of us.
Sincerely,
Martha E. Groome 336-433-7229
City of Greensboro Laboratory and Industrial Waste Section Supervisor
e..,-- Au --
Charles W. Ham, Jr. 910-223-4702
Fayetteville Public Works Commission Water Resources Environmental and Compliance Manager
cc: Steven Drew, City of Greensboro Water Resources Department Director [via email]
Marion J. Noland, Fayetteville Public Works Commission Water Resources Chief Operating
Officer [via email]
Julie Grzyb, NCDENR-DWR NPDES Permit Unit [via email]
Kenney McDowell, City of Greensboro Water Resources Department Deputy Director [via email]
Lori W. Cooper, City of Greensboro Water Reclamation Superintendent [via email]
Alicia Goots, City of Greensboro Laboratory Coordinator [via email]
Kris Pawlak, Meritech, Inc. Laboratory Director [via email]

4f"A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
MEMORANDUM
To:
From:
February 14, 2014
Eric Hudson [[e-mail]]
NCDENR / DWR /PWS Assistant Regional Engineer
Winston-Salem Regional Office
Julie Grzyb
NPDES Unit
Subject: Review of Draft NPDES Permit NC0047384
Greensboro — T.Z. Osborne WWTP
Guilford County
Please indicate below your agency's position or viewpoint on the draft permit for a renewal and expansion of the City of
Greensboro's T.Z. Osborne WWTP and return this form by March 21, 2014. If you have any questions on the draft
permit, please contact me at [phone] or e-mail [e-mail].
RESPONSE: (Check one)
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:
A monitoring condition should be included to require monthly monitoring for bromide because downstream
drinking water treatment plants are sensitive to bromide concentrations with respect to compliance for the EPA
Stage 2 Disinfectant Byproducts Rule (see attachment for justification to require bromide monitoring).
Language should be included in the permit that allows DWR to reopen the permit to include 1,4-dioxane
monitoring or reduction if the discharge from the T.Z. Osborne plant is implicated in any way to levels of 1,4-
dioxane exceeding surface water standards (see attachment for justification).
Opposes th
ce of the above permit, based on reasons stated below, or attached:
Signed (4-61Date: 3.// 6/2O/ y
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwateraualihr.orq
An Equal Opportunity 1 Affirmative Action Employer
NonrthCarolma
Naturally

Justification for Requiring Bromide Monitoring in the NPDES Permit for Greensboro -
T.Z. Osborne WWTP.
Public Water Supply Systems must comply with the Disinfection Byproduct (DBP) Rule, which requires
monitoring of DBPs in the distribution systems. Trihalomethanes (THMs) are DBPs formed by reaction
between chlorine (which is used to disinfect drinking water), natural organic matter, and bromide. In the
presence of chlorine, bromide is oxidized to hypobromous acid, which is a stronger halogen substitution
agent than hypochlorous acid. When bromide is present in the raw water at levels as low as 100 ppb,
DBP kinetics may become accelerated with a direct incorporation of bromide into DBPs. [reference:
Bromide — an Unsuspected Culprit: Assessing Impacts on Stage 2 DBPR Compliance by Cory Hopkins
with Hazen and Sawyer]
The Haw River has exhibited bromide concentrations exceeding 1000 ug/L. [reference: Mapping
historic disinfection byproduct data with ArcGIS to identify North Carolina surface waters with
potentially high bromide concentrations by Jeremy Fireline with North Carolina State University]
The Public Works Commission (PWC) of the City of Fayetteville owns and operates two water
treatment plants. In 2012 the PWC had levels of Total Trihalomethanes (TTHMs) that were higher than
expected. Unusually high TTHM at PWC's water treatment facilities caused PWC and Hazen and
Sawyer to investigate the source of these elevated disinfection byproducts. The investigation revealed
that elevated TTHM may be caused by high concentrations of bromide present in the raw water taken
from the Cape Fear River. Because bromide, which is not currently regulated, is not naturally formed, a
series of sampling and tests has been conducted along the Cape Fear River, and it has been determined
that the chemical is in the water source. [reference: The Bromide Problem in the Cape Fear River near
Fayetteville by z. Michael Wang, PhD, PE, BCEE with Hazen and Sawyer]
On February 5, 2014, Eric Hudson and Tom Boyd of the PWSS-WSRO attended a knowledge sharing
meeting at the City of Greensboro's Mitchell Water Treatment Plant. Dr. Detlef Knappe, with North
Carolina State University, spoke on bromide in the Haw River / Jordan Lake / Cape Fear River. Dr.
Knappe reported bromide sampling results for the Haw River. By far the largest source of bromide was
from Greensboro's T.Z. Osborne WWTP at 3,700 ug/L and a flow rate of approximately 40 MGD.
Given the Greensboro - T.Z. Osborne WWTP is discharging high levels of bromide into the Haw River
and bromide causes DBP compliance problems for downstream water treatment plants, bromide
monitoring should be included in the NPDES permit for Greensboro - T.Z. Osborne WWTP.
Bromide monitoring has previously been included in the NPDES permit for Duke Energy — Belews
Creek Steam Station. The Greensboro — T.Z. Osborne WWTP should also monitor for bromide and the
data should be reported to NC DENR.
Eric Hudson, PWSS-WSRO, - 02/26/2014

Justification for including Language to Reopen NPDES Permit for Greensboro -
T.Z. Osborne WWTP.
Recent monitoring data from the EPA's Unregulated Contaminant Monitoring Rule suggests that
levels of 1, 4-dioxane are above surface water standards at some water treatment facilities in the
Cape Fear Basin. Because 1, 4-dioxane is not removed with conventional water treatment, the
presumption is that the surface water standards themselves are being violated. We understand
that DWR has begun effort to examine available analytical data and determine the source of the
1, 4-dioxane. This in turn, may lead to revisions on some NPDES discharges to require
monitoring or reductions. It is our understanding that if the discharge from the T.Z. Osborne
plant is implicated in any way that either the permit will be reissued or monitoring requirements
added prior to the next review of the NPDES permit. If EPA moves forward with a decision to
regulate 1, 4-dioxane and there are identified dischargers above the established MCL, additional
permit revisions may be required as well.

✓ �
News & Record
• Advertising Affidavit
200 E. Market St
Greensboro, NC. 27401
[phone]
NCDENR DWQ NPDES
ATTN DINA SPRINKLE
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699
Account Number
4002143
Date
February 15, 2014
PO Number Order
Category
Description
512 N SALISBURY 0000030867
Public Notice
Legal Notices
North Carolina Environmental Man-
agement Commission/(NPDES Unit
1617 Mail Service Center
Raleigh. NC 27699-1617
Notice of Intent to Issue a NPDES
wastewater Permit
The North Carolina Environmental
Management Commission proposes
to issue a NPDES wastewater dis-
charge permit to the peroonCs) listed
below. Written comments regarding
tho proposed permit will be accept-
ed until 30 days after the publish
date of this notice. The Director of
the NC Division of Water Resources
(DWR) may hold a public hearing
should there be a significant degree
of public interest. Please mall com-
ments and/or information requests
to DWR at the above address. Inter-
ested persons may visit the DWR at
512 N. Salisbury Street. Raleigh. NC
to review information on file. Addi-
tional information on NPDES permits
and this notice. may be found on our
wobslto: http✓/portal.ncdenr.org/w
ob/wq/swp/ps/npdes/catendar. or
by calling 4919) 807-6390. City of
Greensboro. requested renewal and
an expansion modification of permit
NC0047384 for the T.Z. Osborne
WWTP In Guilford County: this per-
mitted dtacharoo is treated munici-
pal and industrial wastewater to
South Buffalo Creole, Cape Fear Riv-
er Basin.
Public Notice North Carolina Environmental Management Commission/NPDES Unit
Publisher of the
Greensboro News & Record
Before the undersigned, a Notary Public of Guilford, North Carolina, duly commissioned,
, qualified, and authorized by law to administer oaths, personally appeared the Publisher
Representative who by being duly sworn deposes and says: that he/she is the Publisher's
Representative of the News & Record, engaged in the publishing of a newspaper known as
News & Record, published, issued and entered as second class mail in the City of
Greensboro, 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 copy of which is attached
hereto, was published in the News & Record on the following dates:
02/15/2014
and that the said newspaper 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
the requirements and qualifications of Section 1-597 of the General Statutes of North
Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General
Statutes of North Carolina.
• (sign re of person making affidavit)
Sworn to and subscribed before me the `'"' day of
A �
- My Comm. Exp.
. 6/1512014
BUBLAG KAV
iii,,rp 0 CO'
THIS IS NOT A BILL. ilLEASEPAY FROM INVOICE. THANK YOU
20 1+
(Notary Public)

rgCity of Greensboro
North Carolina
July 10, 2013 [via email]
Ms. Julie Grzyb
NC Department of Environment and Natural Resources
Division of Water Quality-NPDES Permits Unit
1617 Mail Service Center
Raleigh NC 27699-1617
re_c_v-404~/ c,,itsk4+7
Water Resources Department
RE: City of Greensboro Comments on T. Z. Osborne Draft Permit NC0047384
Dated July 2, 2013
Dear Julie,
These comments are in response to the latest draft of the City of Greensboro T. Z. Osborne NPDES
Permit NC0047384 attached to your email correspondence of July 2, 2013. We appreciate the changes
made in the current draft in response to our previous comments.
Comments on Page A.(1). Permit Limits (40 MGD)
The comments will be presented in the same order as in the previous City of Greensboro comments letter
of June 13, 2013.
1. Fluoride Limit
We concur with the monthly average fluoride limit of 1.9 mg/I and the daily maximum "monitor and
report" requirement in the current draft.
2. Arsenic Limit
We concur with the 17.4 ug/1 monthly average arsenic limit and the 350 ug/l daily maximum arsenic
limit in the current draft.
Comments on Page A.(2). Permit Limits (56 MGD
3. Fluoride Limit
We concur with the monthly average fluoride limit of 1.84 mg/I and the daily maximum "monitor and
report" requirement in the current draft.
4. Arsenic Limit
We concur with the 15.3 ug/I monthly average arsenic limit and the 347 ug/l daily maximum arsenic
limit in the current draft.
5. Ammonia Nitrogen Limit for 56 MGD
We concur with footnote #13 in the current draft clarifying that the ammonia -nitrogen limits listed on
Page A.(2). will become effective when the annual average calendar year flow of the T. Z. Osborne
POTW reaches 36 MGD. The annual average flow will be reported to DWQ with the December DMR,
which includes this information as part of the calculation of the annual total phosphorus and total
nitrogen loading.

July 10, 2013 Letter to DWQ-Ms. Julie Grzyb re: T. Z. Osborne Final Draft NPDES Permit NC0047384
Page 2
6. Daily Monitoring for CBOD5, TSS, NHS-N and Fecal Coliform
Page A.(2.) includes daily monitoring for CBOD5, TSS, NH3-N and Fecal Coliform. Greensboro previously
requested that the monitoring frequency be modified to reflect the reduced monitoring allowed on
Page A. (1.) if the POTW still met the reduced monitoring criteria during the construction phase and the
NPDES permit limits were the same. It is my understanding that the legal counsel for the North Carolina
Water Quality Association (NCWQA) has contacted Jeff Poupart concerning this topic.
We request that DWQ retain the reduced monitoring frequencies on Page A.(2). but also include
a permit reopener condition which allows DWQ to modify the permit to increase the frequency of
monitoring if there is any variability or concern following the treatment plant upgrade/expansion.
This reopener could also require that the City of Greensboro submit a brief summary of facility
performance after the upgraded plant has been in operation for 12 months. That report would be the
basis for DWQ deciding whether to reopen the permit. We look forward to discussing Item #6 with you
further.
Note: We have provided a schematic of the modification to the current 7ZO activated sludge/
nitrification process which will include the addition of denitrification.
7. Mercury Limit Change Required by EPA
We concur with the 12 ng/1 annual average mercury limit.
Please contact me if you have questions or need additional information.
Sincerely,
.7vf artie Groome
Martie Groome
Laboratory and Industrial Waste Section Supervisor
cc: Steve Drew, Water Resources Department Director (via email)
Kenney McDowell, Water Resources Department Deputy Director (via email)
Don Howard, Water Reclamation Manager (via email)
Lori W. Cooper, ORC-T. Z. Osborne POTW (via email)
Ed Osborne, ORC-North Buffalo POTW (via email)
Alicia Goots, Laboratory Coordinator (via email)
Frank Skee, Pretreatment Coordinator (via email)

City of Greensboro
L J North Carolina
June 13, 2013 [via email]
Ms. Julie Grzyb
NC Department of Environment and Natural Resources
Division of Water Quality-NPDES Permits Unit
1617 Mail Service Center
Raleigh NC 27699-1617
Water Resources Department
RE: City of Greensboro Comments on T. Z. Osborne Draft Permit NC0047384
Dear Julie,
Thank you for providing the additional information on the Reasonable Potential calculations and data for
the T. Z. Osborne permit. The City of Greensboro submits the following comments on the draft T. Z.
Osborne NPDES permit dated May 8, 2013.
General Comment
As you are aware, there are bills currently being considered by the North Carolina General Assembly
that propose to modify the Jordan Lake Rules. Although this correspondence does not contain any
specific comments about the Jordan Lake nutrient targets in the draft permit, the City of Greensboro
wants to document our intention to request a NPDES permit modification should any final legislation
impact any of the limitations or requirements contained in this draft permit.
Comments on Page A.(1). Permit Limits (40 MGD)
1. Fluoride Limit
The cover letter for the draft permit stated: "Fluoride monitoring was changed to monthly and the 1.9
mg/I limitation was changed to a monthly average and weekly limit." The draft permit limits page lists
1.9 mg/I as a daily maximum and a monthly average. Our previous NPDES permit had only a weekly
average limit of 1.9 mg/I for fluoride. We are not aware of any DWQ policy change that would cause the
permit limit to be expressed differently. We request that the weekly average and daily maximum
limits be removed and a fluoride weekly average limit of 1.9 mg/I be added.
2. Arsenic and Selenium Limits and Reasonable Potential Analysis (RPA)
The RPA selenium and arsenic limits were based on a small data set (14 samples). The City of
Greensboro reserves the right to conduct additional monitoring, request that the RPA be conducted
again and the permit reopened prior to the expiration of the NPDES permit.
3. Arsenic Limit
The draft permit contains the same value for the daily maximum limit and the monthly average limit for
arsenic. The previous NPDES permit contained weekly average limits based on the North Carolina
Water Quality Standard. We are not aware of any DWQ policy change that would cause the permit limit
to be expressed differently. We request that the daily maximum and monthly average arsenic limits
be removed and a weekly average limit be developed.

Letter to DWQ-Ms. Julie Grzyb re: T. Z. Osborne Draft NPDES Permit NC0047384 Page 2
Comments on Page A.(2). Permit Limits (56 MGD)
4. Fluoride Limit
As stated previously, the current NPDES permit contains only a weekly average limit of 1.9 mg/I for
fluoride. We are not aware of any DWQ policy change that would cause the permit limit to be
expressed differently. We request that the weekly average and daily maximum limits be removed and
a fluoride weekly average limit of 1.84 mg/1 be added to Limits Page A.(2.).
5. Arsenic Limit
The draft permit contains the same value for the daily maximum limit and the monthly average limit for
arsenic. The previous NPDES permit contained weekly average limits based on the North Carolina
Water Quality Standard. We are not aware of any DWQ policy change that would cause the permit limit
to be expressed differently. We request that the daily maximum and monthly average arsenic limits
be removed and a weekly average limit be developed.
6. Ammonia Nitrogen Limit for 56 MGD
The current NPDES permit would allow the T. Z. Osborne plant to discharge 40 MGD at a concentration
of 2.0 mg/I of ammonia nitrogen. In previous discussions with the DWQ NPDES unit concerning the
expansion of the T. Z. Osborne POTW and the closure of the North Buffalo POTW, the City of
Greensboro requested that the current monthly average ammonia nitrogen limits of 2.0 mg/I summer
and 4.0 mg/I winter be effective until the flow of the T. Z. Osborne POTW reached 40 MGD. The
current waste load allocation would not be exceeded until the POTW reaches a flow in excess of 40
MGD. The proposed ammonia nitrogen limits at 56 MGD result in a 42% reduction from the current
permit allowable load for ammonia nitrogen.
Calculations
Allowable Load
Current Permit
2.0 mg/I * 8.34 * 40 MGD
667.2 pounds/day
Draft Permit
0.82 mg/I * 8.34 * 56 MGD
382.97 pounds/day
The ammonia nitrogen limits in the draft permit are the same values included in the speculative limits
correspondence of December 20, 2010. The speculative limits letter included the following statement
concerning the ammonia limits: "Oxygen Demanding Waste. In order to protect for instream dissolved
oxygen, the BOD ultimate loading was frozen by lowering the ammonia limits to 0.82 mg/I NH3-N
(summer) and 1.64 mg/I (winter). The CBOD5 remains the same at 4.0 mg/I (summer) and 8.0 mg/I
(winter)." It is our understanding that these values were obtained from a draft EPA Water Quality
Criteria document for ammonia that has not yet been finalized/approved by EPA. We request that
language be added to the permit on page A.(2.) to allow the current ammonia -nitrogen limits to be
effective up to a flow of 40 MGD.
7. Daily Monitoring for CBOD5, TSS, NH3-N and Fecal Coliform
Page A.(2.) includes daily monitoring for CBOD5, TSS NH3-N and Fecal Coliform. We request that the
monitoring frequency be modified to reflect the reduced monitoring allowed on Page A. (1.).

Letter to DWQ-Ms. Julie Grzyb re: T. Z. Osborne Draft NPDES Permit NC0047384 Page 3
We look forward to discussing the items presented in this letter in further detail. Please contact me if
you have questions or need additional information.
Sincerely,
.Martie Groome
Martie Groome
Laboratory and Industrial Waste Section Supervisor
cc: Steve Drew, Water Resources Department Director (via email)
Kenney McDowell, Water Resources Department Deputy Director (via email)
Don Howard, Water Reclamation Manager (via email)
Lori W. Cooper, ORC-T. Z. Osborne POTW (via email)
Ed Osborne, ORC-North Buffalo POTW (via email)
Alicia Goots, Laboratory Coordinator (via email)

NPDES/Aquifer Protection Permitting Unit Pretreatment information Request Form
PERMIT WRITER COMPLETES THIS PART:
PERMIT WRITERS- AFTER vou get this form back
Check that
from PERCS:
.
all apply
- Notify PERCS if LTMP/STMP data we said should be
Date of Request
12/8/2011.
municipal renewal
v
on DMRs is not really there, so we can get it for you
Requestor
Julie Grzyb
new industries
(or NOV POTW).
Facility Name
T.Z. Osborne
WWTP expansion
- Notify PERCS if you want us to keep a specific POC
Permit Number
NC0047384
Speculative limits
in LTMP/STMP so you will have data for next permit
ReRegion
g
WSRO
stream reclass.
renewal.
-Email PERCS draft permit, fact sheet, RPA.
Basin
Cape Fear
outfall relocation
- Send PERCS paper copy of permit (w/o NPDES
7Q10 change
boilerplate), cover letter, final fact sheet. Email RPA if
other
changes.
other
check
applicable PERCS staff:
Other Comments to PERCS: •
v
BRD, CPF, CTB, FRB, TAR - Sarah Morrison (807-6310)
CHO, HIW, LUM, LTN, NES, NEW, ROA, YAD - Monti
Hassan (807-6314)
29 SIU's listed In permit application:
9 non -categorical and 20 CIU s •
•
PERCS PRETREATMENT STAFF COMPLETES THIS PART:
Status of Pretreatment Program (check all that apply) •
1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE '
2) facility has no SIU's, does not have Division approved Pretreatment Program
X
3) facility has Sills and DWQ approved Pretreatment Program (list "DEV" if program still under development)
X
3a) Full Program with LTMP
3b) Modified Program with STMP .
4) additional conditions regarding Pretreatment attached or listed below
, Flow, MGD
Permitted
Actual
Time period for Actual
STMP time frame:
Industrial
3.893
2.8817
May 2005-June 2007
Most recent:
Uncontrollable
n/a
17.62
May 2005-June 2007
Next Cycle:
a
s F
e
c '
a
Parameter'of
Concern (POC)
• Check List
POC due to
NPDES! Non-
Disch Permit
Limit
Required by
EPA*
Required
q
by 503 ,,
Sludge
POC due
to SlU***
POTW POC
(Explain
below) ,„„}
STMP
Effluent
Freq
LTMP•
Effluent
Freq
'
X
BOD
X
X
4
Q
X
TSS
' X
X
4
Q
Q = Quarterly
X
NH3
X
4
Q
M = Monthly
X
Arsenic
X
X
4
Q
,f
Cadmium
X
,f
X
X
4
' Q
4
Chrom'iurri •
4
X
X
4
Q
,f
Copper
,f
X
4
Q
X
Cyanide
X
X
'
4
Q
Is all data on DMRs?
,f
Lead.'
,f
X
4
Q
YES
X
Mercury
X
X
X
4
Q
NO (attach data)
X*
Molybdenum
•
4
Q M
.
,f
Nickel .•
X.
,f
X
X
4
Q
X
Silver
X
4
Q
X
Selenium
.
4
Q
,f
Zinc
4
X
4
Q
Is data in spreadsheet?
T
Total Nitrogen
4
Q
YES (email to writer)
X
Phosphorus
X
•
X
'4
Q
NO
X
X
Beryllium
X
4
Q
•
Fluoride
X
4
Q M
4
Q M
•
4
QM
"Always in the LTMP/STMP ** Only in LTMP/STMP if sludge land app or composte (dif POCs for incinerators)
*** Only in LTMP/STMP while SIU still discharges to POTW • **** Only in LTMP/STMP when pollutant is still of concern to POTW
Comme nts to Permit Writer (ex.. explanation of any POCs; info vou have on IU related Investigations into NPDES problems): POTW
1
incinerates sludge (POCs are different than land application or composting). POTW also includes in the LTMP sampling for the following:
acetone and ethyl acetate (once/year influent/effluent),;antimony, cobalt, tin, titanium, vanadium, Bis (2-ethylhexyl) phthalate, carbazole, n-
Decane, fluoranthene, n-Octadecane, o-Cresol, p-Cresol and 2,4,6-Trichlorophenol (1/qtr influent/effluent). '
X*: Selenium is not listed on the DMRs as noted in the LIMP at a quarterly frequency. This POC is not required by EPA and since the r
POTW does not land apply their sludge, it is not required by Part 503.
Copy of T Z Osbome PERCS NPDES request June 30 2011.xlsx
Revised: July 24, 2007

1,V1G LiCal l IN Will UCH -Willa 3U31,u) L1JIL-l.dLe my 0
:ape':Fear River Basin
AU Number- • Name
10 digit Watershed `,030300020:1
De'scription...
Length or- Area
Reedy Fork
Units CILssification Categoric
Category Rating
Use
Reason for Rating
Parameter
Year
16-11-14-2b
South Buffalo Creek
From McConnell Rd to US 70
4.7
FW Miles
WS-V;NSW 5
5 Impaired Aquatic Life Poor Bioclassification Ecological/biological Integrity FishCom 1998
16-11-14-2c
•South Buffalo Creek
From US 70 to Buffalo Creek
4.8
FW Miles
WS-V;NSW 5
Impaired Aquatic Life
Impaired Aquatic Life
Standard Violation Copper
Standard Violation Zinc
2008
2008
ape Fear River Basin
10-digit Watershed
22dI 4A •
0303000.202
.Headwaters Haw River
enalareek-HawiRiver
16-(1)cl
HAW RIVER
From SR 2426 to Troublesome Creek at US29
7.3 FW Miles WS-V;NSW 5
Impaired
Aquatic Life
Standard Violation
Copper
2008
1.N4;River::..
16-(1)c2
HAW RIVER
From Troublesome Creek at U529 to NC87
13.9
FW Miles
WS-V;NSW
5 Impaired Aquatic Life
Standard Violation Turbidity
2012
5
• 16-6-(3)
Troublesome Creek
From dam at Lake Reidsville to Haw River
1.8 .
FW Miles
WS-V;NSW
5 Impaired
Aquatic Life
Standard Violation
Low Dissolved Oxygen
2010
5
••••
pWa�'er�ft�ci
w�l.jK}f-y
r•- * '.'„ °3oiaq m to
16-7a
Little Troublesome
Creek
From source to Reidsville WW T P
3.5
FW Miles
WS-V;NSW
5 Impaired
Aquatic Life
Fair Bioclassification Ecological/biological Integrity Benthos
2000
5
Yt
el.
-4. rt�l�r trl:I
" Eon i=.Haw River
16-(1)a
HAW RIVER
From source to SR 2109
7.8
FW Miles
WS-V;NSW
5 Impaired Aquatic Life
Fair Bioclassification Ecological/biological Integrity Benthos
2000
Friday, February 10, 2012
Draft NC 303(d) List- Comments due March 12, 2012
Page 5 of 177

r
City of Greensboro
J North Carolina
Water Resources Department
February 20, 2013 CERTIFIED MAIL -RETURN RECEIPT 7003 1680 0001 0763 6846
Ms. Julie Grzyb
NC DENR NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
RE: T. Z. Osborne NC0047384 NPDES Permit Application for Renewal/Modification
Dear Julie,
Enclosed please find one (1) original and two (2) copies of the T. Z. Osborne NPDES Permit application
for renewal and modification of NPDES permit #NC0047384. We request renewal of the current NPDES
permit at 40 MGD and an additional permit tier to address the expansion to 56 MGD.
As you and I have discussed previously, the City of Greensboro is under a strict time -line to receive an
Authorization to Construct (A to C) for the BNR process addition/expansion from 40 MGD to 56 MGD in
order to qualify for extension of the Jordan Lake Rules targets to CY2018.
The attached background document will provide additional information about the T. Z. Osborne POTW,
the future plans of the City of Greensboro Water Reclamation Division and the data compiled for this
NPDES permit application.
If you have questions or need additional information, please feel free to contact me.
Sincerely,
r
Martie Groome
Laboratory and Industrial Waste Section Supervisor
336-433-7229 [e-mail]
cc: Steve Drew, Water Resources Director (with attachments via email)
Kenney McDowell, Deputy Water Resources Director (with attachments via email)
Don Howard, Water Reclamation Manager (with attachments via email)
Lori Cooper, ORC - T. Z. Osborne POTW (with attachments via email)
Water Resources Industrial Waste Section
ag@rgimE5
FEB 222613
CENTSOU
RCE } BRANCH

o A North Buffalo closure plan will be submitted to DWQ for review. It is estimated that we
will close the facility by the end of CY 2015.
• The CY 2012 flows for each POTW [19.78 MGD + 6.14 MGD = 25.92 MGD] indicate that the T. Z.
Osborne plant is capable of handling the combined flows until the construction is complete.
• The North Buffalo POTW currently has five (5) Significant Industrial Users with a total permitted flow
of 321,500 gallons per day: (1) Guilford Plating-2,000 gpd (2) Lorillard Inc.-300,000 gpd (3) Pugh
Metal Finishing-5,000 gpd (4) Greensboro Industrial Platers 01-5,000 gpd (5) Triad Anodizing-9,500
gpd. All five of the permits expire on April 30, 2013. Four of these permits will be renewed on May
1, 2013. Guilford Plating will not be renewed.
o Upon closure of the North Buffalo POTW, these four permits will be immediately modified
to reflect the change in the receiving POTW.
Data in Permit Application Submittal
• When calculating the averages reported on the permit application, zero was used for all below
detection limit (BDL) values. This conforms with the average calculations conducted for the DMRs
submitted to DWQ.
• The City of Greensboro voluntarily conducts the full 5-dilution series for all whole effluent toxicity
(WET) tests, rather than the one -dilution pass/fail test that is allowed by the current NPDES permit.
The T. Z. Osborne POTW is required to pass chronic WET tests using 90% effluent. However, data
from all 5 dilutions for each test has been submitted.
• Priority Pollutant Scans — No additional PPA scans have been conducted since the December 2010
permit application submittal. Data from the three PPA scans included in the previous application
has been transferred to this application. PPA scans for T. Z. Osborne will be conducted in 2013,
2014 and 2015 in conjunction with those required for the North Buffalo POTW.
• Second Species Whole Effluent Toxicity tests — No additional second species WET tests have been
conducted since the December 2010 permit application submittal. Data from the four previous
second species tests submitted with the last application is included as an attachment. Four second
species tests will be conducted in conjunction with the 3 PPA scans in 2013, 2014 and 2015.
• Both Greensboro POTWs experienced higher than normal influent and effluent zinc concentrations
starting in December 2011 and continuing through April 2012. Additional influent and effluent
analyses were conducted and an outside engineering firm was consulted, but no source of the zinc
was found. There is no industrial user that could impact both POTW influents, as the T. Z. Osborne
influent sampling site does not include the North Buffalo transfer line discharge. The "problem"
disappeared in April 2012. Please note this is why the zinc values in the permit application are high.
• CY 2011 data was used for Part F on the Significant Industrial User sheets, since the CY 2012 flow
data had not been submitted at the time the application information was being compiled.
Headworks Analysis (HWA)
• An internal draft HWA has been conducted adding the four North Buffalo SIUs to the current T. Z.
Osborne allocation table. No pollutant over -allocations were noted as a result of these additions.
Background Information-T. Z. Osborne NPDES Permit Application Submittal -February 19, 2013 page 3

T. Z. Osborne NC0042784 - NPDES Permit Application Background Information [February 2013]
T. Osborne Permit Background
• The City of Greensboro originally submitted applications for renewal of the T. Z. Osborne NPDES
permit and the North Buffalo NPDES permit on December 31, 2010.
• The T. Z. Osborne NPDES permit expired on June 30, 2011.
• A T. Z. Osborne draft permit was provided to the City of Greensboro by DWQ on August 1, 2012.
• A discussion with DWQ NPDES staff resulted in this submittal of a combined NPDES application for
permit renewal/permit modification for expansion.
T. Z. Osborne Speculative Limits, Environmental Assessment, Engineering Alternatives Analysis and FONSI
• The City of Greensboro requested speculative limits for the T. Z. Osborne expansion to 56 MGD on
November 16, 2010. A response letter from DWQ was postmarked December 28, 2010 and received
January 3, 2011. We concur with all of the speculative limits with the exception of the limits for
ammonia -nitrogen which were based on EPA water quality criteria which currently has not been
adopted by EPA.
o The DWQ Speculative Limits letter included: "Since your proposed facility is subject to SEPA
(State Environmental Policy Act), the FAA (Engineering Alternatives Analysis) requirements
discussed above will need to be folded into the SEPA document. The SEPA process will be
delayed if all EAA requirements are not adequately addressed."
• An Environmental Assessment/Engineering Alternatives Analysis was prepared by Hazen and Sawyer
Engineers and submitted to DWQ in February 2012. A draft copy of the EA/EAA was hand delivered
to Jeff Poupart of the NPDES Unit at the same time the draft was provided to the DWQ EA review
staff.
• A Finding of No Significant Impact (FONSI) was issued for the project on October 9, 2012. An email
confirmation of this decision was provided to Julie Grzyb and Tom Belnick on October 30, 2012.
Closing of North Buffalo POTW NC0024325
• The Jordan Lake Rules will require the City of Greensboro to install Biological Nutrient Removal
(BNR) treatment processes for the reduction of Total Nitrogen. After an extensive design
alternatives study by our consulting engineers, the City of Greensboro made the decision to close
the 16 MGD North Buffalo POTW, expand the T. Z. Osborne POTW from 40 to 56 MGD and build all
BNR treatment processes at the T. Z. Osborne POTW. Many factors went into the decision but
certainly the fact that parts of the North Buffalo POTW were built in 1938 was one of the main
considerations.
o All solids handling (dewatering and incineration) operations are already conducted at the T.
Z. Osborne POTW, with the North Buffalo waste activated sludge being transported via
underground pipeline to T. Z. Osborne.
o An existing wastewater pump station and wastewater transfer line from North Buffalo to T.
Z. Osborne is utilized daily to transfer flow to provide more efficient treatment of the City of
Greensboro's wastewater.
• The Water Reclamation Division plans to close the North Buffalo POTW prior to completion of the T.
Z. Osborne project in 2017 (BNR upgrade/expansion to 56 MGD). Thus, at no time will the City of
Greensboro have a permitted capacity in excess of the current permitted capacity of 56 MGD.
Background Information-T. Z. Osborne NPDES Permit Application Submittal -February 19, 2013 page 2

T.Z. Osborne WWTP Process Flow Description
The T.Z. Osborne Wastewater Treatment Plant (WWTP) is being expanded from 40 million
gallons per day (mgd) to 56 mgd. Flow from the City's 16 mgd North Buffalo Creek WWTP will
be routed to the T.Z. Osborne WWTP for treatment and effluent discharge. The North Buffalo
Creek VVWTP will be decommissioned. The T.Z. Osborne VW TP will provide advanced
biological nutrient removal (BNR) to meet annual nutrient mass loadings for discharge to South
Buffalo Creek per the Jordan Lake Nutrient Management Strategy Rules. The existing unit
processes at the T.Z. Osborne WWTP include fine screening, influent pumping, grit removal,
pre -aeration, flow equalization, primary clarification, activated sludge treatment, secondary
clarification, tertiary filtration, chemical phosphorus removal, chlorination and dechlorination,
scum handling, and solids handling.
Due to the magnitude of this project, this expansion and upgrade project will be broken into
three bid packages. Bid packagel will include the decommissioning of the North Buffalo Creek
WWTP and flow equalization improvements at the T.Z. Osbome WWTP. Bid package 2 will
consist of the aeration system improvements, the BNR basin expansion, mixing improvements,
secondary clarifiers, recycle activated sludge (RAS) pumping, waste activated sludge (WAS)
pumping, nitrified recycle (NRCY), instrumentation, and electrical improvements. Bid package 3
will include tertiary filtration improvements, chlorine disinfection, outfall expansion, and scum
system upgrade.
The attached figure provides an illustration of the process flow diagram and includes a water
balance through the plant. The following is a narrative describing each treatment process
including the proposed modifications of the upgrade and expansion project.
Influent Pumping and Preliminary Treatment
Wastewater is conveyed to the T.Z. Osbome WWTP by a 72-inch interceptor that follows South
Buffalo Creek to the plant. Influent flow is screened through one of four mechanically -cleaned
bar screens and pumped to the grit and pre -aeration facility. The influent pump station consists
of four 25-mgd vertical centrifugal non -clog pumps that operate on variable frequency drives.
Influent flow pumped from the North Buffalo Transfer Pump Station is introduced in the influent
boxes upstream of the grit and pre -aeration facility. Inside the grit and pre -aeration building,
wastewater flows through 24-foot diameter vortex grit chambers before being aerated in the
pre -aeration basin. Flow is subsequently distributed to six primary clarifiers through a set of
fixed weirs and four 42-inch primary influent pipes.
As part of the expansion and upgrade project, the grit influent chamber will be pressurized to
handle influent peak flow from the North Buffalo Creek VWVfP. Additionally, a new flow
equalization diversion structure will be constructed downstream of the pre -aeration tank. Flow
may either be diverted to one of the two equalization basins or bypass the primary clarifiers via
a 60-inch bypass pipe, which will carry flow straight to the aeration basin influent distribution
channel. One new 4.5 million gallon (mg) flow equalization basin will be constructed in addition
to the existing 3.5 mg equalization basin for a combined storage volume of 8 mg. Flow can also
T. Z. Osbome NC0047384 NPDES Permit Application Submittal February 2013 page 1

be diverted to the equalization basins downstream of the primary clarifiers in the primary effluent
junction box.
Primary Treatment
The T.Z. Osborne WWTP has six primary clarifiers. Four clarifiers are rectangular (Primary
Clarifiers 1 through 4) and two clarifiers are circular (Primary Clarifiers 5 and 6). The primary
clarifiers remove suspended solids and floatable materials from the wastewater. In rectangular
Primary Clarifiers 1 through 4, flow is distributed through a number of rectangular submerged
ports. Primary effluent is conveyed to the primary junction box via a 66-inch effluent pipe.
Primary Clarifiers 5 and 6 are circular settling tanks. Primary effluent from clarifiers 5 and 6
flows over the clarifier weir into the launder and out through a 42-inch primary settled effluent
pipe. Primary clarifier effluent is conveyed to the primary effluent junction box, where flow from
all of the primary clarifiers is combined and conveyed to the aeration basins via a box culvert.
Primary effluent flow may also be diverted to the flow equalization basins. The proposed 60-inch
primary clarifier bypass pipe allows for flow to bypass the primary clarifiers to eliminate hydraulic
bottlenecks during wet weather events.
Secondary Treatment
The secondary treatment facilities at the T. Z. Osborne WWTP include the following: aeration
basins, nitrified recycle (NRCY) pumping, secondary clarifiers, return activated sludge (RAS)
pumping, waste activated sludge (WAS) pumping, aeration equipment for providing oxygen to
the biological process, mixing equipment, and chemical phosphorus removal facilities.
Aeration Basins
Primary effluent combines with RAS in the aeration basin influent channel where it is distributed
to the online aeration basins via fixed weirs. The aeration basin influent channel is equipped
with vertical turbine mixers to keep the activated sludge in suspension as it mixes with RAS.
The T.Z. Osbome facility will include 16 aeration basins, twelve of which are existing and four of
which are proposed for the expansion project.
The aeration basins will be configured such that the first three pre -anoxic cells in each aeration
tank may be operated in aerobic or anaerobic/anoxic mode. When the first three cells are
unaerated, they provide biological phosphorus removal, as well as a degree of denitrification
prior to entering the aerobic cells. The following four cells in each aeration basin are operated
aerobically and are equipped with fine bubble diffuser equipment. The aerobic cells provide for
the oxidation of organic matter and ammonia. The following two cells are post -anoxic cells that
may be operated either as aerobic or anoxic basins. These cells will be equipped with fine
bubble diffusers and vertical turbine mixers. The final cell in each BNR basin is the re -aeration
cell, also equipped with fine bubble diffusers. Activated sludge flow in each aeration basin
passes through a series of low-headloss baffle walls in the aerated portion of the basins prior to
flowing over the effluent weirs that lead to the secondary clarifier distribution channel.
T. Z. Osbome NC0047384 NPDES Permit Application Submittal February 2013 page 2

Aeration System
The T.Z. Osborne process aeration system consists of jet aeration in the pre -anoxic cells, fine
bubble diffusers in the aerated and post -anoxic cells, and course bubble diffused aeration in the
secondary clarifier distribution channel. The aeration system is designed to keep solids in
suspension and provide a uniform dissolved oxygen concentration throughout the tank. Four
multi -stage, centrifugal blowers provide air to the biological process. Two of the existing multi-
stage centrifugal blowers will be replaced with single -stage integrally geared centrifugal blowers.
The two new blowers will have a capacity of 21,650 icfm each to provide a total installed blower
capacity of 88,500 icfm.
Mixing
Mechanical mixing is required in the pre -anoxic and post -anoxic zones. Vertical turbine mixing
equipment will be installed in post -anoxic cells of each aeration basin. Jet mix and aeration
equipment will be installed in the first three (pre -anoxic) cells of the new aeration basins to
match the configuration of the existing basins.
Nitrified Recycle
Nitrified recycle (NRCY) pumping and piping will be installed in each basin to transfer nitrate -
rich mixed liquor from the end of the aerobic zone to the pre -anoxic zone to provide for
biological nitrogen removal. NRCY will be conveyed using high-flow/low-head submersible
propeller (window) pumps, each capable of providing 11.25 mgd of flow. Two pumps will be
installed in each basin for Basins 1 through 4 and one pump will be installed in each basin for
Basins 5 through 16.
Secondary Clarification
The T.Z. Osborne WWTP currently operates seven circular secondary clarifiers, each with a
diameter of 130 feet. Three new 160-foot diameter clarifiers (Clarifiers 8 through 10) will be
added to the plant's secondary clarification process. Activated sludge flow from Aeration Basins
1 through 4 is conveyed to the secondary clarifier distribution channel via 42- and 54-inch pipe.
Flow from Aeration Basins 5 through 16 is conveyed directly to the secondary clarifier
distribution channel. A system of sluice gates and weirs provides flow distribution to all ten
secondary clarifiers.
RAS and WAS Pumping
Solids in the mixed liquor settle to the bottom of the secondary clarifiers and are returned by the
RAS pumps to the aeration basin influent channel. The T.Z. Osborne WVVfP currently has
nine RAS pumps. Four more RAS pumps will be added as part of this project. Four pumps are
dedicated to Secondary Clarifiers 1 through 4 in RAS Pump Station 1, three pumps are
dedicated to Secondary Clarifiers 5 and 6 (in RAS Pump Station 2), three RAS pumps serve
Secondary Clarifiers 7 and 8 (in RAS Pump Station 3), and proposed RAS Pump Station 4 will
house three RAS pumps to serve Secondary Clarifiers 9 and 10.
T. Z. Osborne NC0047384 NPDES Permit Application Submittal February 2013 page 3

There will be a total of five WAS pumps located on site. Two WAS pumps are located in RAS
Pump Station 1 and two are in RAS Pump Station 2. The existing drain pump in RAS Pump
Station 2 will be replaced with an additional WAS pump to increase the total WAS pumping
capacity at the WWTP.
Chemical Phosphorus Removal Storage and Feed Facilities
Polyaluminum chloride (PAC) will be fed to the solids handling and filtration processes for
phosphorus chemical removal. PAC will be stored in two 12,500-gallon FRP storage tanks
located under a canopy in a containment area adjacent to Primary Clarifier 1 through 4. Five
mechanical diaphragm metering pumps will feed PAC to three possible locations: 1) the
secondary clarifier distribution boxes located downstream of the aeration basin effluent
distribution channel, 2) filter influent, and the solids handling overflow, and 3) centrate side
streams.
Tertiary Filtration
The T.Z. Osborne WVVfP currently uses traveling bridge filters for tertiary filtration. These filters
will be retrofitted to the diamond cloth type filter in the expansion project to increase the filtration
surface area and capacity of the existing traveling bridge structure. Secondary effluent is equally
distributed to six filter cells containing eight diamond cloth type filter conduits per filter cell. The
filters will be backwashed using a bridge mechanism that travels over the conduits and pumps
filtered water through the cloth fabric to remove the trapped particles. Backwash waste is
collected in the backwash collection channel and is pumped to the RAS discharge line where it
is diverted to the aeration basin influent channel for treatment. Peak flows may bypass the filters
via the filter bypass channel and weirs. The filtered effluent and the filter bypass combine in the
effluent junction box and routed to the chlorine contact tanks.
Disinfection, Post Aeration, and Chemical Storage
Filtered effluent flows through the chlorination/dechlorination and post aeration facilities prior to
being discharged. The WWTP will have six chlorine contact tanks housed in three buildings
with a combined volume of 1.56 mg. Sodium hypochlorite is dosed to the filter effluent prior to
gravity flow to the chlorine contact tanks. Chlorinated effluent is dechlorinated with sodium
bisulfite downstream of the cascade aerators.
Two fiberglass reinforced plastic sodium hypochlorite storage tanks have a combined storage
volume of approximately 20,000 gallons. Two sodium bisulfite storage tanks have a combined
volume of approximately 8,000 gallons.
Scum Handling
Scum from the primary and secondary clarifiers will be pumped to a flotation thickener for scum
treatment. Thickened scum will be subsequently pumped to the existing (refurbished) scum
concentrators for additional thickening prior to being pumped to the incinerator for disposal.
T. Z. Osbome NC0047384 NPDES Permit Application Submittal February 2013 page 4

Solids Handling
The solids handling process at the T.Z. Osborne VVWTP includes thickening, dewatering, and
incineration. Sludge from the primary clarifiers and WAS from RAS Pump Station 1 is pumped
to the sludge receiving and blending tanks. Three sludge transfer pumps convey blended sludge
to one of four gravity thickeners. Waste activated sludge from RAS Pump Station 2 is pumped
directly to the gravity thickeners. Following the thickening process, sludge is pumped to the
holding tanks, where it mixes with conditioning polymer for dewatering. Sludge is subsequently
dewatered with centrifuges and incinerated for ultimate disposal. Centrate from the dewatering
process is routed to the influent pump station for treatment.
T. Z. Osbome NC0047384 NPDES Permit Application Submittal February 2013 page 5

Legend:
EQ = Equalization Basin
FBW = Filter Backwash
FBWR = Filter Backwash Return
ML = Mixed Liquor
RAS = Return Activated Sludge
SCE = Secondary Clarifier Effluent
TWAS = Thickened Waste Activated Sludge
WAS = Waste Activated Sludge
Q=40mgd.l //////////
— * Fine Bar Screens
Q=56mgu / / / / / / / / / /
Centrifuge
lL
Incinerator
Feed Pumps
32167-001 Figure.cdr
South
Buffalo
J c: Creels
�+ C
f—
Orange Text = Flows at 40 mgd Plant Design Capacity
Purple Text = Flows at 56 mgd Plant Design Capacity
Influent
Pump Station
54"
54" Outfall
Splitter Box
54"
Sodium
Bisulfite
Polymer
Flow From
North Buffalo
Creek WRF
Grit
Removal
Grit
FBWR
1=4.[ mga
Q=1.7 mgci
Sodium
Hypochlorite
Chlorine Disinfection
& Cascade Aeration
Centrifuge Feed TWAS Pumps
Pumps Thickened Sludge
Holding Tanks
Fluid Bed
Incinerator
54,,
Filter Bypass
4
Tertiary
Filtration
FBW
=1.0 mgd
—'=1.7 mgd
Gravity
Sludge
Thickeners
Q=0.005 mga
0=0.005 mgd
Primary Sludge
Pumps
EQ
Pre -Aeration
Tank
Scum
Primary
Clarification
Primary
42" Effluent
Junction
Box
RAS
st
Q=80 mgd
5-Stage Q=120 mgd
BNR Basin
NRCY
0=224 mgd
Q=40 mgd
Q=56 mgd
Alum
60"!42"!48"SCE
RAS Pump Station
WAS Pump Station
42" ! 48"ML
Scum
Secondary
Clarification
4--
_ Q=40
0=56 myci
.:1=1.2 mgd
Q=1.6 mgd
Q=40 mgd
Q=56 mgd
I►
VVWTP Process Flow Diagram
Includes Phase 1, 2, and 3 Modifications
City of Greensboro, NC
T.Z. Osborne WWTP
NC0047384
Form 2A

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES— PART F ATTACHMENT 1
SIGNIFICANT INDUSTRIAL USER INFORMATION:
the treatment works, copy questions F.3 through F.8 and
Supply the following information for each SIU. If more than one SIU discharges to
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Aramark Uniform Service
Name:
509 Teague Street
Mailing Address:
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Washers
Industrial
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Industrial laundry
Principal product(s): Cleaning of
Bleach (sodium hvoochloritel, Inhibitor, Turbo Charge (alkalil, Turbo fluff, Floor cleaner, Turbolizer (sourl, turbo flex,
Raw material(s):
fresh
turbo crisp, turbo
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons
per day (gpd) and whether the discharge is continuous or intermittent.
90,700 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits © Yes ❑ No
b. Categorical pretreatment standards 0 Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.S. Problems at the Treatment Works Attributed to Waste Discharge by the
upsets, interference) at the treatment works in the past three years?
0 Yes ® No If yes, describe each episode.
SIU. Has the SIU caused or contributed to any problems (e.g.,

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F. INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES — PART F ATTACHMENT 2
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F,8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Ashland, Inc
Mailing Address: 2401 Doyle Street
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Manufacture of aqueous flocculent and dispersant polymers
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Aqueous flocculent and dispersant polymers
Raw material(s): Miscellaneous poly acryliclacrylamidel,amine terpolymer, alipathic solvents; surfactants, glycol; aliphatic hydrocarbon;
naphthalenic solvents, volatiles sodium hydroxide; miscellaneous non -hazardous organic fatty acids, natural oils, alcohols various monomers,
zinc and DEHP
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons
per day (gpd) and whether the discharge is continuous or intermittent.
30 600 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (_ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards 0 Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
Cl Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 3
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following Information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Chemol Company, Inc.
Mailing Address: 2300 Randolph Avenue
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Refining, bleaching, transesterification and hydrogenation of fats and oils (triglycerides)
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Fatty acids, and esters
Raw material(s): Trisodium phosphate, sulfated tallow, soda ash salt. polyethylene glycol, jojoba oil, propylene glycol, d-limoene,
dibutly tin dilaurate, citric acid, carbon. Flavoring, aliphatic ethoxylates, acrvlates tridecyl alcohol, sulfuric acid. paraffin, silica compounds, fatty
ethoxylates, n-propanol, fatty acids, methyl esters, nickel catalyst, lecithnin, isopropanol, glycerine, ethylenediamine, ethylene vinyl acetate,
ethylene glycol, ethanolamine, defoamer, decvl alcohol, caustic soda, butyl carbitol, bleaching clay, alpha olefin, alkylphenol ethoxylates, 2-
ethylhexanol, 12-hvdroxvstearic acid, isobutanol
F.6. Flow Rate. CY 2011
c. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons
per day (gpd) and whether the discharge is continuous or intermittent.
38,750 gpd ( continuous or X intermittent)
d. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
continuous or intermittent)
gpd
(
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Organic Chemicals, Plastic and Synthetic Fibers 40 CFR Part 414 Subpart H-414.85 (discharge Limits in 414.111)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑Yes g No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 4
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Mailing Address:
Cone Mills — White Oak Plant
2420 Fairview Street
Greensboro, NC 27405
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Dying, slashing, finishing, and sanforizing of denim fabric that is woven at the facility
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Denim cloth
Raw material(s): cotton, sulfur dyes, various other colored dyes (list maintained by POTW). indigo paste, starch. softner, NaOH, acetic
acid, H2SO4. Sodium Sulfide, urea, phosphoric acid defoamer
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
342 200 gpd (_ _ continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or — intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards 0 Yes XENo
If subject to categorical pretreatment standards, which category and subcategory?
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 5
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Mailing Address:
F.4. Industrial Processes.
Dyeing and finishing
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s):
Raw material(s):
softeners
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
228,800 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
intermittent)
Elastic Fabrics of America
3112 Pleasant Garden Road
Greensboro, NC 27406
Describe all the industrial processes that affect or contribute to the SIU's discharge.
Knitted nylonllycra and cottonllycra
dyes, salts, melamine formaldehyde resins, polvacrylic acid polymers, silicone and petroleum based
gpd ( continuous or
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards 0 Yes X❑ No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 6
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Express Container Services
Mailing Address: 208 Chimney Rock Road
Greensboro. NC 27409
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Hot water wash and steam cleaninq of tankers and totes (chemical and food grade)
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Interior tanker and tote cleaning operation
Raw material(s): Caustic, detergent ferric chloride, lime and polymer
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
20,250 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards XQ Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Transportation and Equipment Cleaning l40 CFR Part 442 Subpart A (442.16) and Subpart D (442.40 no PSNS standards)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 7
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F,8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Giibarco, Inc
Mailing Address: 7300 West Friendly Avenue
Greensboro, NC 27420
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Zinc Phosphate Treatment (coating/phosphatinq), Counter Flow Rinse, Electroclean Priming Operation, Meter Washing Operation, Meter Impregnation
Line and Tumbling
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Gasoline metering and dispensing equipment
Raw material(s): Alkaline water -based cleaner/detergent and zinc phosphate,
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
10,520 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (_ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits XQ Yes El No
b. Categorical pretreatment standards XQ Yes 0 No
New Source Metal Finishing 40 CFR Part 433 Subpart A 433.17
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 8
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial
pages as necessary.
Name:
Mailing Address:
F.4. Industrial Processes.
User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
Greensboro Industrial Platers 02
123 Edwardia Drive
Greensboro, NC 27409
Describe all the industrial processes that affect or contribute to the SIU's discharge.
Zinc plating, zinc phosphatinq and passivatinq on stainless steel
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Job Shop Electroplater (no product produced)
Raw material(s): hydrochloric acid, alkaline cleaner, chromic acid, 20%muriatic acid. nitric acid. zinc bath zinc phosphate. black
phosphate solution, sealer and dyes
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
4 700 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits
b. Categorical pretreatment standards
® Yes
® Yes
❑ No
❑ No
intermittent)
If subject to categorical pretreatment standards, which category and subcategory?
Electroplating 40 CFR Part 413 Subparts A1413.14) and E (413.54) Job Shop Discharging Less than 10,000 qpd
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes Ox No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 9
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Machine Specialties
Mailing Address: 1034 Boulder Road
Greensboro. NC 27409
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Rinse, Alkaline cleaning, anodizing (sulfuric), anodizing (hard coat), anodizing (chromic) processes, acid processes, final rinse
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Contract machining and metal finishing of aluminum and stainless steel products
Raw material(s): 50% sodium hydroxide, nitric acid, sodium dichromate, sulfuric acid, chromic add crystal, Selfoc 2541. Hydrite MBS
7330 Selfloc 5102, Selfloc 6030, remover, developer, penetrant,various proprietary chemicals.
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
7,450 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (_ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
New Source Metal Finishing 40 CFR Part 433 Subpart A (433.17)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 10
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Parker Metal Finishing Companv, Inc.
Mailing Address: 719 West Lee Street
Greensboro, NC 27403
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Cleaning. muriatic acid bath, zinc bath, chromate bath
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal Job Shop — Electroplaters (zinc plating)
product(s):
Raw material(s): Zinc. chromate, muriatic acid, potassium chloride, CZ Brite (mild acid), finishers and alkaline
cleaners
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
5 050 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits © Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Electroplating 40 CFR Part 413 Subparts A (413. 14) and E (413.54} -Job Shop Discharging Less Than 10,000 gpd
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 11
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Piedmont Plating Corporation
Mailing Address: 3005 Halts Chapel Rd
Greensboro, NC 27401
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Parts cleaning, zinc and zinc alloy plating, nickel plating, chromatinq and top coating
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): No product made, plating of automotive parts owned by customers
Raw material(s): Zinc, zinc chloride, zinc hydroxide, alkaline cleaner, hydrochloric acid, boric acid, nitric acid, caustic, calcium chloride,
potassium chloride, carrier, brighteners, anti -foam, chromate. inhibitor, sealer, nickel, nickel chloride
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
224305 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. the
the average discharge is continuous for process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether
nt.
gpd (X continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes 0 No
New Source Metal Finishing (40 CFR Part 433 Subpart A (433.17)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 12
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Precision Fabrics Group, Inc.
Mailing Address: 301 East Meadowview Road
Greensboro, NC 27410
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Fabric staging, chemical staging and tenter frames
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Non -woven converted products and woven converted products
Raw material(s): Sizing, starch, softeners, surfactants, metal complex dve, flame retardant, fabric protector, water repellent, various
dyes, salts, chlorine, acetic acid, caustic isopropyl alcohol. Unidvne T-G 532, Phoplex AC, Spartan 590, Pentine SP -1
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
continuous or intermittent)
200.900 gpd (X
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 13
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Precor Strength
Mailing Address: 5407 Millstream Road
Whitsett NC 27377
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Powder coating and five stage wash system including phosphatina process
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Exercise equipment
Raw material(s): Petroleum based sealer, alkaline cleaner, iron phosphate, potassium hydroxide
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
4,385 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
New Source Metal Finishing 40 CFR Par1433 Subpart A (433.17)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F. INDUSTRIAL USER DISCHARGES AND RCRAJCERCLA WASTES - PART F ATTACHMENT 14
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: The Procter and Gamble Manufacturing Co. (Brown Summit)
Mailing Address:
6200 Bryan Park Road
Brown Summit NC 27214
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Mixing (packing lines) and compounding
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Personal Care Products - Toothpaste, denture adhesives and antiperspirants
Raw material(s): Silicone, perfumes, carrageenan, flavors, acetone, ethyl acetate, dyes, soda ash and silica dental type, propylene
glycol, propylene carbonate talc, alcohol, calcium hydroxide, castor oil, cellulose gum, dimethicone copolyol, carbowax polyethylene,
sucralose,citric acid, red pigment, peppermint oil latic acid,corn starch, potassium nitrate, potassium sorbate, sodium fluoride, sorbitol, stannous
chloride, monosodium phosphate, glycerine„sodium stearate; unithox, zags
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system In gallons per
day (gpd) and whether the discharge is continuous or intermittent.
289,200 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (_ _ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Pharmaceutical Manufacturing 40 CFR Part 439 Subpart D (439.46)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 15
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: TEVA (formerly Procter and Gamble Manufacturing Company -Swing Road).
Mailing Address: 100 Swing Road
Greensboro, NC 27419
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Mixing of cough syrups respiratory products , anti -diarrhea medicine and bismuth
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Over -the- counter respiratory products and bismuth
Raw material(s): Benzoic acid, bismuth, bismuth nitrate, bismuth subsalicylate, colors, flavors, methyl cellulose, methyl salicvlate, nitric
acid, salisvlic acid, sodium hydroxide, sodium saccharin, sodium salicylate, sorbic acid, urea, veequm N, acetaminophen, anethole, citric acid
ethyl butyrate, ethyl maltol. us oil, glycerine, quaifenesin,
yethylene
stearate, polysorbate, propylene lq ytcol, sodium benzoate, menthol
sodium carbonate crystals,r
sodium citrate, sacchari, phenol, n, n, carrageenane1 polyoxvl 40
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
49,700 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (—
continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards © Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Pharmaceutical Manufacturing 40 CFR Part 439 Subparts C (439.36) and D (439.46)
F.8. Problems
atthe e enTr at the trent eatment Attributeto
Was three Dischargeyearr?by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets,
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 16
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.B and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Qualicaps, Inc. — --- — --
6505 Franz Warner Parkway
Mailing Address:
Whitsett, NC 27377
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Pin Bar Cleaning, Pour Can Cleaning, Dve Prep, PK Tanks Cleaning,
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Gelatin Capsules, Unfilled
Raw material(s): Gelatin, various food grade dyes, chlorinated floor cleaner
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
75 700 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( _ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 17
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SILL If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
R F Micro Devices — Fab 1
Mailing Address: 7628 Thorndike Road
Greensboro, NC 27409
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Photolithography, Metallization, Etch and Deposition, Test and Backside Operations, RO reject, Air pollution scrubbers, product rinse baths, wet
grinding operations and non -contact cooling.
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Semi -conductor Wafers
Raw material(s): caustic solution, sulfuric acid, ammonium hydroxide, hydrochloric acid, nitric acid, gold salts, phosphoric acid, potassium
iodide solution, hydrofluoric acid, hydrogen peroxide
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
0 gpd (x intermittent)
continuous or
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Electrical and Electronic Components 40 CFR Part 469 Subpart A (469.18)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes QX No If yes, describe each episode.
NOTE: Facility will be closing operations subject to Federal Categorical Standards in CY 2013

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 18
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
R F Micro Devices — Fab 2
Mailing Address: 494 Gallimore Dairy Road
Greensboro, NC 27409
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Etching, Maintenance wet benches, RO)DI water plant, air emission scrubber exhaust, routine cleaning of MBE room
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Semiconductor Wafers and Electronic Crystals
Raw material(s): Caustic, arsenic, aluminum, sulfuric acid, hydrofluoric acid, sodium hypochlorite, photo resist/developers, ammonium
hydroxide, hydrogen peroxide, nitric acid
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
1 . 700 gpd (_ _ continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd (__
continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits X❑ Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Electrical and Electronic Components 40 CFR Part 469 Subpart A (469.18) and Subpart B (469.28)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 19
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial
pages as necessary.
Name:
Mailing Address:
User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
R F Micro Devices — Fab 3
7908 Piedmont Triad Parkway
Greensboro, NC 27409
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Photolithography, Metallization, Etch and Deposition, Test and Backside Operations, RO reject, Air pollution scrubbers, product rinse baths, wet
grinding operations and non -contact cooling.
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Raw material(s): caustic solution, sulfuric acid, ammonium hydroxide, hydrochloric acid, nitric acid, gold salts, phosphoric acid.
Principal product(s): Semiconductor Wafers
potassium iodide solution, hydrofluoric acid, hydrogen peroxide
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
140,900 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Electrical and Electronic Components 40 CFR Part 469 Subpart A (469.18L
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED:
City of Greensboro T.Z. Osborne, NC0047384 Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 20
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Royal Carolina Corporation
Mailing Address: 7305 Old Friendly Road
Greensboro NC 27410
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Printing and Finishing
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Printed non -woven, netting polyesters and cotton
Raw material(s): Water based pigments, water repels, flam retards antimicrobials and softeners
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
8.950 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes LI No
b. Categorical pretreatment standards ❑ Yes X❑ No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
Yes ® No If yes, describe each episode.
NOTE: Facility was removed from the Significant Industrial User Category in CY 2012 because process flow dropped below 25.000 gallons per day

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 21
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Signiflcant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Mailing Address:
F.4. Industrial Processes.
Shamrock Environmental Corporation (Brown Summit
6106 Corporate Par k Drive
Brown Summit, NC 27214
Describe all the industrial processes that affect or contribute to the Sills discharge.
Metal Bearing Waste, Oily Waste and Organic Wastewaters
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge
Raw material(s): 50% NAOH, alum, MR 2405 (metal scavenger), odor buster, polymer,
Principal product(s): Service Industry — Centralized Waste Treatment Facility Non-hazarrs Waste quack gel, diatomite, CO24, sulfuric
Treatment
acid, sodium metabisulfite, P-816E
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
65 950 gpd ( continuous or X intermittent)
b. Non process wastewater flow rate Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards XQ Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Centralized Waste Treatment 40 CFR Part 437 Subpart C (437.35) and Subpart D (Multiple Wastestreams A & B I437.46(c11)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
0 Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 22
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Mailing Address:
Shamrock Environmental 11 (Patton Avenue)
519 Patton Avenue
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Rinses. steam cleaning. hot water cleaning. caustic and detergent cleaning
F.5. Principal Product(s) and Raw Materlal(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Interior tanker and tote cleaning operation
Raw material(s): Detergent, sodium hydroxide, residual from tanker cleaning (acid or alkaline). aluminum brightener, degreaser. B1
(boiler treatment chemical, Marscour DTC KoolStrip T
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
16,850 gpd ( _ continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
intermittent)
gpd (_ _ continuous or
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits XQ Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No Standards are not numerical —PMP
If subject to categorical pretreatment standards, which category and subcategory?
Transportation and Equipment Cleaning 40 CFR Part 442 Subpart A (442.15)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 23
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name:
Evonik Stockhausen, Inc. (formerly Stockhausen, Inc.)
Mailing Address: 2401 Doyle Street
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Mixing vessel washes, scrubbers, utilities and storage tank pipe and connection cleaning,
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Absorbent polymers, water soluble acrylate terpolvmers, concrete polymers, small amount of leather auxiliary
processing products
Raw materal(s): Sodium bi-sulfate, caustic, sulfuric acid, praestol, various ail mixes, ammonia, various oil mix intermediates„ acrylic
acid, sodium hydroxide, monomers, mercaptoethanol, ethylene carbonate, methacrylic acid, surfactants, polymer, hydrogen peroxide
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
180,300 gpd (X continuous or _ intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd
continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits © Yes ❑ No
b. Categorical pretreatment standards 0 Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems
s at the
at the Treatment Works Attributed worbs e to
past three Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets,
0 Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 24
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Triad International Maintenance Corporation (TIMCO)
Mailing Address: 623 Radar Road
Greensboro, NC 27410
F.4. Industrial Processes. Describe all the Industrial processes that affect or contribute to the SIU's discharge.
Metal Finishing- coatingfphosphating (rinse water. phosphate washes)
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): FAA Certified Aircraft Repair Station
Raw material(s): Alkaline leaner and phosphoric acid
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
1,300 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( _ continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Nevi Source Metal Finishing 40 CFR Part 433 Subpart A (413.17)
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes X❑ No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRAICERCLA WASTES - PART F ATTACHMENT 25
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: United Metal Finishing
Mailing Address: 133 Blue Bell Road
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Cleaning, rinses, chromium plating, zinc plating, nickel plating. zinc phosphatinq, alodine, anodize, etching and stripping, acid dip and
brightening
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Metal Finisher (no product)
Raw material(s): chromatic acid. phosphate, nickel zinc chloride alodine, alkaline cleaner, muratic acid, clear, black, blue and yellow
chromate, sealer, sulfuric acid, nitric acid, boric acid, nickel chloride, nickel sulfate, potassium chloride, carrier, brighteners, caustic soda,
modifiers, strippers
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
6,150 gpd (X continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits X❑ Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
New Source Metal Finishing 40 CFR Part 433 Subpart A (433.17)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes C] No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES AND RCRA10ERCLA WASTES - PART F ATTACHMENT 26
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Unitex Chemical Corporation (now LANXESS)
Mailing Address: 520 Broome Road
Greensboro, NC 27406
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Esterification washes, miscellaneous products washes, sulfonamidation washes and facility wash down
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Plastic Additives primarily plasticizers and flame retardants
Raw material(s): Caustic soda, plasticizers, flame retardant, specialty chemicals ( extensive list of all chemicals on file with POTW)
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
26.800 gpd (_ continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Organic Chemicals, Plastics and Synthetic Fibers 40 CFR Part 414 Subpart H — 414.85 (Discharge limits in 414.111)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the pass three years?
❑ Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 27
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3.
F.4.
F.5.
F.6.
F.7.
F.8.
Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Vertellus Performance Materials
Mailing Address: 2110 High Point Road
Greensboro, NC 27403
Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Process Reactors used for Organic Chemical Manufacturing
Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Organic esters, intermediates and DEET
Principal product(s):
Acetic Acid Glacial, Ammonia Anhydrous, Benzoic Acid Various Alcohol, Butanol, Butyric Acid, Butyric Anhydride,
Raw material(s):
Caustic, Citric Acid, Hydrogen Peroxide, Sodium Hypochlorite, Sodium Chloride, Soda Ash, Potassium Hydroxide, Toluene,
Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
78.600 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection
system in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Plastic and Synthetic Fibers 40 CFR Part 414 Subpart H — 414.85 (Discharge Limits in 414.111)
Organic Chemicals,
Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
0 Yes © No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
SUPPLEMENTAL APPLICATION INFORMATION
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 28
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Wire Products, Inc.
Mailing Address: 1319 West Lee Street
Greensboro. NC 27403
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Coating and phosphatinq
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Wire display racks
Raw material(s): Alkaline cleaner phosphoric acid and sealer
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
1,250 gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
Existing Source Metal Finishing 40 CFR Part 433 Subpart A (433.15)
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.

FACILITY NAME AND PERMIT NUMBER:
City of Greensboro T.Z. Osborne, NC0047384
PERMIT ACTION REQUESTED:
Renewal/Modification
RIVER BASIN:
Cape Fear
SUPPLEMENTAL APPLICATION INFORMATION
PART F. INDUSTRIAL USER DISCHARGES AND RCRA/CERCLA WASTES - PART F ATTACHMENT 29
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SW.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional
pages as necessary.
Name: Zink Imaging
Mailing Address:
6900 Konica Drive
Whitsett, NC 27377
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Emulsion making, Coating Solution Preparation and Paper Coating
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Color thermal imaging media
Raw material(s): Dry gelatin powder: nitric acids, methyl cellulose, denatured ethanol, polyvinyl alcohol, sodium hydroxide, 0B1207,
latex, WC-71, zinc stearate, surfactants, silica dispersions, rheolate, glyoxal, glycerol, methyl acetate
F.6. Flow Rate. CY 2011
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
87,250 gpd (X continuous or — intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits © Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes © No If yes, describe each episode.

North Carolina
Department of Administration
Beverly Eaves Perdue, Governor Moses Carey, Jr., Secretary
October 9, 2012
Ms. Hannah Headrick
NCDENR
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: SCH File # 13-E-4300-0075; EA/FONSI; Proposed project is for the T.Z. Osborne
Wastewater Treatment Plant Expansion.
Dear Ms. Headrick:
The above referenced environmental impact information has been reviewed through the State
Clearinghouse under the provisions of the North Carolina Environmental Policy Act.
Attached to this letter are comments made in the review of this document. Because of the nature of the
comments, it has been determined that no further State Clearinghouse review action on your part is
needed for compliance with the North Carolina Environmental Policy Act. The attached comments
should be taken into consideration in.project development.
Sincerely,
Crystal Best
State Environmental Review Clearinghouse
Attachments
cc: Region G
Mailing Address: Telephone: [phone] Location Address:
1301 Mail Service Center fax [phone]I 116 West Jones Street
Raleigh, NC 27699-1301 State Courier #51-01-00 Raleigh, North Carolina
e-mail [e-mail]
An Equal Opportunity/Affirmative Action Employer

ODE R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Govemor Director Secretary
October 10, 2012
MEMORANDUM
TO: Mary Sadler
Hazen and Sawyer
FROM: Hannah Headrick, SEPA Coordinator
Basinwide Planning Unit and SEPA Program
SUBJECT: Guilford County
City of Greensboro — TZ Osborne WWTP Expansion
DWQ#14418, DENR#1566
On October 9, 2012, the State Clearinghouse deemed the North Carolina Environmental Policy Act review on
the above project complete (see attached correspondence from the Clearinghouse). It is now acceptable to
proceed with your permit applications through the Division of Water Quality for the proposed project. No
further actions on the Environmental Assessment are required.
Please contact me at 807-6434 or via email ([e-mail]) if you have any questions.
Thank you.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwateraualitv.orq
An Equal opportunity %Affirmative Action Employer
h7aturallyCar

¼ni
COUNTY: GUILFORD
NORT CAROLINA STATE CLEARINGHOUSE
• DEPARTMENT OP ADMINISTRATION
INTERGOVERNMENTAL REVIEW
H02:WASTEWATER TREATMENT
FACILITIES
MS CARRIE ATKINSON
CLEARINGHOUSE COORDINATOR
DEPT OF TRANSPORTATION
STATEWIDE PLANNING - MSC #1554
RALEIGH NC
REVIEW DISTRIBUTION
CC&PS - DIV OF EMERGENCY MANAGEMENT
DENR LEGISLATIVE AFFAIRS
DEPT OF CULTURAL RESOURCES
DEPT OF TRANSPORTATION
PIEDMONT TRIAD COG
PROJECT INFORMATION
APPLICANT: NCDENR
TYPE: State Environmental Policy Act
Environmental Assessment/Finding
Impact
DESC: Proposed project is for•the T.Z. Osborne Wastewater Treatment
The attached project has been submitted to the N. C
intergovernmental review. Please review and submit
indicated date to 1301 Mail Service Center, Raleigh
If additional review time is needed, please contact
1(44 0110‘e;
STATE NUMBER: 13-E-9300-(
DATE RECEIVED: 08/29/2012
AGENCY RESPONSE: 10/03/2012
REVIEW CLOSED: 10/08/2012
13-6- 11360 -0075
AS A RESULT OF ''IS REVIEW THE FOLLO I
SIGNED BY:
of No Significant
Plant Expansion.
. State Clearinghouse For
your response by the above
NC 27699-1301.
this office at [phone].
OMITTED:Ei] NO COMMENT
ACHEC

COUNTY: GUILFORD
NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
H02:WASTEWATER TREATMENT
FACILITIES
MS CAROLYN PENNY
CLEARINGHOUSE. COORDINATOR
CC&PS - DIV OF EMERGENCY MANAGEMENT
FLOODPLAIN MANAGEMENT PROGRAM •
MSC # 4719
RALEIGH NC
REVIEW DISTRIBUTION
CC&PS - DIV OF EMERGENCY MANAGEMENT
DENR LEGISLATIVE AFFAIRS
DEPT OF CULTURAL RESOURCES
DEPT OF TRANSPORTATION
PIEDMONT TRIAD COG
PROJECT INFORMATION
APPLICANT: NCDENR
TYPE: State Environmental Policy Act
Environmental Assessment/Finding of No Significant Impact
DESC: Proposed project is for the T.Z. Osborne Wastewater Treatment Plant Expansion.
;.l: fti •k.A � jyd•f�
STATE NUMBER: 13-E-4300-0075
DATE RECEIVED: 08/29/2012
AGENCY RESPONSE: 10/03/2012
REVIEW CLOSED: 10/08/2012
•N• ' _
!•• • ire,M l.'S
The attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at [phone].
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED: ii1NO COMMENT[I] COMMENTS ATTACHED
SIGNED BY: n 1:3itit DATE: 1
-"Pe)o4T / .C.4`"r1.:. N,
;N. 4e_ 1 .

COUNTY: GUILFORD
NTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION.
INTERGOVERNMENTAL REVIEW
c
a7 2012, t
MS RENEE GLEDHILL-EARLEY
CLEARINGHOUSE COORDINATOR 4'` PW4',Mi
DEPT OF CULTURAL RESOURCES
STATE HISTORIC PRESERVATION OFFICE
MSC 4617 - ARCHIVES BUILDING
RALEIGH NC
REVIEW DISTRIBUTION
H02 : WASTEWATER TREATME,,,,,,.••,,,,= t .4..w 1 STATE NUMBER: 13-E-4300-0075
DATE RECEIVED: 08/29/2012
AGENCY RESPONSE: 10/03/2012
REVIEW CLOSED: 10/08/2012
FACILI '„ Zs ;{1
CiAlwaz
cgs'
CC&PS - DIV OF EMERGENCY MANAGEMENT
DENR LEGISLATIVE AFFAIRS
DEPT OF CULTURAL RESOURCES
DEPT OE' TRANSPORTATION
PIEDMONT TRIAD COG
PROJECT INFORMATION
APPLICANT: NCDENR
TYPE: State Environmental Policy Act
Environmental Assessment/Finding of No Significant Impact
DESC: Proposed project is for the T.Z. Osborne Wastewater Treatment Plant Expansion.
The attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at [phone].
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED:
SIGNED BY:
i,
•\11:13 IMA45 ,'-N,
A j'*. f
N, SEP 212 .cp_.:
E MEWED P
!.:,. 'WO J
DOA
NO COMMENT 0 COMMENTS ATTACHED
DATE: ek if/1402.,

COUNTY: GUILFORD
NORTH'CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
H02:WASTEWATER TREATMENT
FACILITIES
MS MELBA MCGEE
CLEARINGHOUSE COORDINATOR
DENR LEGISLATIVE AFFAIRS
GREEN SQUARE BUILDING - MSC # 1601
RALEIGH NC
REVIEW DISTRIBUTION
STATE NUMBER: 13-E-4300-0075
DATE RECEIVED: 08/29/2012
AGENCY RESPONSE: 10/03/2012
REVIEW CLOSED: 10/08/2012
CC&PS - DIV OF EMERGENCY MANAGEMENT
DENR LEGISLATIVE AFFAIRS
DEPT OF CULTURAL RESOURCES
DEPT OF TRANSPORTATION
PIEDMONT TRIAD COG
PROJECT INFORMATION
APPLICANT: NCDENR
TYPE: State Environmental Policy Act
Environmental Assessment/Finding of No Significant Impact
DESC: Proposed project is for the T.Z. Osborne Wastewater Treatment Plant Expansion.
The attached project has been submitted to the N. C. State Clearinghouse for'
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at [phone].
AS A RESULT OF THIS REVIEW, HF FOLLC9h'ING IS SUBMITTED:
SIGNED BY:
fa
000
NO COMMENT [1: COMMENTS ATTACHED
DATE:
?hoitz

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE
GOVERNOR
MEMORANDUM TO:
FROM:
SUBJECT:
September 6, 2012
Sheila Green
NC State Clearinghouse
Administrative Building, 5th Floor, Room #502
Verna Wilson
Transportation Engineer
Triad Group, — Transportation Planning Branch
13-E-4300-0075
EUGENE A. Co Tn, JR.
SECRETARY
4.017.0
These are comments from the NCDOT —. Transportation Planning Branch regarding North
Carolina State Clearinghouse of Administration Intergovernmental Review # 13-E-4300-0075.
The Transportation Planning Branch would like to make the North Carolina Department .of
Environment and Natural Resource aware of some project developments; that are listed in the
Greensboro Urban Area CTP, which may impact the study area:
Eastern Urban Loop (Future 1-840), TIP No.1U-2525B
This project is within the 2025 horizon year of the 2035 Greensboro LRTP. The Eastern Urban
Loop from US 29 to US 70 is proposed to be constructed as a 4-lane divided freeway on new
location. This project is currently in the project development phase. For additional information
about this project, including the Purpose and Need, contact NCDOT's Project Development
and Environmental Analysis Branch.
Please see the attached graphics ,for a better view of the proposals. If you have any further
questions, please do not hesitate to contact me at 919-707-0988 or email at
vrwilson l ®ncdot.gov.
Attachments:
Highway map Inset —Greensboro Urban Area
MAIUNG ADDRESS:
NC DEPARTMENT OF TRANSPORTATION
TRANSPORTATION PLANNING BRANCH
1664 MAUL SERVICE CENTER
RALEIGH NC 27899-1654
TRANI{PORTATION
PtANNINe ORANQI
hfp //ncdotorg/doh/pneconsfrud/1pb/
LOCATION:
TRANSPORTATION BUILDING
' 1 SOUTH WILMINI GTON STREET
RALEIGH. NC 27601
Phone: [phone]
Fax: [phone]

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67,

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Executive Summary
EXECUTIVE SUMMARY
This project consists of a State Environmental Policy Act (SEPA) Environmental Assessment (EA) to allow
the City of Greensboro to apply for a National Pollutant Discharge Elimination System (NPDES) permit for
an increase in treatment plant capacity from 40 to 56 million gallons per day (mgd) at the T.Z. Osborne
VNVTP. Pursuant to SEPA, the expansion of an existing discharge facility by 500,000 gallons per day (gpd)
or greater requires an EA to be completed and a FONSI to be issued before DWQ will issue permits and
approvals. The City of Greensboro is proposing this project to comply with the Jordan Lake Nutrient
Reduction Rules for the 20-year planning period and decommission the aging 16 mgd North Buffalo Creek
WVVTP. The proposed project will not increase the total wastewater treatment capacity for the City. The
geographical service area will not be increased beyond the current planning limits.
Greensboro is located in the center of Guilford County. Surrounding communities include the City of High
Point in the southwest comer of Guilford County; the Towns of Oak Ridge, Summerfield, and Stokesdale in
the northwest corner of Guilford County; and the Town of Pleasant Garden south of Greensboro. The City
of Burlington is located in Alamance County, east of Greensboro. The service area is approximately
254 square miles and includes the city limits, the extraterritorial jurisdiction (ETJ), and the planned urban
services area of Greensboro. The service area extends to north of Lake Townsend and is bounded by the
ETJ of the Town of Summerfield, Lake Brandt, and NC 150. The western portion of the service area is
bounded by the City of High Point, Town of Kernersville, and the Town of Oak Ridge. The southern portion
of the service area extends to the Town of Pleasant Garden. The eastern portion of the service area
extends to the edge of Lake Mackintosh, approximately five miles east of 1-840.
The selected alternative to expand the T.Z. Osborne WWTP from 40 to 56 mgd was selected for the least
environmental and economic impact and the most feasible engineering solution. The upgrade and
expansion of the T.Z. Osborne VVV TP to 56 mgd was identified as the most favorable alternative to
address the reduction of total nitrogen and total phosphorus mass allocations required by the Jordan Lake
Nutrient Reduction Rule. The City is not requesting an increase in total permitted discharge capacity, as the
combined capacity of 56 mgd will serve Greensboro through the next planning period. Additionally,
Greensboro intends to rescind the NPDES permit for the North Buffalo Creek WWTP.
Construction activities related to the T.Z. Osborne WWTP expansion will not significantly impact water
resources, floodplains, soils, aquatic and wildlife habitat and resources, air quality, or noise levels. Two
minor forested wetland areas on the treatment plant site outside the fence line may be impacted by
construction of a parallel outfall line to South Buffalo Creek.
It is not expected that the proposed effluent discharge expansion to South Buffalo Creek will impact water
quality. The speculative limits letter stated that South Buffalo Creek has adequate assimilative capacity for
an expanded NPDES discharge from 40 to 56 mgd. South Buffalo Creek is listed as impaired for copper,
zinc, and biological integrity on the 2010 303(d) list. The ambient water quality data for ammonia in South
Buffalo Creek does not justify an ammonia impairment status in this receiving stream. As such, the 2010
Hazen and Sawyer Project No. 32167-001
HA7ENAND SOWER
Environmental Engineers & Sdentltts

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Executive Summary
ammonia impairment status was removed from the Draft 2012 303(d) List. Greensboro proposes that a
tiered NPDES permit for the T.Z. Osborne VWVfP be developed that would contain summer limits of 1 mg/I
and winter limits of 1.8 mg/I per DWQ policy. The T.Z. Osborne VW TP has passed all Whole Effluent
Toxicity (WET) tests in the last five years; therefore, the effluent discharge is not contributing to toxicity in
the receiving stream. Therefore, the copper and zinc impairment status in South Buffalo Creek should not
prohibit an expansion of the T.Z. Osborne UWVfP.
Minimal indirect and cumulative impacts resulting from the proposed project are anticipated to occur from
continued development within the service area. Federal, state, and local programs will help to offset
potential direct, indirect, and cumulative impacts resulting from the proposed project. These programs
include land use planning, open space preservation, erosion and sedimentation control, stormwater,
floodplain management, and water shortage response.
Hazen and Sawyer Project No. 32167-001
H47ENAND SWYIR
Eorlroameatal Engineers i idealists
II

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Table of Contents
Table of Contents iii
1. Proposed Project Description 1-1
1.1 Existing Facilities 1-2
1.2 Proposed Project Scope 1-4
1.3 Service Area 1-4
2. Need for the Project 2-1
2.1 Growth Trends and Population Projections 2-1
2.2 Wastewater Flow Projections 2-2
3. Alternatives Analysis 3-1
3.1 No Action 3-1
3.2 Nutrient Removal Upgrades with Existing Surface Water Discharges to North and South Buffalo
Creeks 3-1
3.3 Land Application 3-4
3.4 Reuse Spray Irrigation 3-6
3.5 Surface Water Discharge to South Buffalo Creek (Selected Altemative) 3-9
4. Existing Environment 4-1
4.1 Topography 4-1
4.2 Soils 4-1
4.3 Land Use 4-3
4.4 Wetlands 4-4
4.5 Prime or Unique Agricultural Lands 4-4
4.6 Public Lands and Scenic, Recreational, and State Natural Areas 4-4
4.7 Areas of Archaeological or Historical Value 4-5
4.8 Air Quality 4-5
4.9 Noise Levels 4-6
4.10 Water Resources (Surface Water and Groundwater) 4-7
4.11 Forest Resources 4-11
4.12 Shellfish or Fish and Their Habitats 4-11
4.13 Wildlife and Natural Vegetation 4-12
Hazen and Sawyer Project No. 32167-001
HAM AND SOWER
Environmental Ea=lasers & Scientists
iii

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Table of Contents
5. Predicted Environmental Effects 5-1
5.1 Topography 5-1
5.2 Soils 5-1
5.3 Land Use 5-2
5.4 Wetlands 5-2
5.5 Prime or Unique Agricultural Lands 5-2
5.6 Public Lands, Scenic and Recreational Areas 5-3
5.7 Areas of Archaeological or Historical Value 5-3
5.8 Air Quality 5-3
5.9 Noise Levels 5-4
5.10 Water Resources 5-5
5.11 Forest Resources 5-6
5.12 Shellfish or Fish and Their Habitats 5-6
5.13 Wildlife and Natural Vegetation 5-7
5.14 Introduction of Toxic Substances 5-12
6. Mitigative Measures 6-1
7. Summary of Local Programs and Ordinances 7-1
7.1 Land Development Ordinance 7-1
7.2 Land Use Planning and Environmental Resource Protection Initiatives 7-2
7.3 Zoning 7-3
7.4 Open Space Plans/Initiatives, Greenways, and Riparian Buffers 7-6
7.5 Erosion and Sedimentation Control 7-11
7.6 Stream Restoration 7-14
7.7 Stormwater Programs and Impervious Surface 7-14
7.8 Floodplain Development Regulations 7-15
7.9 Water Shortage Response 7-18
Hazen and Sawyer Project No. 32167-001
HA7,FdIAND SAWYER
Environmental Engineers & Scteatlsts
iv

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Table of Contents
8. State and Federal Permits Required 8-1
9. References 9-1
10. Qualifications of Preparers 10-1
11. Figures 11-1
Figures
Figure 1-1: Service Area for City of Greensboro 11-2
Figure 3-1: Location of Potential Land Application Sites 11-3
Figure 3-2: Site Plan for T.Z. Osbome WWTP Expansion to 56 mgd 11-4
Figure 4-1: Floodplains in the Service Area 11-5
Figure 4-2: National Wetland Inventory Wetlands in the Service Area 11-6
Figure 4-3: U.S. Geological Survey Map of the Service Area 11-7
Figure 4-4: Watersheds in the Service Area 11-8
Figure 4-5: Surface Waters in the Service Area 11-9
Tables
Table 2-1: Historic and Projected Population for the City of Greensboro 2-1
Table 2-2: Summary of Wastewater Flow Projections 2-2
Table 3-1: Present Worth Analysis for Nutrient Removal Upgrades for 40 mgd T.Z. Osborne WWTP and
16 mgd North Buffalo Creek WWTP (No -Action Altemative) 3-3
Table 3-2: Present Worth Analysis for Land Application Effluent Disposal Altemative 3-5
Table 3-3: Present Worth Analysis for Reclaimed Water Effluent Disposal Alternative 3-8
Table 3-4: Present Worth Analysis for Nutrient Removal Upgrade and Expansion of T.Z. Osborne WWTP
to 56 mgd (Selected Altemative) 3-10
Table 3-5: Current and Speculative Effluent NPDES Permit Limits for North Buffalo Creek and T.Z.
Osbome Facilities Error! Bookmark not defined.
Table 3-6: Summary of Division of Water Quality Ambient Monitoring Data for the Cape Fear River Basin
at Stations B0670000 and B0750000 in South Buffalo Creek Error! Bookmark not defined.
Table 4-1: Surface Water Classifications in the Service Area
Table 4-2: Protected Species Listed for Guilford County, North Carolina
Table 5-1: Summary of Impacts to Threatened and Endangered Species
4-8
4-14
5-7
Hazen and Sawyer Project No. 32167-001
HA7,ENAND SGVYFdt
Environmental Engineers & Scientists
v

Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Table of Contents
Table 6-1: Density Limits in City of Greensboro Zoning Ordinance 7-4
Table 6-2: Density Limits in Guilford County Zoning Ordinance 7-5
Table 6-3: Minimum Open Space Requirements for City of Greensboro 7-7
Table 6-4: Stream Buffer Width Requirements in Watershed Districts in City of Greensboro 7-8
Table 6-5: Stream Buffer Width Requirements in Guilford County 7-10
Table 6-6: Maximum Permissible Velocity for Stormwater Discharges in the City of Greensboro 7-13
Appendices (on CD)
A Speculative Effluent Limits Request Letter for a Proposed Consolidation of Greensboro's North
Buffalo Creek WWTP into an Expanded T.Z. Osbome VVWTP, Division of Water Quality,
December 2010
B T.Z. Osborne and North Buffalo Wastewater Treatment Facilities Nutrient Removal
Additions Project, Nutrient Removal Alternative Selection, Final Master Plan Report
(CDM 1 Hazen and Sawyer, 2011)
C Response to Agency Comments
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Treatment Plant Expansion
Table of Contents
List of Acronyms
BFE Base Flood Elevation
BGPA Bald and Golden Eagle Protection Act
BMP Best management practice
BNR Biological nutrient removal
CBOD5 Carbonaceous biochemical oxygen demand
CO Carbon monoxide
CWA Clean Water Act
DAQ Division of Air Quality
DENR North Carolina Department of Environment and Natural Resources
DWQ Division of Water Quality
EA Environmental assessment
EMC Environmental Management Commission
EPA United States Environmental Protection Agency
ESA Endangered Species Act
ETJ Extraterritorial Jurisdiction
FEMA Federal Emergency Management Agency
FONSI Finding of No Significant Impact
FPPA Farmland Protection Policy Act
FSC Federal Species of Concern
gpcd Gallon per capita day
gpd Gallons per day
GWA General watershed area
HQW High quality water
I/1 Infiltration and inflow
lb/year Pounds per year
IWC Instream waste concentration
LDO Land Development Ordinance
mgd Million gallons per day
mg/I Milligrams per liter
MSL Mean sea level
NAAQS National Ambient Air Quality Standards
NBCSS North Buffalo Creek Sanitary Sewer
NCGS North Carolina General Statutes
NHP North Carolina Natural Heritage Program
NO,t Nitrogen oxides
NPDES National Pollutant Discharge Elimination System
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Table of Contents
List of Acronyms
NRCS National Resources Conservation Service
NRHP National Register of Historic Places
NSW Nutrient Sensitive Water
NWI National Wetland Inventory
03 Ozone
ORW Outstanding Resource Waters
OSA Office of State Archaeology
OSC Open Space, Committee
Pb Lead
PM-10 Particulate matter less than 10 micrometers in diameter
PPM Parts per million
SCS Soil Conservation Service
SEPA State Environmental Policy Act
SHPO State Historic Preservation Office
SIU Significant industrial user
SNHA Significant Natural Heritage Area
SOX Sulfur oxides
T Threatened
TMDL Total maximum daily load
TSP Total suspended particulates
TSS Total suspended solids
USACE United States Army Corps of Engineers
USDA United States Department of Agriculture
USFWS United State Fish and Wildlife Service
USGS United States Geological Survey
VOC Volatile organic compound
WCA Watershed critical area
WET Whole effluent toxicity
WSSA Water and sewer service agreement
WTP Water treatment plant
WWTP Wastewater treatment plant
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Environmental Assessment for
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Treatment Plant Expansion
Proposed Project Description
1. Proposed Project Description
The City of Greensboro (Greensboro) is located in Guilford County, North Carolina, and is situated between
the Cities of Burlington and High Point. Greensboro is geographically located in the Haw River Arm portion
of the Jordan Lake Watershed, the headwaters of the Cape Fear River Basin. Greensboro currently owns
and operates two wastewater treatment plants (WWTPs). The T.Z. Osborne WWTP is a 40 million gallon
per day (mgd) conventional activated sludge facility with nitrification and filtration discharging to South
Buffalo Creek. The North Buffalo Creek WWTP is a 16 mgd conventional activated sludge nitrification
facility discharging to North Buffalo Creek. The combined total wastewater treatment capacity is 56 mgd.
In the early 1990s, Greensboro initiated a project to transfer flow from the North Buffalo Creek WWTP to
the T.Z. Osborne WWTP to alleviate infiltration and inflow (1/I) issues at the North Buffalo Creek WWTP. A
transfer pump station and force main were constructed in 1993. The transfer pump station was capable of
transferring 10 mgd from the North Buffalo Creek WWTP to the T.Z. Osborne WWTP. Flow was transferred
during periods when the North Buffalo Creek influent flow exceeded plant capacity.
In the early 2000s, Greensboro recognized that the I/1 issues in the North Buffalo Creek Sanitary Sewer
(NBCSS) outfall were severe enough to warrant a major rehabilitation and upgrade project. The NBCSS
outfall dates from the early 1900s. In 2003, Greensboro initiated a project to upgrade the transfer pump
station and repair the existing NBCSS outfall. I/1 investigations revealed that a significant portion of the flow
in the outfall originated from I/1 caused by cracks and breaks during wet weather events. Furthermore, the
outfall exhibited significant material degradation. A Final Environmental Assessment (EA) for the NBCSS
Outfall, Transfer Pumping Station, and Force Main Replacement was published with a Finding of No
Significant Impact (FONSI) in 2005. The project included a new plant influent lift station, a 65 mgd transfer
pump station to the T.Z. Osborne WWTP, a new 54-inch force main between the North Buffalo Creek and
T.Z. Osborne WWTPs, and the NBCSS outfall replacement project. Currently, Greensboro is transferring
an average of 9.4 mgd from the North Buffalo Creek WWTP to the T.Z. Osborne WWTP.
The North Buffalo Creek and T.Z. Osborne WWTPs will require significant nutrient removal upgrades due
to the B. Everett Jordan Reservoir Nutrient Management Strategy and Total Maximum Daily Load (TMDL)
adopted in August 2009. Jordan Lake was designated a Nutrient Sensitive Water (NSW) in 1983. In 1997,
the North Carolina Clean Water Responsibility Act included legislation that charged the North Carolina
Environmental Management Commission (EMC) to establish goals for reducing nutrient inputs to nutrient
sensitive waters. The EMC commissioned the Department of Environment and Natural Resources (DENR)
Division of Water Quality (DWQ) to develop the Nutrient Management Strategy and TMDL. The North
Buffalo Creek and T.Z. Osborne WWTPs must meet a combined annual total nitrogen and total
phosphorus mass load allocation of 902,715 pounds/year (lb/year) and 113,315 lb/year, respectively. The
annual mass loadings are equivalent to maximum effluent concentrations of 5.29 milligrams/liter (mg/I) total
nitrogen and 0.66 mg/I total phosphorus at a combined maximum month flow of 56 mgd. The total
phosphorus limit was in effect as of January 2010. The total nitrogen limits will be effective on
January 1, 2018.
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Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Proposed Project Description
CDM Hazen and Sawyer were commissioned in 2006 to evaluate the engineering alternatives for nutrient
reduction strategies at the T.Z. Osborne and North Buffalo Creek WWTPs to comply with the Jordan Lake
Nutrient Reduction Rules. The Final Master Plan Report was published in March 2011. The Master Plan
evaluated six alternatives with a combination of flow, load, and treatment scenarios between the two
WWTPs. The alternatives included the evaluation of modifications to existing plant infrastructure,
identification of new treatment infrastructure, life -cycle cost estimates, and recommended project phasing.
1.1 Existing Facilities
Wastewater generated in Greensboro's service area is currently treated at either the North Buffalo Creek
WWTP or the T.Z. Osborne WWTP. The T.Z. Osborne WWTP is permitted for a discharge of 40 mgd to
South Buffalo Creek (Permit No. NC0047384). The North Buffalo Creek WWTP is permitted for a discharge
of 16 mgd to North Buffalo Creek (Permit No. NC0024325). Both permits expired on June 30, 2011.
Greensboro submitted applications for permit renewals on December 30, 2010. The applications for
renewal are currently in the review process. Greensboro's collection system consists of over 1,400 miles of
gravity sewer, 69 miles of force main, and 47 pump stations conveying raw wastewater to the two treatment
plants. Pump station capacities range from 30 to 2,600 gallons per minute. The combined annual average
wastewater flow was 29.3 mgd in 2010.
1.1.1 T.Z. Osborne WWTP
The T.Z. Osborne WWTP began operation in 1984 as part of the Metro Sewerage Plan developed to
improve and protect Greensboro's water quality and environment. The plant's original rated capacity was
20 mgd. An expansion to 30 mgd occurred in 2001, and a second expansion to 40 mgd occurred in 2003.
The T.Z. Osborne WWTP processes consist of influent pumping and preliminary treatment, primary
treatment, conventional activated sludge with nitrification, secondary clarification, chemical phosphorus
removal storage and feed facilities, recycle activated sludge and waste activated sludge pumping, effluent
filtration, chlorine disinfection with dechlorination, and solids handling. The T.Z. Osborne WWTP currently
handles the solids produced at both WWTPs. Solids handling processes include thickening, dewatering,
and incineration.
The NPDES permit for the plant expired on June 30, 2011. The plant has consistently met its effluent
permit limits of 2.0 and 4.0 mg/I for monthly average summer and winter ammonia, respectively. The
carbonaceous biochemical oxygen demand (CBOD) limits are a monthly average of 4 mg/I and 8 mg/I for
summer and winter, respectively. Other permit limits include a monthly average of 30 mg/I for total
suspended solids and an annual mass limit for phosphorus of 81,156 lb/year. The average flow rate
through the plant between 1997 and 2001 was 18.61 mgd. In 2010, the average daily flow to the plant was
23.3 mgd and included a 9.4 mgd transfer from the North Buffalo Creek WWTP.
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Environmental Engineers i Scientists
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Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Proposed Project Description
1.1.2 North Buffalo Creek WWTP
The North Buffalo Creek WWTP was constructed in 1938 as an 8 mgd secondary treatment facility treating
municipal and industrial waste. The facility was expanded in 1959 to a capacity of 18 mgd. In 1980, the
facility was voluntarily de -rated to 16 mgd to facilitate the nitrification process to reduce the ammonia -
nitrogen content in the plant effluent. The major unit processes at the North Buffalo Creek WWTP include
preliminary treatment, primary treatment, conventional activated sludge with nitrification, secondary
clarification, tertiary filtration, and chlorine disinfection with dechlorination. Biosolids are pumped to the
T.Z. Osborne WWTP for treatment.
The North Buffalo Creek WWTP NPDES permit limits are not as stringent as those for the T.Z. Osborne
WWTP for CBOD and ammonia. CBOD limits are 8 mg/I and 16 mg/I for summer and winter, respectively.
Ammonia is permitted at 4 mg/I and 8 mg/I for summer and winter, respectively. In 2010, the North Buffalo
Creek WWTP did not have any permit limit violations. The average flow rate through the North Buffalo
Creek WWTP from 1997 to 2001 was 13.1 mgd. In calendar year 2010, the total average daily flow to the
North Buffalo Creek WWTP was 15.4 mgd- Approximately 6 mgd was treated and discharged to North
Buffalo Creek, and 9.4 mgd was transferred to the T.Z. Osborne WWTP for treatment and discharge.
The North Buffalo Creek transfer pump station project consisted of a replacement of the original transfer
pump station and 4.6 miles of 54-inch force main from the North Buffalo Creek WWTP to the T.Z. Osborne
WWTP. The pump station routes screened influent to the T.Z. Osborne WWTP. The firm capacity of the
pump station is 65 mgd. Between 2003 and 2010, approximately 4 to 9.4 mgd was transferred to the
T.Z. Osborne WWTP. A peak flow of 40 mgd was transferred in November 2009.
1.1.3 Significant Industrial Users
Greensboro has thirty-four significant industrial users (SIUs) that contribute wastewater flow to either the
T.Z. Osborne or North Buffalo Creek WWTPs. The SIU types include metal finishers and electroplaters,
organic chemical manufacturing, centralized waste treatment, electrical and electronic component
manufacturing, textile manufacturers, one tobacco company, and two pharmaceutical companies. Twenty-
nine SIUs send flow directly to the T.Z. Osborne WWTP and five SIUs send their effluent to the North
Buffalo Creek WWTP.
At the T.Z. Osborne WWTP, the total permitted flow to industry is 3.97 mgd, or approximately 10 percent of
the facility's design flow of 40 mgd. In 2010, actual industrial flow contributed 5.5 percent to the annual
average daily flow. According to a revised draft headworks analysis updated by Greensboro in 2010, the
maximum allowable industrial load was not exceeded for any pollutants of concern. None of the SIUs have
permit limits for total nitrogen, but two have a combined total phosphorus loading limit of 288 lb/day.
Several SIUs have permit limits for arsenic, cadmium, chromium, copper, cyanide, lead, mercury, nickel,
silver, and zinc.
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Environmental Engineers & Scientists
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Environmental Assessment for
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Treatment Plant Expansion
Proposed Project Description
The industrial contribution is significantly less at the North Buffalo Creek WWTP. The total permitted flow of
the five SIUs is 0.32 mgd, or approximately 2.1 percent of the total permitted flow of 16 mgd. Actual
industrial flow accounted for approximately 1.37 percent of the annual average daily flow in 2010. None of
the five industries that discharge to the North Buffalo Creek WWTP have total nitrogen or total phosphorus
permit limits. Several SIUs have permit limits for lead, cyanide, and cadmium. The revised draft headworks
analysis concludes that the SIUs currently discharging to the North Buffalo Creek WWTP will continue to be
accommodated at the T.Z. Osborne WWTP. There have not been any NPDES permit limits violations as a
result of the industrial load allocation and the flow transfer from North Buffalo Creek WWTP to the
T.Z. Osborne WWTP.
1.2 Proposed Project Scope
This project consists of an EA to allow Greensboro to apply for a National Pollutant Discharge Elimination
System (NPDES) permit for an increase in treatment plant capacity from 40 to 56 mgd at the T.Z. Osborne
WWTP. Pursuant to the North Carolina State Environmental Policy Act (SEPA), the expansion of an
existing discharge facility by 500,000 gallons per day (gpd) or greater requires an EA to be completed and
a FONSI to be issued before DWQ will issue permits and approvals. Greensboro is proposing this project
to comply with the Jordan Lake Nutrient Reduction Rules for the 20-year planning period and
decommission the aging 16 mgd North Buffalo Creek WWTP. The proposed project will not increase the
total wastewater treatment capacity for the City. The geographical service area will not be increased
beyond the current planning limits.
This EA includes evaluations of the general environmental issues related to the project, as well as the
impacts of specific infrastructure components of the proposed T.Z. Osborne WWTP expansion from 40 to
56 mgd. This EA documents the need for the project, provides an analysis of the project and effluent
discharge alternatives, and describes the existing environment, predicted environmental impacts, and
mitigative measures.
1.3 Service Area
Greensboro is located in the center of Guilford County. Surrounding communities include the City of High
Point in the southwest corner of Guilford County; the Towns of Oak Ridge, Summerfield, and Stokesdale in
the northwest corner of Guilford County; and the Town of Pleasant Garden south of Greensboro. The City
of Burlington is located in Alamance County, east of Greensboro. Lake Higgins, Lake Brandt, and Lake
Townsend are located north of Greensboro city limits. Randleman Lake is located south of Greensboro.
The T.Z. Osborne and North Buffalo Creek WWTPs presently serve different areas associated with their
respective collection systems. The T.Z. Osborne WWTP service area covers the majority of the eastern,
southern, and western portions of Greensboro's WSSA, including the Piedmont Triad International Airport.
The North Buffalo Creek WWTP service area includes the northern part of Greensboro and includes
parcels north of Route 220 (Wendover Avenue), parcels surrounding North Buffalo Creek and Muddy
Creek, and parcels north of Route 6 (Lee Street). The eastern portion of the North Buffalo Creek WWTP
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Environmental Engineers & Scientists
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Environmental Assessment for
T.Z. Osborne Wastewater
Treatment Plant Expansion
Proposed Project Description
service area includes the western half of Lake Townsend and the entirety of Jordan Branch. The western
part of the North Buffalo Creek VW TP service area includes most of Lake Higgins and approximately half
of Horsepen Creek. The proposed project will combine the two service areas.
The entire service area for Greensboro is approximately 254 square miles. The service area includes the
city limits, the extraterritorial jurisdiction (ETJ), and the planned urban services area of Greensboro. The
service area extends to north of Lake Townsend and is bounded by the ETJ of the Town of Summerfield,
Lake Brandt, and NC 150. The western portion of the service area is bounded by the City of High Point,
Town of Kernersville, and the Town of Oak Ridge. The southern portion of the service area extends to the
Town of Pleasant Garden. The eastern portion of the service area extends to the edge of Lake Mackintosh,
approximately five miles east of 1-840. Figure 1-1 illustrates the location of the wastewater infrastructure
and the service area boundary.
1.3.1 Water and Sewer Service Agreement
A planned urban services area boundary was negotiated in the 2007 Water and Sewer Service Agreement
(WSSA) with Guilford County and other county communities. Historically, annexations and extensions of
the water and sewer service area were established at the request of individual private developers, resulting
in urban sprawl along the outskirts of Greensboro. The purpose of the WSSA was to control the long-term
growth patterns in a sustainable and economically viable manner and to manage water and sewer
treatment resources in Greensboro. The Agreement stipulates that water and sewer installations will not be
considered for extensions beyond the water and sewer service area except for six specific cases listed in
the Agreement. Additionally, the Agreement presents a system that divides the water and sewer service
area into three availability areas, A, B, and C, based on the following: the cost to extend water and sewer
service, the proximity to existing service, and the degree to which that service will protect the Watershed
Critical Area (WCA). Service areas designated as A, B, and C are areas with ample, limited, and scarce
availability of water and sewer services, respectively.
Additionally, Greensboro developed a strategy for future growth in based on two principles. The first
principle is to promote infill and reinvestments in urban areas in need of revitalization. The second principle
is to manage growth at Greensboro's fringe in a sustainable manner through the proper staging of
annexation, development, and infrastructure extensions. Growth tiers are areas where development,
annexation, and extension of public facilities are to be staged over a 20-year period. Growth tier one is
where development is expected to be concentrated and where services can be most easily provided within
the next six years. In areas of growth tiers two and three, growth, annexation, and the extension of public
facilities is anticipated in 6 to 12 years, and beyond 12 years, respectively.
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Environmental Enginesn & Scientists
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Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Need for the Project
2. Need for the Project
The following sections address growth trends (Section 2.1), wastewater flow projections (Section 2.2), and
existing wastewater infrastructure for Greensboro (Section 2.3).
2.1 Growth Trends and Population Projections
In 1940, growth in Greensboro was attributed to major textile centers, such as Cone Mills, Burlington Mills,
and Blue Bell. During and after World War II, Greensboro continued to grow via large-scale expansion of
Greensboro's boundaries through annexation. During the 1970s, aging neighborhoods and buildings were
replaced and development of suburban shopping centers continued. Triggered by a strong national
economy, development continued at the city/county edge in the 1990s. In the 2000s, economic trends
included the continuing decline of Greensboro's industrial base and an increase in various other services.
Greensboro's population growth has slowed over the last two decades. Recent growth is attributed to
annexations. The area in the city limits is approximately 70 percent developed.
Greensboro's population growth over the recent years was the result of natural increase, in -migration,
increased college enrollment, and annexation. From 2001 to 2010, population growth in Greensboro has
averaged 1.9 percent per year. According to the 2010 Census, the population in 2010 was 269,666
persons. In 2011, the City of Greensboro Planning Department developed population projections for 2020
and 2030 to be 324,556 and 390,765 persons, respectively (personal communication). The historic and
projected population is provided in Table 2-1. The population estimates for the years 2015, 2025, and 2035
were interpolated. It is expected that Greensboro will continue to grow at a moderate rate of 2 percent.
Table 2-1: Historic and Projected Population for the City of Greensboro
Year Population
1990 1 183,894
1995 2 192,330
20001 223,891
2005 2 238,440
20101 269,666
2015 297,111
2020 3 324,556
2025 357,660
2030 3 390,765
2035 429,841
Annual Percent Growth
0.92%
3.28%
1.30%
1.82%
2.04%
2.04%
2.04%
2.04%
2.04%
1 The 1990, 2000, and 2010 population are from U.S. Census Bureau.
2 Population estimates are as of July each year from the City of Greensboro Planning
Department.
3 Population projections developed by the City of Greensboro Planning Department.
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Environmental Enghteers & Scientists
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Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Need for the Project
2.2 Wastewater Flow Projections
Greensboro has implemented significant water conservation efforts since 1999. These water conservation
measures have resulted in a decrease in residential and industrial water use concurrent with a reduction in
wastewater flow production. Residential per capita water use has significantly declined due to Greensboro's
public education measures, updated building codes, and the conservation residential rate structure
enforced in 2000. Industrial per capita use also declined as the result of the elimination of the declining
block rate structure in 1999. Greensboro began phasing out the large volume industrial discount in 1999
and fully eliminated the discount on January 1, 2002. The result was a 31 percent reduction in water
consumption among the top ten water customers between 2000 and 2008. The net result of implementing
residential and industrial water conservation measures was a decline in per capita water use and
wastewater production rates.
Per capita wastewater production rates were calculated using the combined historic annual average
wastewater flow at the T.Z. Osborne and North Buffalo Creek WWTPs and the population in the service
area. The highest historic per capita wastewater production exceeded 200 gallons per capita day (gpcd) in
1993. The average and median per capita wastewater production rates were 128 gpcd and 132 gpcd,
respectively, between 2003 and 2010. The 2010 wastewater production rate was 109 gpcd. This value was
selected for the wastewater flow projections, as this year was not excessively wet or abnormally dry.
Table 2-2 summarizes the projected annual average and maximum month wastewater flow to 2035. By
2035, the projected maximum month wastewater flow will be expected to be 56 mgd. The combined
wastewater treatment capacity of 56 mgd is necessary to accommodate the expected growth over the
planning period.
Table 2-2: Summary of Wastewater Flow Projections
Annual Average Maximum Month
Year Wastewater Flow (mgd) Flow (mgd) 2
2010 29.3 35.0
2015 32.4 38.9
2020 35.4 42.5
2025 39.0 46.8
2030 42.5 51.1
2035 46.9 56.2 3
1 Calculated annual average wastewater flow is based on the 2010 average
wastewater production rate of 109 gpcd. A 109 gpcd wastewater production rate
includes infiltration and inflow.
2 The City's maximum month to average day ratio has ranged between 1.14 and 1.24
over the last seven years with an average of 1.2 over the last three years. A ratio of
1.2 was used to be consistent with 15A NCAC 02H .0223.
3 The selected altemative will be designed for a wastewater treatment capacity of
56 mgd.
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Environmental Engineers & Scientists
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Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
3. Alternatives Analysis
CDM Hazen and Sawyer published a Final Master Plan Report in March 2011 that evaluated six
alternatives with a combination of flow, load, and treatment scenarios between the North Buffalo Creek and
T.Z. Osborne WWTPs to comply with the Jordan Lake Nutrient Reduction Rules. The alternatives included
the evaluation of modifications to existing plant infrastructure at both treatment facilities, identification of
new treatment infrastructure, life -cycle cost estimates, and recommended project phasing. The Master Plan
Report recommended expanding the T.Z. Osborne WWTP to 56 mgd and decommissioning the North
Buffalo Creek WWTP. The recommendation was based on economic feasibility and treatment process
reliability. Greensboro elected to move forward with the recommended treatment alternative, which will
result in an expansion of the existing surface water discharge from 40 to 56 mgd in South Buffalo Creek.
This section of the EA expands the treatment analysis provided in the Master Plan Report by providing an
evaluation of the engineering alternatives to a surface water discharge expansion from 40 to 56 mgd in
South Buffalo Creek. The alternatives considered in this EA include:
• No Action Alternative
• Nutrient Removal Upgrades with Existing Surface Water Discharges to North and South
Buffalo Creeks
• Land Application
• Reuse Spray Irrigation
• Surface Water Discharge to South Buffalo Creek (Selected Alternative)
3.1 No Action
Under the no -action effluent disposal alternative, the North Buffalo Creek and T.Z. Osborne WWTPs would
continue to discharge 16 mgd and 40 mgd to the North and South Buffalo Creeks, respectively. The City
would not upgrade their treatment facilities to comply with the Jordan Lake Nutrient Reduction Rules, and
thus would be required to file an appeal to the courts to change the regulation or incur fines as a result of
permit violations. This alternative is eliminated from consideration, as the City intends to comply with the
regulations and maintain compliance with their permits.
3.2 Nutrient Removal Upgrades with Existing Surface Water Discharges to North and South
Buffalo Creeks
Under this alternative, the North Buffalo Creek and T.Z. Osborne WWTPs would continue to discharge
16 mgd and 40 mgd to the North and South Buffalo Creeks, respectively. The influent Toad would continue
to be transferred to the T.Z. Osborne WWTP from the North Buffalo Creek WWTP. Greensboro is currently
transferring approximately 45 percent of the total influent flow from the North Buffalo Creek WWTP to the
T.Z. Osborne WWTP, averaging 9.4 mgd in 2010.
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Environmental Engineers & Scientists
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Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
This alternative would require that Greensboro proceed with the nutrient removal upgrades at both the
T.Z. Osborne WWTP and the North Buffalo Creek WWTP to comply with the Jordan Lake Nutrient
Reduction Rules. Effluent total nitrogen concentration averaged 9.2 mg/I at the T.Z. Osborne WWTP over
the last three years, which exceeds the speculative limit of 5.23 mg/I total nitrogen. The North Buffalo Creek
WWTP effluent total nitrogen averages approximately 18.0 mg/I. Both facilities are adding chemical for
phosphorus removal to meet the Nutrient Reduction Rule for total phosphorus.
The North Buffalo Creek WWTP was first placed into service in 1938 and expanded in 1959. The age of the
infrastructure required that the structural, mechanical, and electrical integrity of the facility be evaluated.
The Master Plan concluded that several rehabilitation efforts would be required to continue operating the
facility. Several structures show evidence of hydrogen sulfide corrosion ranging from moderate to severe.
Several major equipment items have deteriorated beyond repair or are operating significantly past the
recommendation for service life, including the aeration and solids handling equipment. Additionally, it was
recommended that the main electrical system be completely replaced due to age and current technology.
The North Buffalo Creek WWTP will require significant upgrades to improve process reliability and meet the
annual nutrient mass load required by the Jordan Lake Nutrient Reduction Rules. The Master Plan Report
recommended an integrated fixed film activated sludge (IFAS) process and several hydraulic improvements
for a 16 mgd nutrient removal upgrade. This treatment recommendation includes significant aeration basin
improvements with a new aeration system, a retrofit of the aeration basins for the IFAS biofilm media,
anoxic zone partitioning, and mixing and pumping equipment. New tertiary filters, chemical feed systems,
major piping improvements, and significant electrical improvements will also be required.
The Master Plan Report recommended that the T.Z. Osborne facility be upgraded to a conventional
advanced activated sludge process for the nutrient removal upgrade. The improvements for the 40 mgd
nutrient removal upgrade include a retrofit of the existing twelve aeration basins, a new clarifier, a new
return activated sludge pump station, chemical feed and storage improvements, one new chlorine contact
basin, and significant electrical improvements.
Table 3-1 provides the total present worth of the project costs for this no -action alternative. The present
worth cost includes the cost to rehabilitate the North Buffalo Creek WWTP and the nutrient removal
upgrades at both plants. Operation and maintenance (O&M) costs include power, chemical, equipment
replacement, and equipment maintenance and repair costs. The total present worth of this alternative is
$150,700,000.
This alternative will address the wastewater capacity needs in the service area for a combined treatment
capacity of 56 mgd. However, the North Buffalo Creek facility improvements, including structural and
equipment rehabilitation, were estimated to have a capital cost of approximately $48,000,000 compared tc
$19,400,000 to upgrade the T.Z. Osborne WWTP for nutrient removal at 40 mgd. The North Buffalo Creel
facility was constructed in 1938. This facility has exceeded its useful life, and will be expensive to maintain
over the next planning period. This alternative will also result in Greensboro maintaining two NPDES
discharges instead of one NPDES discharge. Therefore, the age of the North Buffalo Creek WWTP
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Environmental Engineers & Scientists
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Environmental Assessment for
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Facility Expansion
Alternatives Analysis
combined with the economic issues with upgrading the facility for regulatory compliance eliminated this
alternative from consideration.
Table 3-1: Present Worth Analysis for Nutrient Removal Upgrades for 40 mgd T.Z. Osborne
WWTP and 16 mgd North Buffalo Creek WWTP (No Action Alternative)
Component
Improvements at North Buffalo Creek
Rehabilitate North Buffalo Creek
Retrofit of Trickling Filters
Aeration Basin Modifications
Tertiary Filtration
Chemical Feed Systems
Yard Piping
Electrical
Improvements at T.Z. Osborne
Aeration Basin Modifications
Secondary Clarifier Modifications
Chemical Feed Systems
Chlorine Contact Basin
Yard Piping
Electrical
Project
Cost 1121
3
$5,400,000
$170,000.
$22,360,000
$6, 860, 000
$1,230,000
$3,180,000
$8,800,000
$13,330,000
$2,470,000
$340,000
$1,220,000
$1,080,000
$1,000,000
Salvage Value
Salvage Useful life
Amount (years) 4
$0
$0
$0
$0
$0
$0
$0
$0
$o
$0
$0
$0
$0
20
20
20
20
20
20
20
20
20
20
20
20
20
Subtotal
$67,400,000
$0
(*)
Present Worth
Project Cost of O&M 5
$67,400,000 $83,300,000
Present Worth
of Salvage
$0
Total Present Worth for Nutrient Removal
Upgrades for 40 mgd T.Z. Osborne WWTP and $150,700,000
16 mgd North Buffalo Creek WWTP:
Note: Time Period = 20 years, Interest Rate = 5.625%
1 Cost in 2010 Dollars.
2 From Final Master Plan Report, March 2011, CDM ! Hazen and Sawyer.
3 Project costs include construction, contractor overhead and profit, bonds and insurance, contingency,
engineering, administration, and legal costs.
4 Useful life of structures, piping, electrical equipment, and mechanical equipment estimated at 20 years.
5 O&M costs include continued pumping to T.Z. Osbome WWTP, plant power costs, chemical requirements,
equipment replacement, staffing needs, and equipment maintenance and repair. A 3% inflation rate per year
was used for power and chemical costs.
Hazen and Sawyer Project No. 32167-001
HA7,FdNAND SkIiYFdt
Environmental Engineers 8 Scientists
3-3

Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
3.3 Land Application
Land application systems include individual or community onsite subsurface systems, drip irrigation, and
spray irrigation. Land application systems generally do not require advanced secondary treatment
processes prior to irrigation (NCAC 15A 02T, Waste Not Discharged to Surface Water). Land application
systems also do not facilitate other options for effluent disposal, such as reuse or high rate infiltration.
Secondary effluent criteria for land application include biochemical oxygen demand (BOD5) and total
suspended solids (TSS) of 30 mg/I, ammonia at 15 mg/I, and fecal coliform at 200 colonies/100 ml.
The land application alternative would require that wastewater flow continue to be transferred from the
North Buffalo Creek V VVTP to the T.Z. Osborne WWTP and treated at the T.Z. Osborne facility. This
alternative would require that the T.Z. Osborne VVWTP be upgraded for nutrient removal to comply with the
Jordan Lake Nutrient Reduction Rules. Treated effluent would be pumped from the T.Z. Osborne facility to
the 60-day storage pond at the land application site.
Suitable property for disposal of land application effluent must be acquired. A conservative land application
rate of 1 inch per acre per week was selected based on similar systems in North Carolina and published
criteria (EPA, 2006). Factoring land for the 60-day storage pond, wetlands, buffers, and access roads,
Greensboro must acquire approximately 7,400 acres of land for effluent disposal of 16 mgd. The closest
suitable and contiguous land application sites with adequate capacity for a flow of 16 mgd was found
approximately 13.4 miles from the T.Z. Osborne WVVI"P. Figure 3-1 illustrates the location of the potential
land application site relative to the T.Z. Osborne and North Buffalo Creek WWTPs. This area is located in
the northeastern corner of the County where minimal development has taken place and is outside of city or
town jurisdictions. The land application site evaluation was limited to Guilford County. Per North Carolina
General Statute (GS) 153A-15, Guilford County prohibits Greensboro from purchasing land outside Guilford
County without the consent of the Board of Commissioners of the county in which the land is located.
Research suggests that land application of secondary treated effluent may reduce the porosity of soil
(i.e. clogging) and the infiltration rate over time (Clanton and Slack, 1987). Therefore, more land may be
required to dispose of the same quantity of effluent as the system ages. Additionally, land application
systems do not maximize the value and service of the property due in part to the large buffer areas that are
required.
Table 3-2 summarizes the total present worth for the land application disposal alternative. Costs include
land acquisition, spray field infrastructure, effluent pump station and force main, upgrades to the
T.Z. Osborne WWTP, and decommissioning the North Buffalo Creek WWTP. The total present worth for
this alternative is approximately $592,900,000, which is 450 percent higher than the selected alternative of
expanding the T.Z. Osborne WVITTP to 56 mgd with a nutrient removal upgrade.
The land application alternative has been removed from consideration for several reasons. First, this
alternative is not economically feasible. The capital and total present worth costs are 4.5 times higher than
the selected alternative. Furthermore, the acquisition of 7,400 acres of land would require four to five years
Hazen and Sawyer Project No. 32167-001
WEN AND SOYE1t
EavIroaa,eatal Enlisters i feteatlsts
3-4

Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
to accomplish prior to design and bidding. The North Buffalo Creek WWTP would require a nutrient
removal upgrade to comply with the Jordan Lake Rules and schedule before all of the land could be
acquired to dispose of 16 mgd.
Table 3-2: Present Worth Analysis for Land Application Effluent Disposal Alternative
Component
Land Application System
Land Acquisition Cost
Spray Field Infrastructure
60-Day Storage Pond
Access Roads
Monitoring Wells
Land Application Pump Station
Effluent Distribution Force Main
improvements at T.Z. Osborne 2
North Buffalo Creek Decommission
Improvements at T.Z. Osborne 6
Salvage Value
Project Salvage Useful life
Cost 113 Amount (years) 4
$35,500,000 $35,500,000 N/A
$198,530,000 $0 20
$210,300,000 $0 20
$400,000 $0 20
$640,000 $0 20
$1,790,000 $0 20
$20,380,000 $0 20
$1, 500, 000
$45,840,000
$0
$0
20
20
Subtotal $514,880,000
$0
(*)
Present Worth Present Worth
Project Cost of O&M 5 of Salvage
$514,880,000 $70,700,000 $11,880,000
Total Present Worth for Land Application of 16 mgd
North Buffalo Creek WWTP Effluent and Nutrient Removal $573,700,000
Upgrade for 40 mgd T.Z. Osborne WWTP :
Note: Time Period = 20 years, Interest Rate = 5.625%
I Cost in 2010 Dollars.
2 From Final Master Plan Report, March 2011, CDM ! Hazen and Sawyer.
3 Project costs include construction, contractor overhead and profit, bonds and insurance, contingency,
engineering, administration, and legal costs.
4 Useful life of structures, piping, electrical equipment, and mechanical equipment estimated at 20 years.
5 O&M costs include continued pumping to T.Z. Osbome WWTP, plant power costs, chemical requirements,
equipment replacement, staffing needs, and equipment maintenance and repair. A 3% inflation rate per year
was used for power and chemical costs.
6 !t was assumed that 50% of the aeration basin improvements would be required to treat to land application
effluent quality. All other plant improvements would be required.
Hazen and Sawyer Project No. 32167-001
HA7.F1V AND SGWFdt
Environmental Engineers & Scientists
3-5

• r
Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
3.4 Reuse Spray Irrigation
Reuse spray irrigation is the beneficial reuse of tertiary treated wastewater effluent. Design criteria for
reclaimed water systems for facilities in which the irrigation system is required to meet the needs of the
facility are more stringent than for land application systems. Per NCAC 15A 02T, Waste Not Discharged to
Surface Water, effluent criteria for reclaimed water systems include BOD5 less than 10 mg/I, TSS less than
5 mg/I, ammonia less than 4 mg/I, fecal coliform at 14 colonies/100 ml, and a maximum turbidity of 10 NTU.
Similar to the land application alternative, the reuse alternative would require that wastewater flow continue
to be transferred from the North Buffalo Creek WWTP to the T.Z. Osborne WWTP and treated at the
T.Z. Osborne facility. This alternative would require that the T.Z. Osborne WWTP be upgraded for nutrient
removal to comply with the Jordan Lake Nutrient Reduction Rules. Treated effluent would be pumped from
the T.Z. Osborne facility to the 60-day storage pond at the land application site. Approximately 6,400 acres
of dedicated land for reuse spray irrigation would be required. Refer to Figure 3-1 for the general location of
potential dedicated spray sites.
In addition to treatment design criteria, the Administrative Code provides design criteria for distribution lines
and reclaimed water utilization. Setback requirements for irrigation and utilization areas are less stringent
than for land application systems. The required setbacks for treatment and storage facilities in reclaimed
water systems are identical to those for land application systems.
Production of reuse quality effluent allows a greater range of options for land application other than a
dedicated land application site. These effluent disposal options include golf courses, residential lawns,
parks and school grounds, game fields (soccer, baseball, football), irrigation of crops, and industrial uses
(such as cooling and wash down water). Water reuse systems in the Piedmont region of North Carolina are
generally landscape irrigation -based systems that experience high demands during the hot, dry summer
season, and little to no demands during the cool, wet winter season. Data collected by the Town of Cary in
its Northeast Reclaimed Water Service Area indicated that reclaimed water customers used the same
amount of potable water in winter as non -reclaimed water users, but used less potable water in the
summer. The Triad area is very similar to the Cary area; however, it may have a slightly cooler climate and
shorter growing season.
A cost effective reduction of a surface water discharge requires commercial and industrial users on a year-
round basis. Examples of commercial and industrial customers that were the top water customers in 2008
include Evonik Stockhausen, Inc., University of NC at Greensboro, Proctor and Gamble, Moses H. Cone
Hospital, and RF Micro Devices. Examples of landscape irrigation -based potential wastewater reuse
customers include the Grandover Resort, the Greensboro Country Club, the Cedarcrest Golf Course, and
the Forest Oaks Country Club.
The T.Z. Osborne WWTP is located in the northeast region of Greensboro, various golf courses and resorts
are as far as 16 miles and as close as 7 miles from the T.Z. Osborne WWTP. Additionally, most of the
industries are located on the western side of Greensboro. Evonik Stockhausen, a chemical and polymer
Hazen and Sawyer Project No. 32167-001
HAZENANDSOVitElt
Environmental Englaten Jk Sdeatists
3-6

Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
manufacturer, is located 10 miles southwest of the T.Z. Osborne WWTP. RF Micro Devices, a
semiconductor design and manufacture company, is located approximately 20 miles west of the VVWTP. In
the present worth analysis of the wastewater reuse alternative, it was assumed that treated effluent would
be pumped from the T.Z. Osborne WWTP to the same land application site discussed in Section 3.2 due to
the extremely long distances required to manufacturing facilities.
Wastewater reuse standards are more stringent than the T.Z. Osborne VWVTP's speculative limits for total
suspended solids, fecal coliform, and turbidity. Therefore, the cost of the reclaimed water effluent disposal
includes the cost of an additional chlorine feed system for the 16 mgd effluent flow pumped to dedicated
spray irrigation sites. Although current effluent total suspended solids at the T.Z. Osborne VWVTP met the
reuse standard of 5 mg/I approximately 58 percent of the time in 2010, it is assumed that the upgraded
facility' s tertiary filtration process will be capable of producing effluent that will meet the reuse permit
monthly average for solids.
Table 3-3 summarizes the total present worth for the reuse disposal alternative. Costs include land
acquisition, spray field infrastructure, effluent pump station and force main, upgrades to the T.Z. Osbome
WWTP, and decommissioning the North Buffalo Creek VWUTP. The total present worth for this alternative
is approximately $457,090,000, which is 340 percent higher than the selected alternative of expanding the
T.Z. Osborne WWTP to 56 mgd.
Water reuse is not considered a reliable effluent disposal option. The extreme seasonal variation in non -
potable water demand requires large contiguous dedicated properties for spray irrigation. The capital and
total present worth costs are 3.4 times higher than the selected alternative. The challenge of land
acquisition for reuse is similar to the land application altemative. The North Buffalo Creek WWTP will
require an upgrade for nutrient removal to comply with the Jordan Lake Nutrient Reduction Rules before
the acquisition of 6,400 acres of land could be accomplished. Therefore, this effluent disposal alternative
was removed from consideration in this EA.
Hazen and Sawyer Project No. 32167-001
HAM Alg&IR
Enlronmental Enelaeen & Scientists
3-7

Environmental Assessment for
T.Z. Osborne Water Reclamation
Facility Expansion
Alternatives Analysis
Table 3-3: Present Worth Analysis for Reclaimed Water Effluent Disposal Alternative
Component
Land Application System
Land Acquisition Cost $30,700,000 $30,700,000 N/A
Spray Field Infrastructure $198,530,000 $0 20
30 and 5 Day Storage Ponds $80,990,000 $0 20
Access Roads $350,000 $0 20
Monitoring Wells $640,000 $0 20
Reuse Effluent Pump Station $1,790,000 $0 20
Effluent Distribution Force Main $20,380,000 $0 20
Improvements at T.Z. Osborne 2
North Buffalo Creek Decommission
Improvements at T.Z. Osborne 6
Subtotal
Salvage Value
Project Salvage Useful life
Cost'' 3 Amount (years) 4
$1,500,000
$62,380,000
$397,450,000
$0
$0
$0
20
20
(*)
Present Worth Present Worth
Project Cost of O&M 5 of Salvage
$397,450,000 $70,700,000 $10,280,000
Total Present Worth for Reuse of 16 mgd
North Buffalo Creek WWTP Effluent and Nutrient Removal $457,900,000
Upgrade for 40 mgd T.Z. Osborne WWTP :
Note: Time Period = 20 years, Interest Rate = 5.625%
1 Cost in 2010 Dollars.
2 From Final Master Plan Report, March 2011, CDM ! Hazen and Sawyer.
3 Project costs include construction, contractor overhead and profit, bonds and insurance, contingency,
engineering, administration, and legal costs.
4 Useful life of structures, piping, electrical equipment, and mechanical equipment estimated at 20 years.
5 O&M costs include continued pumping to T.Z. Osbome WWTP, plant power costs, chemical requirements,
equipment replacement, staffing needs, and equipment maintenance and repair. A 3% inflation rate per year
was used for power and chemical costs.
61t was assumed that all of the recommended aeration basin improvements would be required to treat to reuse
effluent quality standards in addition to all of the other plant improvements.
Hazen and Sawyer Project No. 32167-001
H47ENANT SOWER
Environmental Engineers & Selsntlets
3-8

1.1 Surface Water Discharge to South Buffalo Creek (Selected Alternative)
The Final Master Report identified the upgrade and expansion of the T.Z. Osborne WVVTP from 40 mgd to
56 mgd as the recommended treatment alternative based on economic feasibility and treatment process
reliability. The selected alternative includes decommissioning the aging North Buffalo Creek VVWTP. Per
Section 3.1, significant rehabilitation efforts are required to continue operating the North Buffalo Creek facility,
as several structures date from 1938. The transfer pump station located on the North Buffalo Creek VWVTP
plant site will continue to operate. This pump station will transfer the entire wastewater flow from the North
Buffalo Creek collection system to the T.Z. Osborne WVVfP. The proposed expansion and nutrient removal
upgrade of the T.Z. Osborne facility will comply with the Jordan Lake Nutrient Reduction Rules for nitrogen
and phosphorus.
The recommended treatment alternative will result in an expanded surface water discharge to South Buffalo
Creek. Section 3.5.3 provides a discussion of water quality associated with the expanded discharge.
1.1.1 Design Modifications
Figure 3-2 provides a site plan of the proposed expansion to 56 mgd. All of the construction work will be
contained to plant property. A summary of the plant modifications associated with this alternative are as
follows:
• Modify the existing twelve aeration basins for biological nutrient removal (BNR) and add four
additional BNR basins to accommodate the expanded flow.
• Modify existing aeration system to accommodate the flow expansion.
• Add three new secondary clarifiers with associated retum and waste activated sludge
facilities.
• Add chemical phosphorus removal storage and feed facilities.
• Add two new tertiary filters.
• Add two new chlorine contact tanks.
• Construction of a parallel outfall line to South Buffalo Creek.
Minor modifications will be required at the North Buffalo Creek VW TP. A new 500 HP transfer pump must be
installed in the empty pump slot of existing transfer pump station to accommodate the peak hydraulic
throughput. Existing equipment from buildings and process tankage will be removed, although some of the
tankage will be converted to influent flow equalization. Demolition of the buildings and process tankage will
not be included in the plant decommissioning process.
1.1.2 Cost Estimate
The total present worth analysis for the proposed project is provided in Table 3-4. Capital costs include the
decommission of North Buffalo Creek WWTP, nutrient removal upgrades at the T.Z. Osborne WWTP, and
expansion of the T.Z. Osborne facility from 40 to 56 mgd. Total present worth costs for the selected
altemative are approximately 13 percent less than the no -action alternative, 331 percent less than the land
application alternative, and 240 percent less than the reuse alternative.

Table 3-4: Present Worth Analysis for Nutrient Removal Upgrade and Expansion of
TZ. Osborne WWTP to 56 mgd (Selected Alternative)
Project
Component Cost 1' 2' 3
Decommission North Buffalo Creek $1,500,000
Improvements at TZ. Osborne
Aeration Basin Modifications $33,076,000
Secondary Clarifier Modifications $9,916,000
Chemical Feed Systems $546,000
Disinfection $8,742,000
Yard Piping $3,054,000
Electrical $2,686,000
Salvage Value
Salvage Useful life
Amount (years) 4
$0
$0
$0
$0
$0
$0
20
20
20
20
20
20
Subtotal
$63,900,000
$0
(*)
Present Worth
Project Cost of O&M 5
Present Worth
of Salvage
$63,900,000 $69,300,000
$0
Total Present Worth for Nutrient Removal Upgrade
and Expansion of TZ. Osborne WWTP to 56 mgd: $133,200,000
Note: Time Period = 20 years, Interest Rate = 5.625%
I Cost in 2010 Dollars.
2 From Final Master Plan Report, Match 2011, CDM I Hazen and Sawyer.
3 Project costs include construction, contractor overhead and profit, bonds and insurance, contingency,
engineering, administration, and legal costs.
4 Useful life of structures, piping, electrical equipment, and mechanical equipment estimated at 20 years.
5 O&M costs include continued pumping to T.Z. Osbome WWTP, plant power costs, chemical requirements,
equipment replacement, staffing needs, and equipment maintenance and repair. A 3% inflation rate per year was
used for power and chemical costs.
1.1.3 Water Quality Discussion for the Expanded Surface Water Discharge
The Jordan Lake Nutrient Reduction Rules were adopted in August 2009 to limit nutrient loadings and
provide a nutrient control strategy for both point and non -point sources in the Jordan Lake Watershed. The
biological treatment processes at both the T.Z. Osborne WWTP and the North Buffalo Creek WWTP must be
modified to meet a combined annual total nitrogen and total phosphorus mass load allocation of
902,715 lb/year and 113,315 lb/year, respectively. The annual mass loadings are equivalent to maximum
effluent concentrations of 5.29 mg/I of total nitrogen and 0.66 mg/I of total phosphorus at a combined
maximum month flow of 56 mgd. The total phosphorus limit was in effect as of January 2010. The total
nitrogen limits will be effective on January 1, 2018.
In early 2010, Greensboro requested speculative limits for an expansion of the T.Z. Osborne WWTP from 40
to 56 mgd as a result of the Final Master Plan recommendations for treatment and reliability to meet the
Jordan Lake Nutrient Reduction Rules. DWQ issued a speculative limits letter on December 20, 2010 for

decommissioning the North Buffalo Creek WWTP and expanding the T.Z. Osborne WWTP from 40 to
56 mgd (Appendix A). The letter included the current total Jordan Lake nutrient allocations, as well as
speculative limits for the proposed surface water discharge of 56 mgd to South Buffalo Creek. Table 3-5
summarizes the permit limits at the T.Z. Osborne and North Buffalo Creek VVWTPs (as of June 30, 2011) and
the speculative limits from DWQ in December 2010.
Table 3-5: Current and Speculative Effluent NPDES Permit Limits for North Buffalo Creek and
TZ. Osborne Facilities
Current North Buffalo Current Speculative
Creek WWTP Limits T.Z. Osborne WWTP T2. Osborne WWTP
at 16 mgd Limits at 40 mgd Limits at 56 mgd
Monthly Weekly Monthly Weekly Monthly Weekly
Parameter Average Average Average Average Average Average
CBOD5 (summer), mg/I 8.0 12.0 4.0 6.0 4.0 6.0
CBOD5 (winter), mg/I 16.0 24.0 8.0 12.0 8.0 12.0
Total Suspended Solids, mg/I 30.0 45.0 30.0 45.0 30.0 45.0
Ammonia as N (summer), mg/I 4.0 12.0 2.0 6.0 0.82 2.46
Ammonia as N (winter), mg/I 8.0 24.0 4.0 12.0 1.64 4.92
Dissolved Oxygen, mg/1' 6.0 6.0 6.0
Fecal Coliform, per 100 ml 200 400 200 400 200 400
Total Nitrogen Monitor and Report Monitor and Report 891,272 lb/year 2.3
Total Phosphorus 32,359 lb/year 4 81,156 lb/year 4 112,044 lb/year 5.3
Quarterly Chronic Toxicity 6 90% 90% 90%
Daily minimum concentration.
2 Equals a 5.23 mg/i concentration at design flow.
3 The mass limits presented in this table are the point of discharge limits.
4 Total phosphorus limits went into effect on January 1, 2010 per the Jordan Lake Nutrient Reduction Rules.
5 Equals a 0.66 mg/i TP concentration at design flow.
6 Based on the allowable instream waste concentration.
The North and South Buffalo Creeks are listed as impaired for copper, zinc, and biological integrity on the
Draft 2012 303(d) List. The ammonia impairment status in 2010 for both creeks was removed in 2012. The
speculative limits were developed prior to the removal of the ammonia impairment. Consistent with
Environmental Protection Agency (EPA) policy for impaired waters, DWQ froze the current T.Z. Osborne
WWTP CBOD5 limits of 4 mg/I in summer and 8 mg/I in winter and reduced the monthly average ammonia
concentration. The resulting ammonia speculative limits are 0.82 mg/I in summer and 1.64 mg/l in winter.
The benthic classification for South Buffalo Creek has been classified as poor, hence the reason for the
biological integrity impairment status in this receiving stream. In 2010, South Buffalo Creek was also
assigned an impairment status for ammonia with a reason for the rating as "Data Inconclusive." However, a
review of the ambient water quality data for South Buffalo Creek from the August 2009 Cape Fear River
Basin Ambient Monitoring System Report at stations B0670000 and B0750000 indicates that an ammonia
impairment status for this receiving stream is not justified by the ambient water quality monitoring data. The
90th percentile ammonia data is 0.16 mg/I and 0.09 mg/I at stations B0670000 and B0750000, respectively.
The poor bioclassification status should not be attributed to dissolved oxygen either, as there were no
violations of the water quality standard for dissolved oxygen over the four year monitoring period. Table 3-6
summarizes dissolved oxygen, ammonia, copper, and zinc at Stations B0760000 and B750000. The
ammonia impairment status was removed from the Draft 2012 303(d) List.

Table 3-6: Summary of Division of Water Quality Ambient Monitoring Data for the Cape Fear River
Basin at Stations B0670000 and B0750000 in South Buffalo Creek
L
y o E as a)d E P.
o a. e E d ci) e E �� d
o f Cm 'E s E 5 L so c >
�a
Z U) Z 2 � a v a a s E CI) < Ji
Station B0670000 1
Dissolved oxygen, mg/I 86 0 4.4 5.9 9.3 12.6 16.7 4
Ammonia as N, mg/I 61 21 0.01 0.02 0.05 0.16 1.91 N/A
Copper, pg/I 3 25 8 2 2 3 12 25 7
Zinc, pg/13 26 7 10 10 14 35 115 50
Bioclassification Poor
Station B0750000 2
Dissolved oxygen, mg/I 56 0 5.2 5.7 7.6 10.7 13.2 4
Ammonia as N, mg/I 59 13 0.02 0.02 0.03 0.09 1.8 N/A
Copper, pg/I 3 13 0 2 3 5 8 9 7
Zinc, pg/I 3 13 0 33 36 54 98 110 50
Bioclassification Poor
'DWQ Ambient Water Quality Monitoring Station located upstream of the T.Z. Osbome WWTP discharge.
2 DWQ Ambient Water Quality Monitoring Station located downstream of the T.Z. Osbome WWTP discharge.
3 Permitted as an Action Level in North Carolina.
EPA has delegated control of ammonia toxicity to individual states. DWQ has developed a policy to use an
instream ammonia criterion of 1.0 mg/I in summer and 1.8 mg/I in winter. These ammonia criteria are not
officially criteria in North Carolina as ammonia standards have not been formally adopted for non -trout waters
in this state. For existing discharges where potential toxicity may be occurring, the NPDES permit holder may
use the Whole Effluent Toxicity (WET) test to show that toxicity is not occurring in the receiving stream. The
T.Z. Osbome WV TP has passed all of its WET tests in the last five years. Greensboro proposes that the T.Z.
Osborne WWTP ammonia limits be specified according to the current ammonia toxicity policy for unimpaired
waters. The speculative limits letter stated that South Buffalo Creek has adequate assimilative capacity for an
expanded NPDES discharge from 40 to 56 mgd. Greensboro proposes that a tiered NPDES permit for the
T.Z. Osborne VVWTP be developed that would contain summer limits of 1 mg/I and winter limits of 1.8 mg/I
per DWQ policy.
Copper and zinc are permitted as an action levels per North Carolina Administrative Code 15A NCAC
2B .0200. If a facility consistently fails to pass the WET test, then action level pollutant limits may be
imposed. The current T.Z. Osborne WWTP NPDES permit contains monitoring requirements for copper and
zinc. The facility has passed all of its WET tests in the past five years. The ambient water quality data for
copper and zinc in South Buffalo Creek does indicate 90thpercentile concentration exceedances of the action
level for zinc at Station B0760000 and copper and zinc at Stations B0760000 and B0750000. The permitted
lnstream Waste Concentration (IWC) for the T.Z. Osbome WWTP is 90 percent; therefore, the majority of the
South Buffalo Creek flow is from the T.Z. Osbome WVVTP effluent discharge. The ambient water quality data
may indicate copper and zinc concentrations higher than the action level; however, based on the WET
results, the effluent discharge is clearly not contributing to toxicity in the receiving stream. Therefore, it should

be concluded that the copper and zinc impairment status in South Buffalo Creek should not prohibit an
expansion of the T.Z. Osbome WWTP.
1.1.4 Conclusion
This alternative was selected for the least environmental and economic impact and the most feasible
engineering solution, The upgrade and expansion of the T Z =Osborne WWTP to 56 mgd was identified as
the most favorable alternative to address the reduction of total nitrogen and total phosphorus mass
allocations required.by the Jordan Lake Nutrient Reduction Rule. Greensboro is not requesting an increase in
total permitted 'discharge capacity, as the combined capacity of 56 mgd will<serve Greensboro through the
I? �tY�
next planningeriod .Additionally, Greensboro intends to rescind the,NPDES p permit for the North Buffalo
Y
Creek WWTP.