NC0028746_1993 draft_19930820

State of North Carolina I�
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary ® NF1
A. Preston Howard, Jr., P.E., Director
August 20, 1993
Mr. Leonard E. Stogner, Jr.
Vice President
Rayco Utilities, Inc.
4200 Highway 29
Harrisburg, NC 28075
Subject: NPDES Permit No. NCO028746
Briarwood Subdivision WWTP
Stokes County
Dear Mr. Stogner:
The Division has considered your concerns regarding chronic toxicity limits outlined
in the August 6, 1993 facsimile from Mr. Thurman Horne. In response to these concerns
and your suggested six month window for completion of a low -flow study, the Division
proposes the following modifications to the subject permit:
a) For a period beginning upon the effective date of the permit up until September 1,
1994, Rayco Utilities will be required to monitor for ammonia in the effluent at
Briarwood Subdivision and will also be required to provide semi-annual chronic
toxicity monitoring as outlined in the draft permit. On September 1, 1994, the
chronic toxicity and ammonia monitoring requirements of the permit will be replaced
by monthly average ammonia limits of 1.0 mg/l and 5.9 mg/l for the Summer and
Winter months respectively.
b) The permit will contain a condition (see Part III, condition F) which states that
upon submittal of flow data, the Division will reopen the permit and reevaluate the
toxicity and ammonia requirements of the permit. As a reminder, for accepted
procedures in evaluating low flows, please refer to the document entitled Procedures
for Projecting Low Flow Statistics at an Unga ed Site enclosed in the July 12, 1993
letter from the Division. As you will note in the procedures document, it is
imperative that you coordinate closely with the Division and the USGS such that the
data collected can be quality assured for use in estimating low flow statistics.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Stogner
August 20, 1993
Page Two
Attached is a draft of the revised permit. If any terms or conditions proposed by
this modification are unacceptable to you, you should notify us within fifteen (15) days
following receipt of this letter. If this permit modification is acceptable, Rayco Utilities, Inc.
must complete the attached Notice of Withdrawal of Petition form within thirty days of
receipt of this modification and submit one copy to the Attorney General's Office as specified
on the withdrawal form and one copy to this division. The original Notice of Withdrawal
form should be submitted to the Office of Administrative Hearings.
Please examine the enclosed draft permit and ensure that the changes are acceptable
to you. When you have withdrawn your request for Contested Case Hearing, the modified
permit will be issued. If the proposed modifications are not acceptable to you, please notify
us within thirty (30) days and we will proceed with the adjudicatory process.
If you have any questions or comments regarding the "Procedures" document,
please contact Ruth Swanek of our Technical Support Branch at [phone]. General
questions regarding the Petition for Contested Case Hearing, or requests for additional
information should be directed to Sean D. Goris of our Permits and Engineering Unit at the
same number.
in i
E
cc:
Winston-Salem Regional Office
Elizabeth Rouse Mosely, Office of the Attorney General
Ruth Swanek, Technical Support Branch
Thurman Horne, P.E.
Permits and Engineering Unit
Central Files

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
.PE-
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Rayco Utilities, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Briarwood Subdivision
on NC Highway 66
southeast of Mount Olive
Stokes County
to receiving waters designated as an unnamed tributary to Brushy Fork Creek in the Roanoke'River
Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on January 31, 1997
Signed this day
v-` ,R� �z
�4
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

Rayco Utilities, Incorporated
is hereby authorized to:
Permit No. NC0028746
1. Continue to operate an existing 0.050 MGD activated sludge package -type wastewater treatment
facility consisting of an influent sedimentation chamber, aeration basin, clarification basin, tablet
chlorination and contact chambers located at Briarwood Subdivision, on NC Highway 66,
southeast of Mount Olive, Stokes County (See Part III of this Permit), and
2. Discharge from said treatment works at the location specified on the attached map into an
unnamed tributary to Brushy Fork Creek which is classified Class C waters in the Roanoke
River Basin.

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1. The permittee shall comply with Final Effluent Limitations specified for discharges in
accordance with the following schedule:
Permittee shall comply with Final Effluent Limitations by the effective date of the permit unless
specified below.
2. Permittee shall at all times provide the operation and maintenance necessary to operate the
existing facilities at optimum efficiency.
3. No later than 14 calendar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates, a written notice of compliance or noncompliance. In the latter
case, the notice shall include the cause of noncompliance, any remedial actions taken, and the
probability of meeting the next schedule requirements.

Part II
Page 1 of 14
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
" 16 0 RIVV •
The Director of the Division of Environmental Management
Means the Division of Environmental Management, Department of Environment, Health and
Natural Resources.
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33
USC 1251, et. seq.
5. Mass/Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges
sampled and/or measured during a calendar month on which daily discharges are sampled
and measured, divided by the number of daily discharges sampled and/or measured during
such month. It is therefore, an arithmetic mean found by adding the weights of the
pollutant found each day of the month and then dividing this sum by the number of days
the tests were reported. The limitation is identified as "Monthly Average" in Part I of the
permit.
b . The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday - Saturday) on which daily discharges
are sampled and measured, divided by the number of daily discharges sampled and/or
measured during such week. It is, therefore, an arithmetic mean found by adding the
weights of pollutants found each day of the week and then dividing this sum by the
number of days the tests were reported. This limitation is identified as "Weekly Average"
in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during
a calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "maximum daily discharge." This limitation is identified as "Daily
Maximum," in Part I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
.measured, divided by the number of daily discharges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found
each day of the year and then dividing this sum by the number of days the tests were
reported. This limitation is defined as "Annual Average" in Part I of the permit.

Part II
Page 3 of 14
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow,
averaged monthly. It is determined as the arithmetic mean of the total daily flows recorded
during the calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling,
when both the sample and flow will be representative of the total discharge.
C. A "continuous flow measurement" is a measure of discharge flow from the facility which
occurs continually without interruption throughout the operating hours of the facility. Flow
shall be monitored continually except for the infrequent tunes when there may be no flow
or for infrequent maintenance activities on the flow device.
raw
.1 . -I •
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of
discharge and combined proportional to the rate of flow measured at the time of
individual sample collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the
sampling point. Flow measurement between sample intervals shall be determined by
use of a flow recorder and totalizer, and the present gallon interval between sample
collection fixed at no greater than 1/24 of the expected total daily flow at the treatment
system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of
flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having'a detention time
of greater than 24 hours. In such cases, effluent grab samples may be collected at time
intervals evenly spaced over the 24 hour period which are equal in number of hours to the
detention time of the system in number of days. However, in no case may the time interval
between effluent grab samples be greater than six (6) hours nor the number of samples less
than four (4) during a 24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. Calculation of Means
Arithmetic Mean: The arithmetic mean of any set of values is the summation of the
individual values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of
the individual values where N is equal to the number of individual values. The geometric
mean is equivalent to the antilog of the arithmetic mean of the logarithms of the individual
values. For purposes of calculating the geometric mean, values of zero (0) shall be
considered to be one (1).

1
Page
g , ,:
Penalties for Class H violations are not to exceed $10,000 per day for each day during
which the violation continues, with the maximum amount of any Class H penalty not to
exceed $125,000.
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use
or disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
Except as provided in permit conditions on "Bypassing" (Part II, C-4) and "Power Failures"
(Part II, C-7), nothing in this permit shall be construed to relieve the permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-
215.6 or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the permittee is
responsible for consequential damages, such as fish kills, even though the responsibility for
effective compliance may be temporarily suspended.
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
••-, I'm. I
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of Federal, State or local laws or regulations.
• •-• • •- • �s. ,
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this permit, shall not be affected
thereby.
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists
for modifying, revoking and reissuing, or terminating this permit or to determine compliance
with this permit. The permittee shall also furnish to the Permit Issuing Authority upon
request, copies of records required to be kept by this permit.

Part H
.,
ge 7 of 14
c. Certification. Any person signing a document under paragraphs a. or b. of this section
shall make the following certification:
"I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility -of fines and imprisonment for
knowing violations."
• X111y� • ,
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a
request by the permittee for a permit modification, revocation and reissuance, or termination,
or a notification of planned changes or anticipated noncompliance does not stay any permit
condition.
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed
by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts
122 and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and
North Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. [The
exclusive authority to operate this facility arises under this permit. The authority to operate the
facility under previously issued permits bearing this number is no longer effective. ] The
conditions, requirements, terms, and provisions of this permit authorizing discharge under the
National Pollutant Discharge Elimination System govern discharges from this facility.
MOMIS)NOW919 ' • 10 MIMI guy VIAIWINQ• i6M • • ' •
- a -6147 •
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities.
Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified back-up operator of the appropriate type and any
grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility
must visit each Class I facility at least weekly and each Class II, III, and IV facility at least
daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other. conditions of Title
15A, Chapter 8A .0202. Once the facility is classified, the permittee shall submit a letter to the
Certification Commission which designates the operator in responsible charge within thirty
days after the wastewater treatment facilities are 50% complete.

periods of equipment downtime. This condition is not satisfied if adequate backup
equipment should have been installed in the exercise of reasonable engineering
judgment to prevent a bypass which occurred during normal periods of equipment
downtime or preventive maintenance; and
(C) The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.
5. UpSets
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent .limitations because of factors
beyond the reasonable control of the permittee. An upset does not include noncompliance
to the extent caused by operational error, improperly designed treatment facilities,
inadequate treatment facilities, lack of preventive maintenance,, or careless or improper
operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with
such technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the causes) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part H, E. 6. (b) (B) of this
permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this
permit.
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset
has the burden of proof.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in
a manner such as to prevent any pollutant from such materials from entering waters of the State
or navigable waters of the United States. The permittee shall comply with all existing federal

discharge volumes. Once -through condenser cooling water flow which is monitored by pump
logs, or pump hour meters as specified in Part I of this permit and based on the manufacturer's
pump curves shall not be subject to this requirement.
= 26T.T.6 M
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to
regulations published pursuant to Section 304(g), 33 USC 1314, of the Federal Water
Pollution Control Act, as Amended, and Regulation 40 CFR 136; or in the case of sludge use or
disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and
all data generated must be reported down to the mirnmum detection or lower reporting level of
the procedure. If no approved methods are determined capable of achieving minimum
detection and reporting levels below permit discharge requirements, then the most sensitive
(method with the lowest possible detection and reporting level) approved method must be used.
• " l i .1#% V_1
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or
by imprisonment for not more than two years per violation, or by both. If a conviction of a
person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not
more than 4 years, or both.
•- 13RUMMOR
Except for records of monitoring information required by this permit related to the permittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permittee shall retain records of all
monitoring information, including all calibration and maintenance records and. all original strip
chart recordings for continuous monitoring instrumentation, copies of all reports required by
this permit, for a period of at least 3 years from the date of the sample, measurement, report
or application. This period may be extended by request of the Director at any time.
RM -674_I. ;
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The date, exact place, and time of sampling or measurements;
b . The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.

Part II
Page 13 of 14
This permit is not transferable to any person except after notice to the Director. The Director
may require modification or revocation and reissuance of the permittee and incorporate such
other requirements as may be necessary under the Clean Water Act.
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.
D. 2 of this permit) or forms provided by the Director for reporting results of monitoring of
sludge use or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using
test procedures specified in Part II, D. 4. of this permit or in the case of sludge use or
disposal, approved under 40 CFR 503, or as specified in this permit, the results of this
monitoring shall be included in the calculation and reporting of the data submitted in the
DMR
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, including
exact dates and times, and if the noncompliance has no been corrected, the anticipated time
it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours
under this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case-by-case basis for reports under
paragraph b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6.
of this permit at the time monitoring reports are submitted. The reports shall contain the
information listed in Part II. E. 6. of this permit.

PART III
OTHER REQUIREMENTS
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until
Final Plans and Specifications have been submitted to .the Division of Environmental
Management and written approval and Authorization to Construct has been issued.
W. W C • M, 1W. - a Me%• -
The permittee shall, upon written notice from the Director of the Division of Environmental
Management, conduct groundwater monitoring as may be required to determine the
compliance of this NPDES permitted facility with the current groundwater standards.
C. Changes in Discharges of Toxic Substance
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to
believe:
a.That any activity has occurred or will occur which would result in the discharge, on a
routine or frequent basis, of any toxic pollutant which is not limited in the permit, if that
discharge will exceed the highest of the following "notification levels",
(1) One hundred micrograms per liter (100 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five
hundred micrograms per liter (500 ug/1) for 2.4-dinitrophenol and for 2-methyl-4.6-
dinitrophenol; and one milligram per liter (1 mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the
permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a
non -routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if
that discharge will exceed the highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 ug/1);
(2) One milligram per liter 0 mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the
permit application.
D. Requirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the
most environmentally sound alternative of the reasonably cost effective alternatives. If the
facility is in substantial non-compliance with the terms and conditions of the NPDES permit
or governing rules, regulations or laws, the permittee shall submit a report in such form and
detail as required by the Division evaluating these alternatives and a plan of action within
sixty (60) days of notification by the Division.

Permit No. NCO028746
E. CHRONIC TOXICITY MONITORING (SEMI -ANNUAL -SEPT. 1993, MARCH 1994)
The permittee shall conduct chronic toxicity tests using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration defined as treatment two in the North Carolina procedure document is
90%. The permit holder shall perform semi-annual monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed within thirty days from the
effective date of this permit during the months of September and March. 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 permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT -1 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 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, this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
F. Low Flow Study Reopener
The permittee has the option of submitting to the Division a low flow study which provides an
estimate of the 7Q10 flow of the tributary to Bushy Creek. Upon receiving -this study, the Division
will reopen this permit and reevaluate the toxicity and ammonia requirements of it. To assure
quality, the methods used in the study must be approved by the Division and the permittee will
coordinate closely with the Division and the United States Geological Survey in gathering data.

NC License .RC1378
RAYCO UTILITIES, INC.
4200 Highway 29
Harrisburg, NC 28075
[phone]
August 17, 1993
Ms. Delores O. Nesnow
Administrative Law Judge
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, NC 27611-7447
Subject: Rayco Utilities, Inc.
Briarwood Subdivision
Stokes County
93 EHR 0143
Dear Ms. Nesnow:
SC License 5341
19 1993
BRA
Pursuant to your Order dated June 16, 1993, this is to
advise you of the status of progress regarding the subject
facility.
Rayco has been in communication with NCDEM and believe that
a mutually satisfactory resolution is close. Rayco has
contracted engineering services to evaluate the low flow
conditions in the receiving stream. At the conclusion of
this study,. NCDEM will reevaluate the limitations in the
permit and adjust accordingly.
NCDEM has indicated that they will issue a draft permit
within seven ( 7 ) to fifteen (15 ) days. The draft permit is
to contain interim limitations, a schedule for conducting
the stream flow assessment and a commitment to reevaluate
the effluent limits.
I believe significant progress is being made and that it
would be in everyone's best interest to delay further action
for fifteen (15 ) days to allow time for NCDEM to issue the
draft permit. If the draft permit contains acceptable terms
and conditions, we may be able to resolve this matter
without hearings or other formal legal proceedings.

Ms. Delores O. Nesnow
Page 2
August 17, 1993
I ask that you withhold further action for (15) days to see
if we can reach an acceptable compromise that will allow us
to withdraw our petition for hearing.
I will be in communication with you to advise you of how
this develops. If you have any questions or need to discuss
this with me, please call me at [phone].
Si rely,
Leonard E. Sto er, r.
Vice President
LES/kb
'cc: Mr. J. Thurmon Horne, P.E.
Mr. Don Safrit, NCDEM

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Leonard E. Stogner, Jr.
Vice President
Rayco Utilities, Inc.
4200 Highway 29
Harrisburg, NC 28075
Dear Mr. Stogner:
July 12, 1993
Subject: NPDES Permit No. NCO028746
Briarwood Subdivision WWTP
Stokes County
In accordance with your Petition for Contested Case Hearing filed on January 27, 1993,
the Division proposes the following course of action. Your petition addresses a proposed
change in the NPDES permit limits for ammonia in the subject permit. Your petition also
indicates a concern with the US Geological Survey (USGS) estimate of the 7Q10 flow for
the tributary to Bushy Creek. Based on Title 15A NCAC 2B .0206, the Division used the
best available information from the USGS to arrive at the estimate of zero flow. However,
the division does allow for permittees to collect site flow data in an attempt to validate or
provide revision of flow. In regard to this allowance and your concerns, the Division is
willing to make the following modifications to the subject permit:
a) The monthly average ammonia limits of 1.0 mg/l and 5.9 mg/1 for Summer and
Winter, respectively, will be removed from the permit. As a condition of the
permit, Rayco Utilities, Inc. will still be required to monitor for ammonia. In place
of the ammonia limits, Rayco Utilities, Inc. will be required to provide chronic
toxicity testing of the effluent as outlined in the draft permit.
b) The permit will contain a condition which states that upon submittal of flow
data, the Division will reopen the permit and reevaluate the toxicity testing and
ammonia requirements of the permit. For accepted procedures in evaluating low
flows please refer to the enclosed document entitled, Procedures for Proiectin
Low Flow Statistics At An Unaged Site. As you will note in the procedures
document, it is imperative that you coordinate closely with the Division and USGS
such that the data collected can be quality assured for use in estimating low flow
statistics.
P.O. Box 29535, Raleigh, North Carolina 2.7626-0535 Telephone [phone],015 FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. S togner
T my 12, 1993
Page Two
Attached is a draft of the revised permit. If any terms or conditions proposed by
this modification are unacceptable to you, you should notify us within thirty (30) days
following receipt of this letter. If this permit modification is acceptable, Rayco Utilities, Inc.
must complete the attached Notice of Withdrawal of Petition form within thirty days of
receipt of this modification and submit one copy to the Attorney General's Office as specified
on the withdrawal form and one copy to this division. The original Notice of Withdrawal
form should be submitted to the Office of Administrative Hearings.
Please examine the enclosed draft permit and ensure that the changes are acceptable
to you. When you have withdrawn your request for Contested Case Hearing, the modified
permit will be issued. If the proposed modifications are not acceptable to you, please notify
us within thirty (30) days and we will proceed with the adjudicatory process.
If you have any questions or comments regarding the enclosed "Procedures"
document, please contact Ruth Swanek of our Technical Support Branch at [phone].
General questions regarding the Petition for Contested Case Hearing should be directed to
Sean D. Goris of our Permits and Engineeriniit at the same number.
cc:
Winston-Salem Regional Offic
Elizabeth Rouse Mosely, Office of the Attorney General
Carla Sanderson, Technical Support Branch
Ruth Swanek, Technical Support Branch
Permits and Engineering Unit
Central Files

MEMO TO FILE: NC0028746 Rayco Utilities - Briarwood
DATE: 6/25/93
FROM: Sean D. Goris
After consulting with both Carla Sanderson of the modeling group and Abner Brady of the
Winston-Salem Regional office it was decided that no lenience would be afforded to the
permittee. The reasoning for this was based on the fact that all decisions on low flow
streams made by the Division relies on data from the USGS. Therefore, in the Division's
opinion, the unnamed tributary to Bushy Creek is a zero flow stream until proved
otherwise and the permittee will be required to meet zero flow standards in accordance with
NCAC T15A: 02B .0206. Because the discharge was subject to zero flow regulations, the
permittee was given the standard option in such situations of choosing between an
ammonia limit of toxicity testing. The only response form the permittee concerning this
choice was a statement in which the permittee said he had neither the money or the
inclination to implement either permit condition (see WLA). Given this non -decision, the
Division chose to apply ammonia limits to the permit based on the recommendation of the
region. The permittee has adjudicated the permit on the grounds of the ammonia limit and
the 7Q10 of the stream. Because the stream is considered a zero flow stream, the permittee
has no choice but to either meet an ammonia limit or provide toxicity testing if he wishes to
continue to discharge. Since he has contested the ammonia limit, the division will place a
toxicity test requirement into the permit and drop the ammonia limit so that the permit is in
accordance with current DEM zero flow policy. The permittee has the option to show the
Division that the stream is in fact not a zero flow stream. If this option is exercised, the
Division is willing to reopen the permit and reevaluate the ammonia and toxicity
requirements. But until this option is exercised, the permittee will be subject to current
DEM zero flow requirements. The burden of proof in showing that the stream is not zero
flow rest solely in the hands of the permittee.

North Carolina Division of Environmental Management
Water Quality Section / Rapid Assessment Group
5 March, 1993
MEMORANDUM
To: Don Safrit, P.E., Supervisor
From: Farrell Keough, Environmental Modeler I
Through: Carla Sanderson, Environmental Supervisor
Subject: Briarwood Subdivision WWTP -4
NPDES Permit No. NC0028746
Stokes County
Per your request to send a single, consolidated letter to Mr. Stogner
regarding the issues surrounding his adjudication of the draft permit, enclosed is a
copy of Procedures For Projecting. Low Flow Statistics At An Ungaged_ Site. A copy of
vn �, AAthe originals etter, w/ comments, is also attached so the final draft will include any
pertinent TSB information.
Should you have any questions, please contact myself or Carla Sanderson.
cc: Attachment
Trevor Clements

North Carolina Division of Environmental Management
Water Quality Section / Rapid Assessment Group
24 February, 1993
MEMORANDUM
To: Don Safrit, P.E., Supervisor
From: Farrell Keough, Environmental Modeler I
Through: Carla Sanderson, Environmental Supervisor
Subject: Briarwood Subdivision WWTP
NPDES Permit No. NCO028746
Stokes County
The subject facility is located in a county which will continue to redAve
N H 3 -N limits based on the instream criteria of 1 mg/l for summer and 1.8 mg/l for
winter. The receiving stream for Briarwood Subdivision WWTP has a 7Q10 flow of
Zero, and Standard Operating Procedures dictates a limit based on the instream
criteria for such a designation. This branch has mailed Mr. Stogner a Procedures For
Projecting Low Flow Statistics At An Ungaged Site, (refer attached).
Should you have any questions, please contact Carla Sanderson.
cc: Attachment
Preston Howard
Trevor Clements
Central Files

Procedures for Projecting Low Flow Statistics
At An Ungaged Site
This summary is provided to assist in the development of data to
determine an acceptable projection of the low flow statistics (7Q10, 30Q2)
at stream sites where current information available to DEM yields zero 7Q10
and 30Q2 values. Low flow estimates used by the Division are based on data
collected at many stream sites under cooperative agreements with the U.S.
Geological Survey. Even though a significant data base has been accumu-
lated, it is impossible to collect data at all points on all streams in the
State. Therefore, estimates of the 7Q10 and the 30Q2 for streams where no
actual data has been collected are based on data collected at nearby streams
and a knowledge of the general hydrology of the area.
The Division will not approve new oxygen demanding discharges into
streams, where the estimated 7Q10 and 30Q2 are zero, unless it can be
demonstrated by the applicant for a discharge permit that there is flow at
the site under 7Q10 and/or 30Q2 conditions or that there is an appropriate
mechanism for establishing proper effluent limitations to protect water
quality standards and a reliable technology available to achieve those lim-
itations. To demonstrate that there is flow at the 7Q10 or 30Q2 level
requires collection of supporting data using standard engineering practices
and hydrologic techniques. The most widely used procedure requiring the
least effort and expense is to obtain direct flow measurements at the pro-
posed site, correlate those measurements with concurrent flow at nearby
gage(s) and, using a correlation curve with the 7Q10 and 30Q2 of the gaged
stream, project the 7Q10 and 30Q2 at the proposed site.

I. --'TTTe accuracy of the low flow estimates thus determined depends largely
on how well the streamflows compare - are the streams hydrologically similar
- and if they are similar, how well the relation between the two is defined.
There are several factors to consider when attempting to define the corre-
lation curve:
1. Measurements must be made during periods of base flow, that is when
streamflow is derived from groundwater; no surface runoff. Streams are
normally at base flow 5-7 days after the last rainfall event.
2. To define the curve, measurements must be made to cover a range in
flow; a minimum of 4 or 5 measurements reflecting separate hydrologic
events are normally required. It is unlikely that extreme events (e.g.
7Q10) will occur during the period you are collecting data and the
correlation will have to be extrapolated to the appropriate level. Of
course, the lower the flow is measured, the better the extrapolation
will be. Normally, the lowest streamflows occur in September and
October. Long extrapolations generally will not be accepted. (See
attached sample).
3. Diversions into or out of the stream may make correlation of flow
impossible. Streams affected by diversions will be handled on a case
by case basis.
4. Streamf low measurements must be made using generally accepted standard
engineering practices, such as, current meter measurements, calibrated
weirs, and volumetrically. Non -recognized techniques will not normally
be accepted.
5. Data from continuous stream gages can be obtained from the U.S. Geo-
logical Survey. It is important to note the station number, date and
time in your request for data.
U.S. Geological Survey
P.O. Box 2857
Raleigh, North Carolina 27602
6. The criteria for establishing a positive flow at a site will generally
be considered a projected flow (i.e. 7Q10, 30Q2) greater than 0.05 cfs.
However, each instance will receive individual review and a separate
interpretation.
Approval Procedures: In order to begin a 7Q10 flow study, a request must be
submitted to:
Mr. Trevor Clements and Mr. Curtis Gunter
N.C. DNRCD/DEM Water Resources Division
WQ Section/Technical Services Branch USGS
PO Box 27687 Raleigh, North Carolina 27602
Raleigh, North Carolina 27611-27687
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Tnclude with this request a detailed study plan describing the following:
1. The flow measurement procedures and equipment to be used,
2. A map showing the location of the site,
3. A schedule for developing the flow data and a final report, and
4. A discussion of the facts, if any, which indicate why a positive 7Q10
flow at this site is expected.
The study must not begin until written approval of the plan is received from
DEM.
USGS - Techniques of Water Resources Investigations.
Book 3, Chapter A6. General procedures for gaging streams.
R.W. Carter.and J. Davidian. 1968.
Book 3, Chapter A8. Discharge measurements at gaging stations.
T.J. Buchananan and W.P. Somers. 1969.
Book 3, Chapter A14. Use of flumes in measuring discharge.
F.A. Kilpatrick and V.R. Schneider. 1983.
Book 4, Chapter B1. Low -flow investigations. H.C. Riggs. 1972.
U.S. Geological Survey. Water Resources data for North Carolina.
Water Year 19--.
Yonts, W.L. Low -flow measurements of North Carolina Streams. North Caro-
lina Department of Water and Air Resources.
.11
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Mr. Leonard S togner-t-
Briarwood Subdivision �'��'�"' =�
Ra co Utilities Incorporated ��''- °c ��h � c��
4200 Highway 29
Harrisburg, North Carolina 28075 e c9 ,�,,, -�� �` Pmuao'r s
Subject: Briarwood Subdivision 641.1
� WwTP ,��v✓,
NPDES Permit No. NCO028 4
Stokes County 7 6 M�c,� �''a, �` A ti✓ w� t( v
Dear Mr. Stogner:
In an attempt to address your concerns regarding the 7Q1O of the tributary to Bushy Fork
Creek at your discharge point, I am enclosing a Procedures For Ej:Qjectingr Low Flow Statistics
At An Ungaged Site. (refer attached). The methods outlined in this document are approved by
the DEM for determining low flow statistics.
Should you have any questions, please contact me at (919) 733 I(A�-
t 5 t
Sincei
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Attachment R`�^-s .�,-�- -•�5 .
CC: TiAlArAr-11
Central Filesj`4"` ® `�-
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

03/04/9.3 09:17 FAX [phone] EWS, RAYCO INC. PO1
SCO UTIUTIES, INC.
4200 Highway 29
Harrisburg, NC 28075
[phone]
NC License RC1378 SC License 5341
March 2, 1993
post-It"A brand tax transmittal memo 7671ToLq or pepes
Pro
Ms. Elizabeth Rouse Mosley �'. `C
�oco. Ito
Associate Attorney General Co�SSoC• phone (n8C5
NC Department of Justice '`b i
P.O. Box 629 Fax# •���i Fax Hn�L.r riQ>����
Raleigh, NC 27602-0629
RE: NPDES Permit No. NCO028746
Briarwood Subdivision, Stokes County
93 EHR 0143
Dear Ms. Mosley:
On February 1, 1993, we filed a request for an
administrative hearing for the above referenced facility.
The reason for this request is the state has incorporated
certain changes and additional requirements to the permit.
These matters are obviously of great concern and at*'this
point, we do not understand the need for such drastic
changes. It appears that the basic concern is the flow in
the receiving stream has been classified as 07Q10.
We have operated this facility for over five (5) years and
_have never experienced a zero flow condition. We recognize
that the stream is relatively small but the stream is spring
fed and maintains a continuous base flow. This obversation
is supported by the fact that we have faithfully reported
upstream and downstream concentrations (as required by the
permits) and that, not only was there flow, but there were
no contraventions of water quality standards. It should be
obvious that not only is there flow in the stream but it is
sufficient to assimilate the wastes concentrations currently
being discharged.
It is our understanding that this is the intent of the
effluent limitations.....to protect the water quality of the
receiving stream. Considering this, we can see no
justification for tightening the existing limits.

03/04/93 09:18 FAX [phone] ENS, RAYCO INC. P02
Ms. Elizabeth Rouse Mosley
Page 2
March 2, 1993
The new effluent limits for NH3 as N and/or chronic toxicity
are well beyond the intended capability of this facility and
there are no practical alternatives to comply with the new
permit limits.
In our opinion, the proposed changes are unnecessary and may
be proposed based on information that is in error.
The methods used by USGS to "estimate" flow conditions in
the receiving streams are not exact but are merely based on
the best information and methods available. In this
instance, we believe the estimate is simply in error and
certainly should be reviewed more closely in lieu of
proceeding with an evaluation of eliminating the discharge.
We recognize that the limited resources of your office and
USGS do not allow you to conduct more extensive evaluation
of every site. We accept that we should share in this
effort. I believe it would be more reasonable to allow us
to review the information used to determine the flow
estimated and, if necessary, conduct actual stream flow
gauging following recognized and acceptable methods to more
accurately demonstrate the conditions of the receiving
stream.
1. A copy of the USGS Map indicating the locating of the
discharge for which you based the waste load
allocation.
2. A copy of the original wasteload allocation which
includes the 7010 and 30Q2 flow estimates and drainage
basin for the original NPDES permit and subsequent
reissuances and renewals of the permit for this
facility.
3. A copy of the "...(zero flow policy)" which explains
the procedures being followed in changing these limits.
4. A copy of the procedures to be followed in conducting a
site specific monitoring of stream flow to verify the
correct 7Q10 and 30Q2 of the receiving stream.

03/04/93 09:19 FAIY 704 788 6006 EWS, RAYCO INC. P03
Ms. Elizabeth Rouse Mosley
Page 3
March 2, 1993
Please include directions on the appropriate procedures
to be followed in requesting to conduct such stream
monitoring per Division of Environmental Management
approval.
5. A copy of the flow estimate provided by USGS as a basis
for this waste load allocations.
Again, we hope that you will reconsider and continue our
permit under the existing limits especially since these
limits have shown to protect the receiving steam.
I appreciate your attention to our concerns and hope that
you understand that we want to work with you in resolving
these matters in a mutally beneficial way. I hope that you
will call me if you have any questions or if we can be of
any assistance.
Sincerely,
eonard E. Stognerr, Jr.
vice President
LES/ls

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