NC0020559_Historical_1996-1998

AY OF HENDERSO*
Post Office Box 1434
180 Beckford Drive
Henderson, North Carolina 27536-1434
Phone: [phone] FAX: [phone]
August 14, 1998
Mr. Kenneth Schuster, P. E.
Raleigh Regional Supervisor
NC DENR DWQ
3800 Barrett Drive
Raleigh, NC 27609
Re: City of Henderson Nutbush Creek WWTP
NPDES #NC0020559
Special Order by Consent (SOC)
EMC WQ #96-05
Report and Notification of Meeting Deadline
Dear Mr. Schuster,
N nB=CREKWASTEWATER
TREATMWPIAW
I am submitting the following information as required by our SOC
under Sections 2. (b) 2 and 2 (b) 7:
1. The August, 1998 Quarterly THE Progress Report which
summarizes the efforts made toward toxicity reduction
(Exhibit A).
2. Phase I of the Sewer Rehabilitation Project included a program
to remove inflow/infiltration and an evaluation of the amount
removed from Redbud Basin.
The I/I work was completed prior to the July 31, 1998 deadline
in our SOC, but a certificate of substantial completion has
not been issued because of problems with equipment at the
Redbud Pump Station Upgrade which was not a part of Phase I
when the SOC was amended.
We do have full use of the equalization basin, new generator
and maximum pumping capacity of the existing pumps at the
station.
A letter from the project engineer stating why a Certificate
of Substantial Completion has not been issued is included
(Exhibit B).
A Summary Status Report on the completed I/I work is also
included (Exhibit C).

We need to have a date added to the SOC in April, 1999 to
evaluate the success of the Equilization Basin and I/I work
to prevent bypasses in wet winter weather.
If overflows still occur then additional I/I work and/or
larger pumps will be needed.
If you have any questions, please contact me at 252-431-6081.
Sincerely,
`� IV" '
Thomas M. Spain,
WWTP Director
c: Eric Williams, City Manager
Mark Warren, Assistant City Mgr.
Linda Leyen, Chief Operator
Reggie Hicks, Pretreatment/Lab Sup.

Progress Report
for the Toxicity Reduction Evaluation
at the City of Henderson's Nutbush Creek Wastewater Treatment Plant
NPDES No. NCO020559
May 15 through .august 15,1998
Submitted In Fulfdiment of the Draft Special Order by Consent
EMC WQ No. 96-05
Prepared for
Department of Environment, Health and Natural Resources
3800 Barrett Drive. Suite 100
Raleigh, North Carolina 27609
Prepared by:
City of Henderson
P.O. Box 1434
Henderson, NC
With Assistance by:
Aquatic Sciences Consulting
15751 Bushy Park Rd
Woodbine, Maryland 21797

CITY OF HENDERSON
Post Office Box 1434
180 Beckford Drive
Henderson, North Carolina 27536-1434
Phone: [phone] FAX: [phone]
August 14, 1998
Mr. Kenneth Schuster, P. E.
Raleigh Regional Supervisor
NC DENR DWQ
3800 Barrett Drive
Raleigh, NC 27609
Re: City of Henderson Nutbush Creek WWTP
NPDES #NC0020559
Special Order by Consent (SOC)
EMC WQ #96-05
Report and Notification of Meeting Deadline
Dear Mr. Schuster,
NIJBt.ISH aM WASTEV
TREATMENT PLANT
I am submitting the following information as required by our SOC
under Sections 2. (b) 2 and 2 (b) 7:
1. The August, 1998 Quarterly THE Progress Report which
summarizes the efforts made toward toxicity reduction
(Exhibit A).
2. Phase I of the Sewer Rehabilitation Project included a program
to remove inflow/infiltration and an evaluation of the amount
removed from Redbud Basin.
The I/I work was completed prior to the July 31, 1998 deadline
in our SOC, but a certificate of substantial completion has
not been issued because of problems with equipment at the
Redbud Pump Station Upgrade which was not a part of Phase I
when the SOC was amended.
We do have full use of the equalization basin, new generator
and maximum pumping capacity of the existing pumps at the
station.
A letter from the project engineer stating why a Certificate
of Substantial Completion has not been issued is included
(Exhibit B).
A Summary Status Report on the completed I/I work is also
included (Exhibit C).

We need to have a date added to the SOC in April, 1999 to
evaluate the success of the Equilization Basin and I/I work
to prevent bypasses in wet winter weather.
If overflows still occur then additional I/I work and/or
larger pumps will be needed.
If you have any questions, please contact me at 252-431-6081.
Sincerely, p
(��ivl�r,�-•wry/' �a-�i
Thomas M. Spain,
WWTP Director
c: Eric Williams, City Manager
Mark Warren, Assistant City Mgr.
Linda Leyen, Chief Operator
Reggie Hicks, Pretreatment/Lab Sup.

Progress Report
for the Toxicity Reduction Evaluation
at the City of Henderson's Nutbush Creek Wastewater Treatment Plant
NPDES No. NCO020559
Nlay 15 through august 15,1998
Submitted In Fulfillment of the Draft Special Order by Consent
EhIC WQ No. 9 6 - 0 5
Prepared for
Department of Environment, Health and Natural Resources
3800 Barrett Drive, Suite 100
Raleigh. North Carolina 27609
Prepared by:
City of Henderson
P.O. Box 1434
Henderson. NC
With Assistance by:
.aquatic Sciences Consulting
15751 Busby Park Rd
Woodbine, Maryland 21797

11
Cite of Henderson THE Progress Report
NPDES No. 0020559
Introduction
I
Page 2
August 15. 1998
This quarterly progress report is prepared and submitted to meet the August 15 date
specified by Section 2(b)2 of the City of Henderson's draft Special Order by Consent
(SOC EMC WQ No. 96-05). This report describes the progress made in the last quarter
(May 15 through August 15, 1998), the plans for the next quarter, and any significant
issues that may delay progress in completing the TRE.
Progress in the Preceding Quarter
1. Expanded Pretreatment Program
The City, through it's new Pretreatment Coordinator, is in the process of intensifying the
effort to monitor and evaluate potential sources of toxicity in the collection system.
Progress achieved in the preceding quarter includes:
Beginning the process of updating the chemical usage inventory for the industrial
users by obtaining information on maximum daily_ quantities of chemicals used in
manufacturing.
Entering chemical usage and industry monitoring data on a new computer obtained
for the pretreatment program.
More intensive monitoring of industrial users. which has led to the identification and
correction of a source of toxicity (as described below).
• Conducting more frequent inspections of industrial user facilities.
• Communicating more often with the industries regarding pretreatment activities (at
least biweekly).
2. Results of NNI%VTP Effluent Toxicity Monitoring
The NC Phase II protocol was applied to an effluent samples collected on 22-23 June
and 25-26 June. The results indicated chronic effects to Ceriodaphnua dubia at the 90°0
instream waste concentration (INVC). The chronic value (ChV) was 77.9%effluent:
although. the inhibition concentration (IC25) value was = 900 6-
As required by the NPDES permit, if toxicity is observed, monthly tests will be
performed until compliance is observed. A C dubs chronic test was performed on
effluent sample collected from 16.1 7 July and 21-22 July. The results were a ChV of
55.10o and anIC25 of 52.4%. The next effluent compliance testis scheduled for the
week of August 17th.

City of Henderson THE Progress Report Page 3
NPDES No. 0020559 August 15, 1998
As shown in Appendix A, Nutbush W WTP effluent toxicity continues to be intermittent
and variable (i.e., NOECs vary from 15 to >90°6). In an attempt to ensure that toxic
effluent samples are collected for TIE testing, the City is screening samples for toxicity
using the Microtox chronic (22-h light loss) test. The City is developing a correlation
chart of Xlicrotox and C. dubia results (see Figure 1) to use as a guide in deciding which
samples can be tested as part of the TIE and toxicity source evaluation. As shown in
Figure 1, the correlation between Microtox and C. dubia ChVs appears to be good
(r value = 0.97 for seven paired data points). The Microtox test provides a useful
approximation of the ChV values determined by the C. dubia test.
10
0
0 6
0
r, 4
-a
'a
ff
Figure 1. Comparison of Microtox
and C. dubia ChV Results
I
Y=0.23x+0.78
r2= 0.97
0 2 4 6 8 10
Microtox TUc (100/ChV)
As noted in the last quarterly progress reports. Microtox tests perforated on the final
WWTP effluent show that hydrogen peroxide addition can significantly reduce chronic
toxicity. Although earlier treatability studies have shown a reduction in chronic toxicity
to C. dubia by peroxide addition, data had not been obtained on effluent samples
collected before and after peroxide treatment. In the preceding quarter, the City began

City of Henderson THE Progress Report Page 4
NPDES No. 0020559 august 15. 1998
collecting this information. As shown in Table 1. effluent samples collected after
peroxide addition and final aeration were four to five -fold less chronically toxic than
those collected before peroxide. -aeration treatment.
Table 1. Results of C dubia Chronic Tests Performed on Samples of RIl'TP Effluent Collected
Before and After Hydrogen Peroxide Addition (H2O,) and Post Aeration Treatment.
Sampling Date Effluent Sample IC25 ChV NOEC LOEC
17-28 May 98
Before 1-12O2 AdItion
21.1
15.8
10
15
1 sample test
After H,O2 Addition
68.5
61.2
50
'S
4 Rme
Before H202 Addittcn
14.9
<l 5
<15
15
1 sample test
After H2O, Addition
>90
>90
90
>90
i 13 June
Before 14202 Addition
18.8
21.2
15
30
2 sample tests
after H2O, Addition
>90
17.9
67.5
9(,
3. Results of Effluent Toxicity Characterization
Results for the Phase I TIE test performed in the first quarter of 1998 were inconclusive
due to the low level of chronic toxicity in effluent samples. As noted in the last quarterl}'
report, %ficrotox results have shown that the effluent before peroxide.!ftnal aeration
treatment to be much more toxic than the final effluent. These results were confirmed
using C. dubia. as described above. The Cite is interested in identifying and eliminating
the source(s) of toxicity; therefore. the Phase I TIE for this quarter was collected from the
effluent at a point before peroxide addition and final aeration treatment.
In May. Microtox tests indicated that the final WWTP effluent was chronically toxic;
therefore, the City performed a TIE Phase I test on the sample using C. dubia. Tables A
through D in Appendix B present the results for the baseline and characterization steps.
Unlike the TIE Phase I test performed in April, the effluent was chronically toxic (i.e.,
Ch V=15.80,o. IC25=21.10 6).
Based on the characterization data, chronic toxicity was partially reduced by aeration
(i.e., IC25=41.5%) and completely removed by C 18 solid phase extraction (SPE) column
treatment (IC25- 100). These results confirm results of previous Phase I tests that
showedtoxicitv reduction by aeration and C18 SPE column treatment. The C18 SPE
column was eluted with 1000o methanol and an abbreviated C. dubia test was performed
on the eluate. Acute mortality (48-h) was observed in the methanol at concentrations
corresponding to 4000b and 2000o effluent. This test result confirmed that effluent
toxicity was related to nonpolar organic toxicants. The City decided not to proceed to
identification of the nonpolar organic toxicants because the sample contained a chemical
(pigment) that had been subsequently identified and eliminated (see Item =4). Future

City of Henderson THE Progress Repoli
NPDES No. 0020559
Page 5
.August 15. 1998
Phase II tests for nonpolar organic toxicants may be performed depending on the
occurrence of effluent toxicity. The City also plans to track the sources of nonpolar
organic toxicity as described below (Item =�1.
4. Identification and Control of a Source of Toxicity
Burkart Carolina, a relatively small industrial user of the City's WWTP. began using a
pltthalocyanine blue dispersion (pigment blue 15:1) in production in the fall of 1997. The
city noticed a blue green color in the effluent and the mudwell of the multi -media filters.
which increased dramatically in March and April 1998. The City requested Burkart to
perform a triad of tests to evaluate the potential for the pigment to contribute to effluent
toxicity at the Nutbush Creek W WTP. These tests ccnsisted of acute toxicity tests. 28-
day biochemical oxygen demand (BOD) test. an activated sludge respiration inhibition
test, and selected chemical analyses. -
Test results submitted by Burkart (see Appendix C) indicated that the pigment was not
likely to contribute to effluent toxicity. The acute LC50 value for C. dubia was reported
to be 669 mg'L. Based on the estimated flow contribution for the Burkart facility (0.6%).
a 11% solution of the pigment could be discharged without adverse effects to C. dubia.
However. as shown by the 28-day BOD test the pigment is not particularly
biodegradable. Additional information obtained from the manufacturer of the pigment,
Organic Pigments. confirmed the low biodegradability of the pigment (see Appendix C;
EP.A's Toxic Chemical Release Reporting. Community Right -to -Know, 40 CFR 372).
In March, the Citv noticed that the pigment was accumulating in the activated sludge and
the filters. As the pigment color increased in the sludge, the City began to see color in
the final effluent. At the same time. Microtox and C. dubia tests showed increased
toxicity.
.Uthough Burkart was not issued a pretreatment requirement for toxicity monitoring. the
Citv included this facility in the quarterly industry monitoring event. The results of a
discharge sample collected June 2-3 showed chronic toxicity to C. dzibia at a
concentration more than six -fold lower (<0.1%) than Burkart's discharge flow
contribution (0.6%).
Based on the monitoring results, the City met with Burkart on June 18a' and discussed the
ongoing THE program, Burkart's current manufacturing operation and chemical usage.
and the need to identify and eliminate the cause of the observed toxicity. Burkart
officials advised the City that the pigment was no longer being used and the chemical
would be eliminated at the City's request. A review of the manufacturing process
identified the use of potential toxic amounts of hydrogen peroxide for treating the dye.
The Citv advised Burkart to cease using the hydrogen peroxide until additional tests
could be performed to determine a nontoxic dosage.

City of Henderson THE Progress Report Page 6
NPDES No. 0020559 August 13. 1998
The City conducted tests on the pigment to determine its chronic toxicity and treatability.
Toxicity tests were performed on diluted pigment (at its expected concentration in the
ti WTP effluent) and an aliquot of the pigment after treatment in a bench -scale, batch
reactor that simulated the W"7P's activated sludge process. As shown in Appendix C.
both the untreated and treated pigment samples were toxic at concentrations that are
expected to be discharged to the W WTP.
A second discharge sample was collected from Burkart on June 21 to evaluate the
toxicity of the discharge after the facility modifications. This sample did not include the
waste stream containing pigment and hydrogen peroxide. The results of this retest
indicated only minimal chronic toxicity compared to the facility's discharge flow rate
(i.e., ChV = 0.52%).
In July. Burkart notified the City that it would voluntarily eliminate the use of the
phthalocyanine pigment. The City is in the process of preparing a chemical optimization
plan (COP) for the Burkart facility.
5. Industry Update
The C ity received chemical usage information from the industries for the period when
significant chronic effluent toxicity was observed at the Nutbush Creek NVNVTP
(November and December 1997). A review of this information did not indicate am'
unusual types or quantities of chemicals being used during the toxic period.
The City reviewed plans and specifications for a second dissolved air flotation (DAF) to
be installed .Americal. The City gave authorization for the DAF on June 30`h and the unit
was in operation on Aug 4`h. .Arnerieal will consider additional pretreatment
improvements pending an evaluation of the effect of the additional DAF on discharge
toxicity. America] will conduct a toxicity testing on their discharge in the near future.
I AA4s submitted an engineering report that included recommendations for reducing
loadings of zinc and phosphorus to the W WTP. On august 1, the City and IAk1S entered
into a compliance agreement and consent order to implement the recommendations.
IANis has beetm waste minimization activities. including pipe repair and cleaning
procedures as recommended in the engineering report. Additional waste minimization
procedures will be implemented in the next quarter. IA4ts will also propose a treatment
facility design to achieve compliance with the phosphorus limit.
Softspun notified the City by letter that it will cease dye house operations by Aug 28rh.
The City will issue a zero discharge permit to be effective on that date.
6. Industrial Pretreatment Monitoring
The Citv collected and analyzed industrial discharge samples for chronic toxicity as
specified by the monitoring requirement in the pretreatment permits issued in November

City of Henderson THE Progress Report Page 7
NPDES No. 0020559 .august 15. 1998
1997. The industries were tested at their flow contribution to the Nutbush Creek WWTP
based on 1997-1998 industrial water usage and discharge flow records and WWTP
average monthly effluent flow. The toxicitv test procedures followed the NC Phase II
protocol for C. dubia using two samples.
Discharge samples were collected on June 2-3 and June 5-6 from Americal, Ball Foster.
Iams. J.P. Tavlor, Kennametal. Burkart, and the Sandy Creek Pump Station. Although
Softspun had indicated that its facility would close soon, the City decided to include the
discharge in the quarterly monitoring event. Samples of the Softspun discharge were
collected on June 8.9 and June 11-12. The Burkart retest noted above was performed
using a single sample collected on June 18`h.
A report of the quarterly industry monitoring results has been submitted to DEHNR. No
chronic toxicity was observed in any of the industrial discharges with exception of the
first Burkart test noted above. The test of the Americal discharge was also invalid due to
low control survival. It was not possible to determine if Americal may cause adverse
effects at their discharge flow contribution. Overall, the industry monitoring results did
not indicated a clear source of toxicity. These results are not surprising considering that
the Nutbush Creek WWTP was not chronically toxic during this period (ChV >90%).
Previous studies of the City's collection system have indicated the Sandy Creek Pump
Station to be a source of toxicity as measured by Microtox. Although the June
monitoring results did not show significant chronic toxicity at the pump station's flow
contribution, the City is concerned that Sandy Creek sewershed may be a source of
toxicity during toxic periods.
As noted above, nonpolar organic toxicants appear to be the primary cause of effluent
toxicity: however, these toxicants are difficult to identify. Therefore, the City plans to
track sources of nonpolar organic toxicity. The planned testing will involve sampling
sewer lines in the Sand,. Creek sewershed, testing the samples using C. dvbia , and then
passing toxic samples through a C18 SPE column to determine if the toxicity is nonpolar.
In the next quarter, the City also plans to test selected sewer lines and major industries for
chronic toxicity (using chronic C. dubia tests) to locate the source(s) of toxicity. If
unacceptable toxicity is observed in the next monitoring event, a Refractory Toxicity
Assessment (RTA) test will be performed to determine if the discharge of toxicity would
be expected to pass through the Nutbush Creek WWTP.
Plans for the Next Quarter
The City plans to conduct the following work in the next quarter (August 15 through
November 15, 1998);
1. A chronic C. dubia compliance test will be performed in August and each month
thereafter until results show compliance with the NPDES permit limit.

Citv of Henderson THE Progress Report
NPDES No. 0020559
Page 8
august 15. 1998
2. Additional industry and pump station monitoring will be conducted to identify the
sources of effluent toxicity. The monitoring effort will focus on the Sandy Creek
sewershed, which has been identified as a source of toxicity based on Microtox.
Additional monitoring will include C. dubia chronic toxicit%, tests.
3. The City will inspect J.P. Taylor. Americal. Ball Foster, and Softspun. During the
inspections, the City will discuss activities that the industries have performed to
minimize the discharge of toxicity.
4. The Citv will review water records for industrial and commercial facilities to try to
identify additional potential sources of toxicity.
5. Depending on the occurrence of effluent toxicity, the City may perform a treatabilit}
test to evaluate the toxicity reduction that can be achieved by an upgrade of the
Nutbush Creek WWTP to biological nutrient removal (BNR).

Appendix A
Historical Ceriodaphnia dubia Chronic Toxicity Data
for the Nutbush Creek NN11TP Effluent

CeriodaphrNadubia Chronic Values (ChVs) for City of Henderson
Nutbush Creek IMNTP Effluent
100
80
60
40
20
0
e
YI YI YI W W W W 1� Iti Iti 1� W W W
CL u m S`a•
d O —5 d' O 'z d' O' d
Date

Table A-1 Results of Ceriodaphnia dubia Chrertic Toxicity Tests Performed on the City of Henderson's
Nutbush Creek WWTP Effluent.
ChV
IC25
90%Test Conc.(IWC)
Year
Sample Date
(46 Effluert)
-A -Muent
Laver Limn
Upper Lini'
Sury Adults YcunryFemale
1995
11-Jan
82
>
90
NO
NO
1
22
15-Feb
35
60
63.5
64.6
0
15
22-Mar
>
90
>
90
NO
NO
10
34
19-Aor
>
90
>
90
NO
NO
10
32
24-Mav
>
90
>
90
NC
INC
10
32
21-Jun
>
90
>
90
NO
NO
10
27
19-Jul
18
16
14.9
17.8
0
0
16-Aug
>
90
>
90
NO
NO
8
26
20Sep
>
90
>
90
NC
INC
9
28
16-Oct
61
82
60.5
68
0
13
E-Nov
82
>
90
NO
NO
6
23
6-Dec
35
53
42.6
57
0
5
1996
10-Jan
61
72
40.4
79.5
0
13
28-Feb
35
34
29.8
36.2
0
0
6-Mar
61
61
58.3
62.9
1
3
10-Aor
61
63
60.2
68.3
0
10
15-May
61
49
39.8
57.8
0
6
29-Jun
<
12.5
3.7
36
3.9
0
0
17-Jul
61
59
57
61
0
6
7-Pug
55
71
58.5
78.3
0
16
21-Sep
55
58
53.6
63.7
0
10
23-Oct
>
90
>
90
NO
NO
10
32
6-Ncv
61
75
55.7
86.3
0
8
4-Dec
35
49
38.3
56.6
0
6
25-Dec
35
39
31.6
44.5
0
0
1997
5-Feb
62
77
12.3
79.9
0
6
26-Feb
62
12
8
53.9
0
1
20-Mar
<
12.5
85
INC
NO
0
11
25-Mar
>
90
>
90
NO
NO
10
30
9-Apr
37
39
35.6
43.5
0
0
23-Apr
55
66
55.6
71.7
0
11
7-May
61
85
INC
NO
2
19
11-Jun
>
90
>
90
NC
NC
10
27
9,ul
55
52
49.9
53.8
0
0
16-Jul
78
85
NC
INC
3
22
13-Aug
78
71
56.9
78.9
3
14
17-Sep
>
90
>
90
NC
NO
9
26
1-Nov
>
90
>
90
NC
NO
10
30
19-Nov
21
20
19.7
20.9
G
0
3-Dec
37
39
34.3
47.3
0
5
29-Dec
78
69
41.1
72.6
0
8
1998
28-Jan
78
25
10.9
66.9
2
7
11-Feb
>
90
>
90
4-Mar
>
90
>
90
23-Jun
77.9
>
90
NC
NO
2
20
17-Jul
55.1
52
49.5
52.8
0
1

v
r_t-24-1 s?a ir.1 t Eta �-.. t r.~;
Effluent Aquatic Toxiclty Report Form/Phase 11 Chronic Ceriodaphn/a
Nutbush Creek '/Nn? NPOES#: NC 0020559 Pipe# 001counry Vance
Facility
TEA En4in� • Science & 'Deco. Cats
labotator� Pettorrrvttgtsty7_
^
Signatura of ORC V Signal Is o upervisor
$tart Gat. End Date Stan Ttme lyd Tina
Same akanalicn Sample 1 Samole Z Control
a + r r ' 6 A4 f 8 6 /nV98 11: 55 11 :04
Ccllection Start Data 6i 22/98 6/25/98
tart Renews Pane stwt Renew,
enw2
Treatment 90 90 11.90 r'WrOv1 Control
C0 Mt
Grab N/A N/A
pH Initial 7.7 8.1 8.2 7.8 7.8
8,1
Composite
(Ouranon) 24 l curs 24 hear
-- ---
pH Rnai - 8.2 8.0 i.0
8.1
40
Hardnass(mgl) .
D.O. Initial 7.8 8.0 7.6 7.9 B.0
7,6
Spec.Ccnd.(µmhos/c:n)
I
O.O. Final --- 1 .7 7.4 - 7.6
7.6
Chichne(mgll) <0,01 <O.01
amp. initial 25.4 24.6 25.3 24.5 4.3
24.
Sample tamp. at receipt 0.8 C 2.0 C
7 emp. Final --- 24.7 25.0 -- 24.4
25.'
ChroNo Tort Results
r raa�iam#
rn..n
Final Contra Mortality %
1 4
c i
n t
% Control 3rd Brood
100
Control
# Yotng 18
32
26 20
19 23
25
15 24
21 --- -- 2 -
Control Repro CV
21,6
Adult--
(L)Ive L L L L L L L
t 4 S 7
L L L- --
o t 1 '^
48 Ow Mortality
con" IWC
0 of 10 -2-of 10
28
26 27 24 i6.1
Slgnifiwnt7 Y N Yl
. #Young 8 26 .5 28 29 20
Effluent"
Adult
I10
Final Hleant @
9C �,. Cana
15
(L)ive (p)oad L L L D L L
L Lo
or No
1 2 3 4 5 5 - .....
AnaL�
ENluont°. # ­­Young-10 24 23 23 25 129
26
R own
93 %; NO C= 67.5 %
22 25 28 25.5 Repro. l �e�.g Tee
Adutt
L
a.e Method: Dlro= .
L L L A Normal Drstdb7 Yge�s
30 (L )lve (D)ead L L L L L L Statistic 0 Cdd=L 0 947
2 a 5 ? 8 9 10 Warn
Varienoas7 ��Method: t
t
Ecud 9.49
Stattstic: 5.93 Odtleal.
Effluent`'* # Young
22
22
25 25 26 24 24
25 23
16
Adult
(Clive (D)ead
L
L
L L L L L
L L
L `VA Method: '
Pr,dL.G.•, Ir=I S nn
1 2
3 4 0 7 8 9 10 .ufn Pffluert'4.
Effluent% #Young 25 25 26
22
29
23 126
24 27
30
25.
67.5
Advit
(L)iva (Mead L L L
D
D
-
L s
L L
L
1
1 -
:-rlverali AnaMela: , .. .
EffluentY. # ` our g
21
23
25 23123
0
25
16 122
6
y��tL y[
20.4 !Teel LOEt c 7: NOEC_ 5 7.
Adult
D
D
L D
D D
L
D D
D
Chronic Vail,,,;;-.9
(L)iva (D)ead
(L)
'stwuld use high.nt u.t tSon or
hipnnt wrweneatlon +fin 0.0. >sa mql
Sciences
A -,MAIL Management
MAIL Div. of Environmental
N.C. Department of EHNR
TO. 4401 Reedy Creek Rd.
DEM fonn AT-3 (MI) Rov. 11195
Raleigh, N.C. 27607
TOTAL P.92

]UL-24-1998 14: ;1 EPp-,IHEEPIPr, 0 -.-'� I
Effluent AquaticOxicity Report Form/Phase II Chronic Cerlodaphnia
Facilib/Nutbush Creek VIVPrP
VA
4POESk: NC 0020559� Pipeli County
, Science & Tech.1 Corrrrrents
Sample Intnrmation
Collection Stan Date
Grab
Compcsite
(Duration)
Hardness(mg/1)
Spec.Cond. (µmhos/cn)
Chlorine(mg/1)
Sample temp. at receipt
Sample-1
Sample 2 Control
6/22/98
N/A
6/25/98
N/A
24 hour
40
24 hcurs
<0.01
<0.01
2.0 'c
0.8 'C
Start oats I End oats star Time End Tim
6 /24r98 6 4V98 11: 55 11 :04
Treatment
pH Initial
pH Final
D.C. Initial
D.O, Final
'emp.Initial
'amp. Final
90 �
90
90
COtami
Control
Con°°
7.7
8.1
8.2
17.8
7.8
8.,1
---
8.2
8.0
---
8.0
8.1
7.8
8.0
7.6
7.9
8.0
7.6
---
7.7
7.4
---
7.6
7.6
25.4
24.6
25.3
24.5
4.3
24.
---
24.7
25.0
---
24.4
25.
Conirol M Young ill 0 1 32 126 120 Ll9 123 25 15 1 24 121
Adult L L L L L L L L L L
(L)ive (D)ead
u..n Final Contra Mortality Y u
% Control3rd Brood 100
Contra Repro CV 21 .6
Effluent%
'Vr
I Al Young ll28
126
5
128
129
20
28
26127
1241
1.26.11
Signilicant7LYJ
LNG N
Adult
15 (! )ive (D)ead L L L D L L L L L
-will Final Mortaity Significant
A 90 ; or No Conc.
1 2 3 4 5 6 7 8 9 10 �.�
EffluenP/e 11 Young 0 24 23 23 25 29 26 22 25 28W25.5
ReOEC�'%: NOEL=-5
Method:Ihuln&TIF s TesL
L L L L L L L L L
Normal Distn 7Yes teaihodi iro-h
��
' Li
1 2 3 4 5 6 7 9 10 um
Statistic: Critical! 947
Effluent%
Equal Variances??sMethod:
Statistic: 5.93 Critical: 9.49
Non -Parametric Analvss tit agnUabie):
hlathatl:
1 2 3 4 5 6 7 8 9 10 urn orm.tine i Rank 4n Criticni Sum
Effluent"'.
767.5
L
tt Young
22
22
25
25
26
24
24
25
23
16
23:
Adult
(L)iVe (D)ead
L
L
L
L
L
L
L
L
L
L
N6%
H Young
26
25
26
22
29
23
126124
1 27
30
25.8
Adult
'a
(Dive (0)ead
L
L
L
D
D
L
1,
L
L
LJaIj
1 P 3 1 5 6 z 8 o 10uw. - .. -
Ovlrell An^.Ivats: IL ,
Effluent9'6 fi Young E2.3 25 23 23 0 25 16 22 6 20.4 'Result = PA55! Ag
Yost LDEC= %: NOEL= •67 5 LTD D D L L) D D tip Chronic Value-- 77.9 x
-Should use highest test wmer atlon or
ATi: Environmental Sciences highest concentration with D.O. a5.0 m9A
MAIL Div, of 6nvlronmentsl Menaeamam nw.wran wm s.n.r F.M.+....nw✓
TO: N.C. Department of EHNR
4401 Reedy Crook Rd.
Raleigh, N.C. 27607 DEM form AT-3 (al91) Roy. 11/25

J'-h-24-1338 14:21 *43I•'iEEKI`16 P. _13,t0
INTRODUCTION
At the request of Aquatic Sciences Consulting, EA Engineering, Science, and Technology
performed chronic toxicity testing on 24-hour composite samples of effluent from the City of
Henderson's Nutbush Creek WWTP. The effluent samples were collected on 22-23 June and
25-76 June 1998. The test species, Ceriodaphnia dubia (water flea) were exposed to 90, 67.5,
45, 30, and 15 percent effluent and a laboratory dilution water control. The objectives of the
toxicity testing were to assess the chronic lethality of the effluent samples to the test organisms
and to evaluate the potential for inhibition of reproduction of the organisms exposed to the
effluent concentrations as compared to the dilution water control. This toxicity testing was
conducted under the biomoniloring requirements of NPDES Permit Number NC0020559.
The testing was conducted according to EA's protocol (EA 1996) which is included as
Attachment I, and US EPA (1994), and follows the procedures as presented in the North
Carolina Phase I1 Chronic Whole Effluent Toxicity Test Procedure, Revised February 1998.
The results of the chronic toxicity tests were statistically analyzed, according to EPA guidance
(US EPA 1994) to determine if any effluent concentration was significantly different from the
control with respect to survival or reproduction. The short-term chronic toxicity test endpoints
reported are expressed as the No Observed Effect Concentration (NOEL), the Lowest
Observed Effect Concentration (LOEC), the Chronic Value (ChV), and the 25 percent
inhibition concentration (IC25). The definitions of these chronic endpoints follow US EPA
(1994) and are as follows:
The NQFC is the highest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes no statistically
significant adverse effect on the observed parameter (usually hatchability,
survival, growth, and reproduction).

JLL-24-1999 14: 21 *W1I VEER I ILL, 0 - • J4,'l J
• The LOFC is the lowest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes a statistically significant
adverse effect on the observed parameters (usually hatchability, survival,
growth, and reproduction).
The ChY is a value lying between the NOEC and the LOEC, derived by
calculating the geometric mean of the NOEC and LOEC. The term is
sometimes used interchangeably with Maximum Acceptable Toxicant
Concentration (MATC).
Inhibition Concentration (ICp) - A point estimate of the toxicant concentration
that causes a given percent reduction in a non -quantal biological measurement
such as fecundity or growth. For example, an IC25 is the estimate
concentration of toxicant that causes a 25 percent reduction in mean young per
female or some other non -quantal biological measurement.
in addition, percent reduction in reproduction was calculated for each effluent concentration by
subtracting the mean number of neonates produced by the organisms exposed to each effluent
concentration from the mean number of neonates produced by the control organisms, dividing
that number by the mean number of young produced by the control organisms and multiplying
by 100.
The Effluent Aquatic Toxicity Report Form/Phase II Chronic Ceriodaphnfahas been included
at the beginning of this report. Summaries of sample/test information, including time of test
initiation and termination, test organism source and age, water quality ranges during testing,
reference toxicant data, and test results are presented on pages 5-6. Table 1 summarizes the
collection and receipt data for the effluent samples. Selected water quality parameters of the
samples are reported in Table 2. Toxicity test protocols, copies of raw data sheets, and copies
of statistical analyses are included in Attachments I, I1, and III, respectively. The Report
Quality Assurance Record is included as Attachment IV.

UL-24-19% 14:22 ^I31^IEERIPHa P. 05/10
SUMMARY OF RESULTS
The results of the chronic toxicity test performed on the effluent samples from Nutbush Creek
NYWTP are summarized on page 6. The test was terminated on Day 6, at which time > 80
percent of the control females had produced three broods, and mean young production in the
control was z 15 young per surviving female. At Day 6, there was 20 percent survival of
C. dubia exposed to the 90 percent effluent concentration, which was significantly different
(p=0.05) from the 100 percent survival of control organisms, Seven of the eight mortalities
in the 90 percent effluent concentration occurred on Day 6, following renewal on Day 5 with
the sample collected on 26 June 1998. Survival in the remaining effluent concentrations
ranged from 8o to 100 percent, none of which were significantly different from the control.
Mean young production in the 15, 30, 45 and 67.5 percent effluent concentrations ranged from
23.2 to 26.1 young per female, all of which were greater than the mean young produced in the
control (22.3 young per female). The NOEC was 67.5 percent effluent, the LOEC was 90
percent effluent and the Chronic Value was 77,9 percent effluent. The IC25 was > 90 percent
effluent.
In conformance with EA's quality assurance/quality control program, monthly reference
toxicant tests were conducted on the EA -cultured test species. The results of the C. dubia
reference toxicant tests fell within the acceptable limits established from EA's control charts-
9

3A-24-1993 14: 23 :PMaI;, EERI NG P. Ds, 10
REFERENCES
EA. 1996. Quality Control and Standard Operating Procedures Manual for the EA
Ecotoxicology Laboratory. Revision No.5. EA Manual ATS-102. Internal document
prepared by EA's Ecotoxicology Laboratory, EA Engineering, Science, and
Technology, Inc., Sparks, Maryland.
US EPA. 1994. Short -Term Methods for Estimating the Chronic Toxicity of Effluents and
Receiving Waters to Freshwater Organisms. Third Edition. EPA/600!4-91/002.
U.S. Environmental Protection Agency, Environmenml Monitoring Systems
Laboratory, Cincinnati, Ohio.
4

Illy-24-19?9 14: 23 16 1 `IEER I Pr7
P.07/13
SUMMARY OF SAMPLE/TEST INFORMATION
Test: Daily renewal chronic toxicity test with Ceriodaphnia dubia
Test Procedure: EA Protocol ATS-STC-CD-06 (NC)
North Carolina Ceriodaphnia dubia chronic toxicity testing procedure
(PASS/FAIL and Phase II)
Client Name: City of Henderson
Sample Description: Nutbush Creek R WTP
EA Accession Numbers: AT8-365, AT8-377
Dilute Water Description: Dilute mineral water
EA QC Test Number: TN-98-188
Test initiation time and date: 1155, 24 June 1998
Test completion time and date: 1104, 30 June 1998
=Qism T of Information
Lot Number: Not Applicable
Source: EA's Culture Facility (Sparks, Maryland)
Age: <24 hours old (within a 4-hour window)
,�eferP*�P Toxicant Test Information
Reference Toxicant: Sodium chloride (NaCl)
Dilution Water: Dilute mineral water
EA QC Test Number: RT-98-111
Test Initiation: 9 June 1998
Control Survival: 890% (7 days)
Test Results:
NOEC: 0.6 g/L NaCl
Laboratory control chart acceptability range for chronic NOEC: 0.6-2.4 g/L NaCl
5

JUL-24-1999 14:24 __ ENGINEERING
P.0c3/10
SUMMARY OF SELECTED TEST DATA
Test Species: Cerlodaphnia dubia
Test: Survival and reproduction test
Client Name: City of Henderson
Sample Description: Nutbush Creek WWTP
EA QC Test Number: TN-98-188
Test Concentration
6-Day Survival
Mean Young Production
(percent effluent)
(ant)
(neonates organism(*SD)
Control
100
22.3 (±4.8)
15
90
26.1 (±2.6)
30
100
25.5 (±2.7)
45
100
23.2 (±2.9)
67.5
80
25.8 (±2.5)
90
20'
20.4 (±5.7)t°'
NOEL:
67.5
LOEC:
90
ChV:
77.9
1C25:
> 90
Selected Test Water Quality Parameters Ranpr,— MCZ8 (=9.D.1
Temperature (°C): 24.3 - 25.6 24.9 (±0.4)
pH: 7.5 - 8.2 8.0 (±0.2)
Dissolved Oxygen (mg/L): 7.4 - 8.0 7.7 (±0.2)
Conductivity 04/cm): 101 - 781 386 (±213)
REEM
r. 1.I
(c)
(c)
(c)
(c)
8.5
(a) Statistically different (P=0.05) from control indicating an adverse effect.
(b) Concentrations which have significant mortality are not statistically analyzed for survival
(per EPA guidance).
(c) Reproduction in this effluent concentration was greater than in the control.
e

F
TABLE I SUMMARY OF SAMPLE COLLECTION AND RECEIPT DATA FOR EFFLUENT SAMPLES FROM
NUTBUSH CREEK WWTP
,a
n
EA Accession Collection Receipt Sample Usage a
Number Time and Date Time and Date Time and Date a
AT8-365 1500, 22 JUN 98 to 1025, 24 JUN 98 Initiation: 1155,24 JUN 98
1502, 23 JUN 98 Day 2 Renewal: 1347, 26 JUN 98
AT8-377 1505, 25 JUN 98 to 1025, 27 JUN 98 Day 5 Renewal: 1104, 29 JUN 98
1510, 26 JUN 98
n
i
m
w
u

TABLE 2 SELECTED WATER QUALITY PARAMETERS MEASURED UPON RECEIPT FOR EFFLUENT SAMPLES
FROM NUTBUSII CREEK WWTP
EA Accession Temperature Total Residual Alkalinity Hardness Conductivity
Number (00 PH Chlorine (melt.) (m_ g/L) (melL) 0uS/cm1
AT8-365 0.8 7.4 <0.01 122 132 755
AT8-377 2.0 7.5 <0.01 90 116 700
T

Appendix B
Results of Toxicity Identification Phase I Test Performed on
\utbush Creek 1yWTP Effluent

JUN-05-1933 12:43 Ea ENGINEERING P.01/04
TABLE A SUMMARY OF 5-DAY Ceriodaphnia dubia SURVIVAL DATA FROM
TOXICITY IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES
FROM THE CITY OF HENDERSON (29 MAY 1998)
i
Treatmen
rnntml
lu 251
in
ISM
IOU
Baseline
100
100 Ow
OW
OW
OW
Aeration
80
-- 60
OW
OW
OW
Filtration
100
-- 200)
Ow
OW
OW
Cut column
100
--- 100
100
100
100
EDTA
0.5 ppm
100
--- ---
0ul
04•1
0(a
3.0 ppm
100
--- ---
OW
041
OW
8.0 ppm
100
- ~-
OW
Ow
0(0
Sodium Tluosulfate
2.5 ppm
100
--- —
OW
OW
ON
5,0 ppm
100
--- ---
OW
OW
OW
10.0 ppm
100
— —
Ow
OW
OW
After Peroxide 80 100 100 80 OW 0�
(a) Treatments which have no surviving organisms are not included in the statistical attalysis.
(b) Significantly different (P=0.05) from the treatment control, indicating an adverse effect.
Ito( bls I
u

JJN—a5-1338 12:43 ER ENGINEERING P.02/04
TABLE B SUMMARY OF 5-DAY CerWghnia dubia REPRODUCTION DATA FROM
TOXICITY IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES
FROM THE CITY OF HENDERSON (29 MAY 1998)
Reproduction
(Mean young *der female)
C4nim1
1!2%a zilar
mi
2is
1QQX
Baseline
23.2
19.0 9.Ow
Ow
ow
Ow
Aeration
24.2
--- 23.6
6.2w
Ow
Ow
Filtration
27.4
--- 5.04)
Ow
OW
0p1
C,a Column
24.8
--- 21.2
22.4
26.2
26.6
EDTA
0.5 ppm
29.0
--- ---
01'l
Ow
Ow
3.0 ppn
26.0
— ---
Ow
Ow
OW
8.0 ppm
25.4
--- ---
0w
Ow
0w
Sodium Tluosulfate
2.5 ppm
26.0
--- ---
0(a)
Ow
Ow
5.0 ppm
26.2
--- —
Ow
Ow
Ow
10.0 ppm
25.8
--- ---
Ow
Ow
Ow
AfterPermdde
2L8
23.0 21.2
18.0
8.81a"
14t'1
(a) Those concentrations which Fave no surviving organisms, "haw statisticaily sigaificaat (P-0.05) mortality, are not
analytod for reproduction, per EPA guidelines.
L

JUN-05-1333 12:44 Efl ENGINEERING D.03iO4
TABLE C SUMMARY OF RESULTS OF Ceriodaphnia dubia CHRONIC TOXICITY
IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES FROM THE CITY
OF HENDERSON (29 MAY 1998)
Baseline
Aeration
Filtration
Cra Column
EDTA
0.5 ppm
3.0 ppm
8.0 ppm
Sodium Thiosuhte
2.5 ppm
5.0 ppm
10.0 ppm
Chronic Toxicity Endpoints
(ag percent sample)
MmYoung
NOES
LOEO
ShY
114W
If.Zi
2iatinro'
10
25
15.8
4.7
21.1 (4.1-24.3yy
0
25
50
35.4
2A
41.5 (27.2-44.6)
0
<25
25
<25
6.5
15.3 (12.8-17.4)
0
100
>100
>100
<1.0
>100
1.07
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<So
8.0
12.5
0
After Peroxide 50 75 61.2 1.5 68.5 (37.1-84.4) 0.06
(a) Toxic unit basod ou IC25 values, unless otherwise noted
(b) Mean Young Ratio = ratio of mean young produced in 1Qp% concentration compared to treatmcat control.
(c) Values in parentheses represent 95 percent confidence limits,
�cic� rG�s�G

JJN-05-1999 12:44 ER ENGINEERING '.24'94
TABLE D TOXICITY IDENTIFICATION EVALUATION SYSTEM BLANKS PERFORMED
FOR TESTING ON THE SAMPLE AT8-282 - 5-DAY DATA (29 MAY 1998)
Ceriodaphnla dubia
Treatment System Blanks(Percent)
Survival
Reproduction at Day 6
(mewygung = gun female)
Aeration
100
25.6
Filtration
100
19.5
Cta Extraction
100
26.6
EDTA 0.5 ppm
100
28.2
3.0 ppm
100
25.6
8.0 ppm
100
7.0(1)
Sodium Thiosulfate
2.5 ppm
100
28.4
5.0 ppm
100
25.4
10.0 ppm
100
25.0
(a) Statistically different (P-0.05)
from the treatment control indicating an adverse effect
TOTAL P.©4

Appendix C
Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
Toxic Chemical Release Reporting, Community Right -to -Know, 40 CFR 372
City Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
blicrotox Results for Industry and Pump Station Samples

i1G. 111. J8
P1.,1 IVBURKART CAROLINA Ful
0y111Jegrrys
., ,.'r• Q.,AbOrw•Uti'til;5, INC.
��� An(dyrk:nvf'r0rq�0 Goosu![al.tnnh
13 M1{ry 1998
Veto Semple CONCICJ
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nnotlrors Pc(lunncd by
: PA •sr,C•TRn
Attn: TonOt WHknr'
Snnlple Snurcd:
QR-A•PAU 11I•UE 3RIIA Code! 4012 1 u fUt05n
Anly%ie E- .1l,IIn. I r 4dlu.
I'MYOM.
lt:01 1,000,000 Pen'
01n)Il1011 0xy00n 17u�i1s11d
With
Olnehmnlcxl O%Ygan Uanend • L dry
37,100
PPm .
1'P'"
010chup1icnl QrY9011 Uan,Ond • 15 day
151.00p
73b.000
llpm
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1.2
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01:29f39 12:3a 1a:10a i•F,AN Fr3n:Or3anic Pigments 331 -0918 '39e P, B
ENVIRONMENTAL PROTECTION AGENCY
40 CFR PART 372
(OP?S-400030A; FRL-3803-61
Copper Phthaiocyanine Pigments; Toxic Chemical Release
Reporting; Community Right -to -Know
AGEtICY: Environmental Protection Agency (EPA).
ACTION: Final rule.
SUMMARY: EPA is promulgating a rule to delete Pigment Blue 15. Pigment Green
7, and Pigment Green 36 from reporting requirements under the category "copper
compou:tds" from the list of toxic chemicals under section 313 of the Emergency
Panning and Community Right -to -Know Act. The rule is based on EPA's
conclusion that: (])The copper ion cannot teasonably be anticipated to become
available at a level which induces toxicity from any of these pigments and (2)
there is no evidence that the three chemicals cause or can reasonably be
anticipated to cause adverse human health or environmental effects as specified
Linder section 313(d). By promulgating this rule. EPA is relieving facilities of
their obligation to report in 1991 on releases of Pigment [flue 15, Pigmcnt Green
7, or Pigment Green 36 that occurred in 1990, and on releases Utat will occur
in future years.
DATES: 113is rule (s effective [insert date 30 days after date of publication in
the Federal Register].
FOR FURTFIER INFORMATION CONTACT: Maria 1. Doa, Petitions Coordinator,
Emergency Planning and Community Right -to -Know Hotline, Enviionmental
Protection Agency, Mail Stop OS-120, 401 Irt St., SW., Washington- DC 20460.
Toll free: 800-535-0202, in Washington, DC and Alaska: 202-479-2449.
SUPPLEMENTARY INFORMATION:
I- Introduction
A. Statutory Authority
i the deletion of three copper pigntemfs from reporting requirements under
th4, category "copper compounds" from the section 313 list of toxic chemicals
is issued under section 313(d) and (exl) of the Emergency Planning and
Community Right -to -Know Act (EPCRA) of 1986, also referred to as Title Ill
of the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub.
L. 99-499).
B. Background
Section 313 of EPCRA requires certlin facilities manufacturing, processing,
or otherwise using toxic chemicals to report annually their environmental releases
of such chemicals. Section 313 establishes an initial list of toxic chemicals that
it
t
it
I
11
1
;.
!�I
I

01';4/3e HAS Io:iOM SFA1N Fram:Organic P:Smeats 331
•0918 ?age 7'6
is composed of more than 300 chemcals and 20 chemical categories. Any person
may petition EPA to add chemicals to or delete chemicals from.the list.
EPA issued a statement of petition policy and guidance in the Federal
Register of February 4, 1987 (52 FR 3479), to provide guidance regarding the
recommended content and format for submitting petitions. EPA must respond
to petitions within 180 days either by initiating a tulemaking or by publishing
zn explahation of why the petition has been denied.
11. Description of Petition
On June 1, 1988, EPA received a petition from The Dry Color
Manufacturers' Association (DCMA) to exempt three phthalocyanine pigments
from the reporting requirements under the list of toxic chemicals category
"copper compounds." C.I. Pigment Blue 1S, CAS No. 147-14-8; C.I. Pigment
Green 7, CAS No. 1328-53-6; and C.I. Pigment Green 36, CAS No. 14302-
13-7 are plitlialocyanine pigments covalently bound to copper. Since the
pigments are copper -containing compounds, they are reportable under section
313. After review'of the submitted petition and additional information available
to EPA, the Agency proposed to delete the three phthalocyanine pigments from
reporting under the "copper compounds" category; the proposal was published
in the Federal Register of May 15, 1989 (54 FR 20866). EPA concluded that
the three phthalocyanine pigments cannot be reasonably anticipated to cause
adverse health or environmental effects of concern to warrant continued release
reporting under section 313. A detailed review of the toxicity and environmental
effects of the three intact phthalocyanine pigments, along with an assessment
of actual or potential exposure, is contained in the proposal.
Because DCAIA's petition raised a number of important questions about how
EPA should deal with petitions to delete individual members of listed chemical
categories, the Agency also requested comment on approaches for addressing
these issues and presented four alternatives. The public comment that was
received as a result of the second request is addressed in a notice of policy and
guidance on the metal compound categories that is published elsewhere in this
issue of the Federal Register.
As stated in the above -mentioned notice of policy and guidance on the metal
compound categories, the toxicity of a metal -containing compound that
dissociates or reacts to generate the metal ion can be expressed as a function
of the toxicity induced by the intact species and the availability of the metal
ion, where the degree of dissociation, bioaccumulation, and the level at which
toxicity is induced by the metal ion must be considered. The effects induced
by the metal ions described by the metal compound categories meet the criteria
under section 313(d)(2). Thus, for petitions to exempt metal -containing
compounds from the reporting requirements under section 313. EPA has decided
to base its decisions on the evaluation of all chemical and biological processes
that may lead to metal ion availability as well as on the toxicity exhibited by
the intact species. These decisions will continue to be based on information
provided by cite patitioner, Agency documants, and available literature. The
burden of proof that the metal compound does not generate the metal ion as
a result of one or more transformation processes rests on the submiucr. FPA

04/11/38 i':38 To: 1011 SFn14
Fron:Organic Pigmcn:s 33 -8916 'age 6A
3
will deny petitions for chemicals for which the metal ion availability cannot be '
properly evaluated. EPA will also deny petitions for chenucals'that dissociate
or react to generate die metal ion at a level which can reasonably be anticipated
to cause adverse effects. If the metal compound does not dissociate or react to
generate the metal ion at a level which can reasonably be anticipated to cause
adverse effects, EPA will detenitine whether the effects which may bc' induced
tr+ the intact species meet the toxicity criteria of section 313(d)(2).
It should b.� noted that the above policy would result in a denial of DCMA's
petition if it were received today because DCMA did not address, in the petition.
all of the transformation processes which could lead to the availability of copper
ion from the dace copper pigments. Prior to adopting the above -stated policy,
EPA carried out a technical review to assess the potential availability of copper
ion front the three copper pigments and based its decision on the lack of toxicity
exhibited by the intact species and the limited copper ion availability. EPA's
technical review of the copper pigments, which is provided below, illustrates the
type of analyses which must be conducted by petitioners to justify deletions of
metal compounds from their respective categories.
Ili. Technical Review
In the proposed rule to exempt the copper pigments from the reporting
requirements under the copper compounds category under EPCRA section 313,
EPA stated that there was no indication frorn the available data that the (intact)
copper pigments can reasonably be anticipated to cause acute, chronic, or
environmental toxicity, The issue of copper ion availability from the three
phthalocyanine pigments was not explicitly addressed in the proposed rule.
EPA is concerned with both the potential toxicity induced by intact metal
compounds and with the toxicity induced by the metal ion. Although EPA was
concerned with copper ion availability in its initial review, it did not consider
all the transformation processes that may lead to metal ion availability. The
Agency recently addressed the transformation processes that may generate copper
ion front the copper plithalocyanine pigments. These include, but are not limited
to: hydrolysis, photolysis, abiotic and biotic aerobic degradations, abiotic and
biotic anaerobic degradations, bioavailability of the ion when the compounds are
ingested or inhaled, and bioaccumulation. All readily available data including
studies retrieved from literature searches and documents prepared by EPA were
considered in EPA's assessment of the availability of copper ion from the copper
p11thalocyanine pigments.
1. Copper ion. Copper is recognized as an essential element. It is essential
to a number of normal physiological processes including erythropoieses,
connective tissue metabolism, bone development, and nervous system function.
The National Academy of Sciences' recommended daily allowance (RDA) for
adults is 2.0 to 3.0 milligrams (mg) copper/day. Copper is also used as a
hematinic (to stimulate red blood cell production) in adults at a dose of 3.8 to
7.6 mg/day.
a.. Human health effects. Copper poisoning has been demonstrated in animals
and identified in humans. The liver is the main storage depot for copper, and

0i:29/36 12:36 ro:TOM EFOI'i FrowOrganic Figmeo:s 331 6216 'age 5!6
4
hepatic damage is associated with the accumulation of high levels of copper.
Ilepatic toxicity is characterized by hepatocellular necrosis, regenerative activity,
and cirrhosis. Kidney necrosis and elevated levels of serum copper occur only
after the liver begins to accumulate high levels of copper. These elevated serum
copper levels can progress to sudden hemolytic anemia and jaundice. Fd
The types of neurological effects associated with copper poisoning can
include demyelination and cerebral degeneration. These effects are thought to
be related to defects in camcholamine metabolism. Alterations in brain
neurotransmitter systems have been observed in rats following intraperitoneal
injections of 2 milligrams/kilogram/day (mg/kg/day) for 21 days. Two groups
are at an increased risk from copper exposure. Individuals with Wilson's disease,
an inborn error in copper metabolism, are at a higher risk than the general
population. The metabolic error in Wilson's disease allows copper to accumulate
in die liver, brain, kidney, and cornea, causing hemolytic anemia, neurological
abnormalities, and corneal opacity. In addition, individuals with glucose-6-
phosphate dehydrogenase deficiencies may also be at greater risk of experiencing
toxic effects from copper exposure.
Copper is classified in EPA's group D (insufficient data) for carcinogenic
potential. Copper is generally negarive in mutagenicity bioassays. Bioassays using
oral --copper were negative; subcutaneous injection of copper compounds has been
reported to induce tumor formation in one sex and strain of mice.
EPA has proposed a maximum contaminant level (MCL) of 1.3 milligrams/
liter (mgfL) (3.6 mg/day) copper.
b. Ecological effects. Copper is very toxic to aquatic life. It is sometimes
used as a biocide to control undesirable aquatic plants. EPA has issued Water
Quality Criteria for copper to protect aquatic life. The acute criteria in fresh water
is 22 micrograms/liter (ug/L). The chronic criteria in fresh water is 5.2 ug/L.
In salt water both the acute and chronic criteria are I ug/L.
2. Availability of copper ion. The three, copper ph ilia] ocyanine pigments are
extremely stable to chemically and biologically induced transformations.
a. Thermal stability. The three copper pigments are extremely stable
themially and only begin to show signs of decomposition at temperatures above
500 cc.
b. Hydrolysis. The three copper pigments have very low solubilities in water
(estimates are 8 x 10` to 3 x 1(Y mg/L for Pigment Blue 15, 7 x 1001 to 2
x I0" mg/L for Pigment Green 7, and less than 10'" mg/L for Pigment Green
36) and do not dissociate or hydrolyze in water under environmental conditions.
Hydrolysis of the three copper pigments also does not occur in basic and non -
oxidizing acidic media.
c. Photolysis. Based on studies carried out to determine the light fastness
of the three copper phthalocyanines, it appears that photolysis of these pigments
with resultant release of copper ion will not occur.

30 To: TOM 'FAN Promorganic Pigincns 3-BSI0
5
d. Abiotic oxidation. Data indicate that under environmental conditions,
abiodc oxidation of these copper pigments does not occur. More rigorous
conditions are required to effect die oxidation of the copper phthalocyanines and
subsequent release of copper ion. The pigments can be chemically oxidized to
give plitbalimides and copper nitrate by boiling in dilute nitric acid. Oxidation
of the pigments can also occur by treatment with eerie sulfate in dilute sulfuric
acid at 25 °C, or by reaction with potassium pemianganate.
e. Microbial transformations. No data on the anaerobic or aerobic
biodegradability of *e copper pigments were found. However, based on their
extremely low solubility in water, their large cross -sectional diameter, and with
the exception of the halogens on Pigment Green 7 and Pigment Green 36, the
lack of substituent groups associated with facile primary degradation, these
pigments are expected to be very resistant to degradation processes.
f. Bioavailabiliry. On the basis of molecular weight, extremely low solubility
in water, and data from subchronic toxicity tests, die three phthalocyanine
pigments are not expected to be appreciably absorbed by any route of exposure
or metabolized to yield copper ion.
The lack of toxicity and minimal changes in tissue copper levels observed
in 13—week oral studies of Pigment Blue 15 and Pigment Green 7 in rodents
indicate that appreciable absorption and metabolism to yield copper ion had not
occurred.
g. Qioaccumulation. Because copper ion does not appear to be available from
the phthalocyanine pigments, bioaccumuladon of copper ion is not a concern.
h. Summary. EPA believes that the availability of copper ion from the
phthalocyanine pigments by hydrolysis, photolysis, aerobic and anaerobic
transformations is negligible. Copper ion is not expected to be bioavailable from
the copper pigments. The copper pigments are not expected to be appreciably
absorbed by any route of exposure or metabolized to yield the copper ion.'ne
levels at which copper ion exhibits toxicity far exceed the expected limited
availability of copper ion from the phthalocyanine pigments which results in a
low level of concern for these chemicals. There could be a slight risk to aquatic
life in are situations. The small, infrequent risk is best controlled by control
programs under the Clean Water Act, not by a global reporting requirement.
IV. Comments on the Proposed Exemption of the Three Phthalocyanine
Pigments
EPA received comments from more than 22 commenters on the proposed
exemption of the three copper phdialocyanine pigments front the "copper
category" and on the category issue itself. Eleven commenters were in favor
of granting the exemption, two were in favor of denying the exemption, and
the remaining conunents were directed only to the category issue.
The New York City Department of Environmental Protection believes that
EPA should not exempt the copper pigments from repotting requirements under
the copper compounds category because "it does not appear that EPA considered
the possibility that copper may be. released from the pigments by the action of

OV24!98 12:38 To:TOH SFA N FrowOrganic Pigments 33E Bib 'age 3'6
n
soil micro-organisms.... if the action of bacteria liberates copper into the
envircnment, then the release of die copper pigments represenM.an environmental
hazard." EPA believes that because of the factors specified above (unit 111.2.E)
microbial degradation of the copper pigments with resultant release of copper
ion is highly unlikely.
Arts, Crafts and Theater Safety suggests that before "EPA approves
DChfA's petition DCMA should document the degree" to which polychlorinated
biplicnyls (PCBs) and free copper inadvertently contaminate phthalocyanine
pigments manufactured or imported into the United States. Pursuant to 40 CFR
761.30, phthalocyanine pigmentsdrat contain up to 50 ppm PCBs can be
processed and distributed in commerce. Processing and distribution of
phthalocyanine pigments that contain 50 ppm or greater of PCBs is permitted
only for persons who are granted an exemption under section 6(e)(3)(B) of the
Toxic Substances Control Act (TSCA). PCBs are only reportable under section
313 if they are present at a concentration of 0.1 percent, which is the de minimis
concentration (40 CFR 372.38).
The copper compounds category is subject to the one percent de minimis
concentration. Thus, mixtures that contain copper compounds (except the three
copper phthalocyanine pigments) in excess of the de minimis concentration should
be factored into threshold and release determinations. EPA does not believe that
phthalocyanine pigments contaminated with other copper compounds, and/or
PCBs should be treated differently than other mixtures. The presence of these
impurities did not affect LTA's decision to delete die three copper pig
V. Rulemaking Record
The record supporting this rule is contained in docket number OPTS-
400030A. All documents, including the index of the docket, are available to the
public in the TSCA Public Docket Office from 8 a.m. to noon and l p.m. to
4 p.m., Monday through Friday, excluding legal holidays. The TSCA Public
Docket Office is located at EPA Headquarters, Room NE—G004, 401 M St., SW.,
Washington, DC 20460.
Vl. Regulatory Assessment Requirements
A. Executive Order 12191
Under Executive Order 12291, EPA must judge whether a rule is "major"
and therefore, requires a Regulatory impact Analysis. EPA has determined that
this rule is not a "major rule" because it will not have an effect on the economy
of SICO million or more.
This rule would decrease the impact of the section 313 reporting
d result in cost -savings to
EPArand States. Ther ore, tfshisaa minor nd lrule under Executive Orderrrl2291.
There are 6 major producers, 16 processors of the crude pigment to pigment
grade, and 21 importers of Pigment Blue-15 at a total of 45 sites. There may
be I producer, approximately 14 processors. and 12 importers of Pigment Green-
7 at a total of 26 sites. There are approximately 5 processors and 4 importers
of Pigment Green-36 at a total of 9 sites. EPA estimates the number of producers.

04:14/38 :2:38 lo:1011 SFAIA FrowOrganic Pigments 33E 8918 Page - -
t , 4 i..
processors, and importers that might be subject to reporting under the current
threshold requirements to be no more than 80. The cost savings.of exempting
industry from reporting requirements for these three copper phthaiocyanine
pigments under the "copper category" are estimated at one million dollars, while
the savings for EPA are estimated to be $25,000 (10—year present values using
a 10 percent discount rate).
B. Regulatory Flexibility Act
Under the Regulatory Flexibility Act of 1990, the Agency must conduct
a small business analysis to determine whether a substantial number of small
entities will be significantly affected. Because the rule results in cost savings
to facilities, the Agency certifies that small entities will not be significantly
affected by the rule.
- C. Paperwork Reduction Act
This rule does not have any information collection requirements under the
provisions of the Paperwork Reduction Act of 1980, 44 U.S.C. 3501 et seq.
List of Subjects in 40 CFR Part 372
Chemicals, Community right -to -know, Environmental protection, Reporting and
recordkeeping requirements, Toxic chemicals.
Dated41rAssisraraAdna�icidesandToxicSubsrances.
Therefore, 40 CFR part 372 is amended as follows:
1. The authority citation for part 372 continues to read as follows:
Authority: 42 U.S.C. 11023 and 11048.
§ 372.65 [Amended]
2. In $ 372.65(c) by adding the following language to the copper compounds
listing "(except for C.I. Pigment Blue 15 (PB-15, CAS No. 141-14-8). C.I.
Pigment Green 7 (PG-7, CAS No. 1328-53-6), and C.I. Pigment Green 36 (PG-
36, CAS No. 14302-13 7)".
(FR Doc.91—??17? Filed??—??-91: 8:45 a.m.]
BILL114G CODE 6560.50-F

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TABLE 3 RESULTS OF LIMITED -SCALE CHRONIC TOXICITY TEST'S ON INDUSTRY DISCHARGE SAMPLES FROM
CITY OF HENDERSON NUTBUSH WWTP
Sample Description
EA Accession No:
Test Number:
WHITE EFFLUENT
AT8-354
TN-98-223
Sample Description:
EA Accession No:
Test Number:
WHITE INFLUENT
AT8-355
TN-98-224
Test Concentrations
Survival
Mean Young per
Test Concentrations
Survival
Mean Young per
(percent sample)
(percent)
female (tS.D_)
(percent samolel(percent
l
female W-D.I
Control
100
22.0 (t 2.9)
Control
100
23.4 (t 6.1)
10
100
21.0 (t 1.0)
10
100
26.2 (t 5.0)
25
100
22.2 (f 4.7)
25
100
22.0 (t 5.2)
50
O(')
50
to0
20.6 (t 2.7)
75
Ot')
ON
75
100
17.8 (t 4.0)
100
00)
ow
100
too
16.2 (L 2.6)m
NOEC:
25
NOEC:
75
LOEC:
50
LOEC:
100
ChV:
35.4
ChV:
86.6
IC25:
30.9
(24.8 — 31.4)00
IC25:
67.9 (NC)
(a) T=tmads which haw ao surviving organises me not inoludad in the statistical amlyam
(b) Statistically diffacat 0'-0.05) fiun the ooatml, indicating sn advcm cffcct
(e) Valum in pamd mm rr meant 95 p==d cmfidmm limits.
NC=95 percent wafici am limib arc not eatculabk.

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TABLE 3
Sample Description:
EA Accession No:
Test Number:
BLUE EFFLUENT 111
AT8-356
TN-98-225
Sample Description:
EA Accession No:
Test Number:
BLUE INFLUENT
AT8-357
TN-98-226
Test Concentrations
Survival
Mean Young per
Test Concentrations
Survival
Mean Young per
{percent sample)(percent
)
female aS.D.)
(percent sample)
ercent)
femalg(fS D 1
Control
100
22.6 (12.7)
Control
100
24.0 (f 5.9)
10
100
21.8 (3-3.3)
10
100
16.8 (f 6.9)
25
100
22.4 (13.3)
25
Ot'1
1.0 (12.2)t')
50
0421
5.6 (t 1.1)t'1
50
0t+1
01i1
75
0121
Ot't
75
Ot'1
Oa)
100
Ot'1
0121
100
O<'1
04)
NOEL:
25
NOEC:
10
LOEC:
50
LOEC:
25
Chv:
35.4
Chv:
15.8
IC25:
32.8 (26.6 — 34.2)f`I
1C25:
8.3
(2.7 — 16.7)(`)
(a) Treatments which have no surviving organisms ate not inchuM in the stalistice) analyses
(b) Stntistically da=a (pdh 05) fiom the control, indicating an adverse effect.
(c) Values is parentheses teprewnt 95 percent confidence limits.

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I
'FABLE 4 RESULTS OF CHRONIC TOXICITY TESTS ON FINAL EFFLUENT SAMPLES COLLECTED BEFORE AND
AFTER ADDITION OF HYDROGEN PEROXIDE
Sample Description:
Final Effluent Before H2O2
Final Effluent After 11202
EA Accession Number:
AT8-364,376
AT8-365,377
Test Number:
TN-98-239
TN-98-188
Test Concentrations
Survival
Mean Young per
Survival
Mean Young per
(percent effluent)(percent
female(fS.D.)
(percent)
female (tS.D.)
Control
100
15.0 (t 6.8)
100
22.3 (t 4.8)
15
100
20.6 (t 0.9)
90
26.1 (t 2.6)
30
Ot•1
Ot'1
100
25.5 (t 2.7)
45
0('1
&)
100
23.2 (t 2.9)
67.5
Ot-)
0t'1
8o
25.8 (t 2.5)
90
01'1
Ot'1
20ro1
20.4 (t 5.7)(L)
NOEC: 15 67.5
LOEC: 30 90
ChV: 21.2 779
IC25: 18.8 (NC) >90
(a) Trcatnents which hne significant mortality Of have no surviving organisms are not rtelistically analyzed for reproduction, per EPA guidenco.
(b) Slslistiully dtge mt (P-oO5) from control indicating an adverse cdoct
(c) Values in parenthesis rat 95 paocsd confidence limits.
NC a 95 percent confidence limits are not calculable.
I
R
1-
n

Table C-1. Results of Nlicrotox Chronic Tests (22-h Light Lose) Performed on Industn and Pump
Station Samples.
j 1998Date Sample
IC25
ON
\OEC
LOEC
Feb 13 Americal
Ball Foster
76.2
NC
100
>100
Iams
64
NC
100
>100
J.P. Tavlor
2.0
NC
6.25
<6.25
Kennametal
17
NC
6.2-1
16.25
Softspun
5.4
70.7
50
100
W%Wl) Effluent
70.2
NC
100
>100 �
Mar 6 Americal
26.7
NC
100
>100
Ball Foster
26.4
70.7
50
100
Iams
26.5
35.4
25
50
J.P. Tavlor
21.1
17.7
12.5
25
Kennametal
31.6
70.7
50
100
Softspun
60.9
70.7
50
100
Sandy Creek P.S.
47.1
NC
ICh1
>I00
`AMITPEffluent
40.7
70.7
50
100
Apr 8
-kmerical
2A
NC
6.25
<6.25
Ball Foster
28.6
35.4
25
50
Iants
56.1
NC
100
<100
J.P. Tavlor
25.9
35.4
25
50
i
Kennanetal
L6
NC
6.25
<6.25
Softspun
1.6
NC
NC
<6.25
Sandv Creek P.S.
W-WiP Effluent (Apr 9)
2.16
35.4
25
50
Apr :
Americal
>100
NC
100
>100
Ball Foster
60.6
70.7
50
100
lams
>100
NC
i00
>100
J.P. Taylor
37.5
70.7
50
100
Kennametal
47.5
70.7
50
100
Softspun
23.5
35.4
25
50
Sandy Creek P.S.
75.1
NC
100
>100
RWTP Effluent
44.4
70.7
50
100
Apr 22
Amzrical
? 1
NC
6.25
<6.25
Ball Foster
27
NC
6.25
<6.25
Iams
139
17.7
12 5
25
1 P. Taylor
2 1
NC
6 .2.5
<6.2-5
Kcnnanetal
13.0
177
12 5
25
SoEspun
16
XC
NC
<6.25
Sand. Creek P.S.
3
NC
622
<6.25
W'A'fP Effluent
93
35.4
25
50

TABLE 3 REST IT:I:S Oh LIMITED-SCAU CHRONIC"TONICITY
l'1?S'I'S ON INDUSTRY
DISC HAIMI: SAKIPLES FIMKI
CITY OI' III'\DERSON.
NUTBITSII \\'\\`TP
Industry Name:
AMERICAL
Industry Name:
KE•NN:\\IE•TAI.
0.6 ° 6
EA Accession No:
A1'8-290/306
E.\ Accession No:
ATR-294/310
Test Number:
TN-98-I80
Test Number:
TN-98-184
.Ru.
Test Concentrations
Survival \Mean Young, per
TcsL Concentrations
SUI-VIVA Ncan Yuuug per
(Percent snntple)(percent
remale (:E&D.)
(percent sample)(percent
Icmale ( S.D.)
Control
So 12.4 7.6)
Control
100 20.2 (1 6.0)
0.8
100 l •1.8 (i 5.0)
0.075
100 19.0 (1- 4.8)
1.6
100 l:.6 (:r- 3.2)
0.1 ;
100 20.8 (.I: 2.2)
3.2
100 15.6 (t 4.0)
0.3
100 22.4 (1 2.9)
6.4
40 7.2 9.9)
0.6
100 24.6 ( L 2.2)
12.8
0141 01't
1.2
80 21.4 (1. 2.9)
NOEC:
6.4
NOEC:
1.2
LOEC:
12.9
LOEC:
' 1.2
Chv:
9.1
Clly:
'1.2
IC25:
4.8 (2.8 - 9.6)
IC24;:
1.2
(a) Treamtaus wnich have nt. ,uriHng orannisnis are not utdwled in the stoasneal analvie;
(h) Statistiadly didcfem t P-0 05 1 liom :he cuturA utdicaunl; an n,Ivetac e0kct.

TA111.17. 3 (Contint
Industn_• Nano:
Gall Poster
Industry Name:
I
l\Iltc:
0 I.,.
l\Vc:
FA,%ccessim No:
xr8-293%307
R.\ :\ccession No:
\'f8-292'108
Test Number:
TN-98-181
last dumber:
TN-98-182
rest Concentrations
SurvivalMeanYoung
per
Test Concentrations
Survival
Meall Young per
(percent sample)(percent
female (1:S.D.)
(percent samnik;(percent
lanctic (IS 1).)
Control
100
18.6 (t 3.6)
Control
80
17.0 (I 7.5)
0.0123
100
19.4 (t 4.0)
0.7
100
21.9 ( r 2.5)
0.02;
100
18.0 (t 5.7)
1.4
100
20.8 (a 3-4)
0.05
100
19.2 (.1 6.6)
2.8
sn
24.9 ( 1.9)
O.1
100
19.4(L3.5)
5.6
I11U
23.2(I 5.9)
0.2
100
17.4 (:L 3.9)
11.2
Iu0
26.4 (+ 3.4)
NOGC: 0.2 NOIX: 11.2
LOl C: ;A2 LOGC: 11.2
ClIV: = 0.2 ClIV: . 1 1.2
2 IC2t: 11.2
IC2i: (1.
(n) Tr.anuuns which have no m;nni,m^_ "mulianu, are not induJed in film :aou::nwl ❑nai.m.e:-
tbi $t:w;ticall•:-It Oaiell If I`-•.t Ui li',mt the comr. 1, nuhc:aur, all adverse etlecf

TABLE 3 (Cnntinm:d)
Industry Name:
13L'RKART
Indusuv Name:
S:\NDY CRI'.I•.1:
Iwc:
O.x'!u
I\\'C.•:
3x a..
I AAccessiou No:
ATH-29G311
li.\ Acwssion No:
\TS-291/312
'rettNumber:
TN-98-195
Test Number:
TN-98-186
Tat Concentrations
Survival \da:ul Young per
'rest Concentrations
Survival Mean Young pa'
(percent sample)
(Percent Iemale (.tS.D.)
(percent sample)
(percantl Impale: (I S.D.)
Control
100 18.0 (:r 3.7)
Control
100 15.3 (.t 6.9)
0.1
100 /.0 (j:1.7)""
4.75
100 15.3 (. r 7.S)
0.2
IN 2.9(-tl.I)'"
9.5
100 22.3(1 2.1)
0.4
100 O. -I ( r 0.e))II.I
19
100 WAS ( 1 5 9)
0.x
Ohl 000
3S
100 9.3 (t 5.7)
1.6
0(.1 001
76
olnt i)lul
NOEC:
0.1
N0E-C:
38
LUGC:
i). l
LOGC:
76
Chv:
i).1
ClIV:
53.7
IC25:
0-04 (0.03 0.05)
IC25:
25.4 (6.0 5-I.S)
(.l\ Trc411ieijo which have no :11
mNinQ or-animna are jivi included 111 111v %mt,111ca1
(t1) Statutici lly JIIltrvw ( t1=0 1131 il1'a1 th.- cmit101. im llvallll= 1111 :tu-0r<d rl).2r

TABLE (Continued)
Industry Name:
J.13.
I .\i 1.0lz
lndusti ' Name:
I.1:-?:"4AMI -1-�1
I\A'C:
0.814"o
I\VC:
(} r
L•.:\ Accession No:
aT3-295,309
EA A"assion No:
A4 9
29L-311)
Test Number:
TN-98-183
Test Number:
P! 9 - -94
Test Concentrations
Survival
Mean Young par
Test Concentrations
Survival
Mean Young per
(percent( sample)
( percent
lantalc ( t S.D.
!ar Cnt smnpk)
(I)Crccnt)
1emak: (1 S.D.
Control
100
21.3 (.L 4.2)
C= M(ripl
+00
O.I I
IN
20.2 (! 5.2)
0-(5
-1440
-Wd) (1-1. )
0.22
100
20.2 (.c 4.4)
(4-14
+4(0
={'. i
„ ,
O.88
100
22.9 (1 3.3)
0,4
-100
1.76
100
22.6 (3 3.8)
4_2
go
2 94
NOL•C:
1.76
NOI:C:
4Q
LOHC:
-1.76
1,06C:
:- L 2
Cher:
:• 1 7G
Ch V :
=l .2
IC^_ i:
1.76
IC2::
1.2
(n) Trem::mile Which have u,..nm.i%in3:•r_•: aw:ms are nni included nt the
ib) :Ba(unaall•: +lincr'enl a le..0 1i.nn !I:c ennvnL :m Iwahtm, an .', it•e:xe ,Iloot

TE'-"19-783-7642
Aug
17 2:27 N3 .007 P.02
C
PEIRSON
WHITMAN
ARCHITECTS.
AND
ENGINEERS,
PA.
ESTABLISHED 1938
5510
t,AUNFORD ROAD
P.O. BOX
30398
PHONE
919/782-8300
FAX
9'9083-7642
RALEIGH
N.C.
27622.0398
US.A.
August 13, 1998
Mr. Tom Spain
City of Henderson
P.O. Box 1434
Henderson, NC 2753E
Re! Red Bud Pump Station
P&w Project No. 1322
Dear Mr. Spain:
Xk r g Z- 3
I inspected the subject project yesterday and found
the following deficiencies:
i. The bar screen rake had become unbolted from its
lifting arm and was hanging loose. The bar
screen is inoperative until such time as this
problem is corrected by the contractor.
2. The screw conveyor exhibits, from time to time,
inappropriate noises that indicate probable
misalignment. it is my understanding that the
screw itself exhibits a wobble at the midpoint of
its length.
3. The conduit that carries power wiring to the
screw conveyor motor is not adequately
stabilized. The conduit tends to shake and move
when the conveyor is in operation. over time,
the conduit could fatigue and crack.
4. The electrical cable for pump motor moisture
sensing is wrapped around at least two (2) pipes
inside the equalization basin such that the pump
cannot be removed from the basin without first
disconnecting the cable.

Immary Status Report on
inflow/infiltration
Date
Smoke
Testing (ft.I
Viewing/Cleaned
of Sewer LF
Total Costs
Labor/Equip
Manhole
Restoration
Sewer Line Repair
Eliminate I&I
Gallons Per Minute
3-31-94
-
-
10 (MR)
10 GPM
6-30-94
-
$10,500
8 (MR)
13 GPM
9-30-94
-
4,700 LF
*$114,000
10 GPM
1-3-95
-
4,060 LF
$7,300
-
15 GPM
4-3-95
-
10,325 LF
$5,668
-
7-3-95
-
3,402 LF
$1,506
-
9-29-95
20,245 ft.
10,689 LF
$4,703
-
45 GPM
12-29-95
6,782 LF
$1 1,190
-
3 GPM
3-27-96
6,782 LF
$1 1 ,190
-
3 GPM
*16-28-96
7,718 LF
$12,734
-
9-30-96
169,000 ft.
13,140 LF
$32,355
30 WHO
2 (MR)
15 (SU
250 GPM
12-31-96
10,500 ft.
38,038 LF
$71,856
30 (MHI)
3 (SU
200 GPM
3-31-97
-
2,905 LF
$28,779
2 (SU
100 GPM
6-30-97
-
23,703 LF
$37,887
12 (SU
100 GPM
9-30-07
-
29,830 LF
$191,637
12-31-97
-
19,575 LF
$100,953
10 (SU
100 GPM
4-1-98
-
47,450 LF
$46,332
7 ISU
703 (Rainstoppers)
(Installed)
200 GPM
6-30-98
-
50,400 LF
$43,721
TOTALS)
199,745 LF
279,499 LF
$732,308
20 (MR)
60 (MHI)
37 (SL)
703 (Rainstoppers)
Installed)
*21,049 GPM
(MR) Manhole Restoration
WHO Manhole Inserts
* Purchase of 1&I Truck
*' $70,000 ADS Study Contract to Perform Flow Monitoring
*2 Final Estimated I&I Elimination was summarized and revised from the Quarterly Reports. The
revisions were based on field observations.
(SU Sewer Line Repair

TE1:g19-783-7542 Rug 13 98 2:28 Nc.007 P.03
Mr. Tom Spain
City of Henderson
February 18, 1998
Page 2
9ecause of the severity of these problems, I will not
issue the Certificate of Substantial Completion until
such time as these items are corrected. I have
notified the contractors to return to the project and
correct these deficiencies as soon as possible. I
will keep you informed.
Very truly yours,
PEI 'ON & WHIT ARCHITEC?S AND ENGINEERS, P.A.
MSA/ted
cc: Mark Warren

City of Henderson THE Progress Report Page 2
NPDES No. 0020559 August 15, 1998
Introduction
This quarterly progress report is prepared and submitted to meet the August 15 date
specified by Section 2(b)2 of the City of Henderson's draft Special Order by Consent
(SOC EMC WQ No. 96-05). This report describes the progress made in the last quarter
(May 15 through August 15, 1998), the plans for the next quarter, and any significant
issues that may delay progress in completing the TRE.
Progress in the Preceding Quarter
1. Expanded Pretreatment Program
The City, through it's new Pretreatment Coordinator, is in the process of intensifying the
effort to monitor and evaluate potential sources of toxicity in the collection system.
Progress achieved in the preceding quarter includes:
• Beginning the process of updating the chemical usage inventory for the industrial
users by obtaining information on maximum daily quantities of chemicals used in
manufacturing.
• Entering chemical usage and industry monitoring data on a new computer obtained
for the pretreatment program.
• More intensive monitoring of industrial users. \\ hich has led to the identification and
correction of a source of toxicity (as described below).
• Conducting more frequent inspections of industrial user facilities.
• Communicating more often with the industries regarding pretreatment activities (at
least biweekly).
2. Results of WWTP Effluent Toxicity Monitoring
The NC Phase II protocol was applied to an effluent samples collected on 22-23 June
and 25-26 June. The results indicated chronic effects to Ceriodaphrna dubia at the 90%
instream waste concentration (IWC). The chronic value (ChV) was 77.9%effluent;
although, the inhibition concentration (IC25) value was >90%.
As required by the NPDES permit, if toxicity is observed, monthly tests will be
performed until compliance is observed. A C. dubia chronic test was performed on
effluent sample collected from 16-17 July and 21-22 July. The results were a ChV of
55.1%and anIC25 of 52.4°/u. The next effluent compliance testis scheduled for the
week of August 17ffi.

City of Henderson THE Progress Report
NPDES No. 0020559
Page 3
.August 15, 1998
As shown in Appendix A, Nutbush W WTP effluent toxicity continues to be intermittent
and variable (i.e., NOECs vary from 15 to >90%). In an attempt to ensure that toxic
effluent samples are collected for TIE testing, the City is screening samples for toxicity
using the Microtox chronic (22-h light loss) test. The City is developing a correlation
chart of Microtox and C. dubia results (see Figure l) to use as a guide in deciding which
samples can be tested as part of the TIE and toxicity source evaluation. As shown in
Figure 1, the correlation between Microtox and C. dubia ChVs appears to be good
(r value = 0.97 for seven paved data points). The Microtox test provides a useful
approximation of the ChV values determined by the C. dubia test.
10
V
2
Figure 1. Comparison of Microtox
and C. dubia ChV Results
0 2 4 6 8 10
Microtox Tlk (1001M)
As noted in the last quarterly progress reports, Microtox tests performed on the final
WWTP effluent show that hydrogen peroxide addition can significantly reduce chronic
toxicity. Although earlier treatability studies have shown a reduction in chronic toxicity
to C. dubia by peroxide addition, data had not been obtained on effluent samples
collected before and after peroxide treatment. In the preceding quarter, the City began

City of Henderson THE Progress Report Page 4
NPDES No. 0020559 August 15, 1998
collecting this information. As shown in Table 1, effluent samples collected after
peroxide addition and final aeration were four to five -fold less chronically toxic than
those collected before peroxide/aeration treatment.
Table 1. Results of C dubia Chronic Tests Performe
d W med on Samples of W 1P Effluent Collected
Before and After Hydrogen Peroxide Addition P12O2) and Post Aeration Treatment.
Sampling Date
Effluent Sample
IC25
ChV
NOEC
LOEC
27-28 May 98
Before H202 Addition
21.1
15.8
10
25
1 sample test
After H2O2 Addition
68.5
61.2
50
75
3-4 June
Before H2O2 Addition
14.9
<15
<15
15
1 sample test
After H2O2 Addition
>90
>90
90
>90
23 June
Before H2O2 Addition
18.8
21.2
15
30
2 sample tests
After H2O2 Addition
>90
77.9
67.5
90
3. Results of Effluent Toxicity Characterization
Results for the Phase I TIE test performed in the first quarter of 1998 were inconclusive
due to the low level of chronic toxicity in effluent samples. As noted in the last quarterly
report, Microtox results have shown that the effluent before peroxide/final aeration
treatment to be much more toxic than the final effluent. These results were confirmed
using C. dubia, as described above. The City is interested in identifying and eliminating
the source(s) of toxicity; therefore, the Phase I TIE for this quarter was collected from the
effluent at a point before peroxide addition and final aeration treatment.
In May, Microtox tests indicated that the final W WTP effluent was chronically toxic;
therefore, the City performed a TIE Phase I test on the sample using C. dubia. Tables A
through D in Appendix B present the results for the baseline and characterization steps.
Unlike the TIE Phase I test performed in April, the effluent was chronically toxic (i.e.,
ChV=15.8ao, IC25=21.1%).
Based on the characterization data, chronic toxicity was partially reduced by aeration
(i.e., IC25=41.5%) and completely removed by C18 solid phase extraction (SPE) column
treatment (IC25>100). These results confirm results of previous Phase I tests that
showed toxicity reduction by aeration and C 18 SPE column treatment. The C 18 SPE
column was eluted with 100% methanol and an abbreviated C. dubia test was performed
on the eluate. Acute mortality (48-h) was observed in the methanol at concentrations
corresponding to 400% and 200% effluent. This test result confirmed that effluent
toxicity was related to nonpolar organic toxicants. The City decided not to proceed to
identification of the nonpolar organic toxicants because the sample contained a chemical
(pigment) that had been subsequently identified and eliminated (see Item #4). Future

City of Henderson THE Progress Report Page 5
NPDES No. 0020559 August 15, 1998
Phase II tests for nonpolar organic toxicants may be performed depending on the
occurrence of effluent toxicity. The City also plans to track the sources of nonpolar
organic toxicity as described below (Item #5).
4. Identification and Control of a Source of Toxicity
Burkart Carolina, a relatively small industrial user of the City's W WTP, began using a
phthalocyanine blue dispersion (pigment blue 15:1) in production in the fall of 1997. The
city noticed a blue green color in the effluent and the mudwell of the multi -media filters,
which increased dramatically in March and April 1998. The City requested Burkart to
perform a triad of tests to evaluate the potential for the pigment to contribute to effluent
toxicity at the Nutbush Creek W WTP. These tests consisted of acute toxicity tests, 28-
day biochemical oxygen demand (BOD) test, an activated sludge respiration inhibition
test, and selected chemical analyses.
Test results submitted by Burkart (see Appendix C) indicated that the pigment was not
likely to contribute to effluent toxicity. The acute LC50 value for C. dubs was reported
to be 669 mg/L. Based on the estimated flow contribution for the Burkart facility (0.696),
a 11% solution of the pigment could be discharged without adverse effects to C. dubia.
However, as shown by the 28-day BOD test. the pigment is not particularly
biodegradable. Additional information obtained from the manufacturer of the pigment,
Organic Pigments, confirmed the low biodegradability of the pigment (see Appendix C.
EPA's Toxic Chemical Release Reporting, Community Right -to -Know, 40 CFR 372).
In March, the City noticed that the pigment was accumulating in the activated sludge and
the filters. As the pigment color increased in the sludge, the City began to see color in
the final effluent. At the same time, Microtox and C. dubia tests showed increased
toxicity.
Although Burlmn was not issued a pretreatment requirement for toxicity monitoring, the
City included this facility in the quarterly industry monitoring event. The results of a
discharge sample collected June 2-3 showed chronic toxicity to C. dubia at a
concentration more than six -fold lower (<0.10/6) than Burkart's discharge flow
contribution (0.6%).
Based on the monitoring results, the City met with Burkart on June I and discussed the
ongoing THE program, Burkart's current manufacturing operation and chemical usage,
and the need to identify and eliminate the cause of the observed toxicity. Burkart
officials advised the City that the pigment was no longer being used and the chemical
would be eliminated at the City's request. A review of the manufacturing process
identified the use of potential toxic amounts of hydrogen peroxide for treating the dye.
The City advised Burkart to cease using the hydrogen peroxide until additional tests
could be performed to determine a nontoxic dosage.

City of Henderson THE Progress Report Page 6
NPDES No. 0020559 August 15, 1998
The City conducted tests on the pigment to determine its chronic toxicity and treatability.
Toxicity tests were performed on diluted pigment (at its expected concentration in the
W WTP effluent) and an aliquot of the pigment after treatment in a bench -scale, batch
reactor that simulated the W WTP's activated sludge process. As shown in Appendix C.
both the untreated and treated pigment samples were toxic at concentrations that are
expected to be discharged to the W WTP.
A second discharge sample was collected from Burkart on June 21 to evaluate the
toxicity of the discharge after the facility modifications. This sample did not include the
waste stream containing pigment and hydrogen peroxide. The results of this retest
indicated only minimal chronic toxicity compared to the facility's discharge flow rate
(i.e., ChV = 0.52%).
In Julv, Burkart notified the City that it would voluntarily eliminate the use of the
phthalocyanine pigment. The City is in the process of preparing a chemical optimization
plan (COP) for the Burkart facility.
5. Industry Update
The City received chemical usage information from the industries for the period when
significant chronic effluent toxicity was observed at the Nutbush Creek W WTP
(November and December 1997). A review of this information did not indicate any
unusual types or quantities of chemicals being used during the toxic period.
The City reviewed plans and specifications for a second dissolved air flotation (DAF) to
be installed Americal. The City gave authorization for the DAF on June 30'h and the unit
was in operation on Aug 0. Americal will consider additional pretreatment
improvements pending an evaluation of the effect of the additional DAF on discharge
toxicity. Americall will conduct a toxicity testing on their discharge in the near future.
IAMB submitted an engineering report that included recommendations for reducing
loadings of zinc and phosphorus to the W WTP. On August 1, the City and IAMS entered
into a compliance agreement and consent order to implement the recommendations.
IAMB has begun waste minimization activities, including pipe repair and cleaning
procedures as recommended in the engineering report. Additional waste minimization
procedures will be implemented in the next quarter. IAMB will also propose a treatment
facility design to achieve compliance with the phosphorus limit.
Softspun notified the City by letter that it will cease dye house operations by Aug 28th.
The City will issue a zero discharge permit to be effective on that date.
6. Industrial Pretreatment Monitoring
The City collected and analyzed industrial discharge samples for chronic toxicity as
specified by the monitoring requirement in the pretreatment permits issued in November

City of Henderson THE Progress Report Page 7
NPDES No. 0020559 August 13, 1998
1997. The industries were tested at their flow contribution to the Nutbush Creek W WTP
based on 1997-1998 industrial water usage and discharge flow records and W WTP
average monthly effluent flow. The toxicity test procedures followed the NC Phase 11
protocol for C. dubia using two samples.
Discharge samples were collected on June 2-3 and June 5-6 from Americal, Ball Foster,
Janis, J.P. Taylor, Kennametal, Burkart, and the Sandy Creek Pump Station. Although
Softspun had indicated that its facility would close soon, the City decided to include the
discharge in the quarterly monitoring event. Samples of the Softspun discharge were
collected on June 8-9 and June 11-12. The Burkart retest noted above was performed
using a single sample collected on June 18`h.
A report of the quarterly industry monitoring results has been submitted to DEHNR. No
chronic toxicity was observed in any of the industrial discharges with exception of the
first Burkart test noted above. The test of the Americal discharge was also invalid due to
low control survival. It was not possible to determine if Americal may cause adverse
effects at their discharge flow contribution. Overall, the industry monitoring results did
not indicated a clear source of toxicity. These results are not surprising considering that
the Nutbush Creek W WTP was not chronically toxic during this period (ChV >90%).
Previous studies of the City's collection system have indicated the Sandy Creek Pump
Station to be a source of toxicity as measured by Microtox. Although the June
monitoring results did not show significant chronic toxicity at the pump station's flow
contribution, the City is concerned that Sandy Creek sewershed may be a source of
toxicity during toxic periods.
As noted above, nonpolar organic toxicants appear to be the primary cause of effluent
toxicity; however, these toxicants are difficult to identify. Therefore, the City plans to
track sources of nonpolar organic toxicity. The planned testing will involve sampling
sewer lines in the Sandy Creek sewershed, testing the samples using C. dubia, and then
passing toxic samples through a C 18 SPE column to determine if the toxicity is nonpolar.
In the next quarter, the City also plans to test selected sewer lines and major industries for
chronic toxicity (using chronic C. dubia tests) to locate the source(s) of toxicity. If
unacceptable toxicity is observed in the next monitoring event, a Refractory Toxicity
.Assessment (RTA) test will be performed to determine if the discharge of toxicity would
be expected to pass through the Nutbush Creek W WTP.
Plans for the Next Quarter
The City plans to conduct the following work in the next quarter (August 15 through
November 15, 1998);
1. A chronic C. dubia compliance test will be performed in August and each month
thereafter until results show compliance with the NPDES permit limit.

City of Henderson THE Progress Report
NPDES No. 0020559
Page 8
.August 15, 1998
2. Additional industry and pump station monitoring will be conducted to identify the
sources of effluent toxicity. The monitoring effort will focus on the Sandy Creek
sewershed, which has been identified as a source of toxicity based on Microtox.
Additional monitoring will include C. dubta chronic toxicity tests.
3. The City will inspect J.P. Taylor, America[, Ball Foster, and Softspun. During the
inspections, the City will discuss activities that the industries have performed to
minimize the discharge of toxicity.
4. The City will review water records for industrial and commercial facilities to try to
identify additional potential sources oftoxicity.
5. Depending on the occurrence of effluent toxicity, the City may perform a treatability
test to evaluate the toxicity reduction that can be achieved by an upgrade of the
Nutbush Creek W WTP to biological nutrient removal (BNR).

Appendix A
Historical Ceriodaphnia dubia Chronic Toxicity Data
for the Nutbush Creek WWTP Effluent

Ceriodaphriadubia ChronicValues (ChVs) for City of Henderson
Nutbush Creek WWTP Effluent
100
80
60
W 40
x
20
0
C
n
YI YI YI W W W W 1� Iti 1� 1� W W W
V ? a V R d U R d
v a o o <
Date

v LLK �DLO OW to0� V 1-4 tOn� i� O Y�ONDOOiZL�9n P�Z� W ODD)� ��ZZ(n DL L p�A WDN'-U7�(fijQg co m E,mQS gaoc ao A (o . - � Q
v v v v v v n v n v v v v v v
�I— N O) W Of (,.� o (0 o (0 o O
m Oo J� 0 0 co co U1 O� U V O W N N Ut Ut S O N OI � N� � CT � Ut N� 0 0 Oo O O O O N N
v v v v v v v
PI
v v v v v v v v
" C (0 o N w W N I (p V (" " O O W W 0
N O O O N t0 (0 O O O � CT N O (T O (0 O VI N J
A W UI Ut W � W W c" 0 (.T ....
..N A , '
O�A<00mm�. nn�u,��p�"� Co( Z W OD (oOmrn_ N�o�� A���Z��w�
Vt M WV (0 (0 W 6 W O w V (7 66
NZ R;J: .8zzJlz ozz � (.�ZZ(. 2l Ags zs;! ) W V 82f�(2O.oz�ZZJZZ Z ZA Z
Cow OOf W (0 C7n (On ODnn V UtnnOO Ut W W n V W lO40 W tDNU V n on o,000 60
O N N 000 (0 W W O'"00� O 00000' OOOOOO � O OOOO (0 OO Q O' C� CDD O
- J Ou � O O �j A N O N(D O j O> O m Ou Cl) O Q) O) O O 0 W O W Ut W W rn O V N N A UI N
d I r
c
m

Ji_L-24-19'3a 17 11 Ei ;I JEERING
Effluent Aquatic Toxicity Report Form/Phase 11 Chronic Ceriodaphnla
FacilityNurbush Cieek tnM NPDES#-NC 0020559 Plpe# 001Counry v
abotatoryPerformjngTest Eh EhginScience & Tech. Coma- -ft
SionaturaofORC (/ _ Signet re o uparvisor
6 A4,9816 znV981 11: 55 111 04
Treatment 90 a 90 A
90
C0~01
Control
wool
pH Initial 7.7 8.1
B.Z
7.8
7.8
8.,1
pH Final --- 8.2
8.0
---
8.0
8.1
D.O. Initial 7.8 8.0
7.6
7.9
8.0
7_6
D.O. Final --- 7.7
7.4
-
7.6
7.6
romp.lnitlal 25.9 24.6 25.3 24.5 4.3 24.
remn. Final ___ 24.7 25.0 - 24.4 25.
Finel Contr,� hWrtelily %
^ 4 7 9 100
V. Contrd 3td 8t00d
Control N Young 18 32 26 20 19 23 25 15 24 21 --- -- Z • Contrulfiepro Cv 21 .6
Adult --- -- Ott txs ��
(1,)ive (D)ead L L L L L L L L L L IWC
A v 7 q u..r 0 of i 0 -0-of 10
Ci
Effluent!?6.1 Slgnifloent7 Y N
'. #Young 8 26 5 28 29 20 28 26 Z7 24 Final 51 mmeant 0
Adud 9C or No Cona
15 (L)ive (D)oad L L17 ' d e 7 e 9 10 ..
23
25
29
26
22
i0=9L;N0 C=6!•5%
,milMethad:Adult
EHiuont°°
#Young 0
24 23
A28Repro..'S!k;e-ff's
L
L
L
L
9TIr 0 947
Normal Dlstri 7Ye)Ive
(0)ead L
L L
L
6
7
8
9
10 """"
SladsUc: Cdd=L
t 2 4
EOud Vad
Stadsdc: 5.93 Cddcal: 9.49
Effluent".
# Young
22
22
25
25
26
24
24
25
23
16
23 2
•
Adult
L
L
L
L
L
L
L
L
L
L
a.a
(/A
M:MEO XT'
1
2
3
6 7 S
9
t 0
�.�•
Effluent%
#Young s6 25 26 22
29
23 26 24
27
30
25.
67 5
(L)ive (DJead L L L D
D
L L L
L
L
1 4
"
Aratyelfi:. ...; ..
EHluentY.
#Young
21
23
25
23
23
0
25
16
22
6
20.4
.-nwnll
L
ReetlOECeoult o Sr90. XNOEC_.�•57.
Adult
D
D
L
D
D
D
L
D
D
D
Chranlc Value■ - %,
(L)ive (D}ead
'ehoulE u!� hlQh/�t d.l corcorCrlbn or
hI in�st wneanaat on wutr 0.0. aSA mq
AT,T: Environmental Sciences
MAIL DN. of Environmental Management
N.C. Department of EHNR
TO: 44(311i Rd.
DEM form ATJ (W) ROv. 11195
NR8edCCreek
RakTOTAL
P.02

JUL-24-13'33 14:211 ErU=,UiEEPIIL, 1
Effluent Aquat,,..,)xicity Report Form/Phase II Chro..._ �erfodaphnia
FacilityNuthush Creek D7WTB NPDESk: NC 0020559 Pipe#,County
lab at ry e o TestEA Engineer' , Science & Tech. Comments
x x
A
i9natA o Signet re 6f,64bZupervisor -
Sample Information
Sample 1
6/22/98
Sample 2
6/25/98
Control
Collection Start Date
Grab
N/A
N/A
Composite
(DuraVon)
24 hour
24 hours
Hardness(mgA)
40
S pec. Cond. (µmhoslcm)
<0.01
<0.01
Chlorine(mg/l)
0.8 'D
Sample temp. at receipt
2.0 °C
Start Date I End Date Saul Tlrno End Tlm
6 /24/,986 4V98 11: 55 11 :04
Treatment
pH Initial
pH Final
D.O. Initial
D.O. Final
emp. Initial
emp. Final
90 -
90
90 I
Catnal
Control
Centro
7.7
8.1
8.2
7.8
7.8
8.1
---
8.2
8.0
--
8.0
8.1
7.8
8.0
7.6
7.9
8.0
7.6
---
7.7
7.4
---
7.6
7.6
25.4
24.6
25.3
24.5
4.3
24.
---
24.7
25.0
---
24.4
25.
Orcan5m0 Chronic T9et Results
11 12 ~ Final Control Mortality %
Conirol #Young 18 32 26 20 19 1 23125 15 1 24 1 21 --- -- 2 . % Control 3rd Brood 100
Contra Repro Cv 21 _6
Adult L L L L L L I L I L L I L I --- -- Control Hcpx )WC
(t)ive (D)ead
n 9 A C O 7 O o 1n i1 10 A6.n 1 n . nn I I
Effluent%
l5
Significant7LYJ U N
Final Mortality Significant
t 2 3 4 5 6 7 a 9 10 Mnn 90 % or rNo Conc.
EffluentYe # Young 0 24 23 23 25 29 26 22 A28 ReproRepro. LONOEC= 67.5Adult Method: DunnetT .5 Test30 Vive(D)ead LL L L L L ], L Normal Distnb7Y� Metho6ha 1r0-4 ' 1'.
1 2 3 4 5 6 7 9 10 wn Statistic: 00 cri 0.994=
a
Effluent e
# Young
8
26
5
28
29
20
28
26127
24
26.1
td(uDtt)
R0
(L)ivAe ead
L
L
L
Equal Variance- s1 IvSMethod:
Statistic: 5.93 Critical: 9.49
lyyn-Parametric Analvss lit annlicabls):
1 2 3 4 5 6 7 8 g 10 Yn Method:
FIIL inrJ •% Fan4Sm Critical Sum
Effluent%
677.5
# Youn9
22
1 22
1 25
25
26
24
24
1 25
1 23
16
23.'
Adult
(L)ive (D)ead
L
L
L
L
I L
L
L
I L
1 L
1 L
N%A
# Young
26
1 25
1 26
1 22
29
23
1 26
24
27
30
25.8
Adult
Add
(l)Ive (D)ead
L
L
I L
D
D
I L
L
L
L
L
1 S uw
Overall AnW"=
Effluent96 #Young 21 23 25 23123 0 25 1 16 J 22 6 20.9 'Rerun = PAS SI IL pr
Adult Yost LOEC= "' %: NOEC= 67.5 %
(L)ive (D)ead [7) D L D D D L D D D Chronic Value- 77.9 %
-Should use highest lost wnCeTadon a
ATT: Environmental Sciences highest concentration with D.O.4.0 mo
MAILDiv of anvironmen a Management . .... �. wn.1.w+.w+..
TO: N.G<. Department of �HNR
4401 Reedy Creek Rd
Raleigh, N.C. 27607 OEM form AT-3 (&91) Rev. 11/95

JUL-24-1933 14:21 1 ENGINEERIrIG R•33i1P1
INTRODUCTION
At the request of Aquatic Sciences Consulting, EA Engineering, Science, and Technology
performed chronic toxicity testing on 24-hour composite samples of effluent from the City of
Henderson's Nutbush Creek WWTP. The effluent samples were collected on 22-23 June and
25-26 June 1998. The test species, Ceriodaphnia dubia (water flea) were exposed to 90, 67.5,
45, 30, and 15 percent effluent and a laboratory dilution water control. The objectives of the
toxicity testing were to assess the chronic lethality of the effluent samples to the test organisms
and to evaluate the potential for inhibition of reproduction of the organisms exposed to the
effluent concentrations as compared to the dilution water control. This toxicity testing was
conducted under the biomonitoring requirements of NPDES Permit Number NC0020559.
The testing was conducted according to EA's protocol (EA 1996) which is included as
Attachment I, and US EPA (1994), and follows the procedures as presented in the North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure, Revised February 1999.
The results of the chronic toxicity tests were statistically analyzed, according to EPA guidance
(US EPA 1994) to determine if any effluent concentration was significantly different from the
control with respect to survival or reproduction. The short-term chronic toxicity test endpoints
reported are expressed as the No Observed Effect Concentration (NOEL), the Lowest
Observed Effect Concentration (LOEC), the Chronic Value (ChV), and the 25 percent
inhibition concentration (IC25). The definitions of these chronic endpoints follow US EPA
(1994) and are as follows:
The NS C is the highest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes no statistically
significant adverse effect on the observed parameter (usually hatchability,
survival, growth, and reproduction).

7J_---1-1 a? 141 `1 i EN51NEERI1,G '. J4.•1:J
• The t .OFF, is the lowest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes a statistically significant
adverse effect on the observed parameters (usually hatchability, survival,
growth, and reproduction).
The Chy is a value lying between the NOEC and the LOEC, derived by
calculating the geometric mean of the NOEC and LOEC. The tern is
sometimes used interchangeably with Maximum Acceptable Toxicant
Concentration (MATC).
Inhibition Concentration (ICp) - A point estimate of the toxicant concentration
that causes a given percent reduction in a non -quantal biological measurement
such as fecundity or growth. For example, an IC25 is the estimate
concentration of toxicant that causes a 25 percent reduction in mean young pei
female or some other non -quantal biological measurement.
in addition, percent reduction in reproduction was calculated for each effluent concentration by
subtracting the mean number of neonates produced by the organisms exposed to each effluent
concentration from the mean number of neonates produced by the control organisms, dividing
that number by the mean number of young produced by the control organisms and multiplying
by 100.
The Effluent Aquatic Toxicity Report Form/Phase II Chronic Ceriodaphniahas been included
at the beginning of this report. Summaries of sampleitest information, including time of test
initiation and termination, test organism source and age, water quality ranges during testing,
reference toxicant data, and test results are presented on pages 5-6. Table I summarizes the
collection and receipt data for the effluent samples. Selected water quality parameters of the
samples are reported in Table 2, Toxicity test protocols, copies of raw data sheets, and copies
of statistical analyses are included in Attachments I, 11, and III, respectively. The Report
Quality Assurance Record is included as Attachment IV.

?UL-24-1933 14:22 i ENGINEERING F.05i10
SUMMARY OF RESULTS
The results of the chronic toxicity test performed on the effluent samples from Nutbush Creek
WWTP are summarized on page 6. The test was terminated on Day 6, at which time > 80
percent of the control females had produced three broods, and mean young production in the
control was z 15 young per surviving female. At Day 6, there was 20 percent survival of
C. dubia exposed to the 90 percent effluent concentration, which was significantly different
(P=0.05) from the 100 percent survival of control organisms. Seven of the eight mortalities
in the 90 percent effluent concentration occurred on Day 6, following renewal on Day 5 with
the sample collected on 26 June 1998. Survival in the remaining effluent concentrations
ranged from 80 to 100 percent, none of which were significantly different from the control.
Mean young production in the 15, 30, 45 and 67.5 percent effluent concentrations ranged from
23.2 to 26.1 young per female, all of which were greater than the mean young produced in the
control (22.3 young per female). The NOEC was 67.5 percent effluent, the LOEC was 90
percent effluent and the Chronic Value was 77.9 percent effluent. The IC25 was > 90 percent
effluent.
in conformance with EA's quality assurance/quality control program, monthly reference
toxicant tests were conducted on the EA -cultured test species. The results of the C. dubia
reference toxicant tests fell within the acceptable limits established from EA's control charts.
K

J'JL-24-1992 14:23 1 ENGINEERING Pals/19
REFERENCES
EA. 1996. Quality Control and Standard Operating Procedures Manual for the EA
Ecotoxicology Laboratory. Revision No.S. EA Manual ATS-102. Internal document
prepared by EA's Ecotoxicology Laboratory, EA Engineering, Science, and
Technology, Inc., Sparks, Maryland.
US EPA. 1994. Short -Term Methods for Estimating the Chronic Toxicity of Effluents and
Receiving Waters to Freshwater Organisms. Third Edition. EPA/60014-91/002.
U.S. Environmental Protection Agency, Environmental Monitoring Systems
Laboratory, Cincinnati, Ohio.
4

JUL-24-1998 14:23 a ENGINEERING
P.a7/13
SUMMARY OF SAMPLE/TEST INFORMATION
Test: Daily renewal chronic toxicity test with Cerdodaphnia dubia
Test Procedure: EA Protocol ATS-STC-CD-06 (NC)
North Carolina Ceriodaphnia dubia chronic toxicity testing procedure
(PASS/FAIL and Phase II)
Client Name: City of Henderson
Sample Description: Nutbush Creek WWTP
EA Accession Numbers: AT8-365, AT8377
Dilute Water Description: Dilute mineral water
EA QC Test Number: TN-98-188
Test initiation time and date: 1155, 24 June 1998
Test completion time and date: 1104, 30 June 1998
Organism tot Information
Lot Number: Not Applicable
Source: EA's Culture Facility (Sparks, Maryland)
Age: <24 hours old (within a 4-hour window)
Rderence Toxicant Test Information
Reference Toxicant: Sodium chloride (NaCI)
Dilution water: Dilute mineral water
EA QC Test Number: RT-98-111
Test Initiation: 9 June 1998
Control Survival: 89O1a (7 days)
Test Results:
NOEC: 0.6 g/L NaCI
Laboratory control chart acceptability range for chronic NOEC: 0.6-2.4 g/L NaCI
5

JJL-24-1999 14:24 a ENGINEERING
SUMMARY OF SELECTED TEST DATA
Test Species: Ceriodaphnia dubia
Test: Survival and reproduction test
Client Name: City of Henderson
Sample Description: Nutbush Creek WWTP
EA QC Test Number: TN-98-188
Test Concentration
6-Day Survival Mean Young Production
(percent effluent)
(percent)
(neonalesloreanism
(LSD)
Control
100
22.3 (±4.8)
15
90
26.1 (±2.6)
30
100
25.5 (±2.7)
45
100
23.2 (±2,9)
67.5
80
25.8 (±2.5)
90
20"'
20.4 (±5.7)l°'
Endpuint- ressed ac perccnt
effluent)
NOEC:
67.5
LOEC:
90
Chv:
77.9
IC25:
> 90
Selected Test Water Quality
Parameters
$anpc
M= (2:S.D.)
Temperature (°C):
_
24.3 - 25.6
24,9 (±0.4)
pH:
7.5 - 8.2
8.0 (±0.2)
Dissolved Oxygen (mg/L):
7.4 - 8.0
7.7 (±0.2)
Conductivity (JCS/cm):
101 - 781
396 (±213)
Percent
Seduction
(a) Statistically different (P=0.05) from control indicating an adverse effect.
(b) Concentrations which have significant mortality are not statistically analyzed for survival
(per EPA guidance).
(c) Reproduction in this effluent concentration was greater than in the control.
L

TABLE 1 SUMMARY OF SAMPLE COLLECTION AND RECEIPT DATA FOR EFFLUENT SAMPLES FROM
NUTBUSH CREEK WWTP
EA Accession
Collection
Number
Time and Date
AT8-365
1500, 22 JUN 98 to
1502, 23 JUN 98
AT8-377
1505, 25 JUN 98 to
1510, 26 JUN 98
Receipt
Time and Date
1025, 24 JUN 98
1025, 27 JUN 98
Sample Usage
Time and Date
Initiation: 1155, 24 JUN 98
Day 2 Renewal: 1347, 26 JUN 98
Day 5 Renewal: 1104, 29 JUN 98
r
a
u)
�u
A
N
A
y
z
z
m
Rl
A_
L
P.

TABLE 2 SELECTED WATER QUALITY PARAMETERS MEASURED WON RECEIPT FOR EFFLUENT SAMPLES
FROM NUTBUSH CREEK WWTP
EA Accession
Temperature
Total Residual
Alkalinity Hardness Conductivity
Number
(00
p.H chlorine (mgj�
(mgfL) (mg(j ) (uslicm)
AT8-365
0.8
7.4 <0.01
122 132 755
AT8-377
2.0
7.5 <0.01
90 116 700
.P
-0
I+
O
m

Appendix B
Results of Toxicity Identification Phase I Test Performed on
Nutbush Creek WVR'TP Effluent

JUN-05-1999 12t43 ER ENGINEERING
P.01/34
TABLE A SUMMARY OF 5-DAY Cenodaphnia dubia SURVIVAL DATA FROM
TOXICITY IDENTIFICATION
EVALUATION ON EFFLUENT SAMPLES
FROM THE CITY OF HENDERSON
(29 MAY 1998)
Treatmen
5-day Survival(percentj
1QQ1
rnn"l IU
2i&
SA
Zia
Baseline
100 1DO
Ow
OW
04)
0"'
Aeration
80
60
OW
OW
OG)
Filtration
100 --
20@1
ow
0�'
0(')
CIS column
too ---
100
10D
100
100
EDTA
0.5 ppm,
100
---
Ow
O<al
0(')
3.0 ppm
100 ---
---
OW
0(')
0(4)
8.0 ppm
100 ---
---
OW
ow
OW
Sodium Thiosulfate
2.5 ppm
100 ---
--
O(A)
Ow
Ow
5.0 ppm
100 ---
---
0v"
Ow
Ot9
10.0 ppm
100 ---
--
0(4'
0w
OW
After Peroxide
80 100
100
80
OW
oIR)
(a) Treatments which have no Surviving organisms are not included in the statistical aoaiysis.
(b) Significantly different (P=0.05) from the tfeatment control, indicating an adverse affect.
t�'W Oi l
u

JUN-05-1999 12!43 ER ENGINEERING �.3,'J4
TABLE B SUMMARY OF 5-DAY CetaadapWa dubia REPRODUCTION DATA FROM
TOXICITY IDENTIFICATION EVALUATION ON EFFLUF-NT SAMPLES
FROM THE CITY OF HENDERSON (29 MAY 1998)
Reproduction
(+can youne�ner female)
C4ntml
lox 23Sx
Ml
a&
14fffi.
Baseline
23.2
19.0 9.Ow
Ow
Ow
Ot°
Aeration
24.2
-- 23.6
6.2w
Ow
Ow
Filtration
27.4
--- S.Ow
ON
Ow
Ow
Cs, Column
24.8
--- 21.2
22.4
26.2
26.6
EDTA
0.5 ppm
29.0
--- ---
Ow
0tx
0w
3.0 ppm
26.0
— —
Ow
Ow
Ow
8.0 ppm
25.4
--- ---
Ow
Oto
Olx
Sodium Thiosulfate
2.5 ppm
26.0
-- —
Ow
Ow
Ow
5.0 ppm
26.2
--- --
Ow
Ow
Ow
10.0 ppm
25.8
--- ---
Ow
0w
0w
After Peroxide
21-8
23.0 21.2
18.0
8.8tex
1 4t'l
(a) Tbou oomeeatratioaa which have m surviving organisism or hays statistically significant (P-0.05) mortality. are not
amalyaed for reproduction, per EPA guideline.
qdv
6t'S�
L

JJ`1-3�-1333 12:44 cNuINEERINa D.03/04
TABLE C SUMMARY OF RESULTS OF Ceriodapimia dubia CHRONIC TOXICITY
IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES FROM THE CITY
OF HEN DERSON (29 MAY 1998)
Baseline
Aeration
Filtration
C,a Column
EDTA 0.5 ppm
3.0 ppm
8.0 ppm
Sodium Thioaulfate
2.5 ppm
5.0 ppm
10.0 ppm
Chronic Toxicity Endpoints
(as percent samnle)
MeanYoung
NOEL
LOIRC
m
MIN
1=
Rage)
10
25
15.8
4.7
21.1 (4.1-24.3y4
0
25
50
35.4
2,4
41.5 (27.2- 4.6)
0
<25
25
QS
6.5
15.3 (12.8-17.4)
0
100
>100
>100
<1.0
>100
I.07
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
After Peroxide 50 75 61.2 1.5 68.5 (37.1-84.4) 0.06
(s) Tmtic unit based on IC25 va)uas. uu4as otberwix riled
(b) Mean Ymmg Ratio - ratio of own young padoced in 100% oowmtmtion oompurd to treatment control.
(c) Values in parandmea mpreseot 9s pamnt om5dm w limits.
6�c(d ��s

JUN-05-1999 12:44 EA ENGINEERING P.04iO4
TABLE D TOXICITY IDENTIFICATION EVALUATION SYSTEM BLANKS PERFORMED
FOR TESTING ON THE SAMPLE AT8-282 - 5-DAY DATA (29 MAY 1998)
Ceriodaphnia dubia
Treaun_ent Syslwm Blanks
Survival
(Percent)
Reproduction at Day 6
(m= yountr = fuel
Aeration
100
25.6
Filtration
100
19.5
Cle Extraction
100
26.6
EDTA 0.5 ppm
100
28.2
3.0 ppm
100
25.6
8.0 ppm
100
7.00
Sodium Thiosulfate
2.5 ppm
100
28.4
5.0 ppm
100
25.4
10.0 ppm
100
25.0
(4) ststi.tic4uy different (P-0.05)
from the lrosho L Control iadlcatiaa
an adverse offOCI
ToraL P.a4

Appendix C
Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
Toxic Chemical Release Reporting, Community Right -to -Know, 40 CFR 372
City Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
Microtox Results for Industry and Pump Station Samples

1-16. 01. 08 01 :28 PtY1 *BURKART CAROLINA PIII
RESCAR & ANMYTiCAI
LAbORATOMES, INC.
Annly*jil/PrtMgys Gunsu!tatlnoi,
25 ),Jay 1998
Organic 1•isitwdm
p.0. Box 10,1
areauhot*. nc 7.7401
Alto: lane) Walkor
Sampla Suure,:;
Anelpiy
1'4CAf0 m
10DI
Clnnldotl 0ayoon Dumo,ld
pain Bamplo colloc'M
pare Sa6y,b Recelud
Dotc 6aolplo A,wly"d
Two nt Repnrt
Anal)rn Pcrfwnlcd by
MATAD nevE scan code: 4012 ! B•431050
Wool
610t:hdrnlan10yY0an Demand • G dry
61ocl,ur„iod 0.eygan Domond • 15 day
610CIg111lo01 t)nyvcu 0urtland • 211 day
Olndnandon1111Y • 5 day
OIuJoU'adr1,1111y • I6 day
BiodeOrnJod6ry • 20 day
ASllly • CC 60
Aoala TuAlty • W 60
Wit-)TodclW -LI 40 ' •'
Idatols
Antinwnv
A1a41Jc /
Oarium /
UnJndum
CluolniVnl
J:ap)mr
Laud
Mo(cory
Snlanatnl
5lmple NumMr
Sample Dan
pimilE
3,000,000
37,100
251.000
39('.000
1.2
0.1
10.0
> 1,000
sne
4,690
c 260
KUM
<250
6.40
K 50.0
3,050
<26.0
<U.2
<60.0
) 9857
04/09/9A
ASRIT n Acil""d SNdle Resplralklo 11111
i,01on'IG1
I
y •. (Ittakr 11aa
i a Iat� lhml
ppm 1'atl. Irot h(illk,n
.A Aed a d 6%
a e A(poll 011 'as il' 1 aSIS
an .. perk0*14n1ia dull"
Bit . pt+tubiniki Bfomalaa
4alrs
ppm
pp",
1'1'm
ppn,
ppon
ppm
ppnt
pplo
ppm
pp,rt
ppm
pput
rpm
ppm
ppm
NO rM
W ALIP� 'ro
ws
WOWS
Oa)IONB
41111)NN-07m9/40
03l471J8
1)e .spc•txn
;

0l,24/38 12:18 Ta:TON SFAH Fran:0rganic Pigments
ENVIRONMENTAL PROTEC fION AGENCY
40 CFR PART 372
[OPTS-400030A; FRL-380341
Copper Phthalocyanlne Pigments; Toxic Chemical Release
Reporting; Community Right -to -Know
AGENCY: Environmental Protection Agency (EPA).
ACTION: Final rule.
SUMMARY: EPA is promulgating a rule to delete Pigment Blue 15, Pigment Green
7, and Pigment Green 36 from reporting requirements under the category "copper
compounds" from the list of toxic chemicals under section 313 of the Emergency
Planning and Community Right -to -Know Act. The rule is based on EPA's
conclusion that: (1) The copper ion cannot teasonably be anticipated to become
available at a level which induces toxicity from any of these pigments and (2)
there is no evidence that the three chemicals cause or can reasonably be
anticipated to cause adverse human health or environmental effects as specified
under section 313(d). By promulgating this rule, EPA is relieving facilities of
their obligation to report in 1991 on releases of Pigment Blue 15, Pigment Green
7, or Pigment Green 36 that occurred in 1990, and on releases that will occur
in futute years.
DATES: This rule is effective [insert date 30 days after date of publication in
the Federal Register].
FOR FURTHER INFORMATION CONTACT: Maria J. Doa, Petitions Coordinator,
Emergency Planning and Community Right -to -Know Hotline, Environmental
Protection Agency, Mail Stop OS-120, 401 M St., SW., Washington. DC 20460.
Toll free: 800-535-0202, In Washington, DC and Alaska: 202-479-2449.
SUPPLEMENTARY INFORMATION:
1. Introduction
A. Statutory Authority
i The deletion of three copper pigments from reporting requirements under
thi, category "copper compounds" from ale section 313 list of toxic chemicals
is issued under section 313(d) and (exl) of the Emergency Planning and
Community Right -to -Know Act (EPCRA) of 1986, also referred to as Title Ill
of the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub.
L. 99-499).
273-8918
B, Background
Section 313 of EPCRA requires certain facilities manufacturing, processing,
or otherwise using toxic chemicals to report annually their environmental releases
of such chemicals. Section 313 establishes an initial list of toxic chemicals that
'age 81
,t°
I
.=r
,a
•,i
i.� t
is
i

07'29/3e 0:30 1o:10M SPAIN Fram:Organic Pigments 1-0910 'age 7.1
is composed of more than 300 chemicals and 20 chemical categories. Any person
may petition EPA to add chemicals to or delete chemicals from.the list.
EPA issued a statement of petition policy and guidance in the Federal
Register of February 4, 1987 (52 FR 3479). to provide guidance regarding the
recommended content and fonnat for submitting petitions. EPA must respond
to petitions within 180 days either by initiating a rulemaking or by publishing
an explahation of why the petition has been denied.
11. Description of Petition
On June 1, 1988, EPA received a petition from The Dry Color
Manufacturers' Association (DCMA) to exempt three phihalocyanine pigments
from the reporting requirements under the list of toxic chemicals category
"copper compounds." C.I. Pigment Blue 15, CAS No. 147-14-8; C.I. Pigment
Green 7, CAS No. 1328-53-6; and C.I. Pigment Green 36, CAS No. 14302-
13-7 are pllthalocyanine pigments covalently bound to copper. Since the
pigments are copper -containing compounds, they are reportable under section
313. Aftcrreview'of the submitted petition and additional information available
to EPA, the Agency proposed to delete the three phthalocyanine pigments from
reporting under the "copper compounds" category; the proposal was published
in the Federal Register of May 15, 1989 (54 FR 20866). EPA concluded that
the, three phthalocyanine pigments cannot be reasonably anticipated to cause
adverse health or environmental effects of concern to warrant continued release
reporting under section 313. A detailed review of the toxicity and environmental
effects of the three intact pltthalocyanine pigments, along with an assessment
of actual or potential exposure, is contained in the proposal.
Because DCMA's petition raised a number of important questions about how
EPA should deal with petitions to delete individual members of listed chemical
categories, the Agency also requested comment on approaches for addressing
these issues and presented four alternatives. The public comment that was
received as a result of the second request is addressed in a notice of policy and
guidance on the metal compound categories that is published elsewhere in this
issue of the Federal Register.
As stated in the above -mentioned notice of policy and guidance on the metal
compound categories, the toxicity of a metal -containing compound that
dissociates or reacts to generate the metal ion can be expressed as a function
of the toxicity induced by the intact species and the availability of the metal
ion, where the degree of dissociation, bioaccumulation, and the level at which
toxicity is induced by the metal ion must be considered. The effects induced
by the metal ions described by the metal compound categories meet the criteria
under section 313(dx2). Thus, for petitions to exempt metal -containing
compounds from the repotting requirements under section 313, EPA has decided
to Use its decisions on the evaluation of all chemical and biological processes
that may lead to metal ion availability as well as on the toxicity exhibited by
the intact species. These decisions will continue to be based on information
provided by the petitioner, Agency documents, and avattable ltaroture, The
burden of proof that the metal compound does not generate the metal ion as
a result of one or more transformation processes rests on the submitter. FPA

04/21/38 !':38 to:IOH SFAN From:Organic hgmen:s -273-8918 'age 6!8
3
will deny petitions for chemicals for which the metal ion availability cannot be
properly evaluated. EPA will also deny petitions for chemicals'that dissociate
or react to generate the metal Ion at a level which can reasonably be anticipated
to cause adverse effects. If the metal compound does not dissociate or react to
generate the metal ion at a level which can reasonably be anticipated to cause
adverse effects, EPA will determine whether the effects which may be'induced
by the intact species meet the toxicity criteria of section 313(d)(2).
It should bP noted that the above policy would result in a denial of DCMA's
petition if it were received today because DCMA did not address, in the petition,
all of the transformation processes which could lead to the availability of copper
ion from the three copper pigments. Prior to adopting the above stated policy,
EPA carried out a technical review to assess the potential availability of copper
ion from the three copper pigments and based its decision on the lack of toxicity
exhibited by the intact species and the limited copper ion availability. EPA's
technical review of the copper pigments, which is provided below, illustrates the
type of analyses which must be conducted by petitioners to justify deletions of
metal compounds from their respective categories.
Ili. Technical Review
In the proposed rule to exempt the copper pigments front the reporting
requirements under the copper compounds category under EPCRA section 313,
EPA stated that there was no indication from the available data that the (intact)
copper pigments can reasonably be anticipated to cause acute, chronic, or
environmental toxicity, The issue of copper ion availability from the three.
phthalocyanine pigments was not explicitly addressed in the proposed rule.
EPA is concerned with both the potential toxicity induced by intact metal
compounds and with the toxicity induced by the metal ion. Although EPA was
concerned with copper ion availability in its initial review, it did not consider
all the transformation processes that may lead to metal ion availability. The
Agency recently addressed the transformation processes that may generate copper
ion from the copper phthalocyanine pigments. These include, but are not limited
to: hydrolysis, photolysis, abiotic and biopc aerobic degradations, abiotic and
biotic anaerobic degradations, bioavailability of the ion when the compounds are
ingested or inhaled, and bioaccumulation. All readily available data including
studies retrieved from literature searches and documents prepared by EPA were
considered in EPA's assessment of the availability of copper ion from the copper
phthalocyanine pignrnts.
1. Copper ion. Copper is recognized as an essential element. It is essential
to a number of normal physiological processes including erythropoieses,
connective tissue metabolism, bone development, and nervous system function.
The National Academy of Sciences' recommended daily allowance (RDA) for
adults is 2.0 to 3.0 milligrams (mg) copper/day. Copper is also used as a
henratinic (to stimulate red blood cell production) in adults at a dose of 3.8 to
7.6 mg/day.
a.. Human health effects. Copper poisoning has been demonstrated in animals
and identified in humans. The liver is the main storage depot for copper, and

03:29/38 12:38 To:1011 :Fait/ Fram:organic Figmei.s ?73-6918
4
hepatic damage is associated with the accumulation of high levels of copper.
Hepatic toxicity is characterized by hepatocellular necrosis, regenerative activity,
and cirrhosis. Kidney necrosis and elevated levels of serum copper occur only
after the liver begins to accumulate high levels of copper. These elevated serum
copper levels can progress to sudden hemolytic anemia and jaundice.
The types of neurological effects associated with copper poisoning can
include demyelination and cerebral degeneration. These effects are thought to
be related to defects in catecholamine metabolism. Alterations in brain
neurotransmitter systems have been observed in rats following intraperitoneal
injections of 2 milligrams/kilogram/day (mg/kg/day) for 21 days. Two groups
are at an increased risk from copper exposure. individuals with Wilson's disease,
an inborn error in copper metabolism, are at a higher risk than the general
population. The metabolic error in Wilson's disease allows copper to accumulate
in the liver, brain, kidney, and cornea, causing hemolytic anemia, neurological
abnomialities, and corneal opacity. In addition, individuals with glucose-6-
phosphate dehydrogenase deficiencies may also be at greater risk of experiencing
toxic effects from copper exposure.
Copper is classified in EPA's group D (insufficient data) for carcinogenic
potential. Copper is generally negadve in mutagenicity bioassays. Bioassays using
oral copper were negative; subcutaneous injection of copper compounds has been
reported to induce tumor formation in one sex and strain of mice.
EPA has proposed a maximum contaminant level (MCL) of 1. t milligrams/
liter (ntg[L) (3.6 mg/day) copper.
b. Ecological effects. Copper is very toxic to aquatic life. It is sometimes
used as a biocide to control undesirable aquatic plants. EPA has issued Water
Quality Criteria for copper to protect aquatic life. The acute criteria in fresh water
is 22 micrograms/liter (ug/L). The chronic criteria in fresh water is 5.2 ug/L.
In salt water both the acute and chromic criteria are I ug/L.
2.. Availability of copper ion. The three copper pitthalocyanine pigments are
extremely stable to chemically and biologically induced transformations.
a. Thermal stability. The three copper pigments are extremely stable
thermally and only begin to show signs of decomposition at temperatures above
500 °C.
b. Hydrolysis. The three copper pigments have very low solubilities in water
(estimates are 8 x l0•' to 3 x IW mg/L for Pigment Blue 15, 7 x ICY" to 2
x 1011 mg/L for Pigment Green 7, and less than 10'" mg/L for Pigment Green
36) and do not dissociate or hydrolyze in water under environmental conditions.
Hydrolysis of the three copper pigments also does not occur in basic and non -
oxidizing acidic media.
c. Photolysis. Based on studies carried out to determine the light fastness
of the three copper phthalocyanines, it appears that photolysis of these pigments
with resultant release of copper ion will not occur.
'age Ve

Ci721!88 12:38 To:TOn SPAN from:organic Pigmen's 273-0918 'age 418
d. Abiotic oxidation. Data indicate that under environmental conditions,
abiotic oxidation of these copper pigments does not occur. More rigorous
conditions are required to effect the oxidation of the copper phthalocyanines and
subsequent release of copper ion. The pigments can be chemically oxidized to
give ptttbalimides and copper nitrate by boiling in dilute nitric acid. Oxidation
of the pigments can also occur by treatment with eerie sulfate in dilute sulfuric
acid at 25 °C, or by reaction with potassium pemnanganate.
e. Microbial transformations. No data on the anaerobic or aerobic
biodegradability of tj a copper pigments were found. However, based on their
extremely low solubility it, water, their large cross -sectional diameter, and with
die exception of the halogens on Pigment Green 7 and Pigment Green 36, the
lack of substituent groups associated with facile primary degradation, these
pigments are expected to be very resistant to degradation processes.
f. fi'ioavailability. On the basis of molecular weight, extremely low solubility
in water, and data from subchronic toxicity tests, the three phthalocyanine
pigments are not expected to be appreciably absorbed by any route of exposure
or metabolized to yield copper ion.
The lack of toxicity and minimal changes in tissue copper levels observed
in 13—week oral studies of Pigment Blue 15 and Pigment Green 7 in rodents
Indicate that appreciable absorption and metabolism to yield copper ion had not
occurred.
g. Uioaccumulution. Because copper ion does not appear to be available from
the phthalocyanine pigments, bioaccumulation of copper ion is not a concern.
It. Suntrwry. EPA believes that the availability of copper ion from the
phthalocyanine pigments by hydrolysis, photolysis, aerobic and anaerobic
transformations is negligible. Copper ion is not expected to be bioavailable from
the copper pigments. The copper pigments are not expected to be appreciably
absorbed by any route of exposure or metabolized to yield the copper ion.'The
levels at which copper ion exhibits toxicity far exceed the expected limited
availability of copper ion from the phthalocyanine pigments which results In a
low level of concern for these chemicals. There could be a slight risk to aquatic
life in rare situations. The small, infrequent risk is best controlled by control
programs under the Clean Water Act, not by a global reporting requirement.
IV. Comments on the Proposed Exemption of the Three Phtiralocyanine
Pigments
EPA received comments from more than 22 commenters on the proposed
exemption of the three copper phthalocyanine pigments from the "copper
category" and on the category issue itself. Eleven commenters were in favor
of granting the exemption, two were in favor of denying the exemption, and
the remaining comments were directed only to the category issue.
The New York City Department of Environmental Protection believes that
EPA should not exempt tiro copper pigments from reporting requirements under
the copper compounds category because "it does not appear that EPA considered
the possibility that copper may be released from the pigments by the action of

04,�24!38 12:38 To:TOH SPAIH FromoOrganic Pigments-273-8918 ?age 3!8
6
soil micro-organisms.... If the action of bacteria liberates copper into the
euvbonment, then the release of die copper pigments represents an environmental
harard. EPA believes that because of the factors specified above (unit 111.2.E)
microbial degradation of the copper pigments with resultant release of copper
ion is Highly unlikely.
Arts, Crafts and Theater Safety suggests that before "EPA approves
DCMA's petition DCMA should document the degree" to which polychlorinated
biphenyls (PCBs) and free copper inadvertently contaminate phthalocyanine
pigments manufactured or imported into the United States. Pursuant to 40 CFR
761.30, phthalocyanine pigments that contain up to 50 ppm PCBs can be
processed and distributed in commerce. Processing and distribution of
phthalocyanine pigments that contain 50 ppm or greater of PCBs is permitted
only for persons who are granted an exemption under section 6(e)(3)(B) of the
Toxic Substances Control Act (TSCA). PCBs are only reportable under section
313 if they are present at a concentratioh of 0.1 percent, which is the de minimis
concentration (40 CFR 372.38).
The copper compounds category is subject to the one percent de minimis
concentration. Thus, mixtures that contain copper compounds (except the three
copper phthalocyanine pigments) in excess of the de minimis concentration should
be factored into threshold and release determinations. EPA does not believe that
plithalocyanine pigments contaminated with other copper compounds, and/or
PCBs should be treated differently than other mixtures. The presence of these
impurities did not affect EPA's decision to delete die three copper pigments.
V. Rulemaking Record
The record supporting this rule is contained in docket number OPTS-
400030A. All documents, including the index of the docket, are available to the
public in the TSCA Public Docket Office from 8 a.m. to noon and l p.m. to
4 p.m., Monday through Friday, excluding legal holidays. The TSCA Public
Docket Office is located at EPA headquarters, Room NE-0004, 401 M St., SW.,
Washington, DC 20460.
VI. Regulatory Assessment Requirements
A. Executive Order 12291
Under Executive Order 12291, EPA must judge whether a rule is "major"
and therefore, requires a Regulatory Impact Analysis. EPA has determined that
this rule is not a "major rule" because it will not have an effect on the economy
of $100 million or more.
This rule would decrease the impact of tiie section 313 reporting
requirements on covered facilities and would result in cost -savings to industry.
EPA, and States. Therefore, this is a minor rule under Executive Order 12291.
There are 6 major producers, 16 processors of the crude pigment to pigment
grade, and 21 importers of Pigment Blue-15 at a total of 45 sites. There may
be 1 producer, approximately 14 processors, and 12 importers of Pigment Green-
7 at a total of 26 sites.'iliere are approximately 5 processors and 4 importers
of Pigment Green-36 at a total of 9 sites. EPA estimates the number of producers,

04/21/98 12:38 lo:1011 SFAI`1 Fron:Organic Pigments 73-B918 Page 2/8
1.1 �;' •.
7
processors, and importers that might be subject to reporting under the current
threshold requirements to be no more than 80. the cost savings of exempting
industry from reporting requirements for these three copper phthalocyanine
pigments under the "copper category" are estimated at one million dollars, while
the savings for EPA are estimated to be $25,000 (10-year present values using
a 10 percent discount rate).
B. Regulatory Flexibility Act
Under the Regulatory Flexibility Act of 1980, the Agency must conduct
a small business analysis to determine whether a substantial number of small
entities will be significantly affected. Because the rule results in cost savings
to facilities, the Agency certifies that small entities will not be significantly
affected by the rule.
C. Paperwork Reduction Act
This rule does not have any infonnation collection requirements under the
provisions of the Paperwork Reduction Act of 1980, 44 U.S.C. 3501 et seq.
List or Subjects in 40 CFR Part 372
Chemicals, Community tight -to -know, Environmental protection, Reporting and
recordkeeping requirements,, Toxic chemicals.
Dated:
YY�
AssistantAdmLhi marjarPesticides and Toxic Substances.
Therefore, 40 CFR part 372 is amended as follows:
I. The authority citation for part 372 continues to read as follows:
Authority: 42 U.S.C. 11023 and 11048.
§ 372.65 [Amended]
2. In § 372.65(c) by adding the following language to the copper compounds
listing "(except for C.I. Pigment Blue 15 (PB-15. CAS No. 141-14-8), C.I.
Pigment Green 7 (PG-7, CAS No. 1328-53-6), and C.I. Pigment Green 36 (PG-
36, CAS No, 14302-13-7)".
(FR Doc. 91-????? Filed??_??-91; 8:45 a.m.)
BILL114G COM 6560-50-F

ri
In
z
fy
w
Cr
w
w
TABLE 3 RESULTS OF LIMITED -SCALE CHRONIC TOXICITY TESTS ON INDUSTRY DISCHARGE SAMPLES FROM
CITY OF HENDERSON, NUTBUSH W WTT
Sample Description
EA Accession No:
Test Number:
Test Concentrations
(percent sample)
Control
10
25
50
75
100
NOEC:
AT8-354
TN-98-223
Survival Mean Young per
(percent)
femalee ±S.D_)
100
22.0 (t 2.9)
100
21.0 (t 1.0)
100
22.2 (t 4.7)
ON
&)
ON
0(•)
o(•)
o(•)
25
LOEC: 50
ChV: 35.4
IC25: 30.9 (24.8—31.4)0°
(a) Treatments which have ao sumine agoisms wo rent included in the datistial aadym.
(b) Stalistimily dwac t 0'-0.05) fan the control. indi=tMg an edvan eBoot
(c) Valtms inpumthem reTme t 95 paornt cmfideme li nib.
M=95 percent am6daem limits ne unl u4wiabht
Sample Description:
EA Accession No:
Test Number:
Test Concentrations
(percent samole)
Control
10
25
50
75
100
NOEL:
LOEC:
ChV:
IC25:
WHITE INFLUENT
AT8-355
TN-98-224
Survival Mean Young per
100
23.4 (t 6.1)
100
26.2 (t 5.0)
100
22.0 (t 5.2)
100
20.6 (k 2.7)
100
17.8 (t4.0)
I00
16.2 (f 2.6)P)
75
100
96.6
67.9 (NC)

Wl
0
N
m
rL
z
it
w
w
z
M
z
w
a
w
TABLE 3
Sample Desctiption:
EA Accession No:
Test Number:
BLUE EFFLUENT #1
AT8-356
TN-98-225
Sample Description:
EA Accession No:
Test Number:
BLUE INFLUENT
ATS-357
TN-98-226
Test Concentrations
Survival
Mean Young per
Test Concentrations
Survival
Mean Young per
(percent sunole)samole)
fnercentl
female {fS.D.]
(oerceat mnpW
(,per)
female (tS D.I
Control
too
22.6 (12.7)
Control
100
24.0 {f 5.9)
10
100
21.9 (4:3.3)
10
100
16.8 {f 6.9)
25
100
22.4 (f 3.3)
25
Oµl
1.0 (i 2.2)f'l
50
O(a)
5.6 (t 1.1)(')
50
Ot'l
0(21
75
Ol't
Ol')
75
0('l
&
100
Ot'l
013)
100
0(')
O(A)
NOEC:
25
NOEC:
l0
LOEC:
50
LOEC:
25
ChV:
35.4
ChV:
15.9
IC25:
32.8 (26.6 — 34.2)t`l
IC25:
9.3
(2.7 — 16.7)`T
(a) Treatments wbich have no surviving organisms am act inhaled in the statistical analyses
(b) StatisticaDy differed (Pa0.05) fiom We camtral, indicating an advesse effect
(c) Values in pnendmes represent 95 perceor oon6denm limits.

M
M 0
TABLE 4 RESULTS OF CHRONIC TOXICITY TESTS ON FINAL EFFLUENT SAMPLES COLLECTED BEFORE AND a
9 AFTER ADDITION OF HYDROGEN PEROXIDE
Cr
Sample Description: Final Effluent Before H2O2
Find
Effluent After H2O2
EA Accession Number: AT8-364,376
A78-365,377
Test Number: TN-98-239
TN-99-188
Test Concentrations Survival Mean Young per
Survival
Mean Young per
(percent effluent) (nereertt) female (tS.D.)
cent)
female(iS.D.)
Control 100 15.0 {t 6.8)
100
22.3 (t 4.8)
15 100 20.6 (t 0.9)
90
26.1(t 2.6)
30 Ot'l ow
100
25.5 (t 2.7)
45 O<'1 or-)
100
23.2 (: 2.9)
z
w 67.5 Ot'l Ot'1
8o
25.8 (t 2.5)
w
90 Ot'l Ot'l
20rot
20.4 (t 5.7)tet
z
w
IL
NOEC: 15
67.5
LOEC: 30
90
ChV: 21.2
77.9
N
.y
IC25: 18.8 (NC)
>90
m
m (a) Treatment/ vAw*hnve s4mificaot nuaro,sty cc hwo no anvivin orgrusms arc not stabdieally analyzed for reproduction, per
EPA guidance.
(b) Statistically diffi ' (P-0.05) from control indicating m adveme effect
m (c) Valueainpucadmbrq=seot9emea 5ptconfidmmlimgs.
NC= 95 percent confidence knits we not calcubb1c

Table C-1. Results of Microtox Chronic Tests (22-h Light Loss) Performed on Industry and Pump
Station Samples.
IM Date
Sample
IC25
ChV
NOEC
LOEC
Feb 13
Americal
Ball Foster
76.2
NC
100
>100
Iams
64
NC
100
>100
J.P. Taylor
2.0
NC
6.25
<6.25
Kennametal
1.7
NC
6.25
<6.25
Softspun
5.4
70.7
50
100
WWTPEfuent
70.2
NC
100
>100
Mar 6
Americal
26.7
NC
100
>100
Ball Foster
26.4
70.7
50
100
Iams
26.5
35.4
25
50
J.P. Taylor
21.1
17.7
12.5
25
Kennametal
31.6
70.7
50
100
Softspun
60.9
70.7
50
100
Sandy Creek P.S.
47.1
NC
100
>100
W WTP Effluent
40.7
70.7
50
100
Apr 8
Americal
2,4
NC
6.25
<6.25
Ball Foster
28.6
35.4
25
50
Iams
56.1
NC
100
<100
J.P. Taylor
25.9
35.4
25
50
Kennametal
1.6
NC
6.25
<6.25
Softspun
1.6
NC
NC
<6.25
Sandy Creek P.S.
W'A TP Effluent (Apr 9)
2,16
35.4
25
50
Apr 15
Americal
>100
NC
100
>101
Ball Foster
60.6
70.7
50
100
Iams
>100
NC
100
>lW
J.P. Taylor
37.5
70.7
50
100
Kennametal
47.5
70.7
50
100
Softspun
23.5
35.4
25
50
Sandy Creek P.S.
75.1
NC
100
>100
W WTP Effluent
44.4
70.7
50
100
Apr 22
Americal
2.1
NC
6.25
<6.25
Ball Faster
2.7
NC
6.25
<6.25
Iams
13.9
17.7
125
25
J.P. Taylor
2.1
NC
6.25
<6.25
Kennametal
13.0
17.7
12.5
25
Softspun
1.6
NC
NC
<6.25
Sandy Creek P.S.
3
NC
6.25
<6.25
WWTP Effluent
9,3
35.4
25
50

TABLE 3 RESI ri:I:S OF LIMITED -SCALE Cl IRONIC TONICITY TESTS ON INDUSTRY INSC I1ARGE SAMPLES FROM
CITY OF ►IENDERSON. N[ 7131. iSl l WWTP
Industry Name:
A-MERICAL
Industry Name:
i:ENNAMETAL
IWC:
6.4 ";
lWC:
0.611.)
EA Accession No:
rVIT-290/306
EA Accession No:
AT8-294i310
"rest Number:
TN-98-180
Test Number:
TN-98-184
Test Concentrations
Survival
Mean Young, per
Test Concentrations
Survival Alcan Young per
(percent sample)(percent
female (:tiS.D.)
(percent sample)(percent
temale (d:S.D.)
Control
80
12.4 (� 7.6)
Control
100 20.2 (16.0)
0.8
100
14.8 (15.0)
0.075
100 19.0 (1- 4.8)
1.6
100
15.6 (t 3.2)
0.15
100 20.8 (a 2.2)
3.2
100
15.6 (f 4.0)
0.3
to0 22.4 (t 2.9)
6.4
40
7.2 (t 9.9)
0.6
too 24.6 (t 2.2)
12.8
0(•)
0(at
1.2
80 21.4 (i 2.9)
NOEC:
6.4
NOEC:
1.2
LOEC:
12.8
LOEC:
? 1.2
CItV:
9.1
ClIV:
'1.2
IC25:
4.8 (2.8 - 9.6)
IC25:
1.2
(a) Treatments wnich have no an(tii%ing orpetisnis are licit uruluded lit the staiwical analyse,
(b) Stanstiadly ditl'ercul i P-u 05) fiotn the cutvr.,L indiamng an adverse etYcu.

TABLE 3 (Contim
Industry Name:
Ball foster
Industry Name:
LAMS
f,.\ Acwssion No:
:Cr8-293%307
f.A Accomsion No:
AT8-292'308
Test Number:
TN-98-181
Test Number:
TNA8-182
Test Concentrations
Survival
Mean Young per
Test Coneenlrativas
Survival
Mean Young per
(percent Sample)(Percent
female (:tS.D.)
(percent smnplc)
)erceut
(;:male h S DJ
Control
100
18.6 (t 3.6)
Control
80
17.0 (1 7.5)
0.0125
IN
18.4 (t 4.0)
0.7
100
21.8 (r. 2.5)
0.025
100
18.0 (t 3.7)
1.4
100
20.8 3.4)
0.05
100
19.2 (.1 6.6)
2.8
s0
24.8 ( 1.9)
0.1
100
19.4(E3.5)
5.6
100
23.2(1 5.9)
0.2
100
17.4 (i 3.9)
11.2
100
26.4 (i 3.4)
NOEL:
0.2
NOEC:
11.2
LOEC:
:0.2
LOEC:
Cliv:
= 0.2
ChV:
- 11
1(22;:
'-0.2
IC'::
11.2
(n) Treuluana whlch have uu
m imiwlt ommiumva are nor ulctuded ur rha ::uuca1w11uluhhe•.1.
�h Srar4uicali•:.tin�reni +I`- a
pS r G,nn the convot, 111111a:111nC Ln adwrge eii2rr

TABLE 3 (Centint
Industry Name:
AURKART
Industry Name:
SANDY CREEK
IWC:
0.X'!'o
IWC.':
3X'fi)
EAAcccm,iien No;
:11'X-29G;31 1
E:\ Accession No:
xi-9-2191312
Test Number:
TN-98-185
Test Number:
TN-98-1 X6
Tat Concentrations
.Survival
%'1ean Young per
rest Conec,1tralnons
SUrvi al 1N1can Young per
(percent sample)
(percent
female 0 S.D.)
(percent s:nnole)
,erccnt female H S.l)
Control
100
18.0 (r 3.7)
Control
100 15.3 (.t 6.9)
0.1
100
7.0 (a l .7Y"'
4.75
100 15.3 (r 7.8)
0.2
100
2.9 (t 1.1)""
9.5
100 22.3 (s 2.1)
0.4
100
0.4(t-0.9)n"
19
100 14.8(i 5.9)
0.8
()(a)
()(.1
38
100 9.3 (:E 5.7)
1.6
0W
0(0)
76
0w1 t)wt
NOEC:
'0.1
NOEC:
38
LOEC:
i,. I
L.orC:
76
Chv:
<0.I
Ch V:
53.7
IC25:
0.04 (0.03 0.05)
[C2::
25.4 (6.0 54.8)
(.11 W--hints which have no :;umNing nrganmann nra not included in dw :unttsticaI
tb) Sntuticallp di Gr4nl (P=o 051 ti.nn The c.mtrot imhcalinp an a0 er.e ell:ct.

TABLE (Continued)
Industry Name:
J.P.
TAYI IOR
Indusm. Name:
IWC:
0.88
I%VC:
thir
EA Accession No:
AT8-295;309
EA .accession No:
Test Number:
TN-98-183
Test Number:
TN P 4-94
Test Concentrations
Survival
Mean Young per
Test Concentrations
Survival
Mean Young per
(nercctt sample)
rercant
I�nnale ('tS.D.)
,ercent samnk)
(pereent
lemale (t S.D.
Control
too
21.3 (x 4.2)
Eentfol
-0
20.2 (.i 6.0)
O.1 I
too
20.2 (t 5.2)
O-j�.
400
0.22
too
20.2 (.t 4.4)
4--14
4-W
244�- 1
0.44
80
19.0 (ct 6.4)
Q-.3
4 )0
". 1 ( 2.9�
0.88
IOo
22.8(1 3.8)
4}6
-100
-244r(-4-4-4)
1.76
100
22.6 (3. 3.8)
4-22
4P
21. 2.9)
NOEC:
1.76
NOEC:
44.3
1.0EC:
-1.7C>
1AEC:
>L2
ON:
= • l .76
Ch V:
=1-2
IC^_;:
1.76
1C25:
1.2
(a) Traattwii .; which have no
:um%in_ oreoncnw
are not included in Zhu 'tulialiuil amJ}•:,�s.
lb) tilalmu::dl:• dilTueot t 11=0
iA, Ii om the cnn;n,l.:n,b.:nine
an a.irerue riff..:t

TEL:[phone]
Rug " 18 2:27 No.007 P.02
PEIRSON
WHITMAN
ARCHITECTS
AND
ENGINEERS,
PA.
ESTABLISHED 1938
5510
MUNFORD ROAD
P.O. BOX
30398
PHONE
919/782-8300
FAX
9'9/783-7642
RALEIGH
N.C.
27622-0398
U.S.A.
Auguet 13, 1998
Mr. Tom Spain
City of Henderson
P.O. Box 1434
Henderson, NC 27536
Re: Red Bud Pump Station
P&W Project No. 2322
Dear Mr. Spain:
�XkZl3 �i l3
I inspected the subject project yesterday and found
the following deficiencies:
1. The bar screen rake had become unbolted from its
lifting arm and was hanging loose. The bar
screen is inoperative until such time as this
problem is corrected by the contractor.
2. The screw conveyor exhibits, from time to time,
inappropriate noises that indicate probable
misalignment, it is my understanding that the
screw itself exhibits a wobble at the midpoint of
its length.
3. The conduit that carries power wiring to the
screw conveyor motor is not adequately
stabilized. The conduit tends to shake and move
when the conveyor is in operation. Over time,
the conduit could fatigue and crack.
4. The electrical cable for pump motor moisture
sensing is wrapped around at least two (2) pipes
inside the equalization basin such that the pump
cannot be removed from the basin without first
disconnecting the cable.

Summary Status Report onX�� r
Inflow/infiltration
Date
Smoke
Testing (ft.)
Viewing/Cleaned
of Sewer LF
Total Costs
Labor/Equip
Manhole
Restoration
Sewer Line Repair
Eliminate I&I
Gallons Per Minute
3-31-94
-
10 (MR)
10 GPM
6-30-94
$10,500
8 (MR)
13 GPM
9-30-94
4,700 LF
*$114,000
-
10 GPM
1-3-95
4,060 LF
$7,300
-
15 GPM
4-3-95
10,325 LF
$5,668
-
7-3-95
3,402 LF
$1,506
-
9-29-95
20,245 ft.
10,689 LF
$4,703
-
45 GPM
12-29-95
6,782 LF
$11,190
-
3 GPM
3-27-96
6,782 LF
$11,190
-
3 GPM
*16-28-96
7,718 LF
$12,734
-
9-30-96
169,000 ft.
13,140 LF
$32,355
30 WHO
2 (MR)
15 (SL)
250 GPM
12-31-96
10,500 ft.
38,038 LF
$71,856
30 (MHI)
3 (SL)
200 GPM
3-31-97
-
2,905 LF
$28,779
2 (SL)
100 GPM
6-30-97
-
23,703 LF
$37,887
12 (SL)
100 GPM
9-30-07
-
29,830 LF
$191,637
12-31-97
-
19,575 LF
$100,953
10 (SL)
100 GPM
4-1-98
-
47,450 LF
$46,332
7 (SL)
703 (Rainstoppers)
(Installed)
200 GPM
6-30-98
-
50,400 LF
$43,721
TOTAL(S)
199,745 LF
279,499 LF
$732,308
20 (MR)
60 (MHII
37 (SL)
703 (Rainstoppers)
Installed)
-21,049 GPM
(MR) Manhole Restoration
WHO Manhole Inserts
* Purchase of I&I Truck
*1 $70,000 ADS Study Contract to Perform Flow Monitoring
*' Final Estimated I&I Elimination was summarized and revised from the Quarterly Reports. The
revisions were based on field observations.
(SL) Sewer Line Repair

TEL:[phone] Aug 17 "8 2:28 No.007 P.03
Mr. Tom Spain
City of Henderson
February 18, 1998
Page 2
Because of the severity of these problems, I will not
issue the Certificate of Substantial Completion until
such time as these items are corrected. I have
notified the contractors to return to the project and
correct these deficiencies as soon as possible. I
will keep you informed.
Very truly yours,
PET ON & WHIT ARCHITECTS AND ENGINEERS, P.A.
MSA/ted
cc: Mark Warren

CITY OF HENDERSON
Post Office Box 1434
180 Beckford Drive MJTBUSH OM WASIEWAM
Henderson, North Carolina 27536-1434 TREATMENT PLANT
Phone: [phone] FAX: [phone]
August 14, 1998
Mr. Kenneth Schuster, P. E.
Raleigh Regional Supervisor
NC DENR DWQ
3800 Barrett Drive
Raleigh, NC 27609
Re: City of Henderson Nutbush Creek WWTP
NPDES #NC0020559
Special Order by Consent (SOC)
EMC WQ #96-05
Report and Notification of Meeting Deadline
Dear Mr. Schuster,
I am submitting the following information as required by our SOC
under Sections 2. (b) 2 and 2 (b) 7:
1. The August, 1998 Quarterly THE Progress Report which
summarizes the efforts made toward toxicity reduction
(Exhibit A).
2. Phase I of the Sewer Rehabilitation Project included a program
to remove inflow/infiltration and an evaluation of the amount
removed from Redbud Basin.
The I/I work was completed prior to the July 31, 1998 deadline
in our SOC, but a certificate of substantial completion has
not been issued because of problems with equipment at the
Redbud Pump Station Upgrade which was not a part of Phase I
when the SOC was amended.
We do have full use of the equalization basin, new generator
and maximum pumping capacity of the existing pumps at the
station.
A letter from the project engineer stating why a Certificate
of Substantial Completion has not been issued is included
(Exhibit B).
A Summary Status Report on the completed I/I work is also
included (Exhibit C).

We need to have a date added to the SOC in April, 1999 to
evaluate the success of the Equilization Basin and I/I work
to prevent bypasses in wet winter weather.
If overflows still occur then additional I/I work and/or
larger pumps will be needed.
If you have any questions, please contact me at 252-431-6081.
Sincerely, n
s-
Thomas M. Spain,
WWTP Director
c: Eric Williams, City Manager
Mark Warren, Assistant City Mgr.
Linda Leyen, Chief Operator
Reggie Hicks, Pretreatment/Lab Sup.

Progress Report
for the Toxicity Reduction Evaluation
at the Citv of Henderson's Nutbush Creek Wastewater Treatment Plant
N PDES No. NC0020559
Mav 15 through August 15,1998
Submitted In Fulydlment of the Britt Special Order by Consent
E31C WQ No. 96-05
Prepared for
Department of Environment. Health and Natural Resources
3800 Barrett Drive. Suite 100
Raleigh. North Carolina 27609
Prepared by:
City of Henderson
P.O. Box 1434
Henderson. NC
With Assistance by
Aquatic Sciences Consulting
15751 Bushy Park Rd
Woodbine, Maryland 21797

Citv of Henderson THE Progress Report Page 2
NPDES No. 0020559 August 15, 1998
Introduction
This quarterly progress report is prepared and submitted to meet the August 15 date
specified by Section 2(b)2 of the City of Henderson's draft Special Order by Consent
(SOC EMC WQ No. 96-05). This report describes the progress made in the last quarter
(May 15 through August 15, 1998), the plans for the nest quarter, and any significant
issues that may delay progress in completing the TRE.
Progress in the Preceding Quarter
1. Expanded Pretreatment Program
The City, through it's new Pretreatment Coordinator. is in the process of intensifying the
effort to monitor and evaluate potential sources of toxicity in the collection system.
Progress achieved in the preceding quarter includes:
Beginning the process of updating the chemical usage inventory for the industrial
users by obtaining information on maximum daily quantities of chemicals used in
manufacturing.
• Entering chemical usage and industry monitoring data on a new computer obtained
for the pretreatment program.
• More intensive monitoring of industrial users. which has led to the identification and
correction of a source of toxicity (as described below).
• Conducting more frequent inspections of industrial user facilities.
• Communicating more often with the industries regarding pretreatment activities (at
least biweekly).
2. Results of %N'WTP Effluent Toxicity Monitoring
The NC Phase II protocol was applied to an effluent samples collected on 22.23 June
and 25-26 June. The results indicated chronic effects to Ceriodaphnia dubia at the 90°0
instream waste concentration (INVC). The chronic value (ChV) was 77.90o effluent:
although. the inhibition concentration (IC25) value was =90°0.
.As required by the NPDES permit, if toxicity is observed, monthly tests will be
performed until compliance is observed. A C. du5ra chronic test was performed on
effluent sample collected from 16.17 July and 21-22 July. The results were a ChV of
55.1%and anIC25 of 52.40%. The neri effluent compliance testis scheduled for the
week of August 17th

City of Henderson THE Progress Report
NPDES No. 0020559
Page 3
August 15. 1998
As shown in Appendix A. Nutbush W WTP effluent toxicity continues to be intermittent
and variable (i.e., NOECs vary from 15 to >90%). In an attempt to ensure that toxic
effluent samples are collected for TIE testing, the City is screening samples for toxicity
using the Microtox chronic (22-h light loss) test. The City is developing a correlation
chart of 3licrotox and C. dubia results (see Figure 1) to use as a guide in deciding which
samples can be tested as par of the TIE and toxicity source evaluation. As shown in
Figure 1, the correlation between Microtox and C. dubia ChVs appears to be good
(r value = 0.97 for seven paved data points). The Microtox test provides a useful
approximation of the ChV values determined by the C. dubia test.
u
Figure 1. Comparison of Microtox
and C. dubia ChV Results
0 2
y = 0.23x + 0.78
r, = 0.97
Microtox TUc (1001ChV)
10
As noted in the last quarterly progress reports. Microtox tests performed on the final
WWTP effluent show that hydrogen peroxide addition can significantly reduce chronic
toxicity. Although earlier treatability studies have sho%rm a reduction in chronic toxicity
to C. dubia by peroxide addition, data had not been obtained on effluent samples
collected before and after peroxide treatment. In the preceding quarter. the City began

City of Henderson THE Progress Report
NPDES No. 0020559
Page 4
August 15, 1998
collecting this information. A.s shown in Table 1, effluent samples collected after
peroxide addition and final aeration were four to five -fold less chronically toxic than
those collected before peroxide/aeration treatment.
Table 1. Results of C. dubia Chronic Tests Performed on Samples of X%'WTP Effluent Collected
Before and After Hydrogen Peroxide addition (H2O1) and Post Aeration Treatment.
Sampling Date Effluent Sample IC25 Chi- NOEC LOEC
2 7-28 MEN.98
3efcre H202 Addst:cn
2'' .1
15.9
L)
25
1 sample test
After H202 Addition
68.5
61.2
50
75
3-4 7tute
Before H2O, Addition
14.9
<15
<15
15
1 sample test
After H2O2 Addition
>90
>90
90
>9C
23 hate
Before H2O2Add:t:cn
18.8
'_l.'_
15
30
^_ sample tests
After H2O2 Addition
>90
77.9
67.5
90
3. Results of Effluent Toxicity Characterization
Results for the Phase I TIE test performed in the first quarter of 1998 were inconclusive
due to the low level of chronic toxicity in effluent samples. As noted in the last quarterl}
report, %licrotox results have shown that the effluent before peroxide final aeration
treatment to be much more toxic than the final effluent. These results were confirmed
using C dubia, as described above. The City is interested in identiffiing and eliminating
the source(s) of toxicity; therefore. the Phase I TIE for this quarter was collected from the
effluent at a point before peroxide addition and final aeration treatment.
In May. Microtox tests indicated that the final W A'TP effluent was chronically toxic;
therefore, the City performed a TIE Phase I test on the sample using C. dubia. Tables A
through D in Appendix B present the results for the baseline and characterization steps.
Unlike the TIE Phase I test performed in April, the effluent was chronically toxic (i.e.,
ChV=15.80r6, IC25=21.1°0).
Based on the characterization data, chronic toxicity was partially reduced by aeration
(i.e.. IC25=41.50 u) and completely removed by C 18 solid phase extraction (SPE) column
treatment (IC25%100). These results confirm results of previous Phase I tests that
showed toxicity reduction by aeration and C 18 SPE column treatment. The C 18 SPE
column was eluted with 10006 methanol and an abbreviated C. dubia test was performed
on the eluate. Acute mortality (48-h) was observed in the methanol at concentrations
corresponding to 4000o and 2000,6 effluent. This test result confirmed that effluent
toxicity was related to nonpolar organic toxicants. The City decided not to proceed to
identification of the nonpolar organic toxicants because the sample contained a chemical
(pigment) that had been subsequently identified and eliminated (see Item #4). Future

City of Henderson THE Progress Report Page 5
NPDES No. 0020559 ,august 1.5. 1998
Phase II tests for nonpolar organic toxicants may be performed depending on the
acet:rrence of effluent toxicity. The City also plans to track the sources of nonpolar
organic toxicity as described below (Item #t5).
4. Identscation and Control of a Source of Toxicity
Burkart Carolina, a relatively small industrial user of the City's WWTP, began using a
phthalocyanine blue dispersion (pigment blue 15:1) in production in the fall of 1997. The
city noticed a blue green color in the effluent and the mudwell of the multi -media filters;
which increased dramatically in March and April 1998. The City requested Burkart to
perform a triad of tests to evaluate the potential for the pigment to contribute to effluent
toxicity at the Nutbush Creek WWTP. These tests consisted of acute toxicity tests, 28-
day biochemical oxygen demand (BOD) test. an activated sludge respiration inhibition
test, and selected chemical analyses.
Test results submitted by Burkart (see Appendix C) indicated that the pigment was not
likely to contribute to effluent toxicity. The acute LC50 value for C. dubia was reported
to be 669 mg'L. Based on the estimated flow contribution for the Burkart facility (0.60,,0).
a 114b solution of the pigment could be discharged without adverse effects to C. dubia.
However, as shown by the 28-day BOD test, the pigment is not particularly
biodegradable. Additional information obtained from the manufacturer of the pigment,
Organic Pigments, confirmed the low biodegradability of the pigment (see Appendix C;
EPA's Toric Chemical Release Repotting. Community Right -to -know, 40 CFR 372).
In March, the City noticed that the pigment was accumulating in the activated sludge and
rite filters. As the pigment color increased in the sludge, the City began to see color in
the final effluent. At the same time, Mierotox and C. dubia tests showed increased
toxicity.
Although Burkart was not issued a pretreatment requirement for toxicity monitoring, the
City included this facility in the quarterly industry monitoring event. The results of a
discharge sample collected June 2-3 showed chronic toxicity to C. dubia at a
concentration more than six -fold lower (<O.1%) than Burkart's discharge flow
contribution (0.6%).
Based on the monitoring results. the City met with Burkart on June 18a' and discussed the
ongoing THE program, Burkart's current manufacturing operation and chemical usage.
and the need to identify and eliminate the cause of the observed toxicity. Burkart
officials advised the City that the pigment was no longer being used and the chemical
would be eliminated at the City's request. A review of the manufacturing process
identified the use of potential toxic amounts of hydrogen peroxide for treating the dye.
The City advised Burkart to cease using the hydrogen peroxide until additional tests
could be performed to determine a nontoxic dosage.

City of Henderson THE Progress Report Page 6
NPDES No. 0020559 August 15. 1998
The City conducted tests on the pigment to determine its chronic toxicity and treatability.
Toxicity tests were performed on diluted pigment (at its expected concentration in the
"11VTP effluent) and an aliquot of the pigment after treatment in a bench -scale, batch
reactor that simulated the WWTP's activated sludge process. As shown in Appendix C.
both the untreated and treated pigment samples were toxic at concentrations that are
expected to be discharged to the WWTP.
A second discharge sample was collected from Burkart on June 21 to evaluate the
toxicity of the discharge after the facility modifications. This sample did not include the
waste stream containing pigment and hydrogen peroxide. The results of this retest
indicated only minimal chronic toxicity compared to the facility's discharge flow rate
(i.e., ChV = 0.52%).
In July. Burkart notified the City that it would voluntarily eliminate the use of the
phthalocyanine pigment. The Cite is in the process of preparing a chemical optimization
plan (COP) for the Burkart facility.
5. Industry update
The City received chemical usage information from the industries for the period when
significant chronic effluent toxicity was observed at the Nutbush Creek WR'TP
(November and December 1997). A review of this information did not indicate any
unusual types or quantities of chemicals being used during the toxic period.
The C ity reviewed plans and specifications for a second dissolved air notation (DAF) to
be installed Americal. The City gave authorization for the DAF on June 30'h and the unit
was in operation on Aug 41h. Atnerical will consider additional pretreatment
improvements pending an evaluation of the effect of the additional DAF on discharge
toxicity. America] will conduct a toxicity testing on their discharge in the near future.
IAMB submitted an engineering report that included recommendations for reducing
loadings of zinc and phosphorus to the W WTP. On August 1, the City and IA.MS entered
into a compliance agreement and consent order to implement the recommendations.
IAMB has begun waste minimization activities, including pipe repair and cleaning
procedures as recommended in the engineering report. Additional waste minimization
procedures will be implemented in the nett quarter. IAMs will also propose a treatment
facility design to achieve compliance with the phosphorus limit.
Softspun notified the City by letter that it will cease dye house operations by Aug 281h.
The City will issue a zero discharge permit to be effective on that date.
6. Industrial Pretreatment Monitoring
The City collected and analyzed industrial discharge samples for chronic toxicity as
specified by the monitoring requirement in the pretreatment permits issued in November

City of Henderson THE Progress Report Page 7
NPDES No. 0020559 .August 15. 1998
1997. The industries were tested at their flow contribution to the Nutbush Creek W WTP
based on 1997-1998 industrial water usage and discharge flow records and W WTP
average monthly effluent floc. The toxicity test procedures followed the NC Phase 11
protocol for C. dubia using two samples.
Discharge samples were collected on June 2-3 and June 5-6 from Americal. Ball Foster.
Iams, J.P. Taylor, Kennametal, Burkart, and the Sandy Creek Pump Station. Although
Softspun had indicated that its facility would close soon, the City, decided to include the
discharge in the quarterly monitoring event. Samples of the Softspun discharge were
collected on June 8-9 and June 11-12. The Burkart retest noted above was performed
using a single sample collected on June 18`h.
A report of the quarterly industry monitoring results has been submitted to DEHNR. No
chronic toxicity was observed in any of the industrial discharges with exception of the
first Burk -art test noted above. The test of the Americal discharge was also invalid due to
low control survival. It was not possible to determine if Americal may cause adverse
effects at their discharge flow contribution. Overall. the industry monitoring results did
not indicated a clear source of toxicity. These results are not surprising considering that
the Nutbush Creek WWTP was not chronically toxic during this period (ChV >90%).
Previous studies of the City-s collection system have indicated the Sandy Creek Pump
Station to be a source oftoxieity as measured by Microtox. Although the June
monitoring results did not show significant chronic toxicity at the pump station's flow
contribution. the Citv is concerned that Sandy Creek sewershed may be a source of
toxicity during toxic periods.
As noted above. nonpolar organic toxicants appear to be the primary cause of effluent
toxicity: however, these toxicants are difficult to identify. Therefore. the City plans to
track sources of nonpolar organic toxicity. The planted testing will involve sampling
sewer lines in the Sandy Creek sewershed, testing the samples using C. dubia , and then
passing toxic samples through a C18 SPE column to determine if the toxicity is nonpolar.
In the next quarter, the City also plans to test selected sewer lines and major industries for
chronic toxicity (using chronic C. dubia tests) to locate the source(s) of toxicity. If
unacceptable toxicity is observed in the next monitoring event. a Refractory Toxicity
.Assessment (RTA) test will be performed to determine if the discharge of toxicity would
be expected to pass through the \utbush Creek WNVTP.
Plans for the Next Quarter
The City plans to conduct the following work in the next quarter (August 15 through
November 15, 1998);
1. A chronic C. dubia compliance test will be performed in August and each month
thereafter until results show compliance with the NPDES permit limit.

City of Henderson THE Progress Report
NPDES No. 0020559
Page 8
August 15, 1998
2. Additional industry and pump station monitoring will be conducted to identify the
sources of effluent toxicity. The monitoring effortwill focus on the Sandy Creek
seu ershed, which has been identified as a source of toxicity based on Microtox.
Additional monitoring will include C. dubia chronic toxicity tests.
3. The City will inspect J.P. Taylor. Americal. Ball Foster, and Softspun. During the
inspections, the City will discuss activities that the industries have performed to
ntutimize the discharge of toxicity.
4. The Cite %gill review eater records for industrial and commercial facilities to try to
identity additional potential sources of toxicity.
5. Depending on the occurrence of effluent toxicity, the City map perform a treatabiht}
test to evaluate the toxicity reduction that can be achieved by an upgrade of the
Nutbush Creek WWTP to biological nutrient removal (BNR).

Appendix A
Historical Ceriodapdnia dubia Chronic Toxicity Data
for the Nutbush Creek NVNV7P Effluent

[k Effluent;
N A O w O
O O O O O O
Jan-9`_ �-'•--i---t--j-�1►-r-•:
Apr-9`_
Jul-9`_
Oct-9°
Jan-9f
Apr-9f
Jul-9f
Oct-9f
m
Jan -'a i
Jul-9 i
�=kt-9i
Jan-9E
Apr-9E
Jul-9E
n
N
O
4
01
b
Ib
a
o-
o
z d
F�
o- A
0
�- o
n 0
m <
a
�m
n
<
rTi N
o
n
o_
m
0 0
11

NN -� � I, �vIJ NNN N IQ N
V (� I;U W W "J W m (O _� r W l0 m 0 (A U) Q W �) v W O (A O O) (b
0 z(n>�i'-iv Y-➢�yT�nn�c �S3S1+wC,Zncv)m ,m C m m m `c`.d�Dsm m
v o -a co Q -0(0<vCc v r0
d rs
v v v v v v n v n
v v v v v v
tp CO •J —I W N(O (O-J JmOO m W ON mm fG1 W m r0mmO)N O0) m W O W wmOm-+l0NOl0 W Oo
nOO wm-.1 `OO wm m O-` m-JO r11 NIJ m `Omm tR `m `Ut IJ -` OO w OOOO cn N
v v v V V V V
V
v v v V v v V v
N 0 0 0 N D r0 C a O 1" N O� m D CO (wT N 1 M rp Oi CO m D V p O O ((�� " U) 0 w (O 0 0) c0 �p co ((pp O
rD W G) W N W O N O O m O O co O D O
W W m oA'mwZZwNm W mmN Jam m m
(0z �rozzwZinzzncwwwoOwmoN OZZpzzzZwZ
n nn 6 00000)0
mVO,m iO
n�zzzmz"zz�.�izz�'i,c�o�ii�izr°;�m�o'i,r.��Si(�ou'zmzz4zzzz$'z
wn omw ono onoonC) nnio<ommwn w (000w(oNm�<)annaonnnnrnn
0" N 0 0 0 r0 W W O Q
O O O O
v co � O j�� m O m w N O m m O m 0 W U w U t w�� O J N N A c n
n
0
J•
3
� o
2 e

P_1-24-1'�''8 17;11 ER 9 LEERING
Effluent Aquatic Toxicity Report Form/Phase 11 Chronic Ceriodaphnia
Facility
Nu bush C`eek VNITP NPDES:. NC 0020559 Plpeit 001CounryVance
abotatoryPerfomtingTest EA Engineer r.C, Science & Tech. CotrrrrN"
Rinnntun of CRC v Signet. re 0Wabgiupelviscr
6 44,4816
Treatment 190 190 90
pH Initiall 7.7 18.1 8.2
pH Final --- 5.2 8.0
Stan Time ErA T,mi
11:55 11:04
Sort Aansw' anew
Cpn,q C_neol Comm
7.8 7.8 Bo
D.O. Initial 7.8 8.0 7.6
7.9
8.01
7.6
0.0. Final ---
7.7
7.4
-
7.6
7.6
ramp. initial 25.4
24.6
25.3
24.5
4.3
24.
rernp. Final -_-
24.7
25.0
---
24.4
25.
Wll4i•11F]"Wl
Control pYotrg 11
18 32 26 20 19 23 �25 15 29 21 ---
Adutt L I L I L I L I L I L I L I L I L L---
(L) Ive (D)ead
. a n d 56 7 F o to i t-
Etfluent%. pYoung
Aduk
15 (L)ive (D)oa
Effluent% 0 Young
Adun
30 (L)Iva (D)9F
Etffuont"6 If Young
Aduk
45 )iv)e
Effluent% k Young
Advlt
67.5 (L)ive (D)o
ENluent% fr Young
Adult
90 (
L
)iv
6 (D)e
6 26
25
128
29
20
28
26
27
24
L L
L
1)
IL
L
L
L
L
2
3
4
5
6
9
10
0 24
23
23
25
29
26
22
25
28
L LI
LIL
L
L
L
L
L
L
L IL2 I LS I
L512L L4 I2L I2L 2L 1L
g. 25 26 22 29 23 26l24 Z7 30 125.E
L L L D l_D L L L IliL AWJ
n+... Final Contra Modality % v
Y. Conud 3rd Brood 100
!" a Cortird Repro Cv 21 .6
0 Of 0 o(10
r1ficent? Y N Cl
'Ine! sNnHcant 0
oCn9x o
Repro.
LQE:,lC,,,_ : NO C= 6!S%
Method: """"e
Nortn8101stn ?Yes h6omdS D1L0
slatlsuc: VT Cn[4a1 0 94
Eaual Variant- es4 es Method
Stausac: 5.93 CdHeai: 9.4
N nn-P R f9lIlflilt�61�i3�:�r��
Method•
Fah lants/ P^.,1. c.n t•-'tlrsl Sum
!1 23 25 23r23 0 25 16 22 6 ?f].4 !Teat LoBC S5 DE
%NOECD D L DD L
D D D Chronic Values -9
,,TT: Envilmnmental Sciences
MAIL Dtv. of Environmental Management
N.G Department of EHNR
TO: RRaaWghe N C. 2760 Rd.
t WOW concan"W n *"" DSO. �5.00 m91
02M form AT-3 (W) RQv. 11195
TOTAL P-32

JiA-24-1999 14:33 1 #-,PIEERI^C, 1
Effluent Aquatic'i vAlcity Report Form/Phase II Chronic %,corlodaphnia
Facilib/Nu*bush Creek VNTP
rl
NPOES#- NO 0020559 Pipe#,
), Science & Tech. Cortmerse
Samole Information
Sample 1
Sample 2
Control
Collection Stan Date
C1r�
C(Ouration)
Hardness(mg/l)
S pec.Cond. (µmhos/cm)
Chlodne(mgA)
Sample temp. at receipt
6/22/98
6/25/98
N/A
24 hour
40
N/A
24 hours
(0.01
0.8 'C
(0.01
2.0 'c
Conirol
Own Wow I .". ✓.,. GIIV I IIIIO
6 /124/98 6 /3V98 11: 55 11 :04
Treatment
pH Initial
pH Final
D.O. Initial
D.O. Final
'amp, Initial
'amp. Final
90
90
90
Cor6o1
Iconbral
I Contra
7.7
8.1
8.2
-1.8
7.8
1 8..1
---
8.2
8.0
---
8.0
8.1
7.8
8.0
7.6
7.9
8.0
7.6
---
7.7
7.9
---
7.6
7.6
25.4
24.6
25.3
24.5
4.3
24.
---
24.7
25.0
---
24.4
25.
i m#
n n w e a b a e to 11 10
# Yormg
18
32
26
20
19
23
25
15
24
1 27
---
--
AduH
(Uive (D)ead
L
L
L
L
L
L
L
L
L
L---
--
�I % Control 3rd Brood 100
conva Repro CV 21 .6
19 11 d 5 A 7 A 9 10 11 12 "" I In of 10 0 of 10
EMuent9Y #Young $ 26 5 8 29 20 28 26 27 24 .26.1 Si4n10cant7EY Q N
Adult n.e Find Mortsity Si nificant
15 (L)ive (D)end L L L D L L L L L A 90 % or NoConc.
1 2 3 4 6 7 8 9 10 Mun
EHtuent% #Young 0 24 23 23 25 29 Z6 22 25 28H
gopro pEc- g0 •h; NO = �•5 %
Adult Method: Dunned-`c Tes L L L L L L L L L L Normal Distnpp7]es Metho4ha iro-I L
Statistic: 0 914 critical! 0.947
1 2 3 4 5 6 7 9 10 Meet ----y �T >•
Effluent%
Equal Variances? eSMethod:
Statistic: 5.93 Critical: 9.49
Nan -Parametric Analvss (itaonlicaGlB):
Method:
1 2 3 4 5 6 7 8 9 10 Mtln auh lent •i Fank Sm Crilml Sum
Eliluent°/.
67.5
L
* Youn9
22
22
25
25
26
24
24
25
23
16
23'
Adult
(L)ive (D)ead
L
L
L
L
L
L
L
L
L
L
N/A
* Young
26
25
Z6
22
29
23
26124
27
13025�.BL
L
L
D
D
L
L
L
L
1 S6 7 S 9 10MYn
OVerell A�•tyate•
Effluent% *Young ED
2325 23 23 0 25 16 22 6 20.4 'Result=PAS S/EAIL gAdult Test LOEC=9CJti: NOHC= �)5F go(L)iVe (D)ead D L D D D L D D D t3 � Chronic Value-_ 77.9 x `.
-Should use hlyheat te!! wnceresdon or
ATf: Environmental Sciences highest concentration with 0.0. 4.0 myl
MAIL cNv of Rnvlronmental Managamenr 1 .w. .. ..n n.1 •. w.
T0: Me. Department of 1HNR
4401 Reedy Crook Rd.
Raleigh, N.C. 27607 DEM form AT-3 (aigl) Rov. 11/95

TJL-24-1398 14:21 E 51.14EERI40 P.7'"1n
INTRODUCTION
At the request of Aquatic Sciences Consulting, EA Engineering, Science, and Technology
performed chronic toxicity testing on 24-hour composite samples of effluent from the City of
Henderson's Nutbush Creek WWTP. The effluent samples were collected on 22-23 June and
25-26 June 1998. The test species, Cerfodaphnia dubia (water flea) were exposed to 90, 67.5,
45, 30, and 15 percent effluent and a laboratory dilution water control. The objectives of the
toxicity testing were to assess the chronic lethality of the effluent samples to the test organisms
and to evaluate the potential for inhibition of reproduction of the organisms exposed to the
effluent concentrations as compared to the dilution water control. This toxicity testing was
conducted under the blomonitoring requirements of NPDES Permit Number NC0020559.
The testing was conducted according to EA's protocol (EA 1996) which is included as
Attachment I, and US EPA (1994), and follows the procedures as presented in the North
Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure, Revised February 1999.
The results of the chronic toxicity tests were statistically analyzed, according to EPA guidance
(US EPA 1994) to determine if any effluent concentration was significantly different from the
control with respect to survival or reproduction. The short-term chronic toxicity test endpoints
reported are expressed as the No Observed Effect Concentration (NOEL), the Lowest
Observed Effect Concentration (LOEC), die Chronic Value (ChV), and the 25 percent
inhibition concentration (IC25). The definitions of these chronic endpoints follow US EPA
(1994) and are as follows:
The NQF.0 is the highest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes no statistically
significant adverse effect on the observed parameter (usually hatchability,
survival, growth, and reproduction).

TLL-24-1339 14:21 PkilNEERINu=._µ:1J
• The LORC' is the lowest concentration of toxicant to which organisms are
exposed in a full or partial life -cycle test, which causes a statistically significant
adverse effect on the observed parameters (usually hatchability, survival,
growth, and reproduction).
The M is a value lying between the NOEC and the LOEC, derived by
calculating the geometric mean of the NOEC and LOEC. The term is
sometimes used interchangeably with Maximum Acceptable Toxicant
Concentration (MATC).
Inhibition Concentration (ICp) - A point estimate of the toxicant concentration
that causes a given percent reduction in a non -quantal biological measurement
such as fecundity or growth. For example, an IC25 is the estimate
concentration of toxicant that causes a 25 percent reduction in mean young per
female or some other non -quantal biological measurement.
In addition, percent reduction in reproduction was calculated for each effluent concentration by
subtracting the mean number of neonates produced by the organisms exposed to each effluent
concentration from the mean number of neonates produced by the control organisms, dividing
that number by the mean number of young produced by the control organisms and multiplying
by 100.
The Effluent Aquatic Toxicity Report Form/Phase II Chronic Ceriodaphnfahas been included
at the beginning of this report. Summaries of sample/test information, including time of test
initiation and termination, test organism source and age, water quality ranges during testing,
reference toxicant data, and test results are presented on pages 5-6. Table 1 summarizes the
collection and receipt data for the effluent samples. Selected water quality parameters of the
samples are reported in Table 2. Toxicity test protocols, copies of raw data sheets, and copies
of statistical analyses are included in Attachments I, II, and III, respectively. The Report
Quality Assurance Record is included as Attachment IV.

n-a_-24-1998 14:22 1 jr, INEERING P.05/10
SUMMARY OF RESULTS
The results of the chronic toxicity test performed on the effluent samples from Nutbush Creek
WWTP are summarized on page 6. The test was terminated on Day 6, at which time > 80
percent of the control females had produced three broods, and mean young production in the
control was x 15 young per surviving female. At Day 6, there was 20 percent survival of
C. dubia exposed to the 90 percent effluent concentration, which was significantly different
(P=0.05) from the 100 percent survival of control organisms. Seven of the eight mortalities
in the 90 percent effluent concentration occurred on Day 6, following renewal on Day 5 with
the sample collected on 26 June 1998. Survival in the remaining effluent concentrations
ranged from 80 to 100 percent, none of which were significantly different from the control.
Mean young production in the 15, 30, 45 and 67.5 percent effluent concentrations ranged from
23.2 to 26.1 young per female, all of which were greater than the mean young produced in the
control (22.3 young per female). The NOEC was 67.5 percent effluent, the LOEC was 90
percent effluent and the Chronic Value was 77.9 percent effluent. The IC25 was > 90 percent
effluent.
in conformance with EA's quality assurance/quality control program, monthly reference
toxicant tests were conducted on the EA -cultured test species. The results of the C. dubia
reference toxicant tests fell within the acceptable limits established from EA's control charts.
9

I _u_-24-1993 14: 23 :, JG I � EER I NG P. JG,11
REFERENCES
EA. 1996. Quality Control and Standard Operating Procedures Manual for the EA
Ecotoxicology Laboratory. Revision No.S. EA Manual ATS-102. Internal document
prepared by EA's Eeotoxicology Laboratory, EA Engineering, Science, and
Technology, Inc., Sparks, Maryland.
US EPA. 1994. Short -Term Methods for Estimating the Chronic Toxicity of Effluents and
Receiving Waters to Freshwater Organisms. Third Edition. EPA/600/4-91/002.
U.S. Environmental Protection Agency, Environmental Monitoring Systems
Laboratory, Cincinnati, Ohio.
4

KL-24-1998 14:23 El WEERI,5 P.07/1a
SUMMARY OF SA..MPLE/TEST INFORMATION
Test: Daily renewal chronic toxicity test with Ceriodaphnia dubia
Test Procedure: EA Protocol ATS-STC-CD-06 (NC)
North Carolina Ceriodaphnia dubia chronic toxicity testing procedure
(PASS/FAIL and Phase II)
Client Name: City of Henderson
Sample Description: Nutbush Creek'ArWTP
EA Accession Numbers: AT8-365, AT8377
Dilute Water Description: Dilute mineral water
EA QC Test Number: TN-98-188
Test initiation time and date: 1155, 24 June 1998
Test completion time and date: 1104, 30 June 1998
�papisnl Lot 1n_rormation
Lot Number: Not Applicable
Source: EA's Culture Facility (Sparks, Maryland)
Age: <24 hours old (within a 4-hour window)
�Pfe�ence Toxicant Test Information
Reference Toxicant: Sodium chloride (NaCl)
Dilution Water: Dilute mineral water
EA QC Test Number: RT-98-111
Test Initiation: 9 June 1998
Control Survival: 89 c (7 days)
Test Results:
NOEC: 0.6 g/L NaCl
Laboratory control chart acceptability range for chronic NOEC: 0.6-2.4 g/L NaCl
5

JLL-24-1999 14:24 IGtrEERt U R.0EI/19
SUMMARY OF SELECTED TEST DATA
Test Species: Ceriodaphnia dubia
Test: Survival and reproduction test
Client Name: City of Henderson
Sample Description: Nutbush Creek WWTP
EA QC Test Number: TN-98-188
Test Concentration
6-Day Survival Mean Young Production
Percent
(percent effluent)
(percent)
(neonateslorEanism
(ISD)
Reduction
Control
100
22.3 (±4.8)
—
15
90
26.1 (±2.6)
(c)
30
100
25.5 (±2.7)
(c)
45
100
23.2 (±2.9)
(c)
67.5
80
25.8 (±2.5)
(c)
90
20"'
20,4 (±5,7)t"
8.5
Epdpitint sscdiys pgSrnt
effluent)
NOEC:
67.5
LOEC:
90
ChV:
77.9
1C25:
> 90
Selected Test Water Q11ality
Parameters
R,ange
Mon (
Temperature ('C):
24.3 - 25.6
24.9 (±0.4)
pH:
7.5 - 8.2
8.0 (±0.2)
Dissolved Oxygen (dng/L):
7.4 - 8.0
7,7 (±0,2)
Conductivity OiS/cm):
101 - 781
396 (±213)
(a) Statistically different (P=0.05) from control indicating an adverse effect.
(b) Concentrations which have significant mortality are not statistically analyzed for survival
(per EPA guidance).
(c) Reproduction in this effluent concentration was greater than in the control.
e

TABLE 1 SUMMARY OF SAMPLE COLLECTION AND RECEIPT DATA FOR EFFLUENT SAMPLES FROM
NUTBUSH CREEK WWTP
EA Accession Collection Receipt Sample Usage
Number Time and Date Time and Date Time and Date
AT8-365 1500, 22 JUN 98 to 1025, 24 JUN 98 Initiation: 1155, 24 JUN 98
1502, 23 JUN 98 Day 2 Renewal: 1347, 26 7UN 98
AT8-377 1505, 25 JUN 98 to 1025, 27 JUN 98 Day 5 Renewal: 1104, 29 JUN 98
1510, 26 JUN 98
a
N
a
z
m
A
ti
A1.
T

TABLE 2 SELECTED WATER QUALl TY PARAMETERS MEASURED UPON RECEIPT FOR EFFLUENT SAMPLES
FROM NUTBUSH CREEK WWTP
EA Accession Temperature Total Residual Alkalinity hardness Conductivity
Number (00 Px Chlorine (me/l.l (m_r/L) (mg/L) G:S(cmj_
AT8-365 0.8 7.4 <0.01 122 132 75.5
AT8-377 2.0 7.5 <0.01 90 116 700
ti
A
nai
c
lu
n
►C
Y
G
O

Appendix B
Results of Toxicitri• Identification Phase I Test Performed on
\utbush Creek ANIVTP Effluent

7UN-05-1993 12t43 Ea ENGINEERING P.al/04
TABLE A SUMMARY OF 5-DAY C rio hnia dubia SURVIVAL DATA FROM
TOMCITY IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES
FROM THE CITY OF HENDERSON (29 MAY 1998)
Treatmen
5-day
S rrvivA rcent)
IQU
rontml
10.1 z.
NA
1%
Baseline
100
100 Ow
Ow
OW
OW
Aeration
80
--- 60
Ow
Ow
Ow
Filtration
100
--- 20W
Ow
Ow
Ow
Cte colutnn
100
--- 100
100
100
100
EDTA 0.5 ppm
100
- --
OW
04)
OW
3.0 ppm
100
--- —
Ow
Ow
Ow
8.0 ppm
100
- -
Ow
O("'
Ow
Sodium Thiosulfate
2.5 ppm
100
— --
Ow
Ow
OW
5.0 ppm
100
---
OW
OW
OW
10.0 ppm
100
-- --
Ow
Ow
Ow
After Peroxide
80
100 100
80
O(•)
oP
(a) Treatments which have no surviving organisms are not included in the statistical analysis.
(b) Significantly different (P=0.05) from the treatment control, indicating an adverse affect.
u

JUN-05-1993 12:43 ER ENGINEERING P.02iO4
TABLE B SUMMARY OF 5-DAY Cerindaphnia dubia REPRODUCTION DATA FROM
TOXICITY IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES
FROM THE CITY OF HENDERSON C29 MAY 1998)
Reproduction
(Mean young W female)
C4atm1
1.0.1 2il
M1
lil
10U
Baseline
23.2
19.0 9.013,
Ow
Ow
0(0
Aeration
24.2
-- 23.6
6.2(4
04)
OW
Filtration
27.4
-- 5.Ow
O(')
Ow
Ot't
C,a Column
24.9
21.2
22.4
26.2
26.6
EDTA
0.5 ppm
29.0
--- ---
Ot'I
Ow
Ow
3.0 ppm
26.0
— —
ow
OW
OW
8.0 ppm
25.4
—
0"'
Ow
0w
Sodium Thiosulfate
2.5 ppm
26.0
--- ---
Ow
Ow
Ow
5.0 ppm
26.2
--- --
0w
0w
0w
10.0 ppm
25.8
--- ---
Ow
O(')
0W
After Peroxide
21.8
23.0 21.2
18.0
8.812;
1.4(2)
(a) Those concentrations which Favc no survitiing organisms, m Lave statistically significant (1-0.05) mortality, are not
")mod for reproduction. pc EPA guidelines.
qc%! (Ws/
c

SU,I-a5-1333 12:44 :R ENGiNEERING R.03iO4
TABLE C SUMMARY OF RESULTS OF Ceriodaphnia dubia CHRONIC TOXICITY
IDENTIFICATION EVALUATION ON EFFLUENT SAMPLES FROM THE CITY
OF HENDERSON (29 MAY 1998)
Baseline
Aeration
Filtration
C,8 Column
EDTA
0.5 ppm
3.0 ppm
8.0 ppm
Sodium Thiosulfate
2.5 ppm
5.0 ppm
10.0 ppm
Chronic Toxicity Endpoints
(as percent sample)
MeanYoung
NOEL
LOEC
SAY
TLiot"'
I�Z.i
$atinro)
10
25
15.8
4.7
21.1 (4.1-24.3y°
0
25
50
35.4
2A
41.5 (27.2-44.6)
0
<25
25
<25
6.5
15.3 (12.8-17.4)
0
100
>100
>100
<L0
>100
1.07
<50
50
<50
8.0
12,5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8,0
12.5
0
<50
50
<50
8,0
12.5
0
<50
50
<50
8.0
12.5
0
<50
50
<50
8.0
12.5
0
After Peroxide 50 75 61.2 1.5 68.5 (37,1-84.4) 0.06
(A) Toxic unit basod oa IC25 values, unless otherwise noted
(b) Mean Young Ratio = ratio of main young produced in 100°/a ooa=tmtioa compared to treatment control.
-,C) Values in parentheses represent 95 percent oonfiel ow limits.
41,

J'JN-05-1999 12:44 EA ENGINE=PING P.34i94
TABLE D TOXICITY IDENTIFICATION EVALUATION SYSTEM BLANKS PERFORMED
FOR TESTING ON THE SAMPLE AT8-282 - 5-DAY DATA (29 MAY 1998)
Cerfodaphnfa dubia
Survival
Reproduction at Day 6
TMAtment System Blanke(Percent)
(mean yoLn¢ ner female)
Aeration
100
25.6
Filtration
100
19.5
Cta Extraction
100
26.6
EDTA 0.5 ppm
100
28.2
3.0 ppm
100
25.6
8.0 ppm
100
7.04)
Sodium Thiosulfate
2.5 ppm
100
28.4
5.0 ppm
100
25.4
10.0 ppm
100
25.0
(a) Statistically different (P-0.05) from the treatment control indicating an adverse effect
TOTAL P.04

Appendix C
Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
Toxic Chemical Release Reporting, Community Right -to -Know, 40 CFR 372
City Test Results for the Phthalocyanine Pigment Used by Burkart Carolina, Inc.
blicrotox Results for Industry and Pump Station Samples

i1G• p1. !_l� 01 23 PI'd *BURKART CAROLINA
RUSCARCh & ANAlyTiCAI
' n.,kORAioidi.S, INC.
ry�t�iiik�W. ? Annlyrlrnl/f'rnrg46 COr15U!Wl.lnnh
23 hiaY 1998
(2rgi ni4 11811MM
P.O. 8nx IM7
(hr,911f1b)in, ;eC V492
Alto: (gnat Wtlknr
hale simple Colltcicd
Uafe ba6lpla Atcelved
DOW 6013106 Mlalyocd
()oto nt kepnrt
Anol3ycr °erfommd by
On-A•rAU bl.UG MIR Code! 4012 1
U-031050
Sareplo Sourcdl
AntlYxix
{'_Arjmiiw
ICUDI
Chondo.d Uxypon Dunlond
0,000,0U0
ppm
11300)
0lochdrnlcal UxYptn Dollixnd • e dry
]7,100
ppm
olouhvfltinrl Orypml Udn,ond • 15 day
451.VU0
256.000
ppr,t
Oioclnndvul VAypcu Uonland 28 day
DladnprtdtWltly • Ti day daY
0.1
O1udvp,1da1A14y • 1G day
10,0
. 9iadt0radohlllfy • 29 day
T 1,000
ppm
n ,mr . cc e(I
noulo Tordolce • W 60 "
609
,
A,G]U
m'rn
ppm
Acuto T(vack-1 -LC: SU "'
Meals
<260
ppm
Anlintally
<50.0
ppm
A,oarpc I
<250
ppnt
earium
6.40
ppm
Cadndun'
<50.0
ppm
Chfornlvnl
3,0SD
ppiii
gopfmr
<26.0
(,prrl
..
.. luud
<0.2
ppm
Mo(cvey
<50.0
ppnl
Salntbnl
1 �18877
57ngtle Mvmlxr
Ogrp9196
SUnPIe C]ar,C
ASRIT: n Aedvottd $Ivdxe Rol,101kl6 Inbi+Jinn'lesl
n IAm911a11
plim ^ I'All,. Pul hlllllnn
-9, Aell•o +• 6 QX
a m k1wil i il' Wits
ef, .. Rarkld_, duhh
fit n 1'vm )toJt4 pfonloloa
O009198
04/ 1008
us��Yroe
ll� .sr•.c.tRn
,

0"24/38 12:38 To: TON SFAN
Frm:Organic P;;mer.s
ENVIRONMENTAL PROTECTION AGENCY
40 CFR PART 372
[OPTS-400030A; FRL-3803-61
Copper Phthaiocyanine Pigments; Toxic Chemical Release
Reporting; Community Right -to -know
AGENCY: Environmental Protection Agency (EPA).
ACTION: Final rule.
8918 =,ae 8 a
SUMMARY: EPA is promulgating a rule to delete Pigment Blue 15. Pigment Green
7, and Pigment Green 36 from reporting requirements under the category "copper
compounds" from the list of toxic chemicals under section 313 of the Emergency
Planning and Community Right -to -Know Act. The rule is based on EPA's
conclusion that: (1) The copper ion cannot reasonably be anticipated to become 1
available at a level which induces toxicity from any of these pigments and (2)
there is no evidence that the three chemicals cause or can reasonably be !�
anticipated to cause adverse human health or environmental effects as specified
under section 313(d). By promulgating this rule. EPA is relieving facilities of
their obligation to report in 1991 on releases of Pigment Blue 15, Pigment Green
7, or Pigment Green 36 that occurred in 1990, and on releases that will occur
in futute years.
DATES: Tlhis rule is effective [insert date 30 days after date of publi-cation in
the Federal Register).
FOR FURTHER INFORMATION CONTACT: Maria J. Doa, Petitions Coordinator,
Emergency Planning and Community Right -to -Know Hotline, Environmental
Proi=ion Agency, Mail Stop OS-120, 401 M St., SW., Washington. DC 20460.
Toll free: 800-535-0202. in Washington, DC and Alaska: 202--479 2449. I
SUPPLEMENTARY INFORMATION: I!
I- Introduction
A. Statutory Authority
i�
i the deletion of dtree copper pigments from reporting requirements under
th4 category "copper compounds" from the section 313 list of toxic chemicals
is issued under section 313(d) and (ex1) of the Emergency Planning and
Community Right -to -Know Act (EPCRA) of 1986, also referred to as Title III I
of the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub.
L. 99-499).
U. Rackground
Section 313 of EPCRA requires certain facilities manufacturing, processing,
or otherwise using toxic chemicals to report annually their environmental releases
of such chemicals. Secdon 313 establishes an initial list of toxic chemicals that

04'24/3e 12:39 la:70H SPAIN From:Organic Ptgmer.s
?age T'S
is cumposed of more than 300 chemicals and 20 chemical categories. Any person
may petition EPA to add chemicals to or delete chemicals from.the list.
EPA issued a stnternent of petition policy and guidance in the Federal
Register of Febntary 4, 1987 (52 FR 3479), to provide guidance regarding the
recommended content and format for submitting petitions. EPA must respond
to petitions within 180 days either by initiating a rulemaking or by publishing
an explanation of why the petition has been denied.
11. Description of PetiEun
On June 1, 1988, EPA received a petition from The Dry Color
Manufacturers' Association (DCMA) to exempt three phthalocyanine pigments
from the reporting requirements under the list of toxic chemicals category
"copper compounds." C.I. Pigment Blue 15, CAS No. 147-14-8; C.I. Pigment
Green 7, CAS No. 1323-53-6; and C.I. Pigment Green 36, CAS No. 14302—
13-7 are plltlialocyanine pigments covalently bound to copper. Since the
pigments are copper -containing compounds, they are reportable under section
313. After review'of the submitted petition and additional information available
to EPA, the Agency proposed to delete the three phthalocyanine pigments from
reporting under the "copper compounds" category; the proposal was published
in the Federal Register of May 15, 1989 (54 FR 20866). EPA concluded that
the, three phthalocyanine pigments cannot be reasonably anticipated to cause
adverse health or environmental effects of concern to warrant continued release
reporting under section 313. A detailed review of the toxicity and environmental
effects of the three intact phthalocyanine pigments, along with an assessment
of actual or potential exposure, is contained in the proposal.
Because DCMA's petition raised a number of important questions about how
EPA should deal with petitions to delete individual members of listed chemical
categories, the Agency also requested comment on approaches for addressing
these issues and presented four altemaiives. The public comment that was
received as a result of the second request is addressed in a notice of policy and
guidance on the metal compound categories that is published elsewhere in this
issue of the Federal Register.
As stated in the above -mentioned notice of policy and guidance on the metal
compound categories, the toxicity of a metal -containing compound that
dissociates or reacts to generate the metal ion can be expressed as a function
of the toxicity induced by the intact species and the availability of the metal
ion, where the degree of dissociation, bioaccumulation, and the level at which
toxicity is induced by the metal ion must be considered. The effects induced
by the metal ions described by the metal compound categories meet the criteria
under section 313(d)(2). Titus, for petitions to exempt metal -containing
compounds from the repotting requirements under section 313. EPA has decided
to Lase its decisions on die evaluation of all chemical and biological processes
that may lead to metal ion availability as well as on the toxicity exhibited by
the intact species. These decisions will continue to be based on information
provided by the petitioner, Agency documents, and available literature. The
burden of proof that the metal compound does not generate the metal ion os
a result of one or more transforntation processes rests on the submitter, EPA

04l79/38 i':38 10:1011 SFOIV
From:Organic Pigmc❑.=
-B910 ',yc o:8
3
will deny petitions for chemicals for which the metal ion availability cannot be
properly evaluated. EPA will also deny petitions for chemicals *that dissociate
or react to generate the metal ion at a level which can reasonably be anticipated
to cause adverse effects. If the metal compound does not dissociate or react to
generate the metal ion at a level which can reasonably be anticipated to cause
adverse effects, EPA will detenrune whether the effects which may be'induced
by the intact species meet the toxicity criteria of section 313(d)(2).
It should be noted that the above policy would result in a denial of DCMA's
Petition if it were received today because DCMA did not address, in the petition.
all of the transformation processes which could lead to the availability of copper
ion from Ole thru copper pigments. Prior to adopting the above -stated policy,
EPA carried out a technical review to assess the potential availability of copper
ion from the three copper pigments and based its decision on the lack of toxicity
exhibited by the intact species and the limited copper ion availability. EPA's
technical review of the copper pigments, which is provided below, illustrates the
type of analyses which must be conducted by petitioners to justify deletions of
metal compounds from their respective categories.
111. Technical Review
In the proposed rule to exempt the copper pigments front the reporting
requirements under the copper compounds category under EPCRA section 313,
EPA stated that these was no indication front the available data that the (intact)
copper pigments can reasonably be anticipated to cause acute, chronic, or
environmental toxicity. The issue of copper ion availability from the three.
phihalocyanine pigments was not explicitly addressed in the proposed rule.
EPA is concerned with both the potential toxicity induced by intact metal
compounds and with the toxicity induced by the metal ion. Although EPA was
concerned with copper ion availability in its initial review, it did not consider
all the transformation processes that may lead to metal ion availability. The
Agency recently addressed the transformation processes that may generate copper
ion from the copper phthalocyanine pigments. These include, but are not limited
to: hydrolysis, photolysis, abiotic and biotic aerobic degradations, abiotic and
biotic anaerobic degradations, bioavailability of the ion when the compounds are
ipgesied or inhaled, and bioaccumulation. All readily available data including
studies retrieved from literature searches and documents prepared by EPA were
considered in EPA's assessment of the availability of copper ion from the copper
phthalocyanine pigments.
1. Copper ion. Copper is recognized as an essential element. It is essential
to a number of normal physiological processes including erythropoieses,
connective tissue metabolism, bone development, and nervous system function.
The National Academy of Sciences' recommended daily allowance (RDA) for
adults is 2.0 to 3.0 milligrams (mg) copper/day. Copper is also used as a
hentatinic (to stimulate red blood cell production) in adults at a dose of 3.8 to
7.6 mg/day.
a.. Human healrh effects. Copper poisoning has been demonstrated in animals
and identified in humans. The liver is the main storage depot for copper, and

0;;21;38 12:38 To: TOM WN _ Frau:organic Figmei.s 3 1-6218 °age 5.8
hepatic damage is associated with the accumulation of high levels of copper.
Ilepadc toxicity is characterized by hcpatocellular necrosis, regenerative activity,
and cirrhosis. Kidney necrosis and elevated levels of scrum copper occur only
after die liver begins to accumulate high levels of copper. These elevated serum
copper levels can progress to sudden hemolytic anemia and jaundice.
The types of neurological effects associated with copper poisoning can
include deniyelinadon and cerebral degeneration. These effects are thought to
be related to defects in catecholamine metabolism. Alterations in brain
neurotransmitter systems have been observed in rats following intraperitoneal
injections of 2 milligrams/kilogram/day (mg/kg/day) for 21 days. Two groups
are at an increased risk from copper exposure. Individuals with Wilson's disease,
an inbom error in copper metabolism, are at a higher risk than the general
population. The metabolic error in Wilson's disease allows copper to accumulate
in the liver, brain, kidney, and cornea, causing hemolytic anemia, neurological
abnomtalities, and conceal opacity. In addition, individuals with glucose-6-
phosphate dehydrogenase deficiencies may also be at greater risk of experiencing
toxic effects from copper exposure.
Copper is classified in EPA's group D (insufficient data) for carcinogenic
potential. Copper is generally negadve in mutagenicity bioassays. Bioassays using
oral -copper were negative; subcutaneous injection of copper compounds has been
repotted to induce rumor formation in one sex and strain of mice.
EPA has proposed a maxiinum contaminant level (MCL) of 1.3 milligrams/
liter (tttg/L) (3.6 mg/day) copper.
b. Ecological effects. Copper is very toxic to aquatic life. It is sometimes
used as a biocide to control undesirable aquatic plants. EPA has issued Water
Quality Criteria for copper to protect aquatic life. The acute criteria in fresh water
is 22 micrograms/liter (ug/L). The chronic criteria in fresh water is 5.2 ug/L.
In salt water both the acute and chronic criteria are 1 ug/L.
2. Availability of copper ion. The doer, copper pltthalocyanine pigments are
extremely stable to chemically and biologically induced trans fonnations.
a. Thermal stability. The three copper pigments are extremely stable
themcaliy and only begin to show signs of decomposition at temperatures above
500 °C.
b. lydrolysis. The three copper pigments have very low solubilities in water
(estimates arc 8 x 10` to 3 x IW mg/L for Pigment Blue 15, 7 x I(7" to 2
x 10-16 mg/L for Pigment Green 7, and less than 1G" mg/L for Pigment Green
36) and do not dissociate or hydrolyze in water under environmental conditions.
Hydrolysis of the three copper pigments also does not occur in basic and non -
oxidizing acidic media.
c. Photolysis. Based on studies carried out to determine the light fastness
of the three copper phtiralocyanines. it appears that photolysis of these pigments
with resultant release of copper ion will not occur.

V,':7!38 ;2:30 To: TOM 'FAN _ Fr=Orgunic Pigments 3-8918 -age 4/5
d. Abiotic oxidation. Data indicate that under environmental conditions,
abiotic oxidation of these copper pigments does not occur. More rigorous
conditions are required to effect die oxidation of the copper phthalocyanines and -
subsequent release of copper ion. The pigments can be chemically oxidized to
give plitlialimides and copper nitrate by boiling in dilute nitric acid. Oxidation
of the pigments can also occur by treatment with eerie sulfate in dilute sulfuric
acid at 25 °C, or by reaction with potassium permanganate.
e. Microbial transformations. No data on the anaerobic or aerobic
biodegradability of the copper pigments were found. However, based on their
extremely low solubility in water, their large cross -sectional diameter, and with
the exception of the halogens on Pigment Green 7 and Pigment Green 36, the
lack of substituent groups associated with facile primary degradation, these
pigments are expected to be very resistant to degradation processes.
f. Dioavoilability. On the basis of molecular weight, extremely low solubility
in water, and data from subchronic toxicity tests, the three phthalocyanine
pigments are not expected to be appreciably absorbed by any route of exposure
or metabolized to yield copper ion.
the lack of toxicity and minimal changes in tissue copper levels observed
in 13—week oral studies of Pigment Blue 15 and Pigment Green 7 in rodents
indicate that appreciable absorption and metabolism to yield copper ion had not
occurred.
g. Dioaccumulation. Because copper ion does not appear to be available frorn
die phQlalocyanine pigments, bioaccumuladon of copper ion is not a concern.
h. Summary. EPA believes that the availability of copper ion from the
phthalocyaninr; pigments by hydrolysis, photolysis, aerobic and anaerobic
transfonnadons is negligible. Copper ion is not expected to be bioavailable from
the copper pigments. The copper pigments are not expected to be, appreciably
absorbed by any route of exposure or metabolized to yield the copper ion.'rbe
levels at which copper ion exhibits toxicity far exceed the expected lirnited
availability of copper ion from U1e phthaloeyanine pigments which results in a
low level of concern for these chemicals. There could be a slight risk to aquatic
life in rare situations. The small, infrequent risk is best controlled by control
programs under the Clean Water Act, not by a global reporting requirement.
IV. Comments on the Proposed Exemption of the Three Phthalocyanine
Pigments
EPA received comments from more than 22 commenters on the proposed
exemption of the three copper phdmalocyanine pigments from the "copper
category" and on die category issue itself. Eleven commencers were in favor
of granting the exemption, rovo were in favor of denying the exemption, and
the remaining comments were directed only to the category issue.
The New York City Department of Environmental Protection believes that
EPA should not exempt the copper pigments from repotting requirements under
the copper compounds category because "it does not appear that EPA considered
the possibility that copper may be released from the pigments by the action of

OV24J3e 12:38 To: TOM SFA3N Frou:Organic Pigments 336 HIS
:' -
soil [nitro -organisms.... If the action of bacteria liberates copper into the
environment, then the release of die copper pigments represent[ an environmental
hazard." EPA believes that because of the factors specified above (unit 111.2.E)
microbial degradation of the copper pigments with resultant release of copper
ion is highly unlikely.
Arts, Crafts and Theater Safety suggests that before "EPA approves
DCMA's petition DCMA should document the degree" to which polychlorinated
biphenyls (PCBs) and free copper inadvertently contaminate phthalocyaninc
pigments manufactured or imported into the United States. Pursuant to 40 CFR
761,30, phthalocyanine pignients'dtat contain up to 50 ppm PCBs can be
processed and distributed in commerce. Processing and distribution of
phthalocyanine pigments that contain 50 ppm or greater of PCBs is permitted
only for persons who are granted an exemption under section 6(e)(3)(B) of the
Toxic Substances Control Act (TSCA). PCBs are only reportable under section
313 if they are present at a concentration of 0.1 percent, which is the de minimis
concentration (40 CFR 372.38).
The copper compounds category is subject to the one percent de minimis
concentration. Thus, mixtures that contain copper compounds (except the three
copper phttWocyanine pigments) in excess of the de minimis concentration should
be factored into threshold and release determinations. EPA does not believe that
phthalocyanine pigments contaminated with other copper compounds, and/or
PCBs should be treated differently than other mixtures. The presence of these
impurities did not affect ETA's decision to delete the three copper pigments.
V. Rulemaking Record
The record supporting this rule is contained in docket number OPTS-
400030A. All documents, including the index of due docket, are available to the
public in the TSCA Public Docket Office from 8 a.m. to noon and l P.M. to
4 p.m., Monday through Friday, excluding legal holidays. The TSCA Public
Docket Office is located at EPA lieadquaners, Room NE-0004, 401 M St., SW.
Washington, DC 20460.
VI. Regulatory Assessment Requirements
A. Executive Order 12291
Under Executive Order 12291, EPA must judge whether a rule is "major"
and therefore, requires a Regulatory impact Analysis. EPA has determined that
this rule is not a "major rule" because it will not have an effect on the economy
of SI00 million or more.
Tltis rule would decrease the impact of the section 313 reporting
requiements on covered ult it, cost -savings to industry,
EPArand States. Therc ore, this is a minor lrulesunder Executive Order 12291.
There are 6 major producers, 16 processors of the crude pigment to pigment
grade, and 21 importers of Pigment Blue-15 at a total of 45 sites. There may
be 1 producer, approximately 14 processors. and 12 importers of Pigment Green-
7 at a total of 26 sites.'ilacre are approximately 5 processors and 4 importers
of Pigment Green36 at a total of 9 sites. EPA estimates the number of producers.

04/24/38 12:38 lo:1011 SFAIN — FrawOrganic Pigments 33, -6918 Page 218
processors, and importers that might be subject to reporting under the current
threshold requirements to be no more than 80. The cost savings.of exempting
indusuy from reporting requirements for these three copper phthalocyanine
pigments under the "copper category" are estimated at one million dollars, while
the savings for EPA are estimated to be $25.000 (10—year present values using
a 10 percent discount rate).
B. Regulatory Flexibility Act
Under the Regulatory Flexibility Act of 1980, the Agency must conduct
a small business analysis to determine whether a substantial number of small
entities will be significantly affected. Because the rule results in cost savings
to facilities, the Agency certifies that small entities will not be significantly
affected by the rule.
C. Paperwork Reduction Act
This rule does not have any infonnation collection requirements under the
provisions of the Paperwork Reduction Act of 1980, 44 U.S.C. 3501 et seq.
List of Subjects In 40 CFR Part 372
Chemicals, Community right -to -know, Environmental protection, Reporting and
recordkeeping requirements, Toxic chemicals.
Dated: 9worfor
Asrisranr Adn�icides and Toxic Substances.
Therefore, 40 CFR part 372 is amended as follows:
1. Tile authority citation for part 372 continues to read as follows:
Authority: 42 U.S.C. 11023 and 11048.
§ 372.65 [Amended)
2. In §372.65(c) by adding the following language to the copper compounds
listing "(except for C.I. Pigment Blue 15 (PB-15. CAS No. 147-144), C.I.
Pigment Green 7 (PG-7, CAS No. 1328-53-6), and C.I. Pigment Green 36 (PG-
36, CAS No. 14302-13-7)".
1FR Doc. 91—????7 Filed??—??-91; 8:45 a.m.]
BILLING COTE 6560-50-F

n
M
z
ry
w
M
z
ui
a
w
TABLE 3 RESULTS OF LIMITFD-SCALE CHRONIC TOXICITY TESTS ON INDUSTRY DISCHARGE SAMPLES FROM
CITY OF HENDERSON NUTBUSH WW1P
Sample Description
EA Accession No:
Test Number:
WHITE EFFLUENT
AT8-354
T`N-98-223
Sample Description:
EA Accession No:
Test Number:
WHITE IlVFLUENT
AT8-355
TN 98-224
Test Concentrations Survival Mean Young per
Test Concentrations
Survival
Mean Young per
(percent sample) (percent) female (tS.D_)
(Percent sample)(Percent
l
female (±S.D-)
Control 100 22.0 (h 2.9)
Control
100
23.4 (t 6.1)
10 100 21.0 (f 1.0)
10
100
26.2 (15.0)
25 100 22.2 (± 4.7)
25
100
22.0 (t 5.2)
50 ow Ot21
50
100
20.6 (t 2.7)
75 ow Ol't
75
100
17.8 (t 4.0)
100 OW ow
100
too
16.2 (t 2.6)r°)
NOEC: 25
NOEC:
75
LOEC: 50
LAEC:
100
ChV: 35.4
ChV:
86.6
IC25: 30.9 (24.9-31.4r)
IC25:
67.9 (NC)
(a) Twatm is which have so amvAing mwu isms ace not imluded in the rratia6ml amlym.
(b) Stedatimlly di6ereat O' -0.05) 5rom the omitmi. indicating an adveeae clleat.
(e) Values in puma== m7cunt 95 p"=d canfidotco limits.
NC=95 perccnt eonGdmw limits we not calculable.

a
TABLE 3
Sample Desdiption:
EA Accession No:
Test Number:
BLUE EFFLUENT /11
AT8-356
TN-98-225
Sample Description:
EA Accession No:
Test Number:
BLUE INFLUENT
ATE-357
TN-98-226
Test Concentrations Survival Mean Young per
Test Concentrations
Survival
Mean Young per
(percent sample)(percent female (fS_D)
(percent sample)
(Fgrzgpt2
fcm la a (IS.D,I
Control 100 22.6 (t 2.7)
Control
100
24.0 (f 5.9)
10 100 21.8 (43.3)
10
100
16.8 (f 6.9)
25 100 22.4 (f 3.3)
25
Ow
1.0 (i 2.2)(')
SO Ot'l 5.6 (f 1.1)t')
50
Ot'l
O41
75 Ot'l 0N)
75
Ow
O41
100 Ot't Ot'1
100
Or't
OW
NOEC: 25
NOEC:
10
LOEC: 50
LOEC:
25
ChV: 35.4
ChV:
15.8
IC25: 32.8 (26.6 — 34.2)l`l
IC25:
8.3
(2.7 — 16.7)t`l
(a) Treatttxaits which have no surviving o[gaaisau are not iachtded in die statistical analyses.
(b) Ststistiealty &Tffent 0'=0.05) fimn the emMA indicting an adverse effect
(c) Values in paxatheses tepeaeot 95 percent cmfideam limits.

to
Ih
61
T
TABLE 4 RESULTS OF CHRONIC TOXICITY TESTS ON FINAL EFFLUENT SAMPLES COLLECTED BEFORE AND
rn
m
AFTER ADDITION OF HYDROGEN PEROXIDE
a
n.
0
Sample Description: Final Effluent Before H202
Final
Effluent After H202
EA Accession Number: AT8-364,376
AT8-365,377
Test Number: TN-98-239
TN-98-188
Test Concentrations Survival Mean Young per
Survival
Mean Young per
(percent effluent)(percent female(tS.D.)
(percent
female(tS.D.}
Control 100 15-0 (t 6.8)
100
22.3 (t 4.8)
15 100 20.6 (t 0.9)
90
26.1 (t 2.6)
30 0.) Ota1
100
25.5 (t 2.7)
45 OW Ot't
100
23.2 (t 2.9)
z
z
w
ow 67.5 O01'1
80
25.8 (t 2.5)
In
z
90 OI'1 OI't
20(1
20.4 (t 5.7)t`t
z
z
w
cc
NOFC: 15
67.5
LOEC: 30
90
ChV: 21.2
77.9
in
IC25: 18.9 (NC)
>90
m
m
(a) T=tnsenta wwti h hays significant modality or hive no s Aving organisms are not statistically analyzed for reproduction, Per
EPA guidance.
I'
(b) StatL&Wly diQcrent (P-0.05) from control indicating an advrase cffwL
rom
(r) vatum in parrnthceis mpresent 95 perctrd confidence limits.
I,
NC=95 percent confidante limits am not calculable

Table C-1. Results of Nlicrotoc Chronic Tests (22-h Light Loss) Performed on Industry and Pump
Station Samples.
1998 Date Sample
IC25
CltV
NOEC
LOEC
r
Feb 13 Amencal
Ball Foster
76.2
\C
100
>100
Iams
64
\C
l(A)
>100
J.P. Taylor
10
\C
6.25
<6.25 i
Kennametal
L7
`:C
6.25
<625
Softspun
54
X.7
50
100
IAf\V"rPEflluent
70.2
`-
lt))
>100
Marti Amencal
26.7
\C
10)
>100
Ball Foster
26.4
10.7
50
100
Iama
26.5
35.4
25
50
J.P. Taylor
21.1
17.7
125
25
Kennametal
31.6
',(.7
50
100
Softspun
60.9
'0.7
50
100
Sandy Creek P.S.
47.1
\'C
lfh)
>100
W'IWTPEffluent
40.7
',(.7
50
1W
Apr 8 Amencal
24
`-
6.25
<6.25 I
Ball Foster
28.6
35.4
25
50
Lams
56.1
`:C
10)
<100
J.P. Taylor
25.9
35.4
25
50
Kennnmetal
1.6
\C
6.25
<6.25
Softspun
1.6
X
NC
<6.25
Sandy Creek P.S.
W i? Effluent (Apr 9)
216
35.4
25
50
Apr!S Americal
>100
\C
100
>1011
i Ball Foster
60.6
'0.7
50
1fW
lams
>100
VC
it)u
>100
J.P. Taylor
37.5
70.7
50
100
Kennametal
47.5
70.7
50
100
Softspun
23.5
35.4
25
50
Sandy Creek P.S.
75.1
\C
100
>100
WWTPEffluent
44.4
70.7
50
1(W
Apr 22 Americal
2.1
NC
6.25
<6.25
Ball Foster
27
\C
6.25
<5.25
Iams
13.9
17.7
17 0
25
J.P. Taylor
2 1
`.0
625
<5.25
Kennametal
110
17.7
125
25
Softspun
16
\C
\C
<6.25
Sandy Creek P.S.
3
\C
6_24
<6.25
WW'TP Effluent
93
35.4
25
50

TA131_17 3 RESi 11:I:S Oh l..lt\fIT1iD-SG\LE Cl IRONIC:I TM.ICI'I'). TESTS ON INDUSTRY DISCI I:\R(ili S:\\IPI.I(S hR(lhl
C!'P)-'Oh IIENDERSON. NUT1311S1l \VWTP _ --
Industry Mama:
A.\tERICAL
Industry Name:
KENNAMETAL
n;
IWC:
0.6 96
EA Accession No:
A"I'8-290/306
P..\ tficcession No:
ATR-294i310
Test Number:
TN-98-180
Test dumber:
TN-98-184
Test Concentrations
Survival
Mean Young per
Test Concentrations
Survival
t\icut Young per
(percent sentple)
(percent
female (:ES.D.)
(percent sample)(percent
)
female (d-S.D.)
Control
80
12.4 (y 7.6)
Control
100
202 (16.0)
0.9
100
1.1.8 (i 5.0)
0.07s
100
19.0 (t •1.8)
1.6
100
15.6 (:E 3.2)
0.1 i
100
20.8 (.E 2.2)
32
t00
15.6(1:4.0)
0.3
t00
22.4(t 2.9)
6.4
40
72 (t 9.9)
0.6
100
24.6 (E 2.2)
12.8
prat
opal
1.2
80
21.4 (1 2.9)
NOEC:
6.4
NOEC:
1.2
LOEC:
12.8
LOEC:
' 1.2
Chi':
9.1
Chv:
'1.2
IC25:
4.8 (2.8 - 9.6)
IC2;:
1.2
(a) Treatments wnich have fit, suriwts organisms are not mtduded ill the sransacal +utaly,es
(h) StarisstiaAy dinerent i P-d .lit lion the cuatrol. nttlicaun;i 111 nJver.0 cilect

TAI11l 3
Industry Nanw:
Ball Fusser
Industry Name:
LANts
IWC:
0.IT;)
I1\'c:
fCA Accession No:
:1"1'8-_):i;307
�1
F.\:\cacssionNo:
AT8-292:3(18
'fast Number:
TN-98-181
Test dumber:
'I'N-98-1
S2
Test Concentrations
Survival
{ear Young per
Tcst Concentrations
Survival
\lean Young par
(percent sample)
ercent
Ieru:lle O&D.I
(percent sample)
lerceut
Icnlalc (IS 1).)
Control
100
18.6 (a 3.6)
Control
SO
17.0 ( 1 7.5)
O.0125
I00
18.4 (14.0)
0.7
10O
21.8 ( i 2.5)
0.025
Inn
IS.0 (r 5.7)
1.4
100
20.5 (q 14)
0.05
100
11).2 (1 6.0)
2.8
NO
2-1 8 (1 1 9)
0.1
100
19.4 ( t 3.5)
5.6
100
23.2(1 5.9)
0.2
I00
17.4 (i 3.9)
11.2
100
26.4 (L 3A)
NOGC:
0.2
NOHC:
11.2
LO@C:
%0.2
LOGC:
11.2
ClIV:
: 0.2
ClIV:
. 1 1.2
Ills TrIntillC1113 which have IIU
mniI llc Jlumil:111Y1 ar I of ilich1dCd ill IIIC :'.I:111:IICd1 llllill_.':1C:.
Ibl $emencallly nnalem (1'. �)
Is Ii'.nn IIIc contra.
tit, hca,wgz an ad\vlsc eli�rco

T,afll-F 3 (Cnnlinn,:(l)
Industry Namc:
IWC:
IAAcee:ssion No:
'rest Number:
Test Concentrations
(percent sample)
Control
0.1
0.2
0.4
0.8
L6
B RKART
O.x'!n
: VI'H-296i 31 1
TN-98-IS5
Survival
(ncrccnt)
\•lawn Young Per
f'enulle (.LS.1).)
18.0 (:r 3.7)
7.0 (±1.7)""
2.8 (-t 1.1)"',
0.4 (r 0.9)j1i
ot.1
owl
NOGG: 0•
LOGC:
chv:
IC25: 0,04 (0.03 0.05)
(a) T:aa:mewn which have no em llm arc it'll included in the :lamaical
tb) S+aloneallydifferent tP=U -i l ti'.•m t11.• anmoL imhcafiaa all ea-•aw: rn JCl.
Indusuv Hama:
li.\:\ceession Nu:
Test Number:
rest Concentrations
(percent 5:I111I)IC)
Control
-{.75
95
19
3x
76
NOLC:
L.OGC:
CIIV:
IC'25:
S:\NDY CR1:1:h
3x'1.1
\'rH-291,312
TN-98-1X6
Survival \►ean Young Per
(narcanO ICulnle ( I S.D.)
100 15.3 (r. 6.9)
IOU 15.3(r7.x)
100 22.3(t2.1)
100 14.8 (1 5 9)
100 9.3 (.t 5.7)
o(.1 om1
38
76
53.7
25.4(6.0 5-1.X)

TARLG3 (Conlinucd
indmir• Name:
l.P. TAYLOI2
Indu,tn Name:
r
I\� l
0. K )c.r n
1 \1' C:
Wi ll'.r
rA ACCeSS1011 No:
AT8-295.309
EA accession No:
�,���
A4*8
�rl t "t 111
_�°�-�i w
Test Number:
TN-98-183
Tcst Number:
4:-r494-94
Test Concentrations
Survival
\(call Young par
Tcst Concentrations
Survival
Mean Young per
(perceill Slllliple)
percent
ICIIIale NS.D.)
ICt'Cellt sallIPIC•I
(11crecilt)
ICIIIiIIC (1 S.D.
Control
100
21.3 (.1: 4.2)
GtMIral
-190
0.1I
10o
20.2(.L5.2)
0.22
loo
20 2 (.c 4.4)
444
40A
24kll— :2-
0.44
to
19.0 r 6.4)
A -.a
+00
--1-4-N-2-4)
OX%
100
22.8 (I 3.8)
(1 6
I0(1
.244,(4-2-2)
1.76
100
22.6 (i 3.3)
4-2-
94
2-1. 2 sv)
NOGC:
1.76
NORC:
4-72
LOGC:
..1.76
Ll)1;C;
>1:2
IC2;:
I .�6
IC25:
1
(a) 71-Gmiaallu which hit a m, nrc:utr.: r, are not included it, tLa raan:ae:,l ..milr�x
Ibl :Ilatuac.dl,; din'crrnt t P:.n .; � ii.nu �Ite :�m:r.•L :n.lrc:niu_ an .r.i,•etxe , iia,a

TEl''49-783-7642
Aug 13 98 2:27 N3.007 P.02
PEIRSON
WHITMAN
ARCHITECTS
AND
ENGINEERS,
PA.
ESTABLISHED 1938
5510
PAUNFORD ROAD
P.O. BOX
30398
PHONE
919/782-8300
FAX
919i783-7642
RALEIGH
N.C.
27622-0398
U.S.A
August 13, 1998
Mr. Tom Spain
City of Henderson
P.O. Box 1434
Henderson, NC 2753E
Re: Red Bud Pump Station
P&w Project No. 1322
Dear Mr. Spain:
f Z g
I inspected the subject project yesterday and found
the following deficiencies:
1. The bar screen rake had become unbolted from its
lifting arm and was hanging loose. The bar
screen is inoperative until such time as this
problem is corrected by the contractor.
2. The screw conveyor exhibits, from time to time,
'_:+appropriate noises that indicate probable
misa"ignment. It is my understanding that the
screw itself exhibits a wobble at the midpoint of
its length.
3. The conduit that carries power wiring to the
screw conveyor motor is not adequately
stabilized. The conduit tends to shake and move
when the conveyor is in operation. Over time,
the conduit could fatigue and crack.
4. The electrical cable for pump motor moisture
sensing is wrapped around at least two (2) pipes
inside the equalization basin such that the pump
cannot be removed from the basin without first
disconnecting the cable.

mmary Status Report on
inflowlinfiltration
Date
Smoke
Testing (ft.)
Viewing/Cleaned
of Sewer LF
Total Costs
Labor/Equip
Manhole
Restoration
Sewer Line Repair
Eliminate 1&I
Gallons Per Minute
3-31-94
-
-
10 (MR)
10 GPM
6-30-94
-
$10,500
8 (MR)
13 GPM
9-30-94
-
4,700 LF
*$114,000
-
10 GPM
1-3-95
-
4,060 LF
$7,300
15 GPM
4-3-95
-
10,325 LF
$5,668
-
7-3-95
-
3,402 LF
$1,506
-
9-29-95
20,245 ft.
10,689 LF
$4,703
-
45 GPM
12-29-95
6,782 LF
$11,190
-
3 GPM
3-27-96
6,782 LF
$11,190
-
3 GPM
*16-28-96
7,718 LF
$12,734
-
9-30-96
169,000 ft.
13,140 LF
$32,355
30 WHO
2 (MR)
15 (SL)
250 GPM
12-31-96
10,500 ft.
38,038 LF
$71,856
30 (MHI)
3 (SL)
200 GPM
3-31-97
2,905 LF
$28,779
2 (SL)
100 GPM
6-30-97
23,703 LF
$37,887
12 (SLI
100 GPM
9-30-07
29,830 LF
$191,637
12-31-97
19,575 LF
$100,953
10 (SL)
100 GPM
4-1-98
47,450 LF
$46,332
7 (SL)
703 (Rainstoppers)
(Installed)
200 GPM
6-30-98
50,400 LF
$43,721
TOTAL(S)
199,745 LF
279,499 LF
$732,308
20 (MR)
60 (MHI)
37 (SL)
703 (Rainstoppers)
Installed)
*21,049 GPM
(MR) Manhole Restoration
(MHI) Manhole Inserts
* Purchase of I&I Truck
*' $70,000 ADS Study Contract to Perform Flow Monitoring
*Z Final Estimated I&I Elimination was summarized and revised from the Quarterly Reports. The
revisions were based on field observations.
(SLI Sewer Line Repair

TEL:[phone] Aug 13 98 2:28 No.007 P.03
Mr. Tom Spain
City of Henderson
February 18, 1998
Paae 2
Because of the severity of these problems, I will not
issue the Certificate of Substantial Completion until
such time as these items are corrected. I have
notified the contractors to return to the project and
correct these deficiencies as soon as possible. I
will keep you informed.
Very truly yours,
PET 'ON4S.Acquesta,
WHIT ARCHITECTS AND ENGINEERS, P.A.
MichaeE., Ph.D.
MSA/ted
cc: Mark Warren

[VISION OF WATER QUALIT
MEMORANDUM
To: Judy Garrett /
Through: Larry Ausley �
Matt Matthews t
From: Kevin Bowden %40
June 5, 1997
oil
Subject: Toxicity Reduction Evaluation Phase I Progress Report - May 1997
City of Henderson
Proposed SOC EMC WQ No. 96-05
NPDES Permit No. NC0020559
Vance County
This office has completed a review of the subject Toxicity Reduction Evaluation Phase I Progress
Report dated May 1997. The City has contracted with Burlington Research, Incorporated to provide
assistance in its toxicity reduction efforts. Item 2(b)(2) of the City's proposed SOC requires the City to
submit quarterly progress reports in triplicate to the Raleigh Regional Office no later than the 15th day of
each February, May, August, and November for the duration of the SOC. This progress report covers
THE activities occurring from February through April 1997 and includes information on WWTP effluent
toxicity monitoring, THE Date Log records, reports on the Nutbush and industrial pretreatment evaluations
conducted on January 28, 1997, reporting of RTA and effluent treatment evaluations conducted the week
of February 10, 1997, industrial discharge toxicity monitoring, Microtox"m toxicity monitoring, and
hydrogen peroxide/polymer treatment at the Nutbush WWTP. The facility is required to meet a 90%
chronic permit limitation.
Two multiple concentration toxicity tests were conducted each month during February, March, and
April. Chronic values of (62% & 62%), (<12.5% & >90%), and (37% & 55%) were reported,
respectively. Acute impact measured as 48-h LC50 was absent in all procedures except the April 9 test
which produced a 48-h LC50 value of 78%. Total mortality was observed in the 90% test concentration
for all test procedures except the March 26 test which had no mortality.
THE Date Log information submitted by the City's industries does not reflect changes in chemical
usage or production during the quarter. Notable entries included: 2/12-start-up of the DAF/belt press at
Americal; 3/3 1 -effluent very clear, the primary anaerobic digestor has not foamed during March; and 4/30-
no foaming from the anaerobic digestor during April.
EA Engineering, Science, and Technology, Inc. (EA) conducted industrial site visits at Americal
and Kennametal and also conducted a WWTP evaluation on 1/28/97. In early May the City received the
final WWTP evaluation report from EA which appears in Appendix A. The following recommendations
were offered:
• Monitor the Nutbush WWTP Unit processes for toxicity at varying operating conditions to detemune
the optimum toxicity reduction capability of the units.
• Remove sand and anthracite from influent lines to the first stage trickling filters and level the distributor
arms.
• Increase MI -SS in the oxygen -nitrification process to increase the biodegradation of toxicants.
• Maintain a consistent MCRT in the oxygen -nitrification process.
• Computerize process wastewater characterization data.
• Operation training for the Nutbush staff and hiring a pretreatment coordinator.

Page 2
City of Henderson -Quarterly THE Progress Report -May 1997
June 5, 1997
EA issued a draft RTA report to the City on May 2, 1997. A copy of this report appears in
Appendix B. The following conclusions and recommendations were offered:
Conclusions:
• Softspun, Sandy Creek Line, and Martins Creek Pump Station have been identified as significant
sources of toxicity.
• The West Nutbush collection system does not appear to contribute toxicity to the WWTP.
• Discharges from Americal and Kennametal do not appear to be significant sources of toxicity. Both
systems implemented pretreatment operational changes prior to the RTA.
• Effluent treatment tests indicate that 6.5 hours of post -aeration and a 1-5 ppm hydrogen peroxide
addition can reduce effluent toxicity. MicrotoxTm testing by the City indicates that chlorine addition
and fine particle filtration can reduce toxicity.
Recommendations:
• Additional RTA testing should be performed to verify previous results and to pinpoint sources of
toxicity in the Sandy Creek Line between Martins Creek pump station and the main line sampling
station. All industries in the Sandy Creek Line should be investigated.
• RTA testing should be conducted as part of a comprehensive investigation of toxic discharges.
• Implement a computerized database to track wastewater characterization data and evaluate trends in
sewer discharge characteristics.
• Hydrogen peroxide addition and additional aeration should be considered in the overall strategy for
toxicity reduction.
• Additional chlorine addition and fine particle removal treatments should be conducted.
• Potential impact from chemical additives on the tertiary filters and UV disinfection should be evaluated.
On February 2-3 and March 11-12, composite samples from Americal and J.P. Stevens were
collected and analyzed for acute and chronic toxicity. At a 10.4% estimated flow contribution to the
Nutbush WWTP, the discharge from Americal was acutely non toxic and chronically toxic. The discharge
from J.P. Taylor was acutely and chronically toxic at a 1.0% estimated flow contribution to the WWTP.
The City has been using Microtoxrm to monitor the efficiency of effluent treatments for toxicity
reduction. Efforts have focused on wastewater collected in the Sandy Creek line. The City is currently
compiling and evaluating MicrotoxTm data.
Results of effluent treatment studies suggest that 1-5 mg/1 hydrogen peroxide addition reduces
toxicity in the final effluent. On March 14, 1997, the City began feeding hydrogen peroxide (rate of 1.0
ppm) and cationic polymer (rate unknown) into the treatment system. An IC25 value of 85% was
recorded with samples collected Tuesday through Wednesday and Thursday through Friday of the
following week. The hydrogen peroxide feed was increased to 3.0 mg/1 on March 20 and reduced to 1.5
mg/I on March 26. An IC25 of >90% was recorded for samples collected on March 25-26 and March 27-
28. Although hydrogen peroxide and cationic polymer application continued through the month of April,
the City did not see similar reductions in effluent toxicity for April.
The Discussion section mentions that Nutbush effluent was "characteristically variable" during the
study period and that no apparent direct benefit of reduced toxicity from operation of the

Page 3
City of Henderson -Quarterly THE Progress Report -May 1997
June 5, 1997
pretreatment units at Americal and Kennametal was realized. The report notes reduced color and foaming
in Nutbush effluent since continual operation of the industrial pretreatment units.
The report indicates that closer investigation of the Softspun operation/wastestream and dischargers
tributary to the Martins Creek portion of the Sandy Creek line are warranted.
BRI suggests that the City consider recommendations made by EA which are contained the
Nutbush WWTP evaluation and RTA reports. Staff from the City, BRI, and EA met on May 14 to
discuss actions/activities to be considered by the City in its THE work. The report suggests that a plan of
action will be forwarded to DWQ for review.
The recommendations which appear on page fourteen of the report were presented in error since
the WWTP site evaluation and RTA evaluations have already been received. This issue was addressed
with representatives from Burlington Research on June 3 who will submit a revised recommendations
page.
In summary, recent information provided by EA to the City should prove beneficial in determining
future direction for the TRE. We are disappointed that effluent toxicity for the subject quarter remains
variable. This office has stressed the importance of source reduction activities to the City for many years.
Although we are disappointed with this quarter's toxicity testing results, we acknowledge the THE Date
Log entries which indicate less color and foaming in the effluent. This office supports actions on behalf of
the City to conduct additional RTA testing of industrial users. It appears that in order to reduce effluent
toxicity to acceptable levels, the City will have to aggressively implement source reduction activities and
possibly implement a treatment technology.
Our previous recommendations regarding support for an SOC amendment remain the same: a
reasonable amount of time has passed to resolve effluent toxicity issues and we do not support any
extensions of time to achieve compliance with the final permit limitation for whole effluent toxicity.
If you have any questions, please contact me at 733-2136.
cc: Dennis Ramsey
Ted Cashion -Raleigh Regional Office
Tom Poe -Pretreatment
Aquatic Survey and Toxicology Unit Files
Central Files

State of North Car(
Department of Enviru ., Dent,
Health and Natural Resources
Raleigh Regional Office
James B. Hunt, Jr., Governor
Jonathan B, Howes, Secretary
MEMORANDUM
1"MAI
r�r..r
EDEHNFR
DIVISION OF WATER QUALITY
March 19, 1997
To: Cecil Madden
Construction Grants
Through: Ken Schuster, P.E. I
Regional Supervisor
Judy Garrett
Regional Water Quality Supervisor
From: Ted Cashion
Environmental Chemist j
Subject: City of Henderson
Phase II Sewer Rehabilitation
Special Order by Consent 96-05
NPDES Permit No. NCO020559
Vance County
The City of Henderson recently signed the subject SOC, and we have forwarded it to the Central
Office for placement at public notice and execution. The SOC requires Phase I to be completed
by July 31, 1998, which includes a program to remove 1/I. Phase II includes upgrade/expansion
of the Redbud pump station, and extending sewer services into the Ruin Creek Planning Area,
which includes Dabney Elementary School and Vance -Granville Community College. The Phase
11 engineering report is to be completed by September 30, 1998, submit construction plans by
September 30, 1999, begin construction by February 1, 2000, complete construction by January
31, 2001, and eliminate overflows from the Redbud pump station by March 1, 2001.
The RRO recommends that Construction Grants allow construction in accordance with Phase I
and II of the SOC.
If you have additional questions concerning the SOC please call.
cecil.mem
3800 Barrett Drive, Suite 101, FAX [phone]
Raleigh, North Carolina 27609 J` An Equal Opportunity Affirmative Action Employer
Voice 919-571-4700 ® 500% recycled/ 10% post -consumer paper

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EFFLUENT LIMITATIONS AND MONITORING REQUI
ATTACHMENT A Page 3 of 4
Permit No. NC0021563
Henderson WWTP
REMENTS - TMTRUTM (November 1 - March 3
During the period beginning on the effective
lasting until March 1, 1997, the permittee is
Such discharge shall be limited and monitored
1)� � ;a
00 a
date of this Special Order by Ca n
authorized to discharge from oq&Pl
by the permittee as specified bm w m
WC: (9
s Monitoring Requirements :30
s C-
4.14 mgd
Continuous,
Recording
m or
Flow
BOD, 5 Day 20 degrees C**
12 mg/1 18 mg/l
Daily
Composite
Composite
p Q,E
-? I,E
Total Suspended Solids**
30 mg/1 45 mg/l
Daily
Daily
Composite
E
NH3 as N
6.0 mg/1
Daily
Grab
E
Dissolved Oxygen (minimum)***
Fecal Coliform (geometric mean) 200/100ml 400/100 ml
Daily
Grab
E
E
Residual Chlorine +
Daily
Daily
Grab
Grab
E
Temperature
T
Total Nitrogen (NO2+NO3+TKN)
Monthly
Weekly
Composite
Composite
E
E
Total Phosphorus ****
Quarterly
Composite
E
Chronic Toxicity
* Sample Location: I - Influent, E - Effluent, U - Upstream at NC Highway 39; D - Downstream
(1) at the power lines, (2) immediately above the confluence of Indian and Crooked Run Creeks.
Upstream and downstream samples should be taken mid -morning. Rainfall data shall reported
for the seven consecutive days prior to the day of sampling. c�
** The monthly average effluent BODS and Total Suspended Solids concentrations sh
15% of the respective influent value (85% removal).
+ Required if chlorine disinfection is used.
*** The daily average dissolved oxygen effluent concentration -shall not be less
**** Limit is effective October 1 - March 31. Compliance shall be based upon a qu
average of weekly samples. The limit shall be 1.5 mg/l. ***** Chronic Toxicity - See Attachment B- The pH shall not be less than 6.0 standard units nor greater than 9.0 standarim
shall be monitored daily at the effluent by grab sample.
- There shall be no discharge of floating solids or visible foam in other than t

CHRONIC Try 'Y MONITORING (QUARTER^ —tachment B
State of North Carorlr. - xend� 0020ss9
Department of Environment,
T Q1i , W(Sc� j yr1eVhronic toxicity s
„nc unes;®atfi#med in: The North Carolina P W e
voat� Hunt, Jr., Governor
Jonathan B, Howes, Secretary
The effluent concentration defined as the IPeFm st o nt tion
(IWC) shall be 90%. Suggested effluent serial dilutions for the full
range test are 90%, 67.5%, 45%, 30%, and 15% (these test
concentrations may be modified upon prior approval from the
Environmental Sciences Branch and provided that Phase II test
methodology is adhered to). The chronic value for this analysis will
be determined using the geometric mean of the highest concentration
having no statistically detectable impairment of reproduction or
survival and the lowest concentration that does have a statistically
detectable impairment of reproduction or survival. The presence of 48
hour acute toxicity will be determined using Fisher's Exact Test at 48
hours from test initiation. Collection methods, exposure regimes, and
further statistical methods are described by the document referenced
above.
The permit holder shall perform at a minimum, quarterly monitoring
using these procedures to establish compliance with the Order
condition. Toxicity monitoring shall be conducted 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.
All toxicity testing results required as part of this Order condition
shall be entered on the Effluent Discharge Monitoring Form (MR-1) for
the months in which tests were performed, using the parameter code
THP3B for the Chronic Value and TGA3B for the 48 hour Acute Toxicity
measure (Pass/Fail). Additionally, DEM Form AT-3 (original) is to be
sent to the following address:
Environmental Sciences Branch
N.C. Division of Environmental Management
4401 Reedy Creek Road
Raleigh, NC 27607
Test data shall be complete and accurate and include all supporting
chemical/physical measurements performed in association with the
toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should any test data from this monitoring requirement or tests
performed by the North Carolina Division of Environmental Management
indicate potential impacts to the receiving stream, the NPDES 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 and appropriate
environmental controls, shall constitute an invalid test and will
require immediate retesting (within 30 days of initial monitoring
evenW.Barrft T1vk%itQ-t91subnr�t su st results wf*C1918ansvjtute
non8@"hi-WltC.aW 740nitoring "ent.isEqual Opportunity Affirmative Action Employer
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4
CITY OF HENDE
Post Office Box 143,
180 Beckford Drivc
Henderson, North Carolina 2'
Phone: [phone] FAX
November 14, 1996
Mr. Ken Schuster
Raleigh Regional Supervisor
NC DEHNR-DWQ
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Re: City of Henderson Nutbush Creek WWTP
NPDES #NC0020559
SOC: EMC WQ No. 96-05
Submission of Quarterly THE Report
Dear Mr. Schuster,
_0
R
f
1 U "-
I am forwarding the November Toxicity Reduction Report as required
by Section 2. (b) 2) of Special Order of Consent WQ NO. 96-05.
Please call me at 919-431-6081 if you need further information.
cc: Eric Williams
Xiaolin Chen
Sincerely,
Thomas Spain,
WWTP Director
Rl� NnV 1 5 1996
DE1INR RALEIGH REGIONAL OFFICE

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0
DIVISION OF WATER QUALITY
RALEIGH REGIONAL OFFICE
October 29, 1996
M E M O R A N D U M
TO Cecil Madden
Construction Grants and Loans
THROUGH Judy Garrett ;
Regional Water Quality Supervisor
FROM Randy Jones
Raleigh Regional Office
SUBJECT City of Henderson
Ruin Creek Outfall (Project No. E-SBF-T-95-0024)
Red Bud Pump Station
Red Bud Basin Sewer Rehabilitation
Vance County
On October 8, 1996, you had transmitted the subject plans to the
RRO and asked for comments. As typical for sewer extension
projects in the regions, we have not performed a detailed technical
review of the plans, but have performed a cursory review and do not
have any comments.
You had requested that the RRO provide you with a P4 and had
stated that the application would be forwarded to us ASAP. We
have not received this application form, so we cannot sign off
on any flow. The City must provide the RRO with a report
indicating that I/I flow has been eliminated in the amount of
two times the proposed flo�{ prior to the approval of the P4.
z Ccd�C�-c�
As far as the SOC is concerned, the dates in the SOC are in
the process of being revised to add a phase II to the Pump
Station Rehabilitation. This Phase II would expand the pump
station to meet the twenty-year pumping requirements, as well
as the installation of a standby pump.
The RRO does not object to the method and sequence of
construction.
The Land Quality Section states that it has approved a
sedimentation and erosion control plan for the Ruin Creek
Outfall, that includes a pump station.
If you have any questions, please feel free to contact me at 571-
4700.
file: RUINC.ME

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
October 8, 1996
.ir
Mr. Eric M. Williams, City Manager
City of Henderson
P. O. Box 1434
Henderson, North Carolina 27536-1434
IDEEHNR
Subject: City of Henderson
Ruin Creek Outfall
E-SBF-T-95-0024
Dear Mr. Williams:
The Construction Grants & Loans Section has completed its review of responses
received on September 6, 1996 and has the attached comments. Please provide two copies of a
revised 201 amendment which incorporates responses to these comments for our review and
approval as soon as possible.
If you have any questions or if this office may be of further assistance, please contact
Mr. Ryan Scruggs at [phone] or me at [phone].
Sincerely,
Jay B. Lucas, P.E.
Supervisor, Facilities Evaluation Unit
JBL/pe
cc: Peirson & Whitman
Raleigh Regional Office
DMU
FEU
SBF
Construction Grants & Loans Section aw, FAX [phone]
P.O. Box 29579, Raleigh, North Carolina 27626-0579 NV An Equal Opportunity/Affirmative Action Employer
Voice 919-733 6900 7"' 50% recycles/ 10% post -consumer paper

so M
CITY OF HENDERSON
Additional Technical Review Comments for the
Engineering Amendment to the 201 Facilities Plan
Although the Red Bud pump station appears adequate to handle the existing peak
flows, it does not appear adequate to handle the peak 20-year design flows. In the
response to Comment #9 in Appendix B, the current flow to the Red Bud pump
station is 575,000 gpd and the total peak flow to the pump station (after the
completion of I/I rehabilitation work) is projected to be 1,177,000 gpd including
I/1. This resuI40 a peaking factor of 2.05 rather than the accepted 2.5. Applying
the same peaking factor to the 128,300 gpd of 20-year growth results in a peak 20-
year growth flow figure of 263,000 gpd. By combining these two peak flow
figures, the total peak 20-year design flow to the Red Bud pump station would be
1,440,000 gpd which would require a 1000 gpm rate at the pump station. The
current pumping rate of 979 gpm is only capable of pumping 1,410,000 gpd.
Please provide an engineering justification for the determination of the pump
station's capability to adequately handle the peak 20-year design flows. Include
pumping curves for the two existing pumps in the Red Bud pump station. Also
verify the accuracy of the current flows for the City of Henderson and the Ruin
Creek Basin provided in the table from the response to Comment #9 in Appendix
B.
2. The City of Henderson must receive approval from the Raleigh Regional Office
for the off -site storage of a complete spare pump and motor for the Red Bud pump
station for replacement of an existing pump due to failure rather than provide an
installed backup pump at the pump station.

State of North Carolina I VA
Department of Environment,
Health and Natural Resources 4 kTfw•�r
Division of Water Quality 1
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E H N R
A. Preston Howard, Jr., P.E., Director
November 6, 1996
Mr. Eric M. Williams, City Manager
City of Henderson
Post Office Box 1434
Henderson, North Carolina 27536-1434
SUBJECT: Approval/Engineering Amendment
City of Henderson
201 Facilities Plan
Ruin Creek Outfall
Project No. E-SBF-T-95-0024
Dear Mr. Williams:
The Construction Grants and Loans Section has completed its review of the subject
Engineering Amendment and finds it satisfactory. The amendment addresses the construction of
the approximately 15,800 linear foot Ruin Creek Outfall, rehabilitation of the sanitary sewer
system in the Red Bud Basin, and addition of an automatic mechanical bar screen and a standby
power generator at the Red Bud Pump Station. The total estimated cost of this recommended
work is $2,965,400; however, State Bond Loan funding is limited to $2,765,400.
The subject Engineering Amendment to the City of Henderson 201 Facilities Plan is
hereby approved.
If you have any questions concerning this matter, please contact Mr. Jay Lucas of our
staff at [phone].
Sincerely,
R. Blowe, P.E., Chief
RMS/kc
cc: Peirson & Whitman
Raleigh Regional Office
DMU/FEU/CIU/PMB/SBF
Construction Grants & Loans Section 7,w4, FAX [phone]
P.O. Box 29579, Raleigh, North Carolina 27626-0579 N Vf C An Equal Opportunity/Affirmative Action Employer
Voice 919-733-6900 rrg 50% recycles/ 10% post -consumer paper

CONSULTATION MEETING
Burlington Research, Inc.
PROJECT: City of Henderson THE
DATE: September 24, 1996
TIME: 10:00 AM
PLACE: Raleigh NCDWQ Regional Office
AGENDA: THE Status Review with DWQ
ATTENDEES:
Name Company
C� 61iLu�AA.'rk G'rt
Phone
S�6 y�61 Ex%
c)CLma F-oIlem
"DWQ,/
919-933- S-M3xS.Z3
]SW CaA1(0'4
0941q '
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q/1 -S- 7z1- 7?00
KI&W,Q Y-�;3—Zi3(e
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4 a
CITY OF HENDERSON
THE OVERVIEW WITH DWQ
Raleigh Regional Office
September 24, 1996
10:00 AM
A=da
I. COMPLETED AND ON -GOING ACTIVITIES
A. Monthly Toxicity Monitoring, Nutbush WWTP
B. Toxicity Characterization
C. Industrial Activities
II. PENDING ACTIVITIES

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CITY OF HENDERSON
CHRONIC TOXICITY HISTORY
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-E- CURRENT CL CHRONIC VALUE
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NUTBUSH WWTP THE
Completed and Proposed Activities
19%/97
Completed Activties
1/17/96 Nutbush WWTP effluent toxicity persistency evaluation, Trial #4.
1/18/96 EPA Phase I Toxicity Characterization Procedures, Trial #1.
1/23/96 Meeting with DWQ.
2/9/96 Chemical usage review response to industries with request for follow-up
response on or before April 30.
2/28/96 Meeting with Henderson staff and industry representatives.
(Attendees: Ball -Foster, J. P. Taylor, Kennametal, Softspun,
Americal, Isms)
3/8/96 City visit to Kennametal to discuss enhancements of pretreatment.
3/20/96 Pump Station monitoring for toxicity and surfactants, Set #4.
5/3/96 Pump Station monitoring for toxicity and surfactants, Set #5.
5/22/96 Nutbush Sludge Toxicity Assessment, Trial #1.
5/28/96 Kennametal discharge monitoring for toxicity.
6/12/96 Nutbush Sludge Toxicity Assessment, Trial #2.
6/19/96 Chemical usage review response to industries with request for follow-up
response on or before August 1.
7/9-22/96 Industrial discharge monitoring for toxicity and surfactants:
Americal, Ball -Foster, IAMS, J. P. Taylor,
Maria Parham Hospital, Softspun
7/15/96 Discussions begin with EA Engineering Science and Technology to conduct
RTA.
7/25/96 EPA Phase I Toxicity Characterization Procedures, Trial #2.

0 `
8/7/96 BRI industrial site visits: Kennametal, Americal.
8/12/96 EPA Phase II Toxicity Characterization Procedures, Trial #1.
8/13-9/10/96 Chemical usage review response to industries with request for follow-up
response on or before October 18.
8/15-20/96 Americal pre-treatment on-line.
8/26/96 Americal and WWTP monitoring for toxicity (Americal only), O&G,
surfactants.
8/28/96 Letter to Americal, Kennametal, Softspun requesting scheduling of site visit
by Division of Environmental Assistance.
9/5/96 BRI industrial site visits: Softspun, J. P. Taylor.
9/23/96 EPA Phase I and Phase Il Toxicity Characterization Procedures, Trial #3 and
Trial #2, respectively.
9/27/96 THE Progress Report.
c:MWwI *nIfEN

Toxicity Characterization
Nutbush Effluent Toxicity Characterizations
1/17/96 Nutbush WWTP effluent toxicity persistency evaluation, Trial #4
1/18/96 EPA Phase I Toxicity Characterization Procedures, Trial #1
7/25/96 EPA Phase I Toxicity Characterization Procedures, Trial #2
8/12/96 EPA Phase lI Toxicity Characterization Procedures, Trial #1
9/23/96 EPA Phase I (partial) and Phase II Toxicity Characterization Procedures, Trial
#3 and Trial #2, respectively.
Refractory Toxicity Assessment
Point Source Monitoring
3/20/96 Pump Station monitoring for toxicity and surfactants, Set #4
5/3/96 Pump Station monitoring for toxicity and surfactants, Set #5
5/28/96 Kennametal discharge monitoring for toxicity.
(prior to on-line status of new pre -trot.)
7/9-22/96 Industrial discharge monitoring for toxicity and surfactants:
Americal, Ball -Foster, LAMS, J. P. Taylor,
Maria Parham Hospital, Softspun
8/26/96 Americal and WWTP monitoring for toxicity (Americal only), O&G,
surfactants.
Pre-RTA Evaluations
5/22/96 Nutbush Sludge Toxicity Assessment, Trial #1
6/12/96 Nutbush Sludge Toxicity Assessment, Trial #2
7/15/96 Discussions begin with EA Engineering Science and Technology.

Industrial Activities
2/28/96 Meeting with Henderson staff and industry representatives.
(Attendees: Ball -Foster, J. P. Taylor, Kennametal, Softspun,
Americal, Iams)
Chemical Usage Review
2/9/96 Review response with request for follow-up by April 30.
6/19/96 Chemical usage review response to industries with request for follow-up
response on or before August 1.
8/13-9/10/96 Chemical usage review response to industries with request for follow-up
response on or before October 18.
Site Visits
3/8/96 City visit to Kennametal to discuss enhancements of pretreatment.
8/7/96 BRI industrial site visits: Kennametal, Americal
8/28/96 Letter to Americal, Kennametal, Softspun requesting scheduling of site visit
by Division of Environmental Assistance.
- Kennametal scheduled for November
9/5/96 BRI industrial site visits: Softspun, I P. Taylor
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North CdT6lina Division of Environmental Manageme**
Water Quality Section / Rapid Assessment Group
August 19, 1996
To:
tt
Judy G7Keo
From:
Farrell
Through:
(�
Carla SandersonW
Ruth Swanek a5
Subject:
Henderson - Nutbush Creek WWTP NC0020559
Response to t*aft SOC
Vance County
The Instream Assessment Unit has reviewed the Draft SOC, EMC WQ No. 96 - 05 for the City of
Henderson - Nutbush Creek WWTP, NC0020559. The proposed SOC requests the addition of
domestic and industrial wasteflow with the relaxation of limits for lead and MBAS. Our
recommendations are as follows:
Lead (µgn):
MBAS (µgll):
Chronic Toxicity Test:
Weekly Average
monitor
monitor
Full -Range Monitor Only
As this discharge is to a zero s7Q10 flow stream, any limits above those in the existing permit
would allow for instream violations of the standards. Therefore, rather than recommending
specific limits that would violate the allowable instream concentrations for Lead and MBAS, we
would instead recommend monitoring effluent and instream for these pollutants. Instream
monitoring should occur approximately 100' above the discharge and approximately 50' below
the discharge. The facility should treat its wastewater to the best achievable levels for these
pollutants.
We also concur with the toxicity recommendations contained in this Draft SOC.
cc: Dana Folley
Ted Cashion
Central Files

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North C ision of Environmental Manageme
Water d ection / Rapid Assessment Group
August 19, 1996
MEMORANDUM
To:
From:
Through:
Subject:
Judy Garrett
Farrell Keo '("� ��
Carla SandersonLl'J
Ruth Swanek a5
Henderson - Nptbush Creek WWTP NC0020559
Response to l§taft SOC
Vance County
J
The Instream Assessment Unit has reviewed the Draft SOC, EMC WQ No. 96 - 05 for the City of
Henderson - Nutbush Creek WWTP, NC0020559. The proposed SOC requests the addition of
domestic and industrial wasteflow with the relaxation of limits for lead and MBAS. Our
recommendations are as follows:
Lead (µg/1):
MBAS (µg/l):
Chronic Toxicity Test:
Weekly Average
monitor
monitor
Full -Range Monitor Only
As this discharge is to a zero s7Q10 flow stream, any limits above those in the existing permit
would allow for instream violations of the standards. Therefore, rather than recommending
specific limits that would violate the allowable instream concentrations for Lead and MBAS, we
would instead recommend monitoring effluent and instream for these pollutants. Instream
monitoring should occur approximately 100' above the discharge and approximately 50' below
the discharge. The facility should treat its wastewater to the best achievable levels for these
pollutants.
We also concur with the toxicity recommendations contained in this Draft SOC.
cc: Dana Folley
Ted Cashion
Central Files

Wy OF HENDERSON�
Post Office Box 1434
180 Becidord Drive
Henderson, North Carolina 27536-1434
Phone: [phone] FAX [phone]
March 20th, 1996
Ms. Judy Garrett, Supervisor -Water Quality
Division of Environmental Management
State of North Carolina - DEHNR
3800 Barrett Drive, Suite 101
Raleigh, North Carolina 27609
RE: Your Visit with us Today, March 20th and Assistance
The Redbud Pump Station, our Pending SOC, Etc.
Dear Judy:
OFFICE OF
CITY MANAGER
ERIC M. WILLIAMS
DEHNR RALEIGH REGIONAL OFFICE
Just a short note to follow up and say "thanks" for coming over to meet with a number of
the Staff and the Council's Public Utilities Committee today as we talked about the Ruin Creek
Outfall Project, the Redbud Pump Station and related matters. I always appreciate your
assistance and your willingness to represent the Regional Office in such an effective manner.
Also, thank you so much for arranging the earlier letter of February 26th from Mr. Schuster.
As you know, we're moving ahead with the I&I contract proposal from ADS
Environmental Services, Inc. (I would expect the Council to award the contract at their
Regular Meeting this coming Monday night) and I would very much appreciate anything you
could do to keep the progress going on the State's review of our request for an SOC so that we
can have it in its draft form within the next 2-3 weeks. While working on this, we can be sure
that those requirements, the I&I corrective measures, the Ruin Creek Outfall Project and loan
schedule can all be dovetailed together and coordinated so that we manage all these affairs as
efficiently as possible.
Again, thanks for joining with us and, as always, all of here at the City look forward to
continuing our work with you and your colleagues at the Division on these important
endeavors.
With my very best regards, I am
Sincerely,
CITY OF HENDERSON
Eric
Cit a alter
EMW/dew
XC: Mr.
Kenneth Schuster, P.E.
Regional Supervisor
Mr.
Bob Sledge, DEHNR
Mr.
Mike Acquesta, P.E.
Mr.
Tom Spain
Mr.
James Falkner
Mr.
Frank Frazier

a
DIVISION OF WATER QUALITY
RALEIGH REGIONAL OFFICE
�—
WATER QUALITY SECTION
August8, 1996
MEMORANDUM
To:
Ruth Swanek
Dana Folley
Through:
Judy Garrett
From:
Ted Cashion—�
Subject:
Proposed Additional Flows to Henderson WWTP
NPDES Permit No. NC0020559
Proposed SOC EMC WO 96-05
Vance County
Pq)4e
96� o� �a
7—
Attached is a list of additional flow that the City of Henderson has requested to be included in
their proposed SOC. The proposed SOC requires the City to continue THE progress, and relaxes
limits for chronic toxicity, lead, and MBAS. The SOC will require the City to comply with all final
effluent limitations by March 1, 1997.
Please provide any comments you have concerning this matter as soon as possible.
If you have questions or need additional information please advise.

Contractor delays or failure to obtain funding will not be
considered as events beyond the permittees control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay
the penalties, or challenge them by a contested case petition pursuant
to G.S. 150B-23, will be grounds for a collection action, which the
Attorney General is hereby authorized to initiate. The only issue in
such an action will be whether the thirty (30) days has elapsed.
5. In accordance with the provisions of G.S. 143-215.67(b) the
Commission allows the Town to accept the additional waste specified
below to its waste disposal system. The allocation of additional flow
tributary to the Redbud pump station will be allowed upon acceptable
demonstration to the Director of the removal of an amount of inflow
and infiltration which is twice the amount of new flow to be
connected. The approval of additional flow will be in the form of a
letter from the Director to the City.
RPS = Flows tributary to Redbud Pump Station
Domestic Flow
Gallons per Day
a. North Cooper Drive (3 new restaurants,
hotel, credit union)
26,500 RPS
b. Proposed hotel and convention center and
townhomes, golf course, Satterwhite Point Road
36,000
c. W.A. Currin sewer extension (laundry, car wash,
store and potential of approximately 20 houses
23,000 RPS
d. Central Baptist Church, Ruin Creek Road
4500 RPS
e. Area K - Annexation 158 Bypass
2500 RPS
f. Social Services Building, Ruin Creek Road
2500 RPS
(existing septic tank)
g. Bradford Thomas and waters CPA Building (under
1500 RPS
construction - Ruin Creek Road
h. Lowery Street Sewer Extension
5500
i. Crozier Street Sewer Extension
400
j. Frances Avenue Sewer Extension
360 RPS
k. Foxborough Townhomes - Vicksboro Road
22,000
1. Dabney School
6000 RPS
and Vance Granville
24,000 RPS
(Ruin Creek Outfall)
m. Vance County Economic Development Spec. Building 2500
n. Potential Subdivisions 30,000 (may or
may not be tributary to RPS)
Total Domestic Flow 187,260
Non Domestic Flow
a. Iams expansion 60,000
b. Commercial Seaming 30,000
c. Vance Co. Economic Spec. Building 20,000
d. Potential industrial prospect 30,000
Total Non -Domestic Flow 140,000

CITY OF HENDERSON THE REVIEW
DEM, Archdale Building
January 23, 1996
10:00 am
I. STUDY OBJECTIVES
Obiective One: To monitor the variability and persistency of WWTP final
effluent toxicity.
Obiective Two: To maintain records of production and operational activities at
SIU and WWTP facilities that potentially alter the quality of
discharged and treated wastewaters.
Obiective 11 e: To review available data and information pertinent to WWTP
operations which may directly or indirectly affect the quality of
fatal effluent.
Objective Four: To evaluate point -source discharges for potential contribution of
WWTP fatal effluent refractory toxicity.
Obiective Five: To evaluate SIU chemical use and optimize usage so that only
compounds with low toxicity, low biomass inhibition, and high
rates of biodegradability are used.
Obiective Six: To develop a Chemical Inventory Program for the City.
II. FINDINGS TO DATE
A. Characterization of WWTP Final Effluent Toxicity
B. THE Date Log
C. Industrial Chemical Usage Review

III. PENDING ACTIVITIES
• monthly monitoring of WWTP effluent toxicity and chemistries, X Q 01\kv�t yy^ ---
• monthly submittal of THE Date Logs,
• meetings with City and industry representatives,
• completion of the initial phase of industrial chemical optimization,
• application of EPA Phase I toxicity characterization procedures to WWTP effluent,
• refractory toxicity assessment of point source wastestreams, and
• THE Phase I progress report on or before June 15, 1996 and December 15, 1996.
JANUARY - MARCH
Submittal of chemical usage review to industries by January 31, to
include recommendations for optimization that are immediately
evident. Response deadline of April 30 for data/information.
Trial #1 of EPA Toxicity Characterization Procedures.
Meeting with industry and City representatives.
APRIL - MAY
JUNE
Industrial response to BRI's January chemical usage review followed
by a BRI review response by May 31.
THE Progress Report on or before June 15.
AUGUST - OCTOBER
Completion of first phase of industrial chemical optimization.
Trial #2 of EPA Toxicity Characterization Procedures if needed.
Trial #1 of industrial discharge refractory toxicity assessment, if
needed, preceded by 2 sets of industrial discharge toxicity screening.
NOVEMBER - DECEMBER
Chemical usage review update issued by BRI, with response
deadline of January 15, 1997.

CITY OF HENDERSON
CHRONIC TOXICITY HISTORY
100
---------------------------
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1991
1995
f CURRENT CL -)K- CHRONIC VALUE CL = COMPLIANCE LIMIT
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Table 3. Point source toxicity evaluation, City of Henderson. Phase 1 TRE.
ACUTE
CHRONIC
SOURCE
IWO
COLLECTION
TOXICITY
TOXICITY
COO
CTAS
MBAs
(%)
DATE
(48•H LCS0 %)
(PASS/FAIL)
(m9/L)
(m9/L)
(mg/L)
AMERICAL
0.3
11/15.10194
17.8
FAIL
-
-
12A7-7104
17.8
FAIL
-
-
1/10.11A95
3.4
FAIL
1000
49.0
0.93
BALLANCON
1.0
11/8-9194
> 4.0
PASS
12/14-15At4
> 4.0
PASS
1/24.25196
> 4.0
PASS
S03
2.12
0.14
BURKART
0.04
11/79-30194
> 0.10
PASS
-
-
12/1&15/94
> 0.10
PASS
-
-
1/10.11tes
> 0.18
PASS
38M
10
0.92
"a
3.3
11/1516/94
> 13.2
PASS
-
-
-
12/0-7/94
> 13.2
PASS
1/10.11/95
> 13.2
PASS
199
0.28
0.13
J. P. TAYLOR
1.0
1118.9A94
> 4.0
PASS
-
.
- -
1218.1/94
> 4.0
PASS
-
1/24.25/95
1.3
FAIL
821
2.92
0.35
KENNAMETAL
0.3
11/29.30/94
> 1.2
FAIL
-
-
12/14.15A94
> 1.2
FAIL
-
-
-
1/2a25/95
> 1.2
FAIL
55.7
Z39
Las
MARA PARHAM
1.1
12t7.8194
> 4.4
PASS
-
-
HOSPITAL
12/14/5/94
> 4.4
PASS
1117-18/95
> 4A
PASS
383
9.39
2.46
SOFTSPUN
0.8
120-a/94
2.3
FAIL
-
12/14.15/94
> 3.2
PASS
-
-
-
1/17.18/95
> 3.2
FAIL
942
49.1
0.28
WINSTEAD
0.009
11/1.2194
> 0.030
PASS
-
IZAI.7A94
> 0.0038
PASS
1/17-18/95
> 0.036
PASS
1870
1.05
1.80
2/14.15/95
> 0.036
PASS
-
-
-
REOSUO
40
4/2s25/95
32.0
FAIL
500
2.77
12.5
PUMP STATION
5/8.9/95
28.3
PASS
776
2.09
5.15
5122-23/95
14.9
FAIL
428
2.96
9.71
SANDY CREEK
to
4/24.25/95
56.5
FAIL
531
3.18
8.9
PUMP STATION
5/8-9/95
28.3
FAIL
404
3.59
8.67
5122-23/95
28.3
FAIL
A94
4.08
0.55
M1 � M:'NIRNIf,RWlYCU1O1
UW4 w � �C'/Y114'/I41w1104w114M
11

CITY OF HENDERSON
Post Office Box 1434
180 Beckford Drive
Henderson, North Carolina 27536-1434
Phone: [phone] FAX: [phone]
April 18, 1996
Mr. Ken Schuster, Raleigh Regional Supervisor
NC DEHNR DEM
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
RE: City of Henderson Nutbush Creek WWTP
NPDES #NC0020559
Laboratory Certification #242
Irregularities in Certain Lab Data
Dear Mr. Schuster,
NLMM CRQ7( WASTEWA13
TREATMW RANT
The previous Chemist and Laboratory Supervisor at the Nutbush Creek
WWTP, Mr. Wayne Mitchell, admitted to me on October 18, 1995 that
he had falsified four TKN results for the plant influent , aeration
tank influent, Harris Street Pump Station, and Julia Avenue Pump
Station on August 3, 1995.
Mr. Mitchell admitted that he held samples too long and could not
run them so he made up the results.
I immediately notified Ms. Judy Garrett about our problem and
obtained all laboratory records from September, 1994 to September,
1995 and secured them in a locked file.
This was the period of time that Mr. Mitchell served in the
capicity of Laboratory Supervisor and Chemist.
Mr. Mitchell was demoted to Assistant Chemist and Ms. Xiaolin Chen
has been appointed the new Chemist for our laboratory.
I appointed a committee consisting of Ms. Xiaolin Chen and Ms.
Karen West, my secretary to review all in-house lab data sheets,
contract data and the data entries on the monthly reports from
September, 1994 through September, 1995.
They spent approximately 40 hours each in the review process.

I spent approximately 60 hours interviewing the lab staff,
consulting with City Administration and review of the laboratory
data and investigation findings which I have sumerized below:
1. A total of 124 errors were discovered during the
investigation.
2. Forty three (43) of the errors were from reporting data in the
wrong units (mg/1 instead of ug/1).
3. Nineteen (19) of the errors were reporting the total residue
in the total suspended residue column and failing to record
the total suspended residue for the plant influent.
4. Thirty two (32) of the errors were the result of items such as
leaving a < sign, reading an "8" as a "9", leaving off a 110"
when converting from mg/1 to ug/l, ect..
5. The remaining thirty (30) errors are more diffcult to explain.
Some of them were the result of using one result for a BOD
when we normally use the average for all tests that were in
the proper range. Four (4) of the errors were falsification
of TKN results on August 3, 1995. One was on a monthly
report influent, one was for process control and two of them
were domestic monitoring. Neither the investigating committee
nor I found any further results or reports that appeared to be
falisfied with the exception of six (6) COD results:
Harris Street Pump Station and Julia Avenue Pump Station on
February 3, 1995, the plant influent and the aeration tank
influent on February 14, 1995 and the Iams Company and Ball -
Foster on March 8, 1995. Mr. Mitchell claims to have
performed these COD tests, but the dates and times of analyses
were not recorded.
Mr. Mitchell was new to the position of Chemist in September, 1994
and was dealing with data from four contract labs and the plant
lab.
I think this combined with the stress of expanding the work in the
plant lab led to Mr. Mitchell making excessive errors as ninety
(90) of the errors occurred in his first five months as Chemist.
I am forwarding amended copies of all monthly reports that
contained errors.
I realize that 124 errors (121 on the monthly reports) are a lot
over a thirteen month period, but I would like to note that 11,000
to 12,000 entries were made on these reports not including the
minimum, maximum and average. None of the errors discovered and
corrected affected compliance with our NPDES permit limits.

I feel that our present data management system is much improved.
Direct enteries into the computer for monthly report data and
review of the reports by the Chemist and and an Assistant prior to
my review should ensure that we keep errors to a minimum.
Thank you.
Sincerely,
'-I)Latr+w ✓n .Spam-)
Thomas M. Spain,
WWTP Director
cc: Eric Williams, City Manager
Hartwell Wright, Human Resources Director
Central Files
Files
File: DEM/Laberror

NUTBUSH CREEK WWTP LABORATORY
Errors on NPDES from September- 7444 thrn„rnh cente l ,one
Date
Parameter
Original
Correction
Locatioft
9/29/94
Res. Cl.
80 mg/1
90 mg/1
Eff.
9/20/94
Mercury
2 mg/l
<0.2 mg/l
Inf.
10/3/94 to
Res. Cl.
failed to
changed to
Eff.
10/31/94
convert
ug/1
mg/1 to
ug/1
10/7/94
Res. Cl.
<0.02 mg/1
30.0 ug/l
Eff.
10/7/94
Total
<1.0 mg/l
1.4 mg/l
Eff.
Suspended
Residue
10/14/94
Res. Cl.
0.02 mg/1
60.0 ug/1
Eff.
10/25/94
Res. Cl.
0.02 mg/1
30.0 ug/l
Eff.
10/26/94
Res. Cl.
0.02 mg/l
30.0 ug/l
Eff.
Total
1.4 mg/l
1.6 mg/1
Eff.
Suspended
Residue
Total
2.0 mg/l
2.1 mg/1
Eff.
Suspended
L10/4/94
Residue
Setteable
8.0 mg/1
Matter
Nitrite-
<0.10 mg/1
Em/1Inf.
Inf.
Nitrate
Nitrite-
0.13 mg/1
0.14 mg/l
Inf.
Nitrate
ll/l/94 to
Res. Cl.
to
changed to
Eff.
11/30/94
onvert
ug/l
[Failed
rom mg/lo
ug/111/3/94
Res. Cl.
0.02 mg/1
20.0 ug/1
Eff.
11/8/94
Res. Cl.
0.02 mg/1
30.0 ug/1
Eff.
11/9/94
Zinc
31.0 ug/l
310 ug/1
Eff.
11/22/94
Res. Cl.
0.02 mg/1
30.0 ug/1
Eff.
11/29/94
BOD_
232 mg/1
240 mg/1
Inf.

12/2/94
Res. Cl.
<20 ug/l
20 ug/1
Eff.
Date
Parameter
Original
Correction
Location
12/7/94
Nitrite-
16.8 mg/1
16.9 mg/1
Eff.
Nitrate
12/8/94
Res. Cl.
20 ug/1
30 ug/1
Eff.
12/21/94
BOD
3.0 mg/l
3.2 mg/1
Eff.
12/13/94
Chromium
5.0 ug/l
<5.0 ug/1
Inf.
12/6/94
Selenium
Failed to
<7.0 ug/1
Inf.
convert
from mg/l
to ug/l
<0.007 ug/l
12/13/95
Selenium
Failed to
<7.0 ug/1
Inf.
convert
from mg/1
to ug/1
<0.007 ug/l
Cl.
20 ug/l
30 ug/1
Eff.
Ammonia-
1.0 mg/l
<1.0 mg/1
Eff.
Nitrogen
V121494Res.
Total
2.0 mg/l
<1.0 mg/1
Eff.
Suspended
Residue
Fecal
<4/100ml
4/100ml
Eff.
Coliform
1/25/95
Res. Cl.
70 ug/1
65 ug/l
Eff.
1/26/95
Res. Cl.
60 ug/1
50 ug/l
Eff.
1/11/95
ph
7.4
7.0
Inf.
1/3/95
Total
652 mg/1
350 mg/1
Inf.
Suspended
Residue
1/4/95
Total
not
240 mg/1
Inf.
Suspended
recorded
Residue
1/5/95
Total
not
295 mg/l
Inf.
Suspended
recorded
Residue

1/6/95
Total
not
235 mg/1
Inf.
Suspended
recorded
Residue
Date
Parameters
Original
Correction
Location
1/9/95
Total
not
344 mg/1
Inf.
Suspended
recorded
Residue
1/10/95
Total
720 mg/l
92 mg/l
Inf.
Suspended
Residue
1/11/95
Total
not
150 mg/1
Inf.
Suspended
recorded
Residue
1/12/95
Total
not
190 mg/1
Inf.
Suspended
recorded
Residue
1/13/95
Total
not
200 mg/l
Inf.
Suspended
recorded
Residue
1/17/95
Total
not
85.5 mg/l
Inf.
Suspended
recorded
Residue
1/18/95
Total
not
154 mg/1
Inf.
Suspended
recorded
Residue
1/19/95
Total
not
163 mg/l
Inf.
Suspended
recorded
Residue
1/20/95
Total
not
385 mg/l
Inf.
Suspended
recorded
Residue
1/23/95
Total
not
131 mg/l
Inf.
Suspended
recorded
Residue
1/24/95
Total
not
145 mg/l
Inf.
Suspended
recorded
Residue
1/25/95
Total
not
144 mg/1
Inf.
Suspended
recorded
Residue

1/26/95
Total
Suspended
Residue
not
recorded
132 mg/l
Inf.
Date
Parameters
Original
Correction
Location
1/27/95
Total
Suspended
Residue
not
recorded
129 mg/1
Inf.
1/30/95
Total
Suspended
Residue
not
recorded
157 mg/l
Inf.
FI/331/95
Total
Suspended
Residue
not
recorded
90 mg/l
Inf.
5
COD
not
recorded
201 mg/1
Inf.
1/24/95
COD
not
recorded
239 mg/1
Inf.
1/5/95
Fecal
87/100 ml
86/100 ml
Upstream
2/23/95
Total
Suspended
Residue
155 mg/l
156 mg/1
Inf.
2/14/95
Cyanide
6.0 mg/l
0.006 mg/l
Inf.
2/2/95
Fecal
33/100 ml
133/100ml
NB-8
3/13/95
Temp.
11 Degree C
9 Degree C
Eff.
3/22/95
Fecal
<4/100 ml
11/100 ml
Eff.
3/21/95
Cadmium
<1.0 ug/1
1.0 ug/1
Eff.
3/20/95
MBAS
269 ug/1
2690 ug/1
Inf.
3/20/95
Arsenic
5.0 ug/l
<5.0 ug/l
Inf.
3/2/95
Fecal
167/100 ml
<4/100 ml
NB-8
3/23/95
Fecal
260/100 ml
<4/100 ml
NB-8
4/3/95
Alkalinity
139 mg/l
135 mg/l
Eff.
4/17/95
MBAS
397 ug/1
3970 ug/l
Inf.
4/25/95
MBAS
475 ug/1
4750 ug/l
Inf.
5/31/95
Res. Cl.
10.0 ug/1
<10.0 ug/1
Eff.

Date
Parameters
Original
Correction
Location
7/14/95
Total
222 mg/l
223 mg/l
Inf.
Suspended
Residue
8/30/95
SOD
2.5 mg/l
2.2 mg/l
Eff.
8/30/95
Total
03 mg/l
<1.0 mg/1
Eff.
Suspended
Residue
8/16/95
MBAS
<10 ug/1
<100 ug/l
Eff.
8/16/95
Cyanide
not
<0.005 mg/l
Eff.
recorded
8/3/95
BOD
184 mg/l
208 mg/l
Inf.
8/31/95
BOD
240 mg/l
220 mg/l
Inf.
8/2/95
TKN
19.9 mg/l
Falsified
Inf.
no test
performed
9/27/95
Lead
4.0 ug/l
<3.0 ug/1
Eff.
Total of errors 121 + 3 non NPDES = 124

�f�f�-[rcl�Trf�j9ZToN__
j SAMPLE LOCATION i <'DATE
BLANK ID 6
STD.( /o
wl
CALIBRATION:
TOTAL KJELDAHL
NITROGEN
(TKI) ANALYSES
iFLASK! VOL. ! MV1 I
MV2 (G MV
NO.
! ml I
1 1
i 30.o IGrs?, 4 i
yG, l l a� S
I 2
I 30.o ' 22, 9: !
I 3
I 30.0 ! 17, 3 1
Iztf 3
116,
3 1 31 O
_.STD.I STD ! TKN REPOR
ml i mg/1 mg/I I TKN m,
.5.0 1 10.0
5.0 1 10.0
avpzz�r, ! 55..00 I I 7
,�4 ! ,
O ! !
5.0 zf
30.0 i aD� p i
5.0
30.0 `f t 16,C¢ i (/, i 5.0 1,20 1 G• ! /4,
30.05.0 I D5.0
30.0 i 1
! ! 12 I 30.0 i i i i 5.0
100STD=FiJTy "�',v—%Rv<Gi3�uc—/S,ZY f�PG ✓G,—!7,[a
10STD _af�0 SLOFE _ S(�,O 1rJu�N — iS,zz zvlffA`a,— /,5�7
CALIB _)ION: I 100 STD
,OSTD
c.w m
SLOPE
i

e
_ ---._...__ -.__.- _ . COD WORTCSF.rrm
ANALYSIS BY: ANTONI, VICB,MITC%irLL
DATE TTMr 0- INITIALS XG
?4-
,.

COD WORXSlzrrm
ANALYSIS 3Y: ANTONI, VICR MI^'C4'LL
DATE 3-3-95 TIME 1430 Pni INITIALS xG
W? z84c)> T-4c fjj,.e 1j,9 fp,,,
..
P(,

t �
COD WOFLKSFEET
ANALYSIS BY: m7ONI VIC:C,MITCF.ELL
DATE 3-IJ -�1J TIME 140_ ) n= INITIALS X�
wr izfl- K<- w ,4 pP'~
�q
T.