NC0023884_Permit Modification_20030815

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
August 15, 2003
Mr. John C. Vest, Utilities Director
City of Salisbury
P.O. Box 479
Salisbury, North Carolina28145
ILTZ.NAA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Modification
Permit NCO023884
Yadkin River Regional W\VTP
Rowan County
Dear Mr. Vest:
As agreed upon in the settlement dispute regarding the contested case. the Division of Water Quality is
hereby forwarding the final permit modification. Please find enclosed the revised permit.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
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 a written petition conforming to
Chapter 150B of the North Carolina General Statutes, filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this
decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning this permit modification, please contact Christie Jackson at
telephone number [phone], extension 538.
Sincerely,
Original Signed By
David A. Goodrich
Alan W. Klimek. P.E.
cc: Mooresville Regional Office, Water Quality Section
NPDES Unit
Aquatic Toxicology
EPA Region 1V
1617 Mail Service Center. Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer VISIT us ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit NCO02388-4 �
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water
Pollution Control Act, as amended, the
City of Salisbury
is hereby authorized to discharge wastewater from the facilities located at the
Salisbury -Rowan WWTP
1915 Grubb Ferry Road
Salisbury
Rowan County
and
850 Heiligtown Road
East Spencer
Rowan County
to receiving waters designated as the Yadkin River in the Yadkin -Pee Dee River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IN'
hereof.
The permit shall become effective September 1, 2003.
This permit and the authorization to discharge shall expire at midnight on July 31, 2004.
Signed this day August 15, 2003.
Original Signed By
David A. Goodrich
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

r t Permit NC0023884
SUPPLEMENT TO PERT 1T COLTER SHEET
The City of Salisbury is hereby authorized to:
1. Continue to operate and maintain the existing 7.5 AIGD Grant Creek Wastewater Treatment Train
consisting of
Influent parshall flume
Four mechanical bar screens
Four grit chambers
> Aeration basin with mechanical floating aerators and mixers
➢ Two circular clarifiers and two rectangular clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Belt filter press
Standby power generator
Effluent pump station
Flow measurement instrumentation
This treatment train is located on Grubb Ferry Road in Salisbury in Rowan County.
2. Continue to operate and maintain the existing 5.0 'NIGD Town Creek Treatment Train consisting of:
➢ Two mechanical bar screens
Two grit and grease removal units
Two aeration basins with fixed mechanical aerators and mixers
Two secondary clarifiers
> Screw pump lift station
Two aerobic digesters
> Standby power generator
Flow measurement
➢ Sludge dewatering facilities
> Effluent pump station
This treatment train is located on Heiligtown Road near East Spencer in Rowan County.
3. Continue to operate and maintain an ultraviolet or sodium hypochlorite disinfection system, cascade
post aerator, Parshall flume, effluent sampling station and diffuser at the Yadkin River treatment train.
4. After receiving an Authorization to Construct from the Division, construct and operate a 20.0 NIGD
wastewater treatment system.
5. Discharge from said treatment works at the location specified on the attached map through Outfall 001
into the Yadkin River which is classified as WS-V waters in the Yadkin -Pee Dee River Basin.

Z1,
7.
V_
S
Nn
0
Yadkin River Regional WWTP
State GridQuuL- E171NW/Salisbizy Latkbxlc
35' 44' OT' N
Lcoj#bjde:
80* 26! 50" W
Bacphipg Stream Yadldn River DrainageBasin
Yadkin
StreamClam WS-V Sub -Bay -
03-07-04
45 , _i�
A-1
Fa&ity Locafim
riot ti) scale
NMES Permit No. NCO023884
N rth Rowan County

Permit NCO023884
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (12.5 MGD)
During the period beginning on the effective date of the permit and lasting until expansion beyond 12.5 MGD, the
Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored be the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Avera a
Daily
Maximum
Measurement
Frequency
Sample
T e
Sample
Locations
Flow
12.5 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5 day, 20 °C
(April 1 to October 31)
15.0 mg/L 6
22.5 mg/L
Daily
Composite
Influent &
Effluent
BOD, 5 day, 20 °C
(November 1 to March 31)
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent &
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent &
Effluent
NH3 as N
(April 1 to October 31)
6.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1 to March 31)
12.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen'-
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent
PH 3
Daily
Grab
Effluent
Total Residual Chlorine 4
28 µg/L
Daily
Grab
Effluent
Total Nitrogen
(NO, + NO, + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicity
Quarterly
Composite
Effluent
Notes:
1. Combined effluent from the Grant Creek and Town Creek treatment trains, except that flow, BOD and TSS shall
be sampled separately at the Town Creek treatment train and the Grant Creek treatment train. BOD and TSS
removal efficiency shall be calculated by mathematically aggregating the values for the Grant Creek and Town
Creek treatment trains. (Refer to A. (6.).)
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only applies if chlorine is added to the treatment system.
5. Chronic Toxicity limit (Ceriodaphnicr) at 6.6',o with testing in March, June, September and December (see A. (4)).
6. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85 °"o removal).
7. 7.5 MGD at Grant Creek treatment train. 5.0 MGD at Town Creek treatment train.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC00238S4
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (20 MGD)
During the period beginning after expansion beyond 12.5 MGD and lasting until expiration, the Permittee is
authorized to discharge from Outfall 001. Such discharges shall be limited and monitored be the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Avera a
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow
20 MGD
Continuous
Recording
Effluent
BOD, 5 day, 20 °C
(April 1 to October 31
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent and Effluent
BOD, 5 day, 20 °C
November 1 to March 31
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent and Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent and Effluent
NH3 as N
(April 1 to October 31
1.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1 to March 31
2.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen2
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent
H3
Daily
Grab
Effluent
Total Residual Chlorine'
28,u L
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicity5
Quarterly
Composite
Effluent
Notes:
1. Sample locations: E - Combined Effluent from Grant Creek and Town Creek
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only applies if chlorine is added to the treatment system for disinfection.
5. Chronic Toxicity Limit (Cerzodaphnia) at 10.5 % with tests in March, June, September and December (see A. (5)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCH 23884
A. (3) INSTREAM MONITORING REQUIREMENTS:
EFFLUENT
CHARACTERISTICS
MONITORING REQUIREMENTS
Measurement Frequency
Sample Type
Sample Location
Dissolved Oxygen
June -September
3/week
Grab
Upstream & Downstream
October -May
1/week
pH
June -September
3/week
Grab
Upstream & Downstream
October -Ma
1/week
Temperature
June -September
3/week
Grab
Upstream & Downstream
October -May
1/week
Total Phosphorus
June -September
1/month
Grab
Upstream & Downstream
NO2+NO3
June -September
1/month
Grab
Upstream & Downstream
NH3 as N
June -September
1/month
Grab
Upstream & Downstream
Total Kjeldahl Nitrogen
June -September
1/month
Grab
Upstream & Downstream
Chlorophyll -a
June -September
1/month
Grab
Downstream
Notes:
Upstream = at least 200 feet upstream of the discharge point
Downstream = 0.7 miles above Southern Railroad Bridge.
As a participant in the Yadkin Pee -Dee River Basin Association, the instream monitoring requirements as stated
above are waived. Should your membership in the agreement be terminated, you shall notifi- the Division
immediately and the instream monitoring requirements specified in your permit shall be reinstated.
As per 15A NCAC 2B.0505 (c) (l), stream sampling may be discontinued at such time 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. In such cases, on each day that sampling is discontinued, written justification for the discontinuance shall be
specified in the monitoring report for the month in which the event occurred. This provision shall be strictly
construed and may not be utilized to avoid the requirements of 15 A NC AC 213.0500 when performance of these
requirements is attainable. When sampling is discontinued pursuant to this provision, stream sampling shall be
resumed at the First opportunity after the risk period has ended.
A. (4) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 12.5 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 6.6 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February. 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of \larch, June, September, and December. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
(continued on next page)

Permit N0IO23S84
A. (5) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 20 MGD
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 folloNving months as
described in "North Carolina Phase II Chronic Whole Effluent Toxiciq Test Procedure" (Revised -February- 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February- 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 flail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility
name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of %Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid
test and will require immediate follow-up testing to be completed no later than the last dad- of the month following
the month of the initial monitoring.
A. (5) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 20 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 10.5 %.
(continued on next page)

Permit N010213884
A. (5) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 20 MGD (continued)
41
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised Febrian- 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity- Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of March, June, September, and December. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised-Februan- 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention:. NC DENR / DWQ / Environmental Sciences Branch
1621 Mad Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility
name, permit number, pipe number, count}-, and the month/rear of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of \Vater
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid
test and wi11 require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

Pcrmit NC002388,t 'F
A. (6.) AGGREGATE CALCULATION OF GRANT CREEK AND TOWN CREEK TSS AND
BOD REMOVAL EFFICIENCY
TSS %v%vri, inti = (TSS(;(: ii,,e 1 Flow(;(-) + (TSS-rc i�,ti 1 Flow-rc)
F1owcC + Flowrc
TSS wAvrr I:fti = (TSS(;(-. I:ftl t Flow(;c) + (TSS•rc i•:fti s Flow rc)
Flow(;c + Flowrc
TSSRi;�iov.u. _ [1 - (TSS\twrr efts / TSS\v -ri, i„ti)] x 100' o
Notes:
"Effl" =
Effluent
"Infl" =
Influent
"GC" =
Grant Creek Treatment Train
"TC" = Town Creek Treatment Train
"W'WTP"
= Salisbury -Rowan WWTP
a

NCDENR
#49068
Due: $75.42
SalisburyW"�oSt
AFFIDAVIT OF PUBLICATION
NORTH CAROLINA
ROWAN COUNTY
Before the undersigned a Notary Public of said County and State, duly commissioned, qualified, and authorized by la,
administer oaths, personally appeared wINFRED MENTION, who being first duly sworn, deposes and says that he is
ASSISTANT ADVERTISING DIRECTOR of the Salisbury Post, published, issued and entered as second class mail in t
City of Salisbury, in said County and State, that he is authorized to make this affidavit and sworn statement, that the
notice or other legal advertisement a true copy of which is attached hereto, was published in the Salisbury Post, on t11
following dates:
May 9, 2003
and that the said newspaper in which such notice, paper document or legal advertisement was published was, at th
time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1
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.
Sworn and subscribed before me
This 13th day of May, 2003
f
NOTARY,]
My Commission Expires
PO Box 4639 Salisbury, NC 28145-4639 [phone]

Fwd: Salisbury NPDES Permit Settlement Agreement
f
• Subject: Fwd: Salisbury NPDES Permit Settlement Agreement
Date: Fri, 01 Aug 2003 13:31:31 -0400
From: "Mary Thompson" <MTHOMP@maiIJ us. state. nc. us>
To: <christie [e-mail]>, <[e-mail]>
Dave and Christie -
Randy says the error was just a confusion over symbols, so go ahead and finalize the permit by attaching the
formula as a special condition and make it clear that the symbol is a division sign rather than a plus sign.
- Mary Penny
Subject: Salisbury NPDES Permit Settlement Agreement
Date: Fri, 1 Aug 2003 12:34:18 -0400
From: [e-mail]
To: "Mary Thompson" <[e-mail]>
CC: "Matt Bernhardt" <[e-mail]>,
"John C. Vest" <[e-mail]>,
"Carol Hamilton" <[e-mail]>
Mary Penny:
The formula as amended by Christie Jackson is mathematically identical to
the formula proposed by Salisbury in my 5/ 12/2003 e-mail to you (attached).
The only change is the choice of symbol to indicate division. Salisbury
has no objection to your client's preference.
Randy
"Mary Thompson"
<[e-mail].s
tate.nc.us> cc:
Subject:
07/30/2003 11:01
AM
To: <[e-mail]>
City of Salisbury: Calculation Resolution?
1 of 3 8/l/03 2:09 PN.

City of Salisbury: Calculation Resolution?
r
• Subject: City of Salisbury: Calculation Resolution?
Bate: Wed, 30 Jul 2003 11:01:47 -0400
From: "Mary Thompson" <MTHOMP@mail.j us. state. nc. us>
To: <[e-mail]>
Randy -
In the last calculation, a plus sign needs to be changed to a division sign.
Currently, the calculation shows:
TSSremoval = [1- (TSSwwtp effl + TSSwwtp infl)] x 100%
DWQ says it should read:
TSSremoval = [1- (TSSwwtp effl/TSSwwtp infl)] x 100%
If this change is satisfactory to you and your client, Christie Jackson, the permit writer, can finalize the permit by
adding this as a Special Condition. She does not think the permit modification will need to be re -noticed. Please
respond back to me by e-mail if this is acceptable. If you want to discuss the calculation, please feel free to call
me at my direct dial number [phone].
Thanks for your continued patience and I hope this wraps it up!
Mary Penny
Mary Penny Thompson
Assistant Attorney General
Environmental Division
N.C. Department of Justice
P. O. Box 629
Raleigh, NC 27602-0629
[phone] / main phone
[phone] / direct dial
[phone] / fax
[e-mail]
1 of 1 7/30/03 11:38 AN

Salisbury NPDES Permit Settlement Agreement
-'Subject: Salisbury NPDES Permit Settlement Agreement
Date: Wed, 16 Jul 2003 16:54:42 -0400
From: Dave Goodrich <dave. goodrich@ncmail. net>
To: Mary Thompson <[e-mail]. nc.us>
CC: Christie Jackson <[e-mail]>
Yes. We believe this calculation to be incorrect. It is a fairly simple correction, but Christie Jackson has been
busy with other things and has been out of the office for the last two weeks. She'll return next week and I'll ask
her to make this a priority. We appreciate Randy's patience.
Mary Thompson wrote:
Randy Tinsley is chomping at the bit for an answer- (see attached). Do we have one yet?
Subject: Re: Salisbury NPDES Permit Settlement Agreement
Date: Tue, 15 Jul 2003 17:55:45 -0400
From: [e-mail]
To: "Mary Thompson" <[e-mail]>
CC: chami @ sali sburync.org, [e-mail],
Mbern @ci.salisbury.ne.us
Mary Penny:
Has your client concluded its review (lasting more than two months, so far)
of Salisbury's formula for aggregating data? My impression is that the
formula is straightforward and uncomplicated. Unless there is some reason
to believe that the math is incorrect, can we get your client's agreement
on it?
Randy
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on 07/15/2003 05:47 PM
V RANDALL TINSLEY
To: "Mary Thompson" <[e-mail]>
07/07/2003 03:02 cc: [e-mail], [e-mail],
PM Mbern @ci.salisbury.nc.us
Subject: Re: Salisbury NPDES Permit Settlement Agreement
Mary Penny:
This one is overdue.
Randy
1 of 7
7/21/03 9:47 AN

Salisbury NPDES Permit Settlement Agreement
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on 07/07/2003 03:02 PM
V RANDALL TINSLEY
To: "Mary Thompson" <[e-mail]>
06/23/2003 04:20 cc: [e-mail], [e-mail],
PM Mbern @ci.salisbtiry.nc.us
Subject: Re: Salisbury NPDES Permit Settlement Agreement
(Document link: V RANDALL TINSLEY)
Any news?
"Mary Thompson"
<[e-mail].s To: <[e-mail]>
tate.nc.us> cc: <[e-mail]>,
<Mbei•[e-mail]•y.nc.us>, <[e-mail]>
06/13/2003 11:26 Subject: Re: Salisbury NPDES Permit Settlement Agreement
AM
Randy -
I have prompted my client for an answer on your question and they have
renewed their efforts to address it. They are concerned about the
mathematical calculation and do not remember stipulating to it - which is
causing the delay. If they can agree to it, they will modify the permit
and will not need to re -notice it. If I hear something today, I will
certainly pass it on to you.
- Mary Penny
Mary Penny Thompson
Assistant Attorney General
Environmental Division
N.C. Department of Justice
P. O. Box 629
Raleigh, NC 27602-0629
[phone] / main phone
2 of 7 7/21/03 9:47 AN

Salisbury NPDES Permit Settlement Agreement
[phone] / direct dial
[phone] / fax
[e-mail]
>>> <[e-mail]> 6/12/03 10:17 >>>
Mary Penny:
I am still waiting to hear from you.
Tomorrow may be the deadline for making comments on the draft permit that
was sent out for notice by your client.
Contrary to the permit notice letter sent by your client, the agreement
does not yet exist.
Please let me know if Salisbury can attach the calculations and finalize
the agreement.
A response today from your client would be helpful. It is worth
remembering that the calculations were discussed and OK'd during
negotiations. Although mathemetical aggregation is expressly included in
the permit now, the purpose for spelling out the calculations to be used is
to avoid any disputes in the future (i.e., re -invent the answer that we
have already found and agreed -to).
Randy
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on 06/12/2003 10:17 AM
V RANDALL TINSLEY
To: "Mary Thompson"
<MTHOMP @ mai 1. j us. state. ne.us>
05/30/2003 05:46 cc:
PM Subject: Re: Salisbury NPDES
Permit Settlement Agreement
(Document link: V RANDALL
TINSLEY)
Please let me know ASAP so that we can get on with it. Thanks.
3 of 7 7/21/03 9:47 AN.

Salisbury NPDES Permit Settlement Agreement
` "Mary Thompson"
<[e-mail].s To:
<RTINSLEY @ brookspi erce. com>
tate.nc.us> cc:
Subject: Re: Salisbury
NPDES Permit Settlement Agreement
05/30/2003 05:32
I
I have not heard back from my clients on their review of the calculations
page, so I would say no at this time. I will be out of the office on
Monday, but will try to raise the issue with them again on Tuesday.
>>> <[e-mail]> 5/30/03 1:31 >>>
Mary Penny:
Can the City of Salisbury attach the calculations page to the agreement and
sign it, so that we can dismiss the OAH case?
Randy
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on 05/30/2003 01:30 PM -----
V RANDALL TINSLEY
To: "Mary Thompson"
<MTHOMP @ mail. j us. state.nc. us>
05/19/200310:13 cc:
AM Subject: Re: Salisbury NPDES
Permit Settlement Agreement
(Document link: V RANDALL
TINSLEY)
Is it significant re public notice that the DWQ cover letter on the permit
refers to a settlement agreement that has not actually been finalized?
4 of 7 7/21/03 9:47 AN

Salisbury NPDES Permit Settlement Agreement
Y
"Mary Thompson"
<[e-mail].s To:
<RTINSLEY @brookspierce.com>
tate.nc.us> cc:
Subject: Re: Salisbury
NPDES Permit Settlement Agreement
05/19/2003 10:03
0
Randy -
I forwarded your request to my clients and they are verifying the numbers.
They remember discussing the numbers, but not agreeing to include them in
the permit. This is complicated by the fact that the permit is already out
to notice. Adding changes could mean re -noticing the permit. My client is
looking into your request, but told me it would take a couple of weeks to
return a response.
- Mary Penny
>>> <RTINSLEY @brookspierce.com> 5/19/03 8:56 >>>
Mary Penny:
I have received no response to my e-mails and voicemails to you. Please
let me know how the State wishes to proceed at this point.
Randy
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on 05/19/2003 08:56 AM -----
V RANDALL TINSLEY
To:
MTHOMP @mail.jus.state.ne.us
05/15/2003 09:56 cc:
AM Subject: Salisbury NPDES
Permit Settlement Agreement
5 of 7 7/21/03 9:47 AN

Salisbury NPDES Permit Settlement Agreement
Mary Penny:
Salisbury received yesterday a draft NPDES permit modification referencing
an agreement. I expect this to work out just fine, but please let me know
if Salisbury can attach the calculations to the settlement agreement.
Thank you.
Randy
----- Forwarded by V RANDALL TINSLEY/BPMHL/US on O5/15/2003 09:51 AM
V RANDALL TINSLEY
To:
[e-mail]
05/12/200310:27 cc:
[e-mail], "John C. Vest"
AM <[e-mail]>,
"Matt Bernhardt"
<Mbern@ ci . salisbury.nc.us>
Subject: Salisbury NPDES
Permit Settlement Agreement
Mary Penny:
Attached is the set of calculations that Salisbury would like to have
attached to the permit markup exhibit. This set of calculations was
included in the August letter from John Vest to Dave Goodrich.
Please let me know if we can go ahead and attach this as the new last page
of the exhibit so that the City can go ahead and file the notice of
dismissal, etc in OAH.
Thanks,
Randy
6 of 7 7/21/03 9:47 AN

Re: City of Salisbury WQPA: Permit Mod update?
• Subject: Re: City of Salisbury WgPA: Permit Mod update?
Date: Mon, 30 Jun 2003 16:04:10 -0400
From: "Mary Thompson" <[e-mail]. state. nc. us>
To: <[e-mail]>
CC: <[e-mail]>
Yes, let's run it past Randy.
>>> Dave Goodrich <[e-mail]> 6/30/03 2:52 >>>
There is a mistake in the mathematical calculations. I think we can
agree to put it in. Christie is handling this, so I'll ask her if she's
ready to issue and when. Mary Penny - Do we need to run it past Randy
before finalizing (so he can see if he agrees with our correction)?
Mary Thompson wrote:
> Dave - Last Monday (June 23rd), Randy Tinsley asked me for an update
> on the permit mod. Have you made any decision yet on the calculations
> he wants to attach to the permit? - Mary Penny
1 of 1 7/ l /03 11:23 AN.

City of Salisbury NPDES Permit Appeal
• Subject: City of Salisbury NPDES Permit Appeal
Date: Wed, 11 Jun 2003 13:53:25 -0400
From: "Mary Thompson" <[e-mail]. state. nc.us>
To: <[e-mail]>, <[e-mail]>,
<mike . templeton@ ncmail. net>
Dave, Christie and Mike,
Opposing counsel continues to ask the status of DWQ's decision on whether the City of Salisbury can attach a
table of calculations to our Settlement Agreement (the City has yet to sign it). Back in May, Dave said he would
ask Christie to get Mike's comments on it because he wasn't sure the table was correct. At that time, Dave said it
would take a couple of weeks. Since it's been about 4 weeks now, has there been any decision on whether the City
can include the table or not? I know the permit modification has already been sent out to notice, so we may also
need to decide if DWQ needs to re -notice it. Any update you can give me would be helpful.
Thanks,
Mary Penny
Mary Penny Thompson
Assistant Attorney General
Environmental Division
N.C. Department of Justice
P. O. Box 629
Raleigh, NC 27602-0629
[phone] / main phone
[phone] / direct dial
[phone] / fax
mthomp@mail. j us.state.nc.us
1 of 1 6/ 16/03 10:41 AN

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
o Q ATLANTA FEDERAL CENTER
Z�F�1��02 61 FORSYTH STREET
�r'14 Pilo, EGA ATLANTA, GEORGIA 30303-8960
June 6, 2003
Ms. Christie Jackson
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Draft Permit Modification
Yadkin River Regional WWTP
NPDES No. NCO023884
Dear Ms. Jackson:
In accordance with the EPA/NCDENR MOA, we have completed review of the permit
modification referenced above and have no objections to the draft permit modification conditions.
We request that we be afforded an additional review opportunity only if significant changes are
made to the draft permit modification prior to issuance, or if significant comments regarding the
modification are received. Otherwise, please send us one copy of the permit modification when
issued.
If you have any questions, please call me at [phone].
Siqrely,
MadolyX,S. Dominy, Envi nment Engineer
Permits, Grants and Technic istance Branch
Water Management Division
rt
t JUN 1 1 2003
Intemet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)

Permit NCO023884
SKATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
JRCES
k115 044..
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM r*110
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations r
promulgated and adopted by the North Carolina Environmental Management Commission, and the federal Water
Pollution Control Act, as amended, the
' V
City of Salisbury .�
is hctc}�y autht>rized to dischar�r wastewater from the facilities 5of-4ties located at the 4
1915 Grubb Feria- Road
Rowan County U
lit V-' oL
TmUly G -,.t. 1x".Q.- ]_
850 Heiligtown Road
East Spencer
Rowan County
to receiving waters designated as the Yadkin River in the Yadkin -Pee Dee River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts 1,11, 111, and 1V
hereof.
The permir shall become effective July 1, 2002
This permit and the authorization to discharge shall expire at midnight on July 31, 2004.
Signed this day May 20, 2002.
lfe� /V) AL-)
F Gregory J. Thorpe, Acting Director
Division of L`Vatcr Qualiry
By Authority of the Environmental Management Commission

1 's
Permit NCO023884 ,
SUPPLEMENT TO PERMIT COVER SHEET
The City of Salisbury is hereby authorized to:
Troq k v,
1. Connnue to operate and maintain the exisung 7.5 NIGD Grant Creek \66rStt%""r Treatment Ftrc+i
consisting of
➢ Influent parshall flume
➢ Four mechanical bar screens
➢ Four grit chambers
A Aeration basin with mechanical floating aerators and mixers
➢ Two circular clarifiers and taro rectangular clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Belt filter press
➢ Standby power generator
➢ Effluent pump station
➢ Flow measurement instrumentation �ros��sbvt"�
This k_m7i" is located on Grubb Ferry Road in Rowan County.
`Train
2- Continue to operate and main rain the existing 5-0 MGD Town Creek Wpowmvrer Treatment Fitei4t9
consisting of_
➢ Two mechanical bar screens
➢ T\t-o grin and grease removal units
➢ Two aeration basins ,vith fixed mechanical aerators and misers
➢ Two secondary clarifiers
➢ Screw pump lift station
A Two aerobic digesters
➢ Standby power generator
➢ Flow measurement
A Sludge dewatering facilities
➢ Effluent pump station
This is located on Heiligtown Road near East Spencer in Rowan County-
1�'eo��'i�e►. ;Z.-N or SeaAi vw. k.--)P%cat'�'�'Q
3. Continue to operate and maintain an ultraviolet disc infection system, cascade post aerator, parshafl flume,
effluent sampliri station and diffuser
0
4. After receiving an Authorization to Construct from the Division, construct and operate a 20.0 MGD
wastewater treatment system.
5. Discharge from said treatment works ar the locauon specified on the attached map through OurfaU 001
into the Yadkin River which is classified as DVS-V waters in the Yadkin -Pee Dee River Basin-

Pcrrnit NCO023884
SUPPLEMENT TO PERMIT COVER SHEET
The City of Salisbury is hereby authorized to:
Trot ► r,
1. Connnuc to operate and maintain the cxisung 7.5 NIGD Grant/Creek `fir Treatment
consisting of
➢ Influent parshall flume
➢ Four mechanical bar screens
➢ Four grit chambers
➢ Aeration basin with mechanical floating aerators and mixers
➢ Two circular clarifiers and t-wo rectangular clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Belt filter press
➢ Standby power generator
➢ Effluent pump station
➢ Flow measurement instrumentation S�avr
This is located on Grubb Ferry Road __-__- in Rowan County.
2_ Continue to operate and maintain the existing 5.0 MGD Town Creek W4*@""rrmr Treatment h
consisting of_
➢ Two mechanical bar screens
➢ Two grit and grease removal units
➢ Two aeration basins with fixed mechanical aerators and misers
➢ Two secondary clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Standby power generator
➢ Flow measurement.
➢ Sludge dewatering facilities
➢ L-' ffluent pump station
Thisin*+44&o is located on f-leiligtown Road near East Spencer in Rowan County_
�'r,e V+tit.r•- "�`Y''o�:t or S Q d i v w, >� �► c,..�v i �' Q
3. Continue to operate and maintain an ulrraviolet disc cti infeon system, cascade posr aerator, Parshall flume,
effluent sampliri station and diffuser i
�A-^red `�"�t i a t� k t d, �.•a Y`ti �(� ts.�Wr t �' �I�A. � v�
o �
4. After receiving an Authorization to Construct from the Division, construct and operate a 20.0 MGD
wastewater treatment system.
5. Discharge from said treatment .works ar the location specified on the attached map through OurfaU 001
into the Yadkin River which is classified as \VS-V waters in the Yadkin -Pee Dee River Basin.

�i�i { r�.,�`_ .'jl. / fJ _ r.. / U�' 1` l:�/"l� .t 1:/��'` "-,s �Fjl '"� -_ •: - ;�.,I s- i� �i�l '-✓ �^•.r
-�` �-SL •l 'i`-�1 �• i-r^� %.� `%.ry% .. '/�7 % _��-. ! r" ��=gip'• '-1 vi;' r.'�'
- -tl/- ' ` �Z-, i.' ,v1�'i -�`<1 J i•' /.'•'� JJJ"' i{�
/_
_ - - ' f i _ -' :I �<li�:_ �..:. � r \.. ram: �'�:� � �i.':. L+; •I
_ "•mil; ,. _ ' ` ,.- .1_. i• -�;�. i-
�_''$Q jv't wo 'i " f• Ira l -� ;J r.Or `.` O •`\�='. --, •'y ' 1�, '' - - , � _
1'.'.:�:'C�'`!.q
`•ll 5tl/ I (! -- �i 'b\ r i. �_ \ :f• _'\. -, _-� f _ ,',y!,1 jam; r..• . •�^ J -- .� f ':�
•�'---\L'�- r. r�[�)_,`7y,��1 N;' �.,� -� i:_�i r�r�N ' '(� .(� \� i -F�•'% - / I ^/:
'K':•C '•.i.- � x (u --::_`�.''-:•1., Ji� i L ��-.. p.
Outfall 00l :
r - _ - -
'''•`�` i ��• ~� ' ter` "`r--- �-'•� .�:-- - _ - _ ��� K -•._. _.. '.._.".�-~r � :>
:J''i �. � �;'. r`vi. / - - _� \ . • :'' 'mod • I , �/ -..- - •, — .-. . ' , / -
//; ��YY =-- - �— _ ''•\• L;• ,tea'. 1\: -._` _
::p; =%, _J �% .• '�;� .1.� ,,fir _��� /.i�!�'�� -�— _.,.�;:.: ��`•r=_t• l , �'�' - �,
'% , ,j" (�_ J 9�• ` sOoi.l^ p(r ..<i: ,••'�-�,' `r /`I ''ice_: /, .�i.
/ . i 'r � �."' /" \' •Y - -�U� � � ; vim !'
tL
AI
/• .``•`� '- ,� .=ice- �� 't. / Ir
i ..�.
1
W WTP
Slalc Crid/Quad: El7NW/Salisbury Latiludc:
Longiludc
Rccci,•ing Stream: Yadkin RivCr Oraina);c Basin
Slrcam Class: WS-V Sub -Basin:
35' 44' 07- N
60° 26' 50- w
Yadkin
03-07-04
North
Facility Location
not • +5a;
PD• NCO023884
CountyRowan

Permit NC0023884 �
4
/A- (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (12.5 MGD)
During the period beginning on the effective dale of the permtt and lasting until expansion beyond 12-5 MGD, the
Permiuce is authorized to discharge from UutfalJ 001. Stich dtschirges shall be limited and monitored by the
Pcm-m(ee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Averse
Weekly
Averse
Daily
Maximum
Measurement
Frequency
Sample
T e
Sample
Location[
Flow
12.5 MGD
Continuous
Recording
Effluent •
;r.4F1� a --,+
BOD, 5 day; 20'C
(April 1 to October 31)
I5.0 mg/L
22.5 mg/L
Daily
Composite
Effluent It
T"� 1%
BOD. 5 day, 20 °C
(November 1 to March 31)
30.0 mg/L 4
45.0 mg/L
Daily
Composite
Effluent
S.—flotw
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Effluent
NH3 as N
(April 1 to October 31)
b O mg[L
Daily
Composite
Effluent
NH1 as N
(November 1 to March 31)
12.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen2
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent
pH!
Daily
Grab
Effluent
Total Residual Chlorine
28 pg/L
Daily
Grab
Effluent
Total Nitrogen
(NO, + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxiciiy3
Quarterly
Composite
Effluent
Notes: --- -- -- — - - -- — — __ —
1. Combined Effluent from the Grant Creek and Town Creek treatment trains, except that flow, BOD, and 7'SS shall be sampled separately at the Town Creek
treatment train and the Grant Creek treatment train. BOD and TSS concentrations and BOD and TSS removal efficiency shall be calculated by mathematicall3
aggregating the values for the Grant Creek and Town Creek treatment trains.
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only applies if chlorine is added to the treatment system.
S. Chronic Toxicity omit (Cerrodaphnia) at 6.6 % with testing in March, une, September and December (see
6. And must not exceed 15% of influent concentration (i.e., must achieve 85% removal)
There shall be no discharge of floating solids or visible foam in other than trace amounts.

f1crmit NCO023884
/A-
11) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (12.5 MGD)
During the period beginning on the effective date of the permit and lasting until expansion beyond I2-5 MGD, the
Permitrce is authorized to discharge from OutfalJ 001. Such discharges shall be limited and monitored by the
Permitrce as specified belo,,v:
EFFLUENT
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Weekly
Daily
Measurement
Sample
Sample
Average
Maximum
Fre uenc
Type
Locations
Flow
12.5 MGD
—Average
Continuous
Recording
Effluent •
jt„•F la e �f
BOD, 5 day; 20'C
15.0 mg/L
22.5 m-
Daily
Composite
Effluent it
(April 1 to October 31)
T_`^ J "'t
BOD. 5 day. 20 9C
30-0 mg/L
45.0 mg/L
Daily
Composite
Effluent 4
(November I to March 31)
Total Suspended Solids
30.0 mg/L V
45.0 mg/L
Daily
Composite
Effluent
NH3 as N
6 O mg/L
Daily
Composite
Effluent
(April 1 to October 31)
N113 as N
12.0 mg/L
Daily
Composite
Effluent
(November 1 to March 31)
Dissolved Oxygenz
Daily
Grab
Effluent
Fecal Coliform
200/100 ml
400/100 ml
Daily
Grab
Effluent
(,geometric mean)
Temperature
Daily
Grab
Effluent
pH3
Daily
Grab
Effluent
Total Residual Chlorine
28 pg/L.
Daily
Grab
Effluent
Total Nitrogen
Weekly
Composite
Effluent
(NO, + NO3 + TKN)
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicity'
Quarterly
Composite
Effluent
Notes: -- ... —•-- — ----- --• . .. ..—_ ----- — --
1. Combined Effluent from the Grant Creek and Town Creek treatment trains, except that flow, BOA, and TSS shall be sampled separately at the Town Creek
treatment train and the Grant Creek treatment train. ROD and TSS concentrations and ROD and TSS removal efficiency shall be calculated by mathematical[)
aggregating the values for the Grant Creek and. Town Creek treatment trains.
2- The daily average dissolved osvgen effluent concentration shall not be less than 5.0 mg/L-
3. The pFi shall not be less than 6.0 standard units not greater than 9.0 standard units.
I. Monitoring only applies if chlorine is added to the treatment system-
S. Chronic Toxicity omit (Cerrodaphnia) at 6, % with testing in March,Iunc.September and December (sec
And must -not exceed 15% of influent concentration (i.e., must achieve 85% removal).
%"• 7• $ ^^ r►Q ` Tro,+ Cr,-4� l r V1Ah , S.0 M r. D `ro W'N c t4 rrMf*%&...'#"
There shall be no discharge of floating solids or visible foam in other than [race amounts.

Permit NCO023884
. A. (2) EFFLUENT LIMITATIONS AND MONITORING ItE(ZUIREMl,:NTS (20 MGD)
During the period beginning after expansion beyond 12.5 MGD and lasting until expiration, the Permittee is
authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Fre uenc
Sample
T e
Sample Location
Flow
20 MGD
Continuous
Recording
EKluenl
800. 5 day, 20 °C
(April 1 to October 31)
5.0 mg/L
7.5 mg/L
Daily
Daily
Composite
Influent and Effluent
BOD, 5 day, 20 "C
November 1 to March 31
10.0 mg/L
15.0 mg/L
Composite
Influent and Effluent
_
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent and Effluent
NN3 as N
(April 1 to October 31)
1.0 mg/L
Daily
Daily
Composite
Effluent
NI-13 as N
(November 1 to March 31)
2.0 mg/L
Composite
Effluent
Dissolved Oxygen2
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
_
Temperature
Daily
Grab
Effluent
pR3
Daily
Grab
Effluent
Total Residual Chlorine'
28 pg/L
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicitys
Quarterly
Composite
Effluent
Notes:
I . Sample locations: I - Combined Effluent from Grant/Creeks and Town Creek
2. The daily average dissolved osygen effluent concentration shall not be less than 5.0 mg/L.
3. The pl-f shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only applies if chlorine is added to the treatment system for disinfection.
S. Chronic Tonicity limit (CenMaphnra) at 10.5 % with tests in March, June, September and December (see / . (7)). ,
There shall be no discharge of floating solids or visible foam in other than trace amounts_

Permit NCO023884
A. (3) INSTREAM MONITORING REQUIREMENTS
EFFLUENT
CHARACTERISTICS
MONITORING REQUIREMENTS
Measurement Frequency
SameleType
Sam le Location
Dissolved Oxygen
June -September
3/week
Grab
Upstream & Downstream
October -Ma
I/week
pH
June -September
3/week
Grab
Upstream & Downstream
October -Ma
1/week
Temperature
June -September
3/week
Grab
Upstream & Downstream
October -Ma
1/week
Total Phosphorus
June -September
1/month
Grab
Upstream & Downstream
NO2. NO3
June -Se lember
1/month
Grab
U stream & Downstream
NH3 as N
June -Se lember
1/month
Grab
Upstream & Downstream
Total K'eldahl Nitrogen
June -September
1/month
Grab
Upstream & Downstream
Chloroph ll-a
June -September
I/month
Grab
Downstream
Notes: .
Upstream = at least 200 feet upstream of the discharge point
Downstream = 0-7 miles above Southern Railroad Bridge -
As a participant to the Yadkin Pee -Dee River Basin Association, the instream monitoring requirements as stated above arc waived.
Should your membership in the agreement be terminated, you shall notify the Division immediately and the instream monitoring
requirements specified in your permit shall be reinstated -
As per 1SA NCAC 2B.0505 (c) (4), stream sampling may be discontinued at such time 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- In such cases, on
each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for
the month in which the event occurred- This provision shall be stricdy construed and may not be -utilized to avoid the
requirements of 15A NCAC 213.0500 when performance of these requirements is mrainable. When sampling is discontinued
pursuant to this provision, stream sampling shall be resumed at the first upportunit- after chc risk period has ended.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Z6sqjnts Creek)VWTP)
Beginning on the effective e of this permit and lasting until expiration, the Permitlee is a orized to discharge
treated wastewater from the Gra . Creek W\VTP (Outfall 002) into the combined d' arge pipe- Such discharge
shall be limited and monitored by the itcee as specified below:
EFFLUENT
clan RA cTERlsrl cs
EFFLUENT LIMITAT
MONITORING REQUIREMENTS
Montlily
Average
Averag
Weekly4?Mf
Measureinenl
equency
Sample Type
Sainpte I ocalion
Flow
7.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20° '
Daily
Comp
Influent and EKluent
Total Suspended Solid
Daily
Composite
uenl and Elllueni
tcs:
I I avera e effluent BODS and TSS concentrations shall not exceed 15% of the respective influent
'alue (85% removal). �' �`

Permit NCO023884
A. (3) INSTREAM MONITORING REQUIREMENTS
EFFLUENT
CHARACTERISTICS
MONITORING REQUIREMENTS
Measurement Frequency
SampleType
Sample Location
Dissolved Oxygen
June-Seplember
3/week
Grab
Upstream & Downstream
October -May
1/week
pH
June -September
3/week
Grab
Upstream & Downstream
October -Ma
1/week
Temperature
June -September
3/week
Grab
Upstream & Downstream
October -May
1/week
Total Phosphorus
June -Se [ember
1/month
Grab
Upstream & Downstream
NOz . NO3
June -Se lembes
1/month
Grab
Upstream & Downstream
NH3 as N
June -September
1/month
Grab I
Upstream & Downstream
Total K'eldahl Nitrogen I
June -September
1/month
Grab
U stream & Downstream
Chloroph II -a I
June -September
I/month
Grab I
Downstream
Notes-,
Upstream = at least 200 feet upstream of the discharge point
Downstream = 0.7 miles above Southern Railroad Bridge -
As a participant to the Yadkin Pee -Dee River Basin Association, the instream monitoring requirements as stated above are waived.
Should your membership in the agreement be terminated, you shall notify the Division immediately and the instream monitoring
requirements specified in your permit shall be reinstated.
As per 1SA NCAC 213.0505 (c) (4), stream sampling may be discontinued at such time as flow conditions in the receiving warers
or extreme weather conditions will result in a substantial risk of iniury or death to persons collecting samples- In such cases, on
each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for
the month in which the event occurred. This provision shall be strictly construed and may not be -utilized to avoid the
requirements of 15A NCAC 213.0500 when performance of these requirements is attainable. When sampling is discontinued
pursuant to this provision, stream sampling shall be resumed at the first upporrunity after the risk period has ended.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
tcs Creek WWTP)
Beginning on the effective e of this permit and lasting until expiration, the Pcrmizee is a orizcd to discharge
treated wiste�vater from the Gra . Creek W\VTP (Outfall 002) into the combined d' arge pipe- Such discharge
shall be limited and monitored by the iuee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITAT
MONITORING REQUIREMENTS
Montlily
Average
Weekly
Average
Da'
,mum
m6sureinent
equency
Continuous
Sample Type'
Recording
Sainple Location
Flow
7.5 MGD
Influent or Effluent
BOD, 5-day, 200
it
Daily
Comp
Influent and Effluent
Tolal Suspended Solid
Daily
Composite
uenl and Ellluenl
tes:
I � I avern e effluent GODS and TSS concentrations shall not exceed 15% of the respective influent
clue (85% removal). �'— r�

Permit NCO023884
, r
A. (5) EFFLUENT LIMITATIONS AND MONITORING, I QUIRINICNTS
(Town Creek �>�TP)
Beginning or effccuvc date of (his permit and lasting until expiration, the Permittc uthorized to discharge
treated wastewa(er the -1 o%.--n Creek W\Vf P (Outfall 003) into the combine - charge ripe. Such discharges
.hall he hm+ted and mun,( by the Pcrmit(ee as specified bcloar:
EFFLUENT
EF FLUL IT11iAT10NS -00
MONITOt21NC REQUIREMENTSCHARACTERISTICS
Monthly
Averap,c
Weekly
Average
D
,mum
Measurement
Frequency
Sample
Type
Sample Location
Flow
5 0 MGD
Conlinuous
Recording
Influent or Effluent
BOO, 5-day. 20'C'
D
Compostle
Influent and Effluent
Total Suspended Solids2
Daily
mposile
Influent and Effluent
;1.
es:
1 ,on(hly average effluent 130D5 and TSS concentrations shall not exceed 15% of the respec influent
value (85% removal).
A (6) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 12-5 MGD
Th effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphrtia dubia at an effluent concentration of 6-6 %.
The permit holder shall perform at a minimum, quarterly monitoring using rest procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"� torch Carolina Phase 11 Chronic Vrhole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests wjU be performed during the months of March June, September, and December. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes -
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
(hen multiple -concentration (esting shall be performed at a minimum, in each of the rwo following months as
described in "North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further s(atistical methods are specified in (he "North Carolina Phase I1 Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (1011-1) for (he months in .which tests were performed, using the parameter code TGP313 for the
pass/Fail results and THP313 for (he Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
A((cn6on: NC DCNR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Comple(ed Aquatic Toxicity'rest Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of (he reporting period for which (he report is made.
(continued on nest page)

City`of salisbury
11
8/30/2002 11:36 PAGE 31/31 RightFax
ENCLOSURE 2- Proposed aggregate calculation of Grant Creek and Town Creek TSS and BOD
removal efficiency (example shown is TSS).
TSSWWTP Intl -
(TS.SaC (nfl x F1OWcC) + (TSSTC Inft x FIOWTC)
Flower + FlowT,c
(TSScc Em x FlowGc) + (TSSTc sty x Flow-rc)
TSSWWTP EfPI —
FlowW + F1owTc
TSSaArra,,v — [1-(TSSwwTPsm TSSWWTP X 100%
NOTES: "Elfl" is Effluent
"Inft" is Influent
"GCrr is Grant Creek Treatment Train
"TC" is Town Creek Treatment Train
"WWTP" is Salisbury -Rowan WWTY
Post-W Fax Note
7671
D
# Of
pages
To
Fro I
Co./Dept.
Co. f
l• kW
Phone #�J J_ ,, j�
Phone #
Fax # -
i
Fax # . j
/)
C, l
5
1

DATER & LAND SECTION Fax:[phone] Jul 18 '02 16:01 P.02
r y j
✓ may.,.
State Of NOW) Carolina
R()v (x x )Ill~ R f7epartment of Justice
ATTORNFY GENERAL � N ply l
P. U. r3c7X �.:.� ary Penny Thompson
R-N-EIGI-t Z- iviroamental Division
27602.062 T L (919) 716-WO
F4X; [phone]
MEMORANDUM
TO: Dave Goodrich, Supervisor, DWQ NPDES Permitting Unit
Teresa Rodriguez, j)WQ NPDES Permitting Unit
Susan Wilson, DWQ NPDES Permitting Unit
FROM: Mary Penny Thompson, Assistant Attorney General
DATE: July 19, 2002
RE: Permit Appeal by City of Salisbury
Rowan County; 02 EHR 1003
Please note that I have been assigned to handle the above referenced contested case. I will need
to begin preparing our case as soon as possible. Please review the important dates listed below and
provide me with the requested information by either inter -office mail or by hand deliveiy to the Attorney
General's Of'f icc_ ,A copy of the Petition is attached.
July 18, 2002 Documents Constituting Agency Action. i have a copy of the
Permit, but 1 also need a copy of any and all documentation inS
the permit file as it relates to the drafting and issuing of NPDES —00`
Permit NC 0023884. Please send these materials to this office" S
by August 2, 2002.i''!
September 27, 2002 Any Discovery must be sent to Petitioner by this date to give us
enough time to receive answers prior to hearing. Any discovery
sent to us by.Petitioner insist be responded to wiithin 15 days of
receipt of the questions. All discovery must bei completed by
November 4, 2002.
Week B4nning
November 18, 2002 Hearing is set in High Point, NC with Beecher Gray,
Administrative Law Judge presiding. You have been listed as
witnesses in this case. If you feel you should not be listed as a
witness or if you know of additional witnesses, please notify
this office immediately_
if you have any questions or comments regarding this case, please call me at: (919) 716969, If I am not
available, you may contact Janet Leach for immediate assistance at [phone]_

WATER & LAND SECTION Fax:[phone] Jul 18 '02 16:01 P.03
'lri ? ".14 WKWO
STATE O), NORTH CAROLINA
COUNTY OF (1) ROWAN
CITY OF SALISBJRY
(your name) PETITIONER,
DEPARTMENT OF ENVIRONMENT AND
rJATURAL RESOURCES
IN TIl R OFFICE OF
IATIVE HEARINGS
FORA
CONTESTED CASE �ARING
I
i
RESPONDENT_ }
(The State agency ar board about which you ate complaining) )
I hereby ask for a contested case hearing ag provided for by North Carolina General Statute § 15613 23 because the Respon4era has:
(IDricfly state facts showing how yQU bclleyo you have been ha,mcd by the State agency or board.)
issued, through its Division of Water Quality, NPDES Permit NCO023884 with errors and with conditions, limitations, and
ether requirements that are arbitrary, capricious, orronaous, Contrary to law, and that unnecessarily disadvantage the City of
Salisbury In the operation of its wastewater treatment facilities.
(Ifmorc space is needed, attach additional pages-)
(4) Because of these facts, the Staic agency yr board has: (check at least one from cash column)
dt pttiycd mo of prapczc} X excoodcd its authority or jurisdiction,
nrdcred me to pay a f"mo or civil pcmultyi or x acted orroncously,
{ otherwisesubmwis)lypre.jndicedtnyrights; AND �ailedtousoproper procodure;
_ x acted arbitrarily or capriciously, or
waded to act as required by law or
rule -bate; June 14, 2002 _ -- (6) Your phone nutubel: (3 35) 373-8850
(7) Print your full address, P.O.tr5uxp 20000, (3rreensbvrv, North Carplitnyd 274n2y[0c
($) Print your name; V. Ronda �T sley� ktr cks,/Pierce, A ELerdan, Humphre r�S eonnbd,' L1L_F. - —
You must mail or deliver a COPY of tlus Petition to the State agony or board named an line (3) of this form. You should contact the agunoy or
board to detenWI)c the name of the person to be served.
CERTIFICATE OF SERVICE
I certify that this Petition has bcrn served on the State agency er board named below by depositing a copy of it with the Uslted States Postal Service
with 6Vificlent postage axed bit i.y detivaring it to tt,a x�a.nc,l agcuvy vV W..fat:
(10) Mr. Dan Oakley �11) DENR_
(name ofperson ---d) (State agency of board listad ntr Una 3)
(12) 16D1 Mail Service Center, Raleigh, NC 27699-1601
(atreeta0dmw1p,o. box) Cony) (s4cc) fztF `
(I3) This the 1411 y of JL°ie 20 U2
(y0llr f1(tftptU[e)
WI , yvu ltprc 4;otnp1rLctl LM4 fi)im, y4ju MUST mail or deliver the 01UCF1NA.L AND ONE COLY to the 0111ce 0rq.0tr110151T0t1vC HCartngs, 0714
J4ail Service Center, Ita)eigb, NC 27699-6714- 1
I1-06 (111")

d� \
see
p�RR-S4UR�E.
August 29, 2002
VIA FACSIMILE [phone]
Fisilan Klimek, Director
on of Water Quality
NCDENR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Issuance of NPDES Permit NCO023884
Salisbury -Rowan WWTP
Rowan County
Dear Mr. Klimek:
SFp
Dill o 20p2
�r k1;.
DI
RFCTCRTS OF��AC�TY
Our staffs have been working on the resolution of questions related to the NPDES permit for the
Salisbury -Rowan Utilities Department's WWTP. The permit is currently the subject of a contested case.
In order to facilitate resolution of the contested case and to lay solid groundwork for future cooperation,
SRUD sets out in this letter the following: (1) proposed modifications to Part I of the permit to reflect
actual operations and to resolve BOD, TSS, and disinfection issues; and (2) proposed sampling points for
your staff s concurrence.
PERMIT MODIFICATIONS: Facility Names and Descriptions
As a preliminary matter, it has become clear that the WWTP and its components need to be clearly
identified in order to reflect actual (rather than historical) operations. Therefore, the WWTP has been
renamed the Salisbury -Rowan WWTP and includes the following: (1) the Grant Creek Treatment Train;
(2) the Town Creek Treatment Train; (3) the Yadkin River Treatment Train; and (4) Outfall 001. The
Town Creek Treatment Train is located at 850 Heiligtown Road. The Grant Creek Treatment Train,
Yadkin River Treatment Train, and Outfall 001 are located at 1915 Grubb Ferry Road. The three
treatment trains work together (not separately or individually) to produce a high quality effluent that is
discharged at Outfall 001. Permit clarifications to reflect actual operations are proposed for the first three
pages of the permit (Enclosure 1).
SALISBURY-ROWAN UTILITIES ADMINISTRATION
/ 100 W. Inns St., The Plaza, Suite 301, Salisbury, NC 28144; P.O. Box 479, Salisbury, NC 28145-0479
Y3.,(I"i Phone: [phone]; Fax [phone]
31

PERMIT MODIFICATIONS: TSS/BOD 85% Removal
SRUD objects to the redundancy of the 85% removal requirements for BOD and TSS in light of
the maximum concentration limits imposed on the WWTP's discharge to the Yadkin River. However, in
order to resolve the concerns related to the current permit, SRUD proposes to accept the 85% removal
requirements, revised as follows:
(1) Add the 85% removal requirements to the BOD and TSS effluent limitations for the Salisbury -
Rowan WWTP, as indicated on the enclosed marked -up copy of the permit. Enclosure 1. SRUD
can find no rule that requires the minimum monthly average BOD or TSS removal efficiency to be
set out as a requirement separate from the maximum monthly average BOD or TSS effluent
concentrations. As proposed, the maximum permitted average monthly BOD and TSS effluent
limitations would be the lower of the following:
(a) The current effluent limitation (e.g., 30 mg/L TSS); or
(b) 15% of the influent concentration.
(2) Calculate BOD and TSS removal efficiency based on the aggregate performance of the Grant
Creek and Town Creek Treatment Trains, as shown in Enclosure 2. SRUD believes this
calculation is consistent with the EPA definition and actual operations at the WWTP:
"Percent removal." A percentage expression of the removal efficiency across a treatment
plant for a given pollutant parameter, as determined from the 30-day average values of the
raw wastewater influent pollutant concentrations to the facility and the 30-day average
values of the effluent pollutant concentrations for a given time period.
40 CFR § 13 3. 101 0)(emphasis added). The proposed aggregate calculation of removal efficiency
reflects actual operating conditions — one WWTP, not two or three. However, the proposed
separate sampling of effluents from the two treatment trains that treat for TSS and BOD would
facilitate troubleshooting within the Salisbury -Rowan WWTP.
PERMIT MODIFICATIONS: UV & Sodium Hypochlorite Disinfection Methods
SRUD also proposes, as reflected in Enclosure 1, that UV and sodium hypochlorite be adopted as
acceptable alternatives for disinfection at the Yadkin River Treatment Train.
2

s
STAFF CONCURRENCE: Sampling Points
SRUD also proposes that all parameters be sampled at the Parshall flume of the Yadkin River
Treatment Train (greater accessibility and lower sampling costs), except for the following:
©K (1) Dissolved oxygen. Sample at the effluent of the cascade of the Yadkin River Treatment Train.
6�/ (2) Fecal coliform. Sample at the effluent of the UV channel (or hypochlorite system) of the
Yadkin River Treatment Train.
O'L (3) TSS and BOD 85% Removal. Sample TSS and BOD at the Grant Creek Treatment Train
influent and effluent and at the Town Creek Treatment Train influent and effluent. Sample
flow (influent or effluent) at the Town Creek Treatment Train and Grant Creek Treatment
Train.
It is our understanding that SRUD's use of the foregoing sampling locations does not require any permit
modification.
CONCLUSION
SRUD hopes that the foregoing proposals are acceptable and will eliminate the need for the on-
going contested case. Thank you for your attention to this matter.
Enclosures
Sincerely,
John Vest, P. E.
Utilities Director
3

Permit NCO023884
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal `(later
Pollution Control Act, as amended, the
City of Salisbury
is hereby authorized to discharge wastewater from the facilities located at the
S�A.4 s
1915 Grubb Ferry Road
SC x,.sbv (-' y
Rowan County U
a+�OL
m t _ Avnvi-rn
850 Heiligtown Road
East Spencer
Rowan County
to receiving waters designated as the Yadkin River in the Yadkin -Pee Dee River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective July 1, 2002.
This permit and the authorization to discharge shall expire at midnight on July 31, 2004.
Signed this day May 20, 2002.
'AC-1 /%/) AL-i
GregoryJ. Thorpe, Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

j Y
Permit NCO023884
SUPPLEMENT TO PERMIT COVER SHEET
The City of Salisbury is hereby authorized to:
`%®►i %
I_ Continue to operate and maintain the existing 7.5 INIGD Grant/ Creek r Treatment
consisting of
➢ Influent parshall flume
➢ Four mechanical bar screens
➢ Four grit chambers
➢ Aeration basin with mechanical floating aerators and mixers
➢ Two circular clarifiers and two rectangular clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Belt filter press
➢ Standby power generator
➢ Effluent pump station
➢ Flow measurement instrumentation '`NSJ,a6-1ia�,
This is located on Grubb Ferry Road trtn��n Rowan County.
2. Continue to operate and maintain the existing 5.0 MGD Town Creek "ter Treatment
consisting of:
➢ Two mechanical bar screens
➢ Two grit and grease removal units
➢ Two aeration basins with fixed mechanical aerators and mixers
➢ Two secondary clarifiers
➢ Screw pump lift station
➢ Two aerobic digesters
➢ Standby power generator
➢ Flow measurement
➢ Sludge dewatering facilities
➢ Effluent pump station
This is located on Heiligtown Road near East Spencer in Rowan County.
`t +ti—_i- ►'tee. ' �� or S f, A I v.. � f q. C_VA% 41 `� �
3. Continue to operate and maintain an ultraviolet disT infection system, cascade post aerator, Parshall flume,
effluent sampling station and diffuser Ll
4. After receiving an Authorization to Construct from the Division, construct and operate a 20.0 IVIGD
wastewater treatment system.
5. Discharge from said treatment works at the location specified on the attached map through Outfall 001
into the Yadkin River which is classified as WS-V waters in the Yadkin -Pee Dee River Basin.

• ��.J f•�ll: `', / __ • .. ,. v,, I [ -. r: ar-v/✓-"/_ d !' ":. fr.E ,..'.,.. C! ♦ `-� i//(/i'/ _ y ': i/O. ,�
�-� +1 '�'__J�`S /. r �' "' �_� �%l ;�':,. � .t, :/�`-,� : •-i�,�i,'.-: `::� ,) *-.._ '..�' i,l err♦; , r
7�� \��`(`��y�� �( �1�� '�•� �: f r 'h'( - `--��; �.)�'�. :lid'? _.l ��"�.?"- •/i %'_^�`\� _ •S_%.z�:.11:z,: ;♦:? ' ♦>.; .�,i%,.
S ; r `�•-.1f • % L%'` .1\ \ �4',� �� /'/•� ��\.. �. N'F� .-yam: • '.�1 V%-;'..d i,--- �j o'
_ (�� \\.. � ! I :� // / ���5 1 ,K% �1 /�:. L`C` J l,' /•``mac � '.',.-%-,:i
��:rr- �_= i�, r\� %-! r •n'�.t:.J �� - � Cry' { (! r s;.., ,,. ./� ;�ls. `.J, —. -_ - �'•\ ;';';
i — I\ \ Jj::14'I'— �''- —, lc. _'/ r\ I r�=:1 • \i�,-�`�- �.;:�.��- ,.17 w�„tl--�•_'\� y r� •%r, i ,�� "�-:,��'`�" .1;
V1,1
- .� �� � � i - -�.j. •:%-�\C.'iV
.C/:•'iY' - ° 1, p.
/\.:
,
��7.6_ jig\ it -\ `:��? 1, � ),-•)i .��•y,•. �: - `'��;:: •: ;:
�... __' -i = :.Jr / ,t''I'�S7ii) l !•��i. '�' sN'11,. `)�`:�n o�`�� \ :+�r•
/-�_ �.y - -!�•., � '`-%�� ,i ..ill' \•`.\i? )r.`a;l- .•. _- ,.��•�'..,•... �;i:
- �p� .ID�p' � ...' �'S.:`, ; .._., V..,�'_s"J;,>'�._�_ �. `)\ �,!`C.., \, ^i ,>-.n-ir:_= �}'-,rl? —'>. jjr•%„ "
'�6z0: -- �"r-L 'Y17 \ - ;� \. t 'rr \l\, ' ( 1 • rr O \\\�rd\trN •,_ r/�J e,� /_. \ .1 r
�.� �l - _ �(� O`\... � `�'� )i ,l �i�o,� ' � �. lv'��s15'i •VI' ! fr i :j.
�.:"_��'-`),'.`„✓=i!'e% "' - ".-:\�S`J �li)i,>>.iY- J�; ♦�`rJ:'.`\I��--r../j:'),. i;fi;.J?;. i
r �-t . \`�. "}`--' �.\�\` Q ✓j'.- �✓•' r•rl l.J, q•t _ �' .: �'% iJr'%%ie%jc-, '-
la : trr
y ry r''
j I�i�l�/,f�fy "� �� tI/ `\�•�1� ,\.: eo ,-/r.. �'�_ ,/r�•✓f ,'l \. ^�_.J•�//�'_. �i ,. \. 50i rl/,J,�-"�`..�! I%'1 .u'r � ,. � �, \\\ � `¢-- i , !!t�'' sue:__ _ �•
�.•�jl '11 \\� I r `� 1` t" \��\2 Y_i' -♦_-\ ) .� .I�.! .� � � jrl i! \=� -.- _ it ,
♦ '/� J j/f' .%. :':'a LI ^ �`r7-:!i)� \`, \ %•.i, \S: ` i. %1` C� �) it'r: °� _ _ _
c \ ! �! �`J r +` ..>.'•4�/ _ `tom ; �T j/., ,
.) \ C 0 ufall _ .`\\ '``� ur I �
1O®� i \♦ `\ - "c=-'' J
_
_ \ it r,( _ '•'_'j\, �4 — - -
/.r /l /r1, f\'; `u \ 'C -ll Y.\\l � ,yi5' `'��'.-.rt°' /)t( 'r��` � .♦ — y / r •✓.
�:.!i`` \ . _i r, \ I i ,}'. - °� � \ i //� \� �\_..�,"�,o ��` ' ��_i1 r/ �;P.�Ci' j�''\ ' '�;,,,/ ` //7' l • /!,ie:"'`\ _ ' l
pade �
•i_
�y' \\\'•,-z�% ._ ;.. •�/i,\ 's. i• fir"., r.
;11 y;. >\' •��_ `,i :a ••fir-�1.' I��il
IX
�i19,V _ rr ♦a te,./ / r"•� --'ly t ,�' ;r l "�,;. ;'; \ �_
gym- �\'\ `�j'1_/ 'yam.'_ -=_il= ,. _', ice. '.;!fir., \\,_;C ,_� _��`'`� �� i �ii_'_ \ / \\� .%� _.._ 4\;•- __
410
':. ! / / � - - iy,\�('"'-�.i v-. j � i ii� 5'r - _ � :: �' `i P@ �'� \ \! .I _\ -- - . i`•', ` /l � 1 lj �.:^�. f � ,-�-f-
�' � A91I' cC \ �\ ,I;. .rL r--�. I r� •'1.-
I�Sc
:'�, - _/ i' . \: 1 N , ~ - ,.�= , ,•\1,_ •e �`IIoZ.on 1. .i �i is `i ',' N'`'.
'; 1, /�`- � � l,. i l ,� \\``, \ il• •�•� J � ' ♦qr .'� ),l l/�yn±�•� ♦ �' JnQ'1 (' �i
^'/ ;� \ I/J) ?' \ >,\ r�} tr .� 7 l :�;it:'.: or I•,_7' M..a�22 I.
.i ✓•j //r � \. _ r { ' '�'� r .✓�, �j. ':✓i\� :\\=•.. a �•\. i!'r \'�/�,,r �� 't�tq T
¢�'yE�rr��19.i- \ It\, �; 5 '\ �r:�L/t'. j l`�/"!`�� [� r°, d�%).r' •o,-�E'R,t'i
•"`_•„ J�.121(% l '~L \ '�fp ` '�•� •r•/' r � f\li!)1 / D )�-'1 ``�•
/ l � rt ." i._-� , + �' • ' \ Yc�' ' ';' r 1, 1111
j� �l n •. . �.�j, ice% • ♦, l n` /,, % ° iF'r� � r•
;�.� !.F:.i,\*'=_a�^�i��. \ ..� . �,., : r.'vA'f��. \`r �' •."e ``\ram i, I ;^ '• I I
WWTP
State Crid/Ouad: E17NW/Salisbury Latitude: 35° 44' 07" N
Facility Location
Longitude: 80' 26" 50" W
no[ to scale
Receiving Stream: Yadkin River Drainage Basin: Yadkin
Stream Class: WS-V Sub -Basin: 03-07-04
NPDES Permit No. NC0023884
Noah'
Rowan County

Permit NCO023884
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (12.5 MGD)
During the period beginning on the effective date of the permit and lasting until expansion beyond 12.5 MGD, the
Permittee is authorized to discharge from Outfal] 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Avera e
Weekly
Average
Daily
Maximum
Measurement
Freiltiericy
Sample
Tye
Sample
Locations
Flow
12.5 MGD
Continuous
Recording
Effluent •
BOD, 5 day, 20 °C
(April I to October 31)
15.0 mg/L
22.5 mgfL.
Daily
Composite
Effluent It
T 4 I-je
BOD, 5 day, 20 °C
(November 1 to March 31)
30.0 mg/L 4
45.0 mg/L
Daily
Composite
Effluent 14
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Effluent
NH3 as N
(A riI I to October 31)
6.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1 to March 31)
12.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen2
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent
pH3
Daily
Grab
Effluent
Total Residual Chlorine
28 pg/L
Daily
Grab
Effluent
Total Nitrogen
(NO, + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month.
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicity'
Quarterly
Composite
Effluent
Notes:
1. Combined Effluent from Grant% Creek and Town Creek
2. The daily average.dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only applies if chlorine is added to the treatment system-
S. Chronic Toxicity Gmit (Ceriodap hnia) at 6.6 % with testing in March, June,September and December (see A. (6)).
M.► S t 1��' e -4 C I e.a� sZ4 le-4 tAo L., e. e I trA 0 t., 0 r-
cre4< ,
There shall be no discharge of floating solids or visible foam in other than trace amounts_

Permit NCO023884
A_ (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (20 MGD)
During the period beginning after expansion beyond 12.5 MGD and lasting until expiration, the Permittee is
authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
—'Frequency
Sample
Type
Sample Location
Flow
20 MGD
Continuous
Recording
Effluent
BOD, 5 day, 20 °C
(April 1 to October 31)
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent and Effluent
BOD, 5 day, 20 °C
November 1 to March 31)
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent and Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent and Effluent
NH3 as N
(April 1 to October 31)
1.0 mg/L
Daily
Composite
Effluent
NH3 as N
(November 1 to March 31)
2.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen2
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
2001100 ml
400/100 ml
Daily
Grab
Effluent
Temperature
Daily
Grab
Effluent
pH3
Daily
Grab
Effluent
Total Residual Chlorine^
28Ng/L
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 + TKN)
Weekly
Composite
Effluent
Total Phosphorus
Weekly
Composite
Effluent
Silver
2/month
Composite
Effluent
Copper
2/month
Composite
Effluent
Cyanide
Quarterly
Grab
Effluent
Chronic Toxicity5
Quarterly
Composite
Effluent
Notes:
1. Sample locations: E - Combined Effluent from Grant/Creeks and Town Creek
2. The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Monitoring only apphes if chlorine is added to the treatment system for disinfection.
S. Chronic Toxicity limit (Cenodapbnia) at 10.5 % with tests in March, June, September and December (see A. (7)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NCO023884
A. (3) INSTREAM MONITORING REQUIREMENTS
EFFLUENT
CHARACTERISTICS
MONITORING REQUIREMENTS
Measurement Frequency
Sample Type
Sample Location
Dissolved Oxygen
June -September
3/week
Grab
Upstream & Downstream
October -May
1/week
pH
June -September
3/week
Grab
Upstream & Downstream
October -Ma
1/week
Temperature
June -September
3/week
Grab
Upstream & Downstream
October -May
1/week
Total Phosphorus
June -September
1/month
Grab
Upstream & Downstream
NO2.NO3
June -September
1/month
Grab
Upstream & Downstream
NH3 as N
June -September
1/month
Grab
Upstream & Downstream
Total K'eldahl Nitrogen
June -September
1/month
Grab
Upstream & Downstream
Chloroph II -a
June -September
1/month
Grab
Downstream
Notes:
Upstream = at least 200 feet upstream of the discharge point
Downstream = 0.7 miles above Southern Railroad Bridge_
As a participant in the Yadkin Pee -Dee River Basin Association, the instream monitoring requirements as stated above are waived.
Should your membership in the agreement be terminated, you shall notify the Division immediately and the instream monitoring
requirements specified in your permit shall be reinstated.
As per 15A NCAC 2B.0505 (c) (4), stream sampling may be discontinued at such time 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. In such cases, on
each day that sampling is discontinued, written justification for the discontinuance shall be specified in the monitoring report for
the month in which the event occurred. This provision shall be strictly construed and may not be utilized to avoid the
requirements of 15A NCAC 213.0500 when performance of these requirements is attainable. When sampling is discontinued
pursuant to this provision, stream sampling shall be resumed at the first opportunity after the risk period has ended.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
its Creek WWTP)
Beginning on the effective e of this permit and lasting until expiration, the Permittee is a orized to discharge
treated wastewater from the Gra Creek WWTP (Outfall 002) into the combined d arge pipe. Such discharge
shall be limited and monitored by the ittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITAT
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Da'
000, tmum
Me_asurement
eijueney "
Sample Type
Sample Location
Flow
7.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 200 '
Daily
Comp
Influent and Effluent
Total Suspended Solid
Daily
Composite
vent and Effluent
�ral.e
1 1 average effluent BODS and TSS concentrations shall not exceed 15% of the respective influent
(85% removal). �' �'

Permit NCO023884
A. (5) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
(Town Creek WWTP)
Beginning o effective date of this permit and lasting until expiration, the Permittee i uthorized to discharge
treated wastewater the Town Creek �VtU fP (Outfall 003) into the combine charge pipe. Such discharges
shall be limited and monit by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
EFFLUE IMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
weekly
Average
D -
imum
Measurement
Frequency
Sample
Type
Sample Location
Flow
5.0 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 200C I
D '
Composite
Influent and Effluent
Total Suspended Solids2
Daily
omposite
Influent and Effluent
>No onthly average effluent BODS and TSS concentrations shall not exceed 15% of the respec influentue (85% removal).
A. (6) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) at 12.5 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphr is dubia at an effluent concentration of 6.6 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase I1 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of March, June, September, and December. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DL-NR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
(continued on next page)

ENCLOSURE 2: Proposed aggregate calculation of Grant Creek and Town Creek TSS and BOD
removal efficiency (example shown is TSS).
TSSWWTP Intl
TSSWWTP Effl
(TSSGC Infl X F10WGC) + (TSSTC Infl x F10WTC)
FlOWGC + F1oWTC
(TSSGC Effl X FlOWGC) + (TSSTC Effl X FloWTC)
F10WGC + F1oWTC
TSSRemoval — [1 - (TSSwwTp Effl . TSSwwTp Ifl)] X 100%
NOTES: "Effl" is Effluent
"Infl" is Influent
"GC" is Grant Creek Treatment Train
"TC" is Town Creek Treatment Train
"WWTP" is Salisbury -Rowan WWTP'

WATER & LAND SECTION Fax:[phone] Jul 18 '02 16:01 P.01
C O � 7 E R From tea desk
V Janet D. Leach
-- Paralegal
Department of Justicc
P. O. Box 629
Tex: [phone]
S� I E E T
Fax' (919) 716-6766766
jlaaCb Vuailps.siate.nc.us
I
I
To: Dave Goodrich, Teresa Rodriguez and Susan Wilson
Fax No: 733-0719
Subject: City of Salisbury Permit Appeal NPDES Permit NLC002388�
Date: July 19, 2002
pages: 3
COMMENTS:
Please see attached Memo and petition in reference to the above referenced case.

June 5, 2002
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Subject: Issuance of NPDES Permit NC0023884
Yadkin River Regional WWTP
Rowan County
The City of Salisbury has reviewed the above permit received May 28, 2002 and would like to submit the
following for your consideration:
• It is our understanding that most permits are issued for a 5 year period. This permit is scheduled
to expire in 2 years. Please clarify.
• Although minor, the name of the Waste Treatment Plant is "Grant Creek" as is the creek itself
rather than "Grants Creek".
• The physical address of Grant Creek WWTP is Salisbury rather than Spencer.
• The Supplement to the Permit Cover Sheet states in section 3 that the City "continue to operate
and maintain an ultraviolet disinfection system." The City requests that the language read
"continue to operate and maintain a disinfection system which may consist of ultraviolet
disinfection and/or sodium hypochlorite. In the event of using sodium hypochlorite,
dechlorination will be accomplished using Sodium Bisulfite or Sodium Thiosulfite." Salisbury
would like to have the option of not only using sodium hypochlorite as a "back-up" system to
ultraviolet disinfection but if deemed effective, use it in a cost saving effort.
The City would also like to propose that the location for effluent sampling, other than DO and
fecal coliform for Outfall 001, be changed to the parshall flume effluent. The effluent from the
parshall flume provides better mixing of the combined effluents from Outfall 002 and Outfall 003
at this point in treatment. The collection site is similar in nature to other facilities such as the Cary
WWTP where composite sampling is achieved at a covered parshall flume prior to ultraviolet
disinfection. The turbulence at the current sampling point is similar to the bottom of the cascade
and is very hard on equipment used for composite sampling. We have experienced significant and
premature wearing of the composite sampler pump as compared with samplers at our other
locations. Pump tubing also has to be changed four to five times more often than similar samplers.
The manufacturer, Isco, has advised us that all of this is due to the length of the suction line which
is 20 to 22 feet long. At the proposed location, a five-foot suction line would be sufficient. This
would save a substantial amount of money, "down time", as well as pumps, tubing and
replacement heads. Additional treatment, of UV disinfection, would affect only fecal coliform
which would, of course, be collected at the effluent of the UV channel which is in operation at that
time. We agree that Dissolved Oxygen should be taken at the effluent of the cascade. (See
attachment for diagram of proposed sampling points.)

Concerning BOD and TSS removal, it is noted that "Failure of either (or both) of the treatment
facilities to achieve 85% removal would result in a violation of a permit condition." Also, "If
BOD5 or TSS is exceeded at Outfall 001, it will result in a violation of a permit limit." We
propose that the language "Failure of either (or both) of the treatment facilities to achieve 85%
removal would result in a violation of a permit condition" be eliminated from the permit. We
feel that the quality of the effluent at Outfall 001 should be the primary consideration. Every other
consideration is secondary to ensuring that the discharge into the river at that point meets all
requirements. It is not reasonable , in our opinion, to create three potential points of violation.
85% removal is helpful in determining the efficiency of the individual facilities.

-rto") z 0
e , hall
,A7 .13 :
-Town Cre2�
o (-U'-
ito I) P",y a
U V 6q:�,taM
.,

• as
_ -s
q_->h claz —
t7e& -/, R -U 7
04(�j " -644 b, -//Qm -
Cuj-L Ocuwl
Cj5
WJOA- a:�-, co b(c) uj-�
a
J�k �o I vv

- god
-SEe
August 29, 2002
ZA FACSIMILE [phone]
. Alan Klimek, Director
Division of Water Quality
NCDENR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Issuance of NPDES Permit NCO023884
Salisbury -Rowan WWTP
Rowan County
Dear Mr. Klimek:
Re 4
Sep
0
DIV,
DIRF00 W,q F� QUq
S pF�ciC�rl'
Our staffs have been working on the resolution of questions related to the NPDES permit for the
Salisbury -Rowan Utilities Department's WWTP. The permit is currently the subject of a contested case.
In order to facilitate resolution of the contested case and to lay solid groundwork for future cooperation,
SRUD sets out in this letter the following: (1) proposed modifications to Part I of the permit to reflect
actual operations and to resolve BOD, TSS, and disinfection issues; and (2) proposed sampling points for
your staffs concurrence.
PERMIT MODIFICATIONS: Facility Names and Descriptions
As a preliminary matter, it has become clear that the WWTP and its components need to be clearly
identified in order to reflect actual (rather than historical) operations. Therefore,. the WWTP, has been
renamed the Salisbury -Rowan WWTP .and includes the following: (1) the Grant Creek Treatment Train;.
(2) the Town Creek Treatment Train; (3) the Yadkin River Treatment Train; and (4) Outfall 001. The
Town Creek Treatment Train is located at 850 Heiligtown Road. The Grant Creek Treatment Train,
Yadkin River Treatment Train, and Outfall 001 are located at 1915 Grubb Ferry Road. The three
treatment trains work together (not separately or individually) to produce a high quality effluent that is
discharged at Outfall 001. Permit clarifications to reflect actual operations are proposed for the first three
pages of the permit (Enclosure 1).
SALISBURY-ROWAN UTILITIES ADMINISTRATION .
100 W. Innes St., The Plaza, Suite 301, Salisbury, NC 28144; P.O. Box 479, Salisbury, NC 28145-0479
p}Jn Phone: [phone]; Fax [phone]
�l ,

q .1
tIX x.,k
pERMIT MODIFICATIONS: TSS/BOD 85% Removal
SRUD objects to the redundancy of the 85% removal requirements for BOD and TSS in light of
the maximum concentration limits imposed on the WWTP's discharge to the Yadkin River. However, in
order to resolve the concerns related to the current permit, SRUD proposes to accept the 85% removal
requirements, revised as follows:
(1) Add the 85% removal requirements to the BOD and TSS effluent limitations for the Salisbury. -
Rowan WWTP, as indicated on the enclosed marked -up copy of the permit. Enclosure 1. SRUD
can find no rule that requires the minimum monthly average BOD or TSS removal efficiency to be
set out as a requirement separate from t� maximum
average monthlyeBODDor TSS effluent
and TSS effluent
concentrations. As proposed, the max p
limitations would be the lower of the following:
(a) The current effluent limitation (e.g., 30 mg/L TSS); or
(b) 15% of the influent concentration.
(2) Calculate BOD and TSS removal efficiency based on the aggregate performance of the Grant
Creek and Town Creek Treatment Trains, as shown in Enclosure 2. SRUD believes this
calculation is consistent with the EPA definition and actual operations at the WWTP:
"Percent removal." A percentage expression of the removal efficiency across a treatment
plant for a given pollutant parameter, as determined from the 30-day average values of the
raw wastewater influent pollutant concentrations to the facility and the 30-day average
values of the effluent pollutant concentrations for a given time period.
40 CFR § 133.1010)(emphasis added). The proposed aggregate calculation of removal efficiency
reflects actual operating conditions — e � �a treatment trains that treat foP,* not two or three. r TSS TSS and BOD would
owever, the proposed
separate sampling of effluents from th
facilitate troubleshooting within the Salisbury -Rowan WWTP.
PERMIT MODIFICATIONS: UV & Sodium Hypochlorite Disinfection Methods
SRUD also proposes, as reflected in Enclosure 1, that UV and sodium hypochlorite be adopted as
acceptable alternatives for disinfection at the Yadkin River Treatment Train.

3
STAFF CONCURRENCE: Sampling Points
SRUD also proposes that all parameters be sampled at the Parshall flume of the Yadkin River
Treatment Train (greater accessibility and lower sampling costs), except for the following:
(1) Dissolved oxygen. Sample at the effluent of the cascade of the Yadkin River Treatment Train.
(2) Fecal coliform. Sample at the effluent of the UV channel (or hypochlorite system) of the
Yadkin River Treatment Train.
(3) TSS and BOD 85% Removal. Sample TSS and BOD at the Grant Creek Treatment Train
influent and effluent and at the Town Creek Treatment Train influent and effluent. Sample
flow (influent or effluent) at the Town Creek Treatment Train and Grant Creek Treatment
Train.
It is our understanding that SRUD's use of the foregoing sampling locations does not require any permit
modification.
CONCLUSION
SRUD hopes that the foregoing proposals are acceptable and will eliminate the need for the on-
going contested case. Thank you for your attention to this matter.
Enclosures
Sincerely,
'a4a ��
John Vest, P. E.
Utilities Director
3

June 5, 2002
NPEDS Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Issuance of NPDES Permit NC0023884
Yadkin River Regional WWTP
Rowan County
IQ�J_a� d�
JUL
2 2002 I
I
DEIdR - WATER GU4LITY
_ PL�'I°:T SOURCE 6nf;CH I
The City of Salisbury has reviewed the above permit received May 28, 2002 and would like to submit the
following for your consideration:
• It is our understanding that most permits are issued for a 5 year period. This permit is scheduled
to expire in 2 years. Please clarify.
• Although minor, the name of the Waste Treatment Plant is "Grant Creek" as is the creek itself
rather than "Grants Creek".
• The physical address of Grant Creek WWTP is Salisbury rather than Spencer.
• The Supplement to the Permit Cover Sheet states in section 3 that the City "continue to operate
and maintain an ultraviolet disinfection system." The City requests that the language read
"continue to operate and maintain a disinfection system which may consist of ultraviolet
disinfection and/or sodium hypochlorite. In the event of using sodium hypochlorite,
dechlorination will be accomplished using Sodium Bisulfite or Sodium Thiosulfite." Salisbury
would like to have the option of not only using sodium hypochlorite as a "back-up" system to
ultraviolet disinfection but if deemed effective, use it in a cost saving effort.
The City would also like to propose that the location for effluent sampling, other than DO and
fecal coliform for Outfall 001, be changed to the parshall flume effluent. The effluent from the
parshall flume provides better mixing of the combined effluents from Outfall 002 and Outfall 003
at this point in treatment. The collection site is similar in nature to other facilities such as the Cary
WWTP where composite sampling is achieved at a covered parshall flume prior to ultraviolet
disinfection. The turbulence at the current sampling point is similar to the bottom of the cascade
and is very hard on equipment used for composite sampling. We have experienced significant and
premature wearing of the composite sampler pump as compared with samplers at our other
locations. Pump tubing also has to be changed four to five times more often than similar samplers.
The manufacturer, Isco, has advised us that all of this is due to the length of the suction line which
is 20 to 22 feet long. At the proposed location, a five-foot suction line would be sufficient. This
would save a substantial amount of money, "down time", as well as pumps, tubing and
replacement heads. Additional treatment, of UV disinfection, would affect only fecal coliform
which would, of course, be collected at the effluent of the UV channel which is in operation at that
time. We agree that Dissolved Oxygen should be taken at the effluent of the cascade. (See
attachment for diagram of proposed sampling points.)

Concerning BOD and TSS removal, it is noted that "Failure of either (or both) of the treatment
facilities to achieve 85% removal would result in a violation of a permit condition." Also, "If
BOD5 or TSS is exceeded at Outfall 001, it will result in a violation of a permit limit." We
propose that the language "Failure of either (or both) of the treatment facilities to achieve 85%
removal would result in a violation of a permit condition' be eliminated from the permit. We
feel that the quality of the effluent at Outfall 001 should be the primary consideration. Every other
consideration is secondary to ensuring that the discharge into the river at that point meets all
requirements. It is not reasonable , in our opinion, to create three potential points of violation.
85% removal is helpful in determining the efficiency of the individual facilities.
Carol Hamilton
a 1") Alai���
LZ2#
Support Services Manager
cc: File
Randy Tinsley