NC0084387_Fact Sheet_20200610

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Fact Sheet
NPDES Permit No. NCO084387
Permit Writer/Email Contact: Derek Denard/[e-mail]
Date: l OJun2020
Division/Branch: NC Division of Water Resources/Water Quality Permitting Section
Compliance & Expediated Permitting Branch
Fact Sheet Template: Version 28Mar2019
Permitting Action:
N Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
See Permit Application Attachment A NCO084387_Renewal (Application)_20190925_8p.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Charlotte Water/ Lee S. Duke, Jr. WTP
Applicant Address:
5100 Brookshire Blvd, Charlotte, NC 28216-3371
Facility Address:
7980 Babe Stillwell Farm Road, Huntersville, NC
Permitted Flow:
Not limited
Facility Type/Waste:
Water Treatment Plant, Conventional
Facility Class:
Grade I Physical Chemical
Treatment Units:
three (3) stages of flocculation, two (2) sedimentation basins,
chlorination equipment, two (2) filters, three (3) 9 MG clearwells, an
equalization basin, a clarifier, dechlorination equipment, a sludge
thickener, and a residuals storage lagoon
Pretreatment Program (Y/N)
No
County:
Mecklenburg
Region
Mooresville
Briefly describe the proposed permitting action and facility background: This facility is a conventional
technology water treatment plant [coagulation, flocculation, sedimentation, and filtration] with discharge
of wastewaters from media filter backwash and sedimentation basins with a design potable flowrate of
25.31 MGD and a maximum monthly average wastewater discharge of 0.605 MGD based on data
submitted.
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Eli ig bility for Coverage under the General Permit NCG590000 — The Lee S. Duke WTP is eligible for the
general permit. The facility has no record of toxicity failures in the past five years. The permittee
reviewed the current version of general permit and did not wish for this facility to be covered.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
001
Stream Segment:
11-115-(1.5) Corrected. [See Attachment B: McDowell Creek 1p]
Stream Classification:
WS-IV Corrected. [See Attachment B]
Drainage Area (mi2):
28.3
Summer 7Q 10 (cfs)
1.8
Winter 7Q 10 (cfs):
4.2
30Q2 (cfs):
4.8
Average Flow (cfs):
31.0
IWC (% effluent):
36.6
303(d) listed/parameter:
NO [See Attachment C: 2018 Integrated Report _072519_p410]
Subject to TMDL/parameter:
NO, 4b TMDL Alternative: 11-115-(1.5)a was listed as exceeding
criteria in 2012 for Fish Community. 11-115-(1.5)b was listed as
exceeding criteria in 2012 for Benthos. Charlotte -Mecklenburg Storm
Water Services completed McDowell Creek Watershed Management
Plan March 2, 2008: hgps:Hdeq.nc.gov/about/divisions/water-
resources/water-resources-grants/319- rg ant-program/nc-watershed-
restoration-plans
[See Attachment D: NC DEQ_ TMDL Alternative_3p]
Basin/Sub-basin/ffUC:
Catawba/03-08-33/030501011401
USGS Topo Quad:
Lake Norman S
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of May2015 through Nov2019.
Table. Effluent Data Summary Outfall 001 (Compete table below or insert Excel Pivot Table.)
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DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Data
PQL
Limits
MA DM UoM
deg c
50 narrative ntu
Parameter T
Max
IMin Average
00010 - Temperature, Water Deg. Centigrade
33
8 22.2
00070 - Turbidity
11 0.5 1.9
00400 - pH
7.8
6.1
6.9
Not < 6.0 or > 9.0 su
00625 - Nitrogen, Kjeldahl, Total (as N)
0.25
0.25
0.25
<0.25
mg/1
00630 - Nitrite plus Nitrate Total (as N)
0.37
0.08
0.19
mg/1
00665 - Phosphorus, Total (as P)
0.1
0.1
0.1
<0.1
mg/1
00951 - Fluoride, Total (as F)
350
100
174.7
<100
ug/1
01042 - Copper, Total (as Cu)
5
2
2.4
<2, <5
ug/1
01045 - Iron, Total (as Fe)
110
34
65.5
<50
ug/1
01055 - Manganese, Total (as Mn)
350
10
67.4
<10
ug/1
01105 - Aluminum, Total (as Al)
2000
170
603.2
ug/1
50050 - Flow, in conduit or thru treatment plant
2.469
0.0002
0.363
mgd
50060 - Chlorine, Total Residual
53
6
15.5
<6, <10
28 ug/1
C0530 - Solids, Total Suspended - Concentration
34
2.5
4.9
<2.5 - 7.1
30 45 mg/1
C0600 - Nitrogen, Total - Concentration
0.37
0.08
0.20
<0.25
mg/1
C0665 - Phosphorus, Total as P - Concentration
0.11
0.1
0.1
<0.1
mg/1
MA = monthly a\,erage; DM = daily maximum; PQL = practical quantitation limit; UoM = Unit of Measure
Table. Verification of the following data: Attachment E
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
Parameter
Date <
Value
UoM
Comments
00951 - Fluoride, Total (as F)
7/14/2015
190
ug/1
units should be mg/l?
00951 - Fluoride, Total (as F)
10/13/2015
210
ug/l
units should be mg/l?
00951 - Fluoride, Total (as F)
1/12/2016
110
ug/l
units should be mg/l?
00951 - Fluoride, Total (as F)
7/12/2016
230
ug/1
units should be mg/l?
00951 - Fluoride, Total (as F)
7/19/2016
280
ug/1
units should be mg/l?
00951 - Fluoride, Total (as F)
10/13/2016
170
ug/l
units should be mg/l?
00951 - Fluoride, Total (as F)
1/10/2017 <
100
ug/1
units should be mg/l?
00951 - Fluoride, Total (as F)
4/11/2017
190
ug/1
units should be mg/l?
00951 - Fluoride, Total (as F)
7/18/2017
160
ug/l
units should be mg/l?
01042 - Copper, Total (as Cu)
4/10/2018 <
2
mg/l
units should be ug/l?
01045 - Iron, Total (as Fe)
4/10/2018
100
mg/1
units should be ug/l?
01055 - Manganese, Total (as Mn) 4/10/2018
60
mg/1 units should be ug/l?
Permittee response: The fluoride
errors from your email yesterday should
have been reported in mg/l. The
Copper, Iron and Manganese errors should have been reported in ug/l. See
Attachment E: Date Reporting
Error Info Request_20200228.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
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verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: No instream monitoring is required or proposed.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): No.
Name of Monitoring Coalition: NA.
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): There is no record of NOVs.
There was one Notice of Deficiency (NOD) for a TRC value of 53 µg/L for 13Sep2016. [See Attachment
F NC0084387 MR Violations Jan2015_Dec2019_2p]
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility has no record of toxicity failures in the past five years (100% pass rate). [See
Attachment G_WET Testing Summary September 2019 HQ p 66]
Summarize the results from the most recent compliance inspection: The facility was reported as compliant
with a facility evaluation rating of 4 (very reliable).
[See Attachment H NC0084387_Inspection_20191029_8p]
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA.
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA.
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: NA.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
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Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: No Changes to
TRC limits are proposed.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of/z detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between Jun2015 and
Nov2019. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit:
Monitoring Only. Total The maximum predicted concentration for Fluoride was <50% of the
allowable concentration. However, Fluoride is in use at this facility. There Florid remains a
pollutant of concern.
No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: Total Copper.
If applicable, attach a spreadsheet of the RPA results [See Attachment I] as well as a copy of the
Dissolved Metals Implementation Fact Sheet for freshwater/saltwater [See Attachment J] to this Fact
Sheet. Include a printout of the RPA Dissolved to Total Metal Calculator sheet if this is a Municipality
with a Pretreatment Program.
Toxicitv Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: Chronic Whole Effluent Toxicity (WET) testing - testing of
Ceriodaphnia dubia shall be performed as 7-day pass/fail, monitoring only, test at 37% effluent
concentration, during January, April, July and October [See A. (2.)].
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DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Describe proposed permit actions based on mercury evaluation: NA.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: NA.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA.
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA.
7. Technology -Based Effluent Limitations (TBELs)
Municipals (if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l
BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES for TSS.
However, this facility is a municipal WTP.
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA.
Are 85% removal requirements for BOD51TSS included in the permit? NA.
If NO, provide a justification (e.g., waste stabilization pond). NA.
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases,
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existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA.
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): No.
If YES, confirm that antibacksliding provisions are not violated: NA.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 213.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12. Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes — Outfall 001
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
No limit, Monitor &
Report
No change
15A NCAC 2B .0505
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TSS
MA 30 mg/1
No change
TBEL. Secondary treatment
DM 45 mg/1
standards/40 CFR 133 / 15A NCAC
2B .0406
pH (su)
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 213.0211 (14)
TRC
28 µg/L
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0211 (3)
Turbidity (NTU)
Monitor & Report
Insert Footnote: See
WQBEL. State WQ standard, 15A
Section 14 below.
NCAC 2B .0211 (21)
Total Aluminum
Monitor & Report
No change
Total Fluoride
Monitor & Report
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0211 (9)
Total Phosphorous
Monitor & Report
No change
WQBEL. Required to comply with
NC chl-a WQS, 15A NCAC
2B.0200.
TKN
Monitor & Report
No change
WQBEL. Required to comply with
chl -a WQS, 15A NCAC
NC NC chl0.
NO3-N + NO2-N
Monitor & Report
No change
TN
Monitor & Report
No change
Chronic WET
Monitor & Report
No change
WQBEL. No toxics in toxic
Testing
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Electronic
Required
Update Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MA - Monthly Average, DM — Daily Max
The draft permit includes the following significant changes from the existing permit:
1. The permit map and supplement to cover page was updated for the following:
a. The correct stream index number is 11-115-(1.5).
b. The correct stream classification is WS-IV.
2. The facility classification Grade I Physical Chemical was added to the effluent page.
3. Concurrent sampling with WET test samples is no longer required.
4. The following footnote was inserted for Turbidity: Discharge from this facility shall not cause
receiving -stream turbidity to exceed 50 NTU. If instream background conditions exceed 50 NTU,
this discharge shall not cause instream turbidity to increase.
5. The following footnote was inserted for Fluoride: Total Fluoride: This requirement applies only
to wastewater discharges from plants that backwash with fluoridated finished water.
6. The number of conventional filters was corrected from two (2) to four (4).
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13. Public Notice Schedule:
Permit to Public Notice: 02/13/2020 [See Attachment K]
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
[For Permittee Draft Comments See Attachment L]
[For PWSS Comments See Attachment M: PWSS_Review WS Discharge_20200312_4p]
14. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes.
If Yes, list changes and their basis below:
1. The following footnote was inserted for Turbidity: Discharge from this facility shall not cause
receiving -stream turbidity to exceed 50 NTU. If instream background conditions exceed 50 NTU,
this discharge shall not cause instream turbidity to increase.
2. The following footnote was inserted for Fluoride: Total Fluoride: This requirement applies only
to wastewater discharges from plants that backwash with fluoridated finished water.
3. The number of conventional filters was corrected from two (2) to four (4).
15. Fact Sheet Attachments (list in order of reference):
A. NC0084387_Renewal (Application)_20190925_8p
B. McDowell Creek - Stream Index and Classification_lp
C. 2018 Integrated Report _072519_p410
D. NC DEQ_ TMDL Alternative _3p
E. Date Reporting Error Info Request_20200228
F. NC0084387 MR Violations Jan2015_Dec2019_2p
G. WET Testing Summary September 2019 HQ p 66
H. NC0084387_Inspection _20191029_8p
1. NC0084387 RPA_5p
J. Fact Sheet Memo FW_4p
K. North Carolina Public Notices _The Charlotte Observer_20200213_2p
L. Permittee Draft Comments _20200306_4p
M. PWSS_Review WS Discharge_20200312_4p.
N. NC0084387 Review Checklist
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ROY COOPER
Grnwnor
MICHAEL S. REGAN
Sccrcrary
LINDA CULPEPPER
bir(y ror
Charlotte Water
Attn: John C. Huber, Chief of Operations
5100 Brookshire Blvd
Charlotte, NC 28216-3371
Subject: Permit Renewal
Application No. NCO084387
Lee S. Dukes WTP
Mecklenburg County
Dear Applicant:
NORTH CAROLINA
Environmental Quality
October 04, 2019
The Water Quality Permitting Section acknowledges the October 1, 2019 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150E-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deg.nC.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincerely,
Wren Thedford
Administrative Assistant
Water Quality Permitting Section
ec: WQPS Laserfiche File w/application
f DUE
North Caro r.a Departmertof Env rorr erta Qua t}. 1 D vson of Water Res3uro?s
��' Mmresv a Rego" Off ce 1 613 East Oerter Averue. Su to 301 1 hrmresv e, North Caro na 28115

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
CHARLOTTE
Wt)TER
September 25, 2019
Division of Water Resources
WQ Permitting Section — NPDES
1617 Mail Service Center
Raleigh NC 27699-1617
Subject: Renewal NPDES Permit # NCO084387
Lee S. Dukes Water Treatment Plant
Mecklenburg County
WQ Permitting Section,
RECEIVED
OCT 01 2019
NCDEQIDWRINPDES
Charlotte Water would like to request renewal of NPDES permit NCO084387 at the Lee S. Dukes
Water Treatment Plant. The current permit is set to expire February 28, 2020. Enclosed is the
completed NPDES Permit Applications Short Form C.
Also attached to the Short Form C are:
• Solids Management Plan
• Plant Flow Schematic
• Outfall/Discharge Location
If you have any questions, please contact me at 704-399-2426 extension 222 or Gabe Sasser at
704-507-5267.
Sincere) L C 44��
John C. uber
Chief or Operations
City of Charlotte
Charlotte Water
Charlotte Water 5200 Brookshire Blvd, Charlotte, NC 28216 charlottewater.org
d? Operated by the City of Charlotte

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number INCO084387
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Charlotte Water
Lee S. Dukes WTP
7980 Babe Stillwell Rd.
Huntersville
North Carolina / 28078
(704-948-6954)
(704-948-7581)
dbanick@ci. charlotte. nc. u s
2. Location of facility producing discharge:
Check here if same as above
Street Address or State Road
City
State / Zip Code
County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name City of Charlotte
Mailing Address 5200 Brookshire Blvd
City Charlotte
State / Zip Code North Carolina
Telephone Number 704-399-2142
Fax Number 704-393-9163
4. Ownership Status:
Federal ❑ State ❑ Private ❑ Public
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NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
5. Type of treatment plant:
® Conventional (Includes coagulation, flocculation, and sedimentation, usually followed by
filtration and disinfection)
❑ Ion Exchange (Sodium Cycle Cationic ion exchange)
❑ Green Sand Filter (No sodium recharge)
❑ Membrane Technology (RO, nanofiltration)
Check here if the treatment process also uses a water softener ❑
6. Description of source water(s) (i.e. groundwater, surface water)
Surface Water
7. Describe the treatment process(es) for the raw water:
Raw Water is treated with potassium permanganate and carbon as needed. Aluminum sulfate is
added at the head works of the plant. The water then passes through three stages of
flocculation before entering the sedimentation basins. Chlorine is added just before filtration.
Following filtration, lime, fluoride and chlorine are added to the water prior to flowing to
clearwells.
8. Describe the wastewater and the treatment process(es) for wastewater generated by the
facility:
Solids are generated from the water treatment process, consisting mostly of alum residuals.
Solids generated from the sedimentation basins are discharged thru a gravity thickener and
then to a holding lagoon. Solids are also generated from filter backwashes and discharged to an
EQ basin. The solids from the EQ basin are sent to a clarifier. The solids are then sent to the
thickener before being directed to a holding lagoon. Clarified water goes over the weir of the
clarifier, through a de -chlorination chamber to the NPDES discharge point. Solids from the
holding lagoon are removed and land applied according to permit requirements.
Solids Plan
1. Solids generated from the sedimentation basins are discharged thru a gravity
thickener and then discharged to a holding lagoon.
2. Solids generated from filter backwashes are discharged to an EQ basin. The solids
from the EQ basin are sent to a clarifier. The solids are then sent to the thickener before
entering a holding lagoon. Clarified water goes over the weir of the clarifier, through a
dechlorination chamber to Outfall 001.
3. Solids from the holding lagoon are removed and land applied by a contractor as a
liquid. We also have the ability to tanker the liquid to a belt press for land application or
land fill disposal.
4. The contractor must follow permit # WQ 0000057 Version 2.
9. Number of separate discharge points: 1
Outfall Identification number(s) 001
10. Frequency of discharge: Continuous ❑ Intermittent
If intermittent:
Days per week discharge occurs: 7
Duration: Approximately 4 hours per day
Page 2 of 4 Version 5/2012

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
11. Plant design potable flowrate 25.31 MGD
Backwash or reject flow .206 MGD
12. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
McDowell Creek
13. Please list all water treatment additives, including cleaning chemicals or disinfection
treatments, that have the potential to be discharged.
Alum / aluminum sulfate Yes
Iron sulfate / ferrous sulfate Yes
Fluoride Yes
Ammonia nitrogen / Chloramines No
Zinc -orthophosphate or Sweetwater CP1236 No
List any other additives below:
Chlorine, Powdered Activated Carbon, Potassium Permanganate, Lime,
Liquid Linear Phosphate, Sodium Bisulfite
Note: Chlorine dioxide will be applied to the raw water from Lake Norman in the future; no
implementation date has been set as construction has not been completed.
Ferrous sulfate may be applied in the future to the raw water from Lake Norman as well.
14. Is this facility located on Indian country? (check one)
Yes ❑ No
15. Additional Information:
Provide a schematic of flow through the facility, include flow volumes at all points in
the water treatment process. The plan should show the point[s] of addition for
chemicals and all discharges routed to an outfall [including stormwater].
30 Solids Handling Plan (Please see Question 8)
16. NEW Applicants
Information needed in addition to items 1-15:
New applicants are highly encouraged to contact a permit coordinator with the
NCDENR Customer Service Center.
Was the Customer Service Center contacted? ❑ Yes ❑ No
Analyses of source water collected
Engineering Alternative Analysis
Discharges from Ion Exchange and Reverse Osmosis plants shall be evaluated using a
water quality model.
Page 3 of 4 Version 5/2012

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
17. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
John
of Person
Title
Sig toe of Applicant I Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application,
record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that
Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21
or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5
years, or both, for a similar offense.)
Page 4 of 4 Version 5/2012

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Lee S.
Dukes Water Treatment Plant
Process Flow Diagram
r'C—'lIOCarbon Alum Chlorine Polymer KMnO,
Chlorine Chlorine Floudde
Lime Clearwell
1
9 MG
Sedimentation Filter
East Module 1 East Module 1
Clearwell
:Lakeorman
Finished
2
High Service
10 To 978
Raw --.Marmon Da Flow25.3nmtl
Water
9 MG
Pump Station
Zone
Sedimentation Filler
East Module 2 East Module 2
Clearwell
3
9MG
Backwash
Water
Polymer
Sod Basin
Clarifier
jDe-chloftafion
Residuals
EO
Efsae<'t
To Creek
Clar�er
Cutfall
Wf. 001
Ohcnarye
Mar Oesip
Eo Bain
Mar es Flova
Solids
FlOVf
JBem d
I�[lu.nt: 138 rro
Eft— Md
Thickened
Residuals
s Thickener
Lagoon
Land Application
25 Sep 2019

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
z
_ Lake Norman
\./
11
s�
McDowell Creek
[flogs south]
. 'i -W.—
Babe Stillwell Far�.m' Rd
\
Approximate
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N
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N.
Outfall001
t [flows south]
Charlotte Water
Lee S. Dukes Water Treatment Plant (WTP)
7980 Babe Stillwell Farm Road, Hunterville 28078
Receivine Stream: McDowell Creek Stream Class: WS-IV; CA
Stream Segment: 11-11545) Sub -Basin: 03-08-33
Drainage Basin: Catawba HUC: 03050101
Latitude: 35' 25' 42" Longitude: 81° 53' 17"
State GridIUSGS Ouad: FI5NW / Lake Norman S
77
ON
Facility
ETA V
Location
Scale 1:24,000
NPDES Pen -nit NC0084387
NOY't%? Mecklenburg County

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
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DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
2018 NC Intergrated Report
Catawba River Basin Upper Catawba Subbasin 03050101
11-38-34-11-3-5 Marks Mountain Branch
From source to Gragg Prong
Classification I C;Tr,ORW
Length or Area
1 Units FW Miles Previous AU Number
Parameter of Interest
Category Assessment Criteria StatusN Collection —Year
Benthos (Nar, AL, FW)
1 Meeting Criteria ]
2014
Fish Tissue Mercury (Nar, FC, NC)
4t Exceeding Criteria ]
2012
11-115-(1) McDowell Creek
From source to U.S. Hwy. 21
Classification C
Length or Area
2 Units FW Miles Previous AU Number
Parameter of Interest
Category Assessment Criteria Status Collection —Year
Fish Community (Nar, AL, FW)
4b Exceeding Criteria 2002
Fish Tissue Mercury (Nar, FC, NC)
4t Exceeding Criteria 2012
11-115-(1.5)a McDowell Creek
(From U.S. Hwy. 21 to SR 2136 Mecklenburg Co
Classification WS-IV Length or Area 4 U�s FW Miles Previous AU Number
Parameter of Interest Cal, t
Fish Community (Nar, AL, FW) 4b iExceeding Criteria 12002
Fish Tissue Mercury (Nar, FC, NC) I4t Exceeding Criteria 12012
11-115-(1.5)b McDowell Creek
FromSR2136 Mecklengurg Co to a point 0.7 mile upstream of mouth
Classification WS-IV (Length or Area
Parameter of Interest
Benthos (Nar, AL, FW)
Fish Tissue Mercury (Nar, FC, NC)
3 Units FW Miles (Previous AU Number)
Category Assessment Criteria Status Collection —Year
4b Exceeding Criteria 2012
4t Exceeding Criteria 2012
7/23/2019 2018 NC Integrated Report Page 410 of 1727

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NORTH CAFLIfA
Environmental Quality NC DEQ
TMDL Alternative
TMDL Alternative
A TMDL Alternative is a watershed restoration plan or set of actions pursued in the near -term
that, when fully implemented, are designed to attain water quality standards. Communities that
are taking initiative to voluntarily create and execute plans to clean up impaired waters may
defer or even bypass the need for a TMDL: These alternative plans are locally crafted and
executed, giving flexibility in the restoration process: Both DWR and EPA recognize these
restoration efforts and, if guidelines are met, are reflected on NC's 303(d) list.
There are two options for TMDL alternatives: 5r (9-element watershed plan) or 4b Demonstration
Plan.
5r (9-Element Watershed Plan)
Impaired waters with a DWR-approved 9-Element (9E) Watershed Plan are eligible for Category
5r on the 303(d) list: Waters with a 5r designation are still considered impaired, and included on
the 303(d) list, but TMDL development is deferred while the plan is being implemented. Projects
identified in the 9E Watershed Plan are eligible for 319 funding
(https: deq.,nc.gov/about/divisions/water-resources/planning nonpoint-source-management/319-
grant-program)..
9E Watershed Plans are consistent with the EPA's framework to develop watershed -based plans
and consist of nine key elements. The elements are intended to ensure that the contributing
causes and sources of nonpoint source pollution are identified, that key stakeholders are
involved in the planning process and that restoration and protection strategies are identified that
will address the water quality concerns. An overview of the 9E framework is provided in
Introduction to the 9 Elements of a Watershed Restoration Plan
(https://files.nc.gov/ncdeq/Water Quality/Planning/NPU/319/WatershedMGTPlanS_9element/9E intro
presentation.pd)

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
view approvea i MUD alternatives ntipaj aeq,nc.gov/about/divisions/water-
resources/planning modeling-assessment/tmdl-alternative/approved-tmdl-alternatives)
4b Demonstration Plan
Impaired waters with enforceable pollution control programs in place that are expected to solve
pollution problems (i.e„ meet water quality standards) are commonly referred to as "Category
4b" waters because they are moved from Category 5 (303(d) list - impaired and needs TMDL) of
the State's Integrated Report to Category 4b (impaired but TMDL not required). While pollution
control programs are not TMDLs, they must have many of the same features, and there must be
some legal or financial assurance that they will be implemented:
A Category 4b demonstration allows DWR and EPA to formally recognize actions that, from a
Local. perspective, provide a more appropriate and effective response to impairment than TMDL
development. DWR has developed guidance (North Carolina's Division of Water Resources
Category 4b Demonstration Guidance
(https://files.nc.gov/ncdeq/Water Quality/Planning/TMDL/Alternatives/NC 4bGuidance2014.pdf) ) for
communities interested in developing a plan to address impaired waters. The guidance describes
the elements required to qualify for Category 4b: Communities interested in pursuing this option
should review the guidance document and plan to meet with DWR's Modeling and Assessment
Branch prior to development. Some communities may find that they are already meeting most if
not all of the required elements.
View approved TMDL alternatives (httpst deq.nc:gov/about/divisions/water-
resources/planning modeling-assessment/tmdl-alternative/approved-tmdl-alternatives)
Modeling & Assessment
Water Quality Data Assessment (/about/divisions/water-resources/planning modeling=
assessment/water-quality-data-assessment)
TMDLs (/about/divisions/water- resources
/planning modeling-assessment/tmdls)

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
TMDL alternative (/about/divisions/water-resources/planning/modeling-
assessment/tmdl-alternative)
Approved TMDL Alternatives (/about/divisions/water-resources/planning modeling=
assessment/tmdl-alternative/approved-tmdl-alternatives)
Water Quality Modeling (/about/divisions/water-resources/planning modeling=
assessment/water-quality-monitoring)
Basinwide Hydrologic Modeling (/about/divisions/water-resources/water-
planning modeling-assessment/basinwide-hydrologic-modeling)
Special Studies (/about/divisions/water-resources/planning modeling=
assessment/special-studies)
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DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
MONITORING REPORT(MR) VIOLATIONS for:
Report Date:
02/11/20 Page:
1 of 2
Permit:
NCO084387
MRS Between 1
- 2015 and 12 - 2019
Region:
%
Violation
Category:%
Program Category:
Facility Name: %
Param Name %
County:
%
Subbasin: %
Violation Action: %
Major Minor:
%
PERMIT: NCO084387
FACILITY: Charlotte Water - Lee S. Dukes WTP
COUNTY: Mecklenburg
REGION: Mooresville
Limit Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT
OUTFALL
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
11 -2015
001
Effluent
Chlorine, Total Residual
11/10/15
Weekly
ug/I
28
30
7.1
Daily Maximum
No Action, BPJ
Exceeded
12 - 2015
001
Effluent
Chlorine, Total Residual
12/15/15
Weekly
ug/I
28
32
14.3
Daily Maximum
No Action, BPJ
Exceeded
03 - 2016
001
Effluent
Chlorine, Total Residual
03/15/16
Weekly
ug/I
28
50
78.6
Daily Maximum
No Action, BPJ
Exceeded
03 - 2016
001
Effluent
Chlorine, Total Residual
03/23/16
Weekly
ug/I
28
36
28.6
Daily Maximum
No Action, BPJ
Exceeded
05 - 2016
001
Effluent
Chlorine, Total Residual
05/10/16
Weekly
ug/I
28
29
3.6
Daily Maximum
No Action, BPJ
Exceeded
08 - 2016
001
Effluent
Chlorine, Total Residual
08/23/16
Weekly
ug/I
28
40
42.9
Daily Maximum
No Action, BPJ
Exceeded
09 - 2016
001
Effluent
Chlorine, Total Residual
09/13/16
Weekly
ug/I
28
53
89.3
Daily Maximum
Proceed to NOD
Exceeded
10 - 2016
001
Effluent
Chlorine, Total Residual
10/04/16
Weekly
ug/I
28
45
60.7
Daily Maximum
No Action, BPJ
Exceeded
10-2016
001
Effluent
Chlorine, Total Residual
10/11/16
Weekly
ug/I
28
38
35.7
Daily Maximum
No Action, BPJ
Exceeded
10 - 2016
001
Effluent
Chlorine, Total Residual
10/13/16
Weekly
ug/I
28
45
60.7
Daily Maximum
No Action, BPJ
Exceeded
11 -2016
001
Effluent
Chlorine, Total Residual
11/15/16
Weekly
ug/I
28
34
21.4
Daily Maximum
No Action, BPJ
Exceeded
11 -2016
001
Effluent
Chlorine, Total Residual
11/22/16
Weekly
ug/I
28
32
14.3
Daily Maximum
No Action, BPJ
Exceeded
01 -2017
001
Effluent
Chlorine, Total Residual
01/24/17
Weekly
ug/I
28
31
10.7
Daily Maximum
No Action, BPJ
Exceeded
09 - 2017
001
Effluent
Chlorine, Total Residual
09/12/17
Weekly
ug/I
28
39
39.3
Daily Maximum
No Action, BPJ
Exceeded
09 - 2017
001
Effluent
Chlorine, Total Residual
09/19/17
Weekly
ug/I
28
29
3.6
Daily Maximum
No Action, BPJ
Exceeded
10 - 2017
001
Effluent
Chlorine, Total Residual
10/03/17
Weekly
ug/I
28
38
35.7
Daily Maximum
No Action, BPJ
Exceeded

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
MONITORING REPORT(MR) VIOLATIONS for:
Permit: NCO084387 MRS Between 1 - 2015 and 12 - 2019 Region: %
Facility Name: % Param Name % County: %
Major Minor: % L
Report Date: 02/11/20 Page: 2 of 2
Violation Category:% Program Category: %
Subbasin:% Iq
Violation Action:
PERMIT: NCO084387
FACILITY:
Charlotte Water- Lee S. Dukes WTP
COUNTY: Mecklenburg
REGION: Mooresville
Limit Violation
MONITORING
VIOLATION
UNIT OF
CALCULATED
%
REPORT
OUTFALL
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
10 -2017
001
Effluent
Chlorine, Total Residual
10/24/17
Weekly
ug/I
28
40
42.9
Daily Maximum
No Action, BPJ
Exceeded
10 - 2017
001
Effluent
Chlorine, Total Residual
10/31/17
Weekly
ug/I
28
34
21.4
Daily Maximum
No Action, BPJ
Exceeded
11 -2017
001
Effluent
Chlorine, Total Residual
11/21/17
Weekly
ug/I
28
38
35.7
Daily Maximum
No Action, BPJ
Exceeded
12 - 2017
001
Effluent
Chlorine, Total Residual
12/05/17
Weekly
ug/I
28
30
7.1
Daily Maximum
No Action, BPJ
Exceeded
12 - 2017
001
Effluent
Chlorine, Total Residual
12/27/17
Weekly
ug/I
28
44
57.1
Daily Maximum
No Action, BPJ
Exceeded
01 - 2018
001
Effluent
Chlorine, Total Residual
01/30/18
Weekly
ug/I
28
37
32.1
Daily Maximum
No Action, BPJ
Exceeded
02 - 2018
001
Effluent
Chlorine, Total Residual
02/27/18
Weekly
ug/I
28
43
53.6
Daily Maximum
No Action, BPJ
Exceeded
05 - 2018
001
Effluent
Chlorine, Total Residual
05/09/18
Weekly
ug/I
28
33
17.9
Daily Maximum
No Action, BPJ
Exceeded
08 -2018
001
Effluent
Chlorine, Total Residual
08/14/18
Weekly
ug/I
28
39
39.3
Daily Maximum
No Action, BPJ
Exceeded
09 -2018
001
Effluent
Chlorine, Total Residual
09/18/18
Weekly
ug/I
28
44
57.1
Daily Maximum
No Action, BPJ
Exceeded
01 -2019
001
Effluent
Chlorine, Total Residual
01/29/19
Weekly
ug/I
28
33
17.9
Daily Maximum
No Action, BPJ
Exceeded
05 -2019
001
Effluent
Chlorine, Total Residual
05/28/19
Weekly
ug/I
28
31
10.7
Daily Maximum
No Action, BPJ
Exceeded

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
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�F
•
-
2015�
2016
•
•
•
2017
•
•
•
2018
•
•
•
2019
>10.4("
•
•
Lawrence Sprinkle-Weaverville WTP
NCO085154/001
County: Bunc67W
Ceri7dPF
Begin: 12/1/2015 Chr Monit:
90%
NonComp:
J
F
M
A
M
2015
Pass
-
-
Pass
•
2016
Pass,
0
0
Pass
•
,2017
Passl
•
•
Pass
•
•Q18
Passl
•
•
Pass
•
-
Passl
•
•
Pass
•
-
NC0036366/01!
County: Guilford
-
Begin: 3/1/2001
fathead 24h LC50
a j a NonComp: 9�
M
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•
•
H
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•
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•
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Lee S. Dukes WTP (CMUD)
NCO084387/001
County: Mecklenburg
Ceri7dPF
Begin: 5/1/2015
Chr Monit:
37%
NonComp:
J
F
M
A
M
2015
Pass
-
-
Pass
-
2016
Pass
-
-
Pass
-
2017
Pass
-
-
Pass
-
2018
Pass
-
-
Pass
-
2019
Pass
-
-
Pass
-
Ceri7dPF
-
,
•
-
201s
2016
•
•
•
•
2017
•
•
•
•
2018
•
•
_
2019
•
•
•
•
•
•
Illlllll�
•
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•
•
Illlllll�
•
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•
•
Illlllll�
•
•
•
Illlllll�
•
Region: ARO
-
7Q10:
•
Pass
•
•
-
•
Fail
•
•
•
Pass
•
•
R
Pass
•
•
_
Pass
•
•
-
Basin: CPF09'
-
-
PF: NA IWC: 100
A
•
•
H
•
1
•
•
H
•
1
•
•
H
•
•
•
•
H
•
•
Region: MRO
70,10
l
Basin: CTB05 Jan Apr Jul Oct
PF: IWC: Freq: Q
J A S O
Pass - - Pass
Pass - - Pass
Pass - - Pass
Pass - - Pass
Pass - - Pass
N
`10.4(P)
N
H
H
,H
•
SOC JOC:
N
Pass
Pass
Pas;
Pas$
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C
Legend: P= Fathead minnow (Pimphales promelas), H=No Flow (facilitv is active), s = Split test between Certified Labs Page 66 of 121

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Ms. Jacqueline A. Jarrell
Operations Chief
Environmental Management Division
Charlotte Water
5100 Brookshire Blvd.
Charlotte, North Carolina 28216
Dear Ms. Jarrell:
NORTH CAROLINA
Environmental Quality
October 29, 2019
Subject: Compliance Evaluation Inspection
Lee S. Dukes WTP
NPDES Permit No. NCO084387
Mecklenburg County
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
October 22, 2019, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our
findings by forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this report, please do
not hesitate to contact Mr. Bell at [phone] or atrRc-1l1(.
Sincerely,
EA
DocuSigned by:
4,� H Pzu"
F161 FB69A2D84A3...
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Rusty Rozzelle, MCWQP (via email)
D EQ
..� North Carolina Department of Environmental Quality I Division of Water Resources
�^ Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NDRTH nARJ, it �
704.663.1699

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 IS I 3 I NCo084387 111 121 19/10/22 I17 18 i d 19 i S i 201
211111 I I I I I I II 11 1 I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70Id I 71 I,. I 72 I �, I 73I I I74 751 I I I I I I I80
LJ LJ I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES Dermit Number)
09:15AM 19/10/22
15/04/01
Lee S. Dukes WTP
7980 Babe Stillwell Farm
Exit Time/Date
Permit Expiration Date
Huntersville NC 28078
11:20AM 19/10/22
20/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
///
David M Banick/ORC/704-399-2426/
Gabe Sasser//704-399-2142 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jacqueline A Jarrell,5100 Brookshire Blvd Charlotte NC 282163371//704-336-5433/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
cuSigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 10/29/2019
Wes Bell a-19Pb'GGli
696D90CC3437...
Signature of Mana obQ,9iditewii�wer Agency/Office/Phone and Fax Numbers Date
Andrew Pitne A"uw H P'tt9WR/MR0 WQ/704-663-1699 Ext.2180/ 10.29.19
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NPDES yr/mo/day Inspection Type
NCO084387 I11 12, 19/10/22 117 18 ICI C
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit: NCO084387 Owner - Facility: Lee S. Dukes WTP
Inspection Date: 10/22/2019 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
M
❑
❑
❑
application?
Is the facility as described in the permit?
M
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The Division received the permit renewal application package on 10/1/19.
The last compliance evaluation inspection by DWR staff was performed on 7/23/16.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
M
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: The records reviewed during the inspection were organized and well maintained. Discharge
Monitoring Reports (eDMRs) were reviewed for the period September 2018 through August
2019. No effluent limit violations were reported and all monitoring frequencies were correct.
Laboratory
Yes No NA NE
Page# 3

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit: NCO084387 Owner - Facility: Lee S. Dukes WTP
Inspection Date: 10/22/2019 Inspection Type: Compliance Evaluation
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: On -site field analvses (DH. temperature. TRC) are performed under Charlotte Water/Lee S.
Dukes WTP's laboratory certification #5221. Charlotte Water Environmental Laboratory
Services performs analyses of all permit -required parameters with the exception of field
parameters and chronic toxicity. ETT Environmental has been contracted to perform the
chronic toxicity analyses.
Facility staff must ensure that new pH buffers are used (pH meter calibrations) each day
effluent analyses are performed. The pH meter calibrations are performed approximately six
to eight hours prior to the effluent analyses. This Office recommends re -checking the 7.0
SU buffer prior to future effluent analyses.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
MEI
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: The subject permit requires effluent grab samples.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ 0 ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The NPDES wastewater treatment facilities appeared to be Droperly operated and well
maintained.
Equalization Basins Yes No NA NE
Is the basin aerated? 0 ❑ ❑ ❑
Is the basin free of bypass lines or structures to the natural environment? ❑ 0 ❑ ❑
Page# 4

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit: NCO084387
Inspection Date: 10/22/2019
Owner -Facility: Lee S. Dukes WTP
Inspection Type: Compliance Evaluation
Equalization Basins
Yes No NA NE
Is the basin free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
0❑
# Is basin size/volume adequate?
0
❑
❑
❑
Comment: The equalization (EQ) basin is eauipped with a bvpass outlet to an unnamed tributary to
McDowell Creek. No bypasses have occurred in several years. The EQ basin is also
equipped with a high water alarm that is connected to the on -site SCADA system. The
alarm did not operate properly during the inspection; however, the alarm was repaired and
placed into operation by the following day. The ORC indicated that the alarm system will be
placed on a periodic testing schedule.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
M
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
❑
❑
0
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
❑
❑
0
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
❑
❑
❑
Comment:
De -chlorination
Yes No NA NE
Type of system ?
Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑
❑
MEI
Is storage appropriate for cylinders?
❑
❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑
❑
0
❑
Are the tablets the proper size and type?
❑
❑
MEI
Comment: The equalization basin effluent is dechlorinated prior to entering the clarifier. The clarifier
effluent is also dechlorinated and passes through the dechlorination contact chamber prior
to flow measurement and discharge. Aqueous sodium bisulfite is used for dechlorination.
Page# 5

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit: NC0084387 Owner -Facility: Lee S. Dukes WTP
Inspection Date: 10/22/2019 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Are tablet de -chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use?
Comment:
Chemical Feed
Yes No NA NE
Is containment adequate?
0
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Are backup pumps available?
M
❑
❑
❑
Is the site free of excessive leaking?
0
❑
❑
❑
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
M
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
MEI
Comment: The flow meter is calibrated annually and was last calibrated on 3/11/19 by Charlotte
Water's Instrument & Controls personnel.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
M
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The effluent appeared clear with no floatable solids or foam. The receiving stream did not
appear to be negatively impacted.
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Yes No NA NE
❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
Page# 6

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit: NCO084387 Owner -Facility: Lee S. Dukes WTP
Inspection Date: 10/22/2019 Inspection Type: Compliance Evaluation
Solids Handling Equipment Yes No NA NE
Comment: The facilitv is eauiDDed with a aravitv sludae thickener and sludae storaae laaoon (concrete
sides with clay lined bottom). Facility staff had lowered the water level and placed an
absorbent boom in the gravity thickener to address an oil leakage/sheen. The leakage was
in the process of being repaired.
The sludge lagoon supernate (manually discharged) is combined with the dechlorinated
clarifier effluent prior to flow measurement and discharge to the receiving stream.
The sludge is land applied by a contracted company (Synagro) under the authority of Permit
No. WQ0000057.
Page#

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
Lee S. Duke WTP
WWTP/WTP Class
PC-1
NPDES Permit
NCO084387
Outfall
001
Flow, Qw (MGD)
0.605
Receiving Stream
McDowell Creek
HUC Number
030501011401
Stream Class
WS-IV
El Apply WS Hardness WQC
70110s (cfs)
1.80
70110w (cfs)
4.20
4.80
30Q2 (cfs)
31.00
QA (cfs)
1.51
1Q10s (cfs)
Effluent Hardness
25 mg/L (Avg)
Upstream Hardness _
_ _ _ _ 25 mg/L (Avg)
Combined HardnessChronic
___
_ _ _ _ _ _ _ _ 25 mg/L
Combined Hardness Acute
_ _ _ 25 mg/L
Data Source(s)
❑ CHECK TO APPLY MODEL
Follow directions for data entry. In some cases a
comment menu list the available choices or a
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
Par01
Par02
Par03
Par04
Par05
Par06N
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Parts
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Par25
Table 2. Parameters of Concern
Name w4s Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
0.5899
FW
3.2396
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
117.7325
FW
905.0818
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
lag/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
lag/L
Copper
Aquatic Life
NC
7.8806
FW
10.4720
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
2.9416
FW
75.4871
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
37.2313
FW
335.2087
lag/L
Nickel
Water Supply
NC
25.0000
WS
N/A
lag/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
0.2964
ug/L
Zinc
Aquatic Life
NC
126.7335
FW
125.7052
ug/L
NCO084387 RPA 2020, input
4/19/2020

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Lee S. Duke WTP
Outfall 001
NCO084387 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM
Qw (MGD) =
0.60
1Q10S(cfs)=
1.51
7QIOS(cfs)=
1.80
7Q10W (cfs) =
4.20
30Q2 (cfs) =
4.80
Avg. Stream Flow, QA (cfs) =
31.00
Receiving Stream:
McDowell Creek HUC 030501011401
DATA POINTS = 58
WWTP/WTP Class: PC-1
IWC% @ 1Q10S =
38.30900081
IWC% @ 7Q10S =
34.25096674
lWC% @ 7Q10W =
18.25108454
IWC% @ 30Q2 =
16.34253522
IW%C @ QA =
2.935976424
Stream Class:
WS-IV
Qw = 0.60495667 MGD
COMBINED HARDNESS (m¢/L)
Acute = 25 mg/L
Chronic = 25 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 25 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
�
F
ChApplied
ronic Acute
n # Der. Max Pred Cw Allowable Cw
(1)
z
Standard
Acute: 27.34
No detects
Copper
NC
7.8806 FW(7Q10s) 10.4720
ug/L
16 0
NO DETECTS
_ _
Chronic: 23.01
No detects
Max MDL = 5
Acute: NO WQS
Fluoride
NC
1800 FW(7Q10s)
ug/L
19 13
479.5
Chronic. 5,255.3
No RP, Predicted Max < 50% of Allowable Cw -
No value > Allowable Cw
Monitoring optional do to usage indicated.
NCO084387 RPA 2020, rpa
Page 2 of 5 4/19/2020

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Date Data BDL=1/2DL Results
1 25 25 Std Dev.
2 Mean
3 C.V.
4 n
5 10th Per value
6 Average Value
7 Max. Value
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58 F
1
25.0000 2
0.0000 3
1 4
25.00 mg/L 5
25.00 mg/L 6
25.00 mg/L 7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Upstream Hardness
Date Data BDL=1/2DL Results
25 25 Std Dev.
Mean
C.V.
n
10th Per value
Average Value
Max. Value
Use"PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
25.0000
0.0000
1
25.00 mg/L
25.00 mg/L
25.00 mg/L
NCO084387 RPA 2020, data
-3- 4/19/2020

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
REASONABLE POTENTIAL ANALYSIS
Pall
Date Data
1 7/14/2015 <
2 7/12/2016 <
3 7/19/2016 <
4 10/13/2016 <
5 1/10/2017 <
6 4/11/2017 <
7 7/18/2017 <
8 11/14/2017 <
9 1 /9/2018 <
10 4/10/2018 <
11 7/10/2018 <
12 10/9/2018 <
13 1 /8/2019 <
14 4/9/2019 <
15 7/9/2019 <
16 10/8/2019 <
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL Par13
Copper Values" then "COPY"
. Maximum data
points = 58
BDL=1/2DL
Results
5 2.5
Std Dev.
0.5123
2 1
Mean
1.1875
2 1
C.V.
0.4315
2 1
n
16
2 1
2 1
Mult Factor =
1.33
2 1
Max. Value
2.50 ug/L
2 1
Max. Fred Cw O
DETECTS ug/L
2 1
2 1
2 1
2 1
5 2.5
2 1
2 1
2 1
Use"PASTE SPECIAL
Fluoride Values" then "COPY"
. Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
7/14/2015
190
190
Std Dev.
2
10/13/2015
210
210
Mean
3
1/12/2016
110
110
C.V.
4
4/12/2016
<
100
50
n
5
7/12/2016
230
230
6
7/19/2016
280
280
Mult Factor =
7
10/13/2016
170
170
Max. Value
8
1/10/2017
<
100
50
Max. Fred Cw
9
4/11/2017
190
190
10
7/18/2017
160
160
11
11/14/2017
350
350
12
1/9/2018
200
200
13
4/10/2018
250
250
14
7/10/2018
220
220
15
10/9/2018
<
100
50
16
1/8/2019
<
100
50
17
4/9/2019
<
100
50
18
7/9/2019
<
100
50
19
10/8/2019
160
160
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
158.9474
0.5708
19
1.37
350.0 ug/L
479.5 ug/L
-4-
NCO084387 RPA 2020, data
4/19/2020

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Date: 4/19/2020
FACILITY: Lee S. Duke WTP Outfall 001
NPDES PERMIT: NCO084387
Dissolved to Total Metal Calculator
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
Receiving Receiving Rec. Stream
NPDES Total Suspended Combined Combined Instream Instream
Effluent
Upstream Hard Avg (mg/L) =
25
EFF Hard Avg (mg/L) =
25
US EPA
Maximum Allowable Effluent Concentration
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
Dissolved
Metals
Translators- using
(MAEC) as a Total Metal
PARAMETER
Default Partition
=Dissolved Metal Translator
Chronic
Acute
Coefficients
Chronic
Acute
lug/,]
[ug/1]
streams
[ug/1]
[ug/11
Cadmium (d)
0.15
0.82
0.252
0.59
3.24
Cd -Trout streams
0.15
0.51
0.252
0.59
2.01
Chromium III (d)(h)
24
183
0.202
117.73
905.08
Chromium VI (d)
11
16
1.000
11.00
16.00
Chromium, Total (t)
N/A
N/A
Copper (d)(h)
2.7
3.6
0.348
7.88
10.47
Lead (d)(h)
0.54
14
0.184
2.94
75.49
Nickel (d)(h)
16
145
0.432
37.23
335.21
Ni - streams (t)
N/
s[Iver(d)(h,acute)
0.06
0.30
1.000
0.06
0.30
Zinc (d)(h)
36
36
0.288
126.73 125.71
Beryllium
6.5
65
1.000
6.5
65
Arsenic (d)
150
340
1.000
150
340
(d) = dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(h) = hardness -dependent dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(t) = based upon measurement of total recoveable metal. See 15A NCAC 02B .0211 for more information.
The Human Health standard for Nickel in Water Supply Streams is 25
mg/L which is Total Recoverable metal standard.
The Human Health standard for Arsenic is 10 µg/L which is Total Recoverable metal standard.
Stream
Stream
Solids
Hardness
Hardness
Wastewater
Wastewater
Upstream
Hardness
summer
summer 7010
1010
Flow Limit
-Fixed Value-
chronic
Acute
Concentration
Concentration
Hardness
Average
7010 (CFS)
(MGD)
[MGD]
[MGD]
(mg/L)
(mg/L)
(mg/L)
(Chronic)
(Acute)
Average (mg/L)
(mg/L)
1.8000
1.1613
0.9742
0.6050
10
25.000
25.000
34.2510
38.3090
25
25

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit No. NC0084387
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/1
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
2B.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.136672-[ln hardness] (0.041838)} e^{0.9151 [In hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness] (0.041838)} e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[1n hardness] (0.041838)} • e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute
WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-4.705}
Nickel, Acute
WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 e^{0.8460[ln hardness]+0.0584}
Page 1 of 4

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit No. NCO084387
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit No. NCO084387
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
_ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q 10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1 Q 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + { [Kpo] [ss('+a>] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q 10 + Qw) (Cwgs) — (s7Q 10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q 10)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Permit No. NC0084387
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
25
Default Value
[Total as, CaCO3 or (Ca+Mg)]
Average Upstream Hardness (mg/L)
25
Default Value
[Total as, CaCO3 or (Ca+Mg)]
7Q10 summer (cfs)
1.8
NPDES file and RIMS
1Q10 (cfs)
0.9742
RPA collection, NPDES file and
RIMS
Permitted Flow (MGD)
Flow not limited; Maximum
0.605
Monthly Average used per WTP
strategy
Date: April 19, 2020
Permit Writer: Derek C. Denard
Page 4 of 4

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
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DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Unariotte uaserver, i ne
Feb. 13, 2020
Miscellaneous Notices
PUBLIC NOTICE North Carolina Environmental Management Commission/NPDES Unit
1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES
Wastewater Permit NC0084387 Lee S. Dukes WTP The North Carolina Environmental
Management Commission proposes to issue a NPDES wastewater discharge permit to the
person(s) listed below. Written comments regarding the proposed permit will be accepted
until 30 days after the publish date of this notice. The Director of the NC Division of Water
Resources (DWR) may hold a public hearing should there be a significant degree of public
interest. Please mail comments and/or information requests to DWR at the above address.
Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC to review
information on file. Additional information on NPDES permits and this notice may be found
on our website: http://deq.nc.gov/about/divisions/water-resources/water-resources-
permits/wastewater-branch/npdes-wastewater/public-notices,or by calling [phone].
Charlotte Water applied to renew NPDES permit NC0084387 for the Lee S. Duke WTP, 7980
Babe Stillwell Farm Rd, Huntersville, Mecklenburg County, discharging filter -backwash
wastewater to McDowell Creek, Catawba River Basin. LP4562225
Show results beginning at page:

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB >
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v zuzu Ivorin k-,aronna rress -)ervice I Please be sure to read our User Agreement
.(/static/mspn/docs/user agreement_nc.pdf).

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 17, 2020
MEMORANDUM
To: Clinton Cook [[e-mail]]
NC DEQ / DWR / PWS Regional Engineer
Mooresville Regional Office
From: Derek C. Denard, Environmental Specialist
DWR / NPDES / Expedited and Compliance Permitting
Central Office, Raleigh (919-707-3618)
Subject: Review of Discharge to Surface Waters Designated Water Supply (WS)
• McDowell Creek [11-115-(1.5)], WS-IV,
03-08-33 [14UC: 030501011401] Catawba
■ conventional water treatment facility filter backwash & sedimentation basin
for: Renewal of NPDES Permit NCO084387
Charlotte Water — Lee S. Duke, Jr. WTP
Mecklenburg County
Please provide your comments by March 13, 2019 [email OK]
RESPONSE:
I concur with the issuance of this permit provided the Permittee properly operates and
maintains the facility; the Permittee meets the stated effluent limits prior to discharge; and the
discharge does not contravene the designated water quality standards.
I concur with issuance of the above permit provided the following conditions are met:
Samples collected and measurements taken, as required by the permit, shall be
representative of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is representative of the discharge for the period of
time that the sample represents. If effluent water characteristics fluctuate such that a sinLyle
sample cannot represent the period of time that the sample is intended to represent,
additional samples shall be collected.
I oppose the issuance of the above permit based on reasons stated below, or attached:
Signed: Date: 1 2e cc: Me
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
ertm�a� 919.707.9000

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
From: Denard, Derek
To: Cook, Clinton; Kaufman, Tammv
Subject: RE: Review of Discharge to WS waters - Renewal of NPDES Permit NCO084387 - Charlotte Water — Lee S. Duke,
Jr. WTP
Date: Thursday, March 12, 2020 2:40:00 PM
Attachments: nudes standard conditions - 20111109.2.odf
Clint,
Thanks for the comments.
FYI. The NPDES permit standard conditions require representative sampling (see attached). We don't
usually include the standard conditions with a draft individual permit since it is public noticed,
reviewed and approved separately.
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard&ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Cook, Clinton <[e-mail]>
Sent: Thursday, March 12, 2020 2:25 PM
To: Denard, Derek <[e-mail]>; Kaufman, Tammy <[e-mail]>
Subject: FW: Review of Discharge to WS waters - Renewal of NPDES Permit NCO084387 - Charlotte
Water— Lee S. Duke, Jr. WTP
Mr. Denard and Ms. Kaufman,
I appreciate the opportunity to review the subject draft NPDES permit and have attached an
electronic copy of the memorandum describing my response. [The file name is NCO084387 (Lee
Duke WTP).pdf.] Please also find the entire package attached.

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
If you have any questions or need any additional information, please let me know.
Thanks,
Clint
Clinton O. Cook, PE
Regional Engineer
Division of Water Resources — Public Water Supply Section
North Carolina Department of Environmental Quality
704 663 1699 office
704 663 6040 fax
clinton.cookUncdenr.gov
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Denard, Derek
Sent: Monday, February 17, 2020 5:04 PM
To: Cook, Clinton <clinton.cookCcDncdenr.gov>
Subject: Review of Discharge to WS waters - Renewal of NPDES Permit NC0084387 - Charlotte Water
— Lee S. Duke, Jr. WTP
Clinton,
Please find the attached memo and draft permit for review of discharge to WS waters. This is for the
renewal of NPDES Permit NC0084387 for Charlotte Water's Lee S. Duke, Jr. WTP.
If you have any questions, please let me know.
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denardCa ncdenr.gov
N. C. Division of Water Resources

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
NPDES PERMIT NEW / RENEWAL
DRAFT / FINAL
CHECK LIST
Permittee
Charlotte Water
Facility
Lee S. Dukes WTP
Permit No.
NCO084387
Stream Class
WS-IV; CA
Regional Office
MRO
Permit Writer
Derek Denard
Permit Drafting Initiated [BIMS Events] review application for completeness)
01/10/2020
RO staff report requested [BIMS Events], sent email to:
Cory Basinger [[e-mail]]; Wes Bell [[e-mail]]
02/17/2020
RO staff report received [BIMS Events] :
No comments
EAA Review (new or expanding)
NA
Draft Permit
unknown
Create/Edit GIS Map
unknown
Update/ Create Permit Outfall (Lat/Lon, HUC code, etc. [BIMS]
unknown
Data/RPA Review
Final 4/19/2020
Add. Info. Requested [BIMS Events] :
NA
Add. Info. Received [BIMS Events]:
NA
Complete Draft Permit
2/10/2020
Draft Fact Sheet & Fact Sheet Binder
unknown
Draft Cover Letter
unknown
Proof Read for Peer Review
unknown
Submit Cover, Permit, Map, Factsheet Binder (including Application, Add. Info.) for Peer Review
by Emily Phillips
06/03/2020
Peer Review Completed
06/05/2020
Proof Read Draft for Public Notice
unknown
Prepare Public Notice Statement
unknown
Updated Public Notice System
unknown
Submitted for Public Notice on
02/10/2020
Region comments on draft requested to (see draft to whom list):
Cory Basinger [[e-mail]]; Wes Bell [[e-mail]]
02/17/2020
Region comments on draft received from:
No Comments
Draft to additional reviewers ATB [BIMS Events]:
hannah.headrick ncdenr. ov; [e-mail]
02/17/2020
Draft from additional reviewers ATB [BIMS Events]:
No comments
Draft to additional reviewers WOCG [BIMS Events]:
Maureen.Kinne ncdenr. ov
02/17/2020
Draft from additional reviewers WOCG [BIMS Events]:
Maureen.Kinne ncdenr. ov
No comments
If stream class WS, Draft to additional reviewers PWS (see draft to whom list) [BIMS Events]:
Clinton Cook
02/17/2020
If stream class WS, Draft form additional reviewers PWS [BIMS Events]:
03/12/2020
Other agency comments re uested(see draft to whom list, for S —DMF / Shellfish)[BIMS Events]:
02/17/2020
Farmer, Richard <Richard.Farmer@ mecklenburgcountync.gov>
Other agency comments received [BIMS Events] :
No comments
Newspaper Notice Received (add to factsheet binder)
Unknown
Public notice published [BIMS Events]
02/13/2020

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
BIMS Scheduled Issuance Date [BIMS Events - automatic]
Permit Effective Date for Final
Expiration Date
Prepare Final Permit
Finalize Factsheet & Binder
Prepare Final Cover Letter
Final to DocuSign (proof read):
Add (3) Document packages to the Envelope Page to send to John- Please upload in the following order:
1. Cover Letter, Draft Permit, Map (combined into one file), Boilerplate
2. Fact Sheet, plus supporting documents in one file (called "Fact Sheet Binder"):
i. PDF copy of Application
ii. RPA and supporting data sheet (see Tips section)
iii. All calculations for limits
iv. Emails (see Tips section)
V. Any comments received
vi. Affidavit of Publication (scanned copy)
vii. WET testing and Monitoring summary
viii. Compliance Summary
ix. Any other pertinent information supervisor needs to look at
3. Copy of Previous Effective Permit (also include necessary versions)
After signing:
1. Permit writer receives an email from DocuSign that states the Document has been completed.
2. Click View Completed Documents.
3. While viewing the documents in DocuSign, click Download icon which appears above the
document. Download as separate PDFs to your personal permit file folder on the H drive or OneDrive.
4. Permit writer prints and sends out 3 copies:
a. To Permittee: permit, cover letter, map, boilerplate
b. To NPDES File Room: cover letter, permit, map, fact sheet
c. To Central Files: cover letter, permit, map, boilerplate, fact sheet
5. Permit writer imports e-copy of cover letter and final permit (signed) to Laserfiche.
6. Permit writer imports e-copy of Fact Sheet (i.e. all documents) to Laserfiche.
7. Permit writer imports WORD version of Final Permit into Sharepoint or the S: Drive under SWP-Point
Source>NPDES>Permit Files> (find permit number, import your files as a file folder labeled as
"permit number_year", or create a file for the current renewal year and import your files into that folder)
8. Permit writer imports WORD version of Fact Sheet into Sharepoint or S: Drive. (same instructions as #7)
9. Charles processes permits as usual and puts a stapled Permittee copy in the mail basket "Already scanned
in Laserfiche". Also, if stapled, Wren knows it has already been put in Laserfiche.
10. Charles puts NPDES File Room copy in the NPDES File Room. Charles gives Central Files copy of
the permit to permit writer after updating BIMS to QA/QC.
11. To QA/QC:
-Once Charles issues the permit in BIMS, then Permit Writer goes into BIMS>Tasks>Maintain
Permit>Input Permit Number>Outfall>Highlight outfall>Select Maintain>Limits>Check that limits match
what is in the permit
12. Permit writer responds via email to Charles Weaver that QA/QC is completed.
13. Permit writer puts hard copy of permit in Central Files basket at end of hall to send to Central Files.
Email Final to the following recipients: MRO / Corey Basinger [[e-mail]], Edward Watson
[[e-mail]]; Andrew Pitner [[e-mail]]; Wes Bell [[e-mail]]; Aquatic Toxicology Branch / Hannah
Headrick [[e-mail]]; Cindy Moore [[e-mail]]; Wastewater Operator Certification Group / Maureen Kinney
[[e-mail]]; Richard Farmer [[e-mail]]; McIntire, Mark D, Duke Energy
Corporation [[e-mail]]; David Penalva, NOVA [[e-mail]]; Keith Rice, NOVA [[e-mail]]

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
From: Denard. Derek
To: Banick, Dave; Sasser. Gabe
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes WTP
Date: Friday, February 28, 2020 11:21:00 AM
David,
Get whoever you can to sign them and mail them to the mail service center address on the form.
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denardancdenr.aov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Banick, Dave <[e-mail]>
Sent: Friday, February 28, 2020 7:39 AM
To: Denard, Derek <[e-mail]>; Sasser, Gabe <[e-mail]>
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes
WTP
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ov
Derek,
A few questions about the amendments you asked for from the oldest reports dated 7/2015, 10/2015 and 1/2016.
1. Our IT staff that handles our eDMR submittals says we cannot use the eDMR system for these due to their age.
2. These reports only had a signature required from the ORC, can I still submit them to you with only my
signature?
3. Would it be ok to scan them and email them to you or do you need a physical copy through the mail?
Thanks,
David Banick / Lee S. Dukes WTP Supervisor
CHARLOTTE WATER
7980 Babe Stillwell Farm Rd. / Huntersville N.C. 28078
P:704.948.6954 x 260 / C:704.634.9104 / Fax:[phone] / charlottewater.org

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
From: Denard, Derek <derek.denardna ncdenr.gov>
Sent: Wednesday, February 12, 2020 4:23 PM
To: Banick, Dave <dbanick(@ci.charlotte.nc.us>; Sasser, Gabe <gsasser(@ci.charlotte.nc.us>
Subject: Re: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes
WTP
Gabe,
Thanks for the information about the units.
I don't know how I managed to copy and paste the Phosphorus data line in the second table I set you. Please
ignore it.
I am not sure we are taking paper DMRs anymore. For the corrected DMRs that pre -date eDMR, see if you
can create an entry in eDMR. The eDMR website will upload that corrected data to our database. If eDMR
does not work for the older ones, then correct it on paper and send it to me. I will have to find a home for it
in our files. I'm thinking Laserfiche so the regional office can view it too.
For the DMRs that were after eDMR, please do the correction through eDMR.
Thanks,
Derek Denard
Environmental Specialist
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard(a)ncdenr.aov
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Banick, Dave <[e-mail]>
Sent: Wednesday, February 12, 2020 12:13 PM
To: Denard, Derek <derek.denard(@ncdenr.gov>; Sasser, Gabe <gsasserPci.charlotte.nc.us>
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes
WTP
CAUTION:sternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ov
Derek,
The fluoride errors from your email yesterday should have been reported in mg/I.

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
The Copper, Iron and Manganese errors should have been reported in ug/I.
We do not have a record of the Phosphorus result your showing from 7/26/15. We do have records and reported a
Phosphorus sample on the DMR from 7/14/15 with a result of <0.10. Do you know where the result for 7/26/15
came from?
For the amendments we will be sending in, is it acceptable for them to be in the old format we were using before
the eDMR program started? It would match what you have currently on file for those dates and would allow us to
re -submittal quicker.
Thank you for your help.
David Banick / Lee S. Dukes WTP Supervisor
CHARLOTTE WATER
7980 Babe Stillwell Farm Rd. / Huntersville N.C. 28078
P:704.948.6954 x 260 / C:704.634.9104 / Fax:[phone] / charlottewater.ora
From: Denard, Derek <derek.denard(a ncdenr.gov>
Sent: Tuesday, February 11, 2020 12:47 PM
To: Banick, Dave <dbanick( ci.charlotte.nc.us>; Sasser, Gabe <gsasser( ci.charlotte.nc.us>
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NC0084387 Charlotte Water - Lee S Dukes
WTP
Dave,
There is no time frame for the DMR amendments, but I will need you to verify the units for the listed data within
30 days (by the end of public notice for the draft permit). An email acknowledging what the correct parameters are
would be fine. I would like to finalize the permit and factsheet at that point.
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard(a)ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Banick, Dave <dbanick(@ci.charlotte.nc.us>

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Sent: Tuesday, February 11, 2020 12:33 PM
To: Denard, Derek <derek.denard(a ncdenr.gov>; Sasser, Gabe <gsasser(a ci.charlotte.nc.us>
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes
WTP
'Txternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ov
Derek,
At first glance it appears to be a units mistake. I will go back and review the reports from the dates you provided,
however it will take some time as these dates will be archived on paper copies. What is your time frame for us to
have any amendments ready to submit?
Thank you.
From: Denard, Derek <derek.denard(@ncdenr.gov>
Sent: Tuesday, February 11, 2020 12:10 PM
To: Sasser, Gabe <gsasser(@ci.charlotte.nc.us>
Cc: Banick, Dave <dbanick(@ci.charlotte.nc.us>
Subject: RE: [External] Re: [EXT] Data entry errors for units of measure - NCO084387 Charlotte Water - Lee S Dukes
WTP
Gabe,
Here they are. Sorry I missed that.
Parameter
Sample
UoM
Value
Modifier
Date
Comments
00665 - Phosphorus, Total (as P)
Grab
mg/I
WAIVER
7/26/2015
00951- Fluoride, Total (as F)
Grab
ug/I
0.19
7/14/2015
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.21
10/13/2015
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.11
1/12/2016
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.23
7/12/2016
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.28
7/19/2016
units should be
mg/I?
00951 - Fluoride, Total (as F)
Grab
ug/I
0.17
10/13/2016
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.1
LESSTHAN
1/10/2017
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.19
4/11/2017
units should be
mg/I?
00951- Fluoride, Total (as F)
Grab
ug/I
0.16
7/18/2017
units should be
mg/I?
01042 - Copper, Total (as Cu)
Calculated
mg/I
2
LESSTHAN
4/10/2018
units should be
ug/I?
01045 - Iron, Total (as Fe)
Calculated
mg/I
100
4/10/2018
units should be
ug/I?
01055 - Manganese, Total (as
Calculated
mg/I
60
4/10/2018
units should be
Mn)
ug/I?

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard(2ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sasser, Gabe <gsasser(@ci.charlotte.nc.us>
Sent: Tuesday, February 11, 2020 11:37 AM
To: Denard, Derek <derek.denard @ncdenr.gov>
Cc: Banick, Dave <dbanick(@ci.charlotte.nc.us>
Subject: [External] Re: [EXT] Data entry errors for units of measure - NC0084387 Charlotte Water - Lee S Dukes
WTP
verify. Send all suspi
What are the dates associated with the results below? I included Dave Banick who is the supervisor at Dukes WTP.
Sent from my iPhone
On Feb 11, 2020, at 11:26 AM, Denard, Derek <derek.denard(@ncdenr.gov> wrote:
Gabe,
I found a few data points that I believe were reported in the wrong units (see below). The one for
copper may effect limitation, but I assumed that is was <2 lag/I. Please verify what the units are for
these entries and make the necessary amendments to DMRs. I should have a draft permit for you this
week.
Parameter
UoM
Value
Modifier
Comments
00951- Fluoride, Total (as F)
ug/I
0.19
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.21
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.11
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.23
units should be mg/I?

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
00951- Fluoride, Total (as F)
ug/I
0.28
units should be mg/I?
00951 - Fluoride, Total (as F)
ug/I
0.17
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.1
LESSTHAN
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.19
units should be mg/I?
00951- Fluoride, Total (as F)
ug/I
0.16
units should be mg/I?
01042 - Copper, Total (as Cu)
mg/I
2
LESSTHAN
units should be ug/I?
01045 - Iron, Total (as Fe)
mg/I
100
units should be ug/I?
01055 - Manganese, Total (as Mn)
mg/I
60
units should be ug/I?
Thanks,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denardancdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
From: Sasser, Gabe
To: Denard, Derek
Cc: Bell, Wes; Jarrell, Jackie
Subject: RE: [External] RE: [EXT] Draft NPDES Permit NCO084387 - Charlotte Water - Lee S. Dukes WTP
Date: Wednesday, March 11, 2020 11:46:49 AM
EXLerndl email. b U1 Uptll dLLdU1111t111S unless you verify. Send all suspicious email as an
attachment to reoort.spamCcDnc.gov
Derek,
Thanks for reviewing my comments and responding so quickly. Regarding signatory authority, John
Huber and myself have completed the "Delegation for Signature Authority" form and plan to mail
that off to the Water Quality Permitting Section tomorrow morning.
We also plan to complete the following link Online Document Upload Form to begin serving as
eDMR submitters for both of our WT plants (Lee Dukes — NCO084387 and Franklin — NC0084549).
We will be assuming this duty from Jackie Jarrell. I'm not sure if you are the point person on that but
just wanted you to be aware of our plans moving forward.
Gabe Sasser / Operations Manager
CHARLOTTE WATER
5200 Brookshire Blvd. / Charlotte, NC 28216
P:704-399-2142 / C:704-507-5267 / charlottewater.org [charlottewater.org]
From: Denard, Derek <[e-mail]>
Sent: Friday, March 6, 2020 3:55 PM
To: Sasser, Gabe <[e-mail]>; Banick, Dave <[e-mail]>
Cc: Basinger, Corey <[e-mail]>; Bell, Wes <[e-mail]>; Headrick,
Hannah <hannah.head [e-mail]>; Farmer, Richard
<Richard.Farmer@ mecklenburgcountync.gov>
Subject: RE: [External] RE: [EXT] Draft NPDES Permit NCO084387 - Charlotte Water - Lee S. Dukes
WTP
Gabe,
In response to your comments for the draft permit:
• Since this facility is a conventional technology WTP and has a discharge greater than 0.05
MGD, Total Kjeldahl Nitrogen, Nitrate/Nitrite, and Total Nitrogen are required by the WTP
permitting strategy.
9 According to the WTP permitting strategy, WET testing is a requirement for all conventional

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
technology water treatment plants. Chronic WET testing is required for instream waste
concentrations greater or equal to 0.25% (IWC >/= 0.25%). If you are interested, reduced
annual monitoring is available under coverage of general permit NCG590000.
• For Fluoride monitoring the following footnote can be inserted for the final:
Total Fluoride: This requirement applies only to wastewater discharges from plants that
backwash with fluoridated finished water.
• The supplement to coverage page (2 of &) will be corrected to indicate "four (4) conventional
filters".
If you have any questions, please contact me.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard(cDncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sasser, Gabe <gsasser(@ci.charlotte.nc.us>
Sent: Friday, March 06, 2020 3:01 PM
To: Denard, Derek <derek.denard(@ncdenr.gov>; Banick, Dave <dbanick(@ci.charlotte.nc.us>
Cc: Basinger, Corey <corey.basinger(@ncdenr.gov>; Bell, Wes <wes.bell(@ncdenr.gov>; Headrick,
Hannah <hannah.head rick(@ncdenr.gov>; Kinney, Maureen <Maureen.Kinne)J(@ncdenr.gov>;

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
Farmer, Richard <[e-mail]>
Subject: [External] RE: [EXT] Draft NPDES Permit NCO084387 - Charlotte Water - Lee S. Dukes WTP
External email. Do not click links ments unless you verify. Send all suspicious email as an
�achment to reoort.spam(cDnc.gov
Hi Derek,
I hope you are doing well today. After reviewing draft permit NC0084387, I would like to
respectfully ask that the quarterly parameters of Total Fluoride, Total Phosphorus, Total Kjeldahl
Nitrogen, Nitrate/Nitrite, Total Nitrogen and Chronic Whole Effluent Toxicity be removed from the
Lee S. Dukes water treatment plant (WTP) monitoring requirements. Outfall 001 has demonstrated
a history of non -detect to very low detection levels for these parameters as indicated in the attached
spreadsheet which covers the last 2 years of monitoring results.
In particular, there is strong justification for removing Total Fluoride from the quarterly permit
requirements listed on page 3 of the draft (Effluent Limitations and Monitoring Requirements).
While fluoride ion is added to finished water at Dukes WTP, it is added downstream from the
filtration process and therefore will not contribute any fluoride to the spent filter backwash water
processed and then discharged at Dukes Outfall 001. As indicated in the attached spreadsheet, the
highest observed concentration of Total Fluoride over the last 2 years at Outfall 001 is 160 ppb. In
contrast, our target drinking water concentration is 0.7 mg/L or 700 ppb.
Given that Dukes WTP is categorized as a physical chemical facility, we would greatly appreciate the
removal of Chronic WET testing from the quarterly permit requirements. We have consistently
passed this test at Outfall 001 as demonstrated in the attached spreadsheet. Considering our history
of passing this analysis coupled with the challenges of sample collection, shipping and costliness for
continuing to monitor this parameter, we would like to see this requirement removed from the
permit.
Also, I noticed a correction that needs to be made on page 2 of the draft. In bullet 4, the Dukes
treatment process includes 4 conventional filters instead of 2.
Derek, I certainly appreciate your thoughtful consideration with respect to our requested
adjustments to draft permit NC0084387. We would be more than happy to discuss this matter with
you at a time of your convenience. Thanks and have a great weekend.
Gabe Sasser / Operations Manager
CHARLOTTE WATER
5200 Brookshire Blvd. / Charlotte, NC 28216
P:704-399-2142 / C:704-507-5267 / charlottewater.org[charlottewater.org]
From: Denard, Derek <[e-mail]>
Sent: Monday, February 17, 2020 4:44 PM

DocuSign Envelope ID: 99CAD692-D859-4A89-B86E-F54550E08CEB
To: Banick, Dave <dbanick(@ci.charlotte.nc.us>; Sasser, Gabe <gsasser(@ci.charlotte.nc.us>
Cc: Basinger, Corey <corey.basinger(@ncdenr.g-ov>; Bell, Wes <wes.bell(@ncdenr.gov>; Headrick,
Hannah <hannah.head rick(@ncdenr.gov>; Kinney, Maureen <Maureen.Kinney(@ncdenr.gov>;
Farmer, Richard <Richard.Farmer(@mecklenburgcountync.gov>
Subject: [EXT] Draft NPDES Permit NCO084387 - Charlotte Water - Lee S. Dukes WTP
Please find the attached draft for NPDES Permit NCO084387 - Charlotte Water - Lee S. Dukes WTP.
If you have questions concerning the draft, please contact me at 919-707-3618, or via e-mail
at
derek.denard(@ncdenr.gov.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 707 3618 office
919 707 9000 main DWR
derek.denard&ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.