NC0046345_Fact Sheet_20220316

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FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require
full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile
home parks, etc) that can be administratively renewed with minor changes, but can include
facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing,
instream monitoring, compliance concerns).
Basic Information for Ex edited Permit Renewals
Permit Writer / Date
Brianna Young 8/6/2021
Permit Number
NC0046345
Facility Name / Facility Class
Reidsville WTP / PC-1
Basin Name / Sub -basin number
Cape Fear / 03-06-01
Receiving Stream / HUC
UT to Troublesome Creek / 030300020203
Stream Classification / Stream Segment
WS-V; NSW / 16-6-(3)
Does permit need Daily Maximum NH3
N/A
limits?
Does permit need TRC limits/language?
Already present
Does permit have toxicity testing? IWC (%) if
so
Yes; IWC = 90%
Does permit have Special Conditions?
Yes — tox reopener
Does permit have instream monitoring?
Yes — upstream hardness
Is the stream impaired (on 303(d) list)?
Yes - DO
Any obvious compliance concerns?
Yes — See Section 2 below
Any permit mods since last permit?
No
New expiration date
4/30/2026
Comments on Draft Permit?
Yes — See Section 7 below
Section 1. Facility Overview:
The Reidsville WTP operates a conventional WTP designed for a potable flowrate of 9.0
MGD. The facility generates backflow with a continuous discharge. The maximum,
monthly average discharge between February 2018 and January 2021 was approximately
0.385 MGD.
Section 2. Compliance History (January 2016 to March 2021):
• 2 NODs for TRC limit violations
• 2 NOVs for TRC limit violation
• 2 NOVs for copper limit violations
• 2 NODs for TSS limit violations
• 4 NOVs for TSS limit violations
• 4 NOVs for frequency violations (1 each for TRC, pH, TSS, turbidity)
• Failed 9 of the last 12 tox tests (failed 15 since January 2017)
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303(d) listing:
I16-6{3)
Troublesome Creek
From dam at lake Reidsville to Haw River
IClassificat ion
C;NSW
Length or Area I
2 U n its
IFW Miles
(Previous AU Number)
ent Criteria Status Reason for Rating
Exceeding Criteria
1> 10% and >90 conf
Parameter of Interest
(Dissolved Oxygen (4 mg/I, AL, FW)
Category
Section 3. RPA:
The maximum monthly average flow between February 2018 and January 2021 was
approximately 0.385 MGD.
• Copper — RP; limits with monthly monitoring applied
• Aluminum — No RPA required per 2012 WTP guidance; monitoring maintained
as alum has the potential to be discharged
• Iron — No RPA required as there is no longer a water quality standard; Monitoring
removed as permittee indicated ferrous sulfate is not used in the treatment process
and previous permit had monitor only (per current WTP guidance)
• Manganese — No RPA required as there is no longer a water quality standard;
Monitoring reduced to quarterly as the facility discharges to WS-class waters (per
current WTP guidance)
• Fluoride — RP; limits with monthly monitoring applied
• Zinc — RP; limits with monthly monitoring applied (monitoring optional)
Section 4. NCG590000 General Permit Eligibility:
• They use conventional technology, therefore they are eligible
• They have failed 9 of the last 12 tox tests, therefore they are not eligible by tox
standards
• They do not discharge to HQW or ORW waters, therefore they are eligible
• They have limits for multiple parameters, therefore they are not eligible
• Conclusion: They are not eligible for the NCG59
Section 5. Changes from previous permit to draft:
• Updated eDMR footnote in A(1) and language in A(5)
• Updated outfall map
• Added facility grade in A(1)
• Updated language on the Supplement to Permit Cover Sheet
• Updated receiving stream characteristics on Supplement to Permit Cover Sheet
based on DEQ stream classifications website
• Components list updated on Supplement to Permit Cover Sheet
• Added units of measure in A(1)
• Turbidity monitoring reduced to 2/month in A(1) as not a limited parameter
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• Removed monitoring for total iron in A(1) per current WTP guidance and since
there is no longer a WQS
• Monitoring increased to monthly for copper, fluoride, and zinc in A(1)
• Limits added for fluoride and zinc in A(1) per RPA
• Limits for copper updated in A(1) per RPA
• Effluent hardness sample changed to grab in A(1) per current WTP guidance
• Updated footnotes in A(1)
• Updated tox language in A(2) — test changed from monitor only to limit as facility
has history of failed toxicity tests
• Compliance schedule added as A(4) as new limits for copper, fluoride, and zinc in
A(1)
Section 6. Changes from draft to final:
•
Section 7. Comments received on draft permit:
• Zach Thomas (ATB; via email 5/12/21): Everything for tox looks good.
• Scott Jewel (City of Reidsville; via email 6/17/21):
o Requests permit remain as monitoring for toxicity in lieu of a permit limit
• Working with ATB to find the culprit causing toxicity failures.
• Todd Crawford provided additional information concerning
interference for ultra -low chlorine testing. Cindy Moore reviewed
toxicity sampling data and feels permittee is very close to finding a
solution to the problem.
• Permittee will work with the toxicity labs and conduct multiple -
concentration testing, review of toxicity data SDS with chemical
suppliers and specifically the polymer.
• Permittee will contact other water plants in the triad that have
waste lagoons at their facilities and compare/contrast.
o Corrected DMRs are being processed so there should be sufficient
evidence justifies removing section A. (4) Schedule of Compliance
(Outfall 002) and all of the steps for corrective action (page 6 of 10).
• If this section remains in the final permit, on page 6 of 10 Section
A. (4) Schedule of Compliance (Outfall 002) should be updated to
reflect outfall 002 in lieu of the printed outfall 001.
• (Update before issuance- the Division gave the permittee an ample
amount of time to correct DMR data and the permittee chose not to
update. )
o Requests zinc remain optional as they do not use a zinc -based
orthophosphate.
• DWR Response:
o Toxicity monitoring: The Division appreciates the City's efforts to
determine the cause(s) of the toxicity failures. However, although the City
is working on this issue, the need for the new monitoring test is still
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evident based on the history of past failures. Therefore, the limited test
will remain in the permit.
o New parameter limits and compliance schedule: remove if DMRs show
previous data was erroneous and RPA shows no potential (2022
UPDATE: Permittee did not submit new data.)
o Zinc: Scott Jewel of the City of Reidsville submitted information to the
Division stating that zinc -orthophosphate is not used and therefore zinc
monitoring should be optional. The Division acknowledges the permittee
does not use zinc -orthophosphate in their treatment, therefore monitoring
will return to optional.
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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/1
Cadmium, Acute
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151 [In hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[In hardness](0.041838)} • e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln 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}
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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}
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/WQBELs 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.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit
Writer compiles the following information:
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• Critical low flow of the receiving stream, 7Q10 (the spreadsheet
automatically calculates the 1Q10 using the formula 1Q10 = 0.843
(s7Q10, 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.
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) x (s7Q10, cfs *Avg. Upstream
Hardness, mg/L)
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10
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.
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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 =
Ctotal
1
1 + { [Kpo] [SSUU+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
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 = (s7Q10 + Qw) (Cwqs) — (s7Q10) (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 s7Q10)
s7Q10 = 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 s7Q10 may be incorporated as applicable:
1 Q 10 = used in the equation to protect aquatic life from acute toxicity
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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.
8. 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)
[Total as, CaCO3 or (Ca+Mg)]
29
BIMS
Average Upstream Hardness
(mg/L)
[Total as, CaCO3 or (Ca+Mg)]
23
BIMS
7Q10 summer (cfs)
0
BIMS
1Q10 (cfs)
0
BIMS
Permitted Flow (MGD)
0.385
Max monthly avg
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Rockingham Now
Advertising Affidavit
, 1921 Vance Street
Reidsville, NC 27320
[phone] Fax: [phone]
NCDEQ-DIVISION OF WATER RESOURCES
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
Account Number
4019534
Date
May 19, 2021
PO Number Order
Category
Description
0000719088
Public Notice
North Carolina Environmental Man-
agement Commission/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES
Wastewater Permit NC0046345
Reidsville WTP The North Carolina
Environmental Management Com-
mission 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 sig-
nificant degree of public interest.
Please mail comments and/or infor-
mation requests to DWR at the
above address. Interested persons
may visit the DWR at 512 N. Sails -
bury Street, Raleigh, NC 27604 to re-
view information on file. Additional
information on NPDES permits and
this notice may be found on our
website: http://deq.nc.gov/abaut/di
visions/water-resources/water-
resou rces•permits/wastewater-
branch/npdes-wastewater/public-
notices,or by calling [phone].
City of Reidsville [230 W Morehead
Street, Reidsville NC 27320] has re-
quested renewal of permit
NC0046345 for its WTP in Rocking-
ham County. This permitted facility
discharges filter -backwash waste-
water to an unnamed tributary (UT)
to Troublesome Creek in the Cape
Fear River Basin. Currently total re-
sidual chlorine, total fluoride, and to-
tal copper parameters are water
quality limited. This discharge may
affect future allocations in this seg-
ment of the UT to Troublesome
Creek.
Legal Notices
Public Notice North Carolina Environmental Management Commission/NPDES Unit 1617 Mail'
Publisher of the
Rockingham Now
Before the undersigned, a Notary Public duly commissioned. qualified, and authorized by
law to administer oaths, personally appeared the Publisher's Representative who by being
duly sworn deposes and says: that he/she is authorized to make this affidavit and sworn
statement: that the notice or other legal advertisement. a copy of which is attached hereto.
was published in the Rockingham Now on the following dates:
05/19/2021
and that the said newspaper in which such notice, paper document, or legal advertisement
was published. was at the time of-each/arid every such publication, a newspaper meeting all
the requirements and qualifications oj`Section 1-597ofthe 9erai Stat 1 of North
Carolina.
Sworn to and subscribed before me the 19th day of Ma
State of Virginia
County of Hanover
My commission expires:
Billing Representative
(Notary Pub
Richard A. Hundley
Notary Public
Commonwealth of Virginia
Notary Registration No. 7904041
Commission Exp. Jan 31, 2024
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

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wnoie tttluent 1 OXICIiy 1 esting ana seat Monitoring summary
Reddies River WTP NC0083291/001 County: Wilkes Region: WSRO Basin: YADO1 Mar Jun Sep Dec
Fthd24PF Begin: 3/1/2014 Ac P/F Monit: 90% Ft NonComp: 7Q10: PF: 0.063 IWC: Freq: Q
SOC_JOC:
1 F M A M 1 J A S 0 N D
2017 - - H - H H - - H
2018 - - H - - H - - H - - H
2019 - - H - - H - - H - - H
2020 - - H - - - - - - - - -
Reidsville Lake WTP -outfall 002 NC0046345/001 County: Rockingham Region: WSRO Basin: CPF01 Jan Apr Jul Oct
Ceri7dPF Begin: 7/1/2017 Chr Monit: 90% NonComp: 7Q10: PF: IWC: Freq: Q
SOC JOC:
J F M A M J J A S 0 N D
2017 Fail Pass - Fail Pass - -
2018 Fail - Pass - Fail Pass
2019 Fail - Pass Pass Fail Fail Fail Fail Fail Fail
2020 Pass - - Fail Fail Pass Fail - Pass -
2021 Fail - - - - -
Reidsville WWTP NC0024881/001 County: Rockingham Region: WSRO Basin: CPF01 Jan Apr Jul Oct
Ceri7dPF Begin: 6/1/2013 chr lim: 61% NonComp: Single 7Q10: 7.4 PF: 7.5 IWC: 61 Freq: Q
SOC JOC:
J F M A M J J A S 0 N D
2017 >100 - - Pass - Pass - Pass -
2018 Pass - - Pass - Pass - Pass -
2019 Pass - - Pass Pass Pass -
2020 Pass - - Pass Pass Pass -
2021 Pass - - - - -
REXAM, Inc.
Ceri7dPF
NC0087874/001
Begin: 12/1/2004 chr lim 90%
County: Guilford Region: WSRO Basin: CPF02 Feb May Aug Nov
NonComp: 7Q10: 0 PF: 0.001 IWC: 100 Freq: Q
SOC_JOC:
J F M A M J 1 A S 0 N
2017 - H - - H - - H - - H
2018 - H - - H - - H - - H
2019 - H - - H - H - - H
2020 - H - - H - - - - -
Rhodia, Inc.-Solvay-CH2M Hill NC0084638/001
Ceri7dPF Begin: 5/1/2016 chr lim: 90%
County: Gaston
NonComp: Single
Region: MRO
7Q10: 0.0
Basin: CTB37 Mar Jun Sep Dec
PF: 0.194 IWC: 100 Freq: Q
SOC_JOC:
J F M A M J J A S 0 N D
2017 H Pass Pass - - Pass - - Pass - - Pass
2018 - Pass - - Pass - - Pass - - Pass
2019 - H - - H - - H - - H
2020 - H - - H - - H - -
Legend: P= Fathead minnow (Pimphales oromelas). H=No Flow (facility is active). s = Split test between Certified Labs
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ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
MEMORANDUM
To:
NORTH CAROLINA
Environmental Quality
May 11, 2021
Jeff Bryan
NC DEQ / DWR / Public Water Supply
Winston-Salem Regional Office
From: Brianna Young
Compliance and Expedited Permitting Unit
Subject: Review of Draft NPDES Permit NC0046345
Reidsville WTP
Rockingham County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
June 11, 2021. If you have any questions on the draft permit, please contact me at 919-707-3619 or via
e-mail [[e-mail]].
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
RESPONSE: (Check one)
M'
Concur with the issuance of this permit provided the facility is operated and maintained properly,
the stated effluent limits are met prior to discharge, and the discharge does not contravene the
designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signed:
'yew t 0 A-%EOQ �• S' CD
Date:Sit.S- .
NORTH
D E _
Department of Environmental Uual6y
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

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Young, Brianna A
From: Thomas, Zachary T
Sent: Wednesday, May 12, 2021 11:23 AM
To: Young, Brianna A
Cc: Moore, Cindy
Subject: RE: NPDES Permits NC0046345 and NC0075965
Hi Brianna,
Everything for Tox looks good!
Thank you,
Zach Thomas
Environmental Specialist II
Aquatic Toxicology Branch
NCDEQ— Division of Water Resources
919-743-8439
Submit ATForms electronically to: [e-mail]
-TIE
.,.•
Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Young, Brianna A
Sent: Tuesday, May 11, 2021 3:32 PM
To: Thomas, Zachary T <[e-mail]>
Cc: Moore, Cindy <[e-mail]>
Subject: NPDES Permits NC0046345 and NC0075965
Good afternoon,
The Reidsville WTP (NC0046345) and Burnsville WTP (NC0075965) have been submitted for public notice this week.
Please provide any comments by June 11, 2021.
Thank you,
Brianna Young, MS
Environmental Specialist II
Compliance and Expedited Permitting Unit
NC DEQ/ Division of Water Resources
Office: 919-707-3619
[e-mail] (e-mail preferred during State of Emergency)
Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617
1

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.
2

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Young, Brianna A
From: Scott Jewell <[e-mail]>
Sent: Thursday, June 17, 2021 12:14 PM
To: Young, Brianna A
Cc: Boyd Hawley; Jesse S. Barnes; Jerry Rothrock; Thomas, Zachary T; Moore, Cindy
Subject: [External] Formal Response to Draft Permit NC#0046345
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Brianna,
Thank you for the emaiis and the phone call regarding our permit renewal NC#0046345.
I also spoke with Zach Thomas yesterday at the Aquatic Toxicology Branch and
additionally had a conference call with Zach and Cindy Moore yesterday
afternoon. Collectively, we are trying to figure out the culprit that is causing us to fail
toxicity. They were extremely helpful in answering some of my questions and providing
some guidance on pursuing the solution of passing toxicity. Also, Todd Crawford has
provided additional information concerning interference for our ultra -low chlorine
testing. Cindy Moore has reviewed our toxicity sampling data and feels that we are very
close to finding a solution to our problem. I plan to work with the toxicity labs and
conduct multiple -concentration testing, review of toxicity data SDS with our chemical
suppliers and specifically our polymer. I will also contact other water plants in the triad
that have waste lagoons at their facilities and compare/contrast. With that said, I would
respectfully request that our permit remain as monitoring for toxicity in lieu of a permit
limit.
I am processing the eDMR's and the hard copies of the non -electronic DMR's that need
to be revised. As instructed, I will scan and email the hard copies to you at the same
time I submit them to the State with a letter of explanation. Once this is completed,
there should be sufficient evidence that these corrected reporting errors would justify
removing section A.(4) Schedule of Compliance (Outfall 002) and all of the steps for
corrective action (page 6 of 10).
As we discussed, we do not use a zinc -based orthophosphate. So, I am respectfully
requesting that zinc remain as an optional testing parameter.
If this section remains in the final permit, on page 6 of 10 Section A.(4) A.(4) Schedule
of Compliance (Outfall 002) should be updated to reflect outfall 002 in lieu of the printed
outfall 001.
Respectfully submitted,
Scott Jewell
1

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
e, six pewee
SCOTT JEWELL
SUPERINTENDENT/ORC
WATER TREATMENT PLANT
CITY OF REIDSVILLE
PUBLIC WORKS DEPARTMENT
278 Reid Lake Road 1 Reidsville, NC 27320
THE CITY OF w:336-342-40011 c: 336-213-73731 fax:[phone]
I_eic1s_.:11e Pursuant [e-mail] I http://reidsvillenc.gov
NORTH CAILBLEVA Follow Us — Facebook
North Carolina
General
Statues, Chapter 132, email correspondence to and from this address may be
considered public record under the North Carolina Public Records Law and may
possibly be disclosed to third parties.
2

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
f
Cover Letter
To:
NCDENR/DWQ/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
From:
City of Reidsville
Renewal NPDES Permit # NC0046345
278 Reid Lake Road
Reidsville, NC 27320
Oct 14, 2020
RECEIVED
OCT 2 8 2020
NCDEQ/DWRINPDES
Enclosed with this cover letter please find the completed application for the
renewal of NPDES Permit # NC0046345.
Also enclosed is a narrative of the solids handling plan for the permit.
Please contact me directly at [phone] or email at [e-mail]
should you have any questions regarding this renewal.
Respectfully,
Charles Scott Jewell
Plant Superintendent/Plant ORC/NPDES ORC

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
r
Solids Handling Plan
To:
NCDENR/DWQ/NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
From:
City of Reidsville
Renewal NPDES Permit # NC0046345
278 Reid Lake Road
Reidsville, NC 27320
Oct 14, 2020
The sludge/solids for the Reidsville WTP is generated from waste alum sludge
from the sedimentation basins and filter backwash water. This waste is gravity
feed to two 650,000 gallon sludge lagoons. Waste from the lagoons 1) is
pumped to an earthen drying bed and then the solids are hauled by a private
contractor or 2) is directly pumped from the lagoon into tankers and land
applied by a private contractor as needed.
Please contact me directly at [phone] or email at [e-mail]
should you have any questions regarding this renewal.
Respectfully,
Charles Scott Jewell
Plant Superintendent/Plant ORC/NPDES ORC

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
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
NC000046345
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 City of Reidsville
Facility Name Reidsville Water Treatment Plant
Mailing Address 278 Reid Lake Road
278 Reid Lake Road Reidsville
State / Zip Code NC/27320
Telephone Number 336-342-4002
Fax Number 336-349-2880
e-mail Address [e-mail]
2. Location of facility producing discharge:
Check here if same as above X
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 Chuck Smith
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
4. Ownership Status:
1100 Vance Street
Reidsville
NC/27320
336-349-1050
336-349-2880
Federal ❑ State ❑
Private ❑ Public X
Page 1 of 3 Version 5/2012

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
i.
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
5. Type of treatment plant:
X 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:
Aluminum sulfate is used for coagulation, potassium permanganate is used to control iron
and manganese. Polymer is added as a settling agent. Sulfuric acid and caustic soda is
used for pH adjustment.
8. Describe the wastewater and the treatment process(es) for wastewater generated by the
facility:
The wastewater originates from backwashing filters and cleaning basins. The wastewater is
held in two 650,000 gallon lagoons for settling and decant is discharged to the outfall and
sludge is land applied. Dechlorination is added as needed prior to discharge to the outfall.
9. Number of separate discharge points: 1
Outfall Identification number(s) 002
10. Frequency of discharge:
Continuous X Intermittent ❑
If intermittent:
Days per week discharge occurs: Duration:
11. Plant design potable flowrate 9 MGD
Backwash or reject flow 14 MGD
12. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Little Troublesome Creek (see topo map attached)
13. Please list all water treatment additives, including cleaning chemicals or disinfection
treatments, that have the potential to be discharged.
Alum / aluminum sulfate
Yes X No
Page 2 of 3 Version 5/2012

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
NPDES PERMIT APPLICATION - SHORT FORM C - WTP
For discharges associated with water treatment plants
Iron sulfate / ferrous sulfate
Fluoride Yes X No
Ammonia nitrogen / Chloramines
Yes No X
Yes X No
Zinc -orthophosphate or sweetwater CP1236 Yes No X
List any other additives below:
Corrosion Inhibitor (Brenntag Aquapure 3655 & 3637)
Polymer Praestol K111L
14. Is this facility located on Indian country? (check one)
Yes ❑ No X
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].
• Solids Handling Plan
16. NEW Applicants n/a
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 El 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.
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.
Charles (Chuck) Smith Public Works Director
Print�e�d0 name of Person-7
e�rsonn Signing
Title I
10 ff1/t6 Z7� 00
Signature of Applicant 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 3 of 3 Version 5/2012

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
City of Reidsville
Reidsville WTP
Latitude: 36° 16' 57" N USGS Quad: Reidsville
Longitude: 79° 39' 35" W Permitted Flow: N/A
Receiving Stream: UT to Troublesome Creek Sub -Basin: 03-06-01
Drainage Basin: Cape Fear River Basin Stream Class: WS-III NSW
NPDES Permit NC0046345
Rockingham County

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
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CONFORMED DRAWING

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Scott Jewell
Client: Reidsville, City of- WTP
278 Reid Lake Rd
Reidsville, NC 27320
Report Date: 10/12/2020
Date Sample Rcvd: 10/8/2020
Meritech Work Order # 10082014 Sample: 002/Lagoon Grab 10/8/20
Parameters Results Analysis Date Reporting Limit Method
Hardness (titration) 18 mg/L 10/8/20 1 mg/L SM 2340C
I hereby certify that I have reviewed and approve these data.
ndo, t4sanN
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Scott Jewell
Client: Reidsville, City of- WTP
278 Reid Lake Rd
Reidsville, NC 27320
Report Date:
Date Sample Rcvd:
10/19/2020
10/9/2020
Meritech Work Order # 10092047
Parameters
Hardness (titration)
Re ults
Sample: 002/Lagoon Grab
Analysis Date
20 mg/L 10/15/20
Reporting Limit
1 mg/L
10/9/20
Method
SM 2340C
I hereby certify that I have reviewed and approve these data.
tctIAR '1 Yi t)
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Scott Jewell
Client: Reidsville, City of- WTP
278 Reid Lake Rd
Reidsville, NC 27320
Report Date:
Date Sample Rcvd:
10/19/2020
10/12/2020
Meritech Work Order # 10122008
Parameters
Hardness (titration)
Results
Sample: 002/Lagoon Grab
Analysis Date
24 mg/L 10/15/20
Reporting Limit
1 mg/L
10/12/20
Method
SM 2340C
1 hereby certify that 1 have reviewed and approve these data.
Y nc C1 i o t)
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
•
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Scott Jewell
Client: Reidsville, City of- WTP
278 Reid Lake Rd
Reidsville, NC 27320
Report Date: 10/19/2020
Date Sample Rcvd: 10/13/2020
Meritech Work Order # 10132016 Sample: 002/Lagoon Grab 10/13/20
Parameters Results Analysis Date Reporting Limit Method
Hardness (titration) 20 mg/L 10/15/20 1 mg/L SM 2340C
T hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Meritech, Inc.
Environmental Laboratory
Laboratory Certification No.165
Contact: Scott Jewell
Client: Reidsville, City of- WTP
278 Reid Lake Rd
Reidsville, NC 27320
Report Date:
Date Sample Rcvd:
10/19/2020
10/14/2020
Meritech Work Order # 10142009
Parameters
Hardness (titration)
Results
Sample: 002/Lagoon Grab
Analysis Date
20 mg/L 10/15/20
Reporting Limit
1 mg/L
10/14/20
Method
SM 2340C
1 hereby certify that 1 have reviewed and approve these data.
Laboratory Repr sentative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Young, Brianna A
From: Graznak, Jenny
Sent: Thursday, April 15, 2021 12:56 PM
To: Young, Brianna A
Subject: FW: Reidsville WTP info (NC0046345)
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem NC 27105
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Boone, Ron <[e-mail]>
Sent: Wednesday, April 14, 2021 11:24 AM
To: Graznak, Jenny <[e-mail]>; Lowery, Patricia <[e-mail]>
Subject: RE: Reidsville WTP info (NC0046345)
My notes and thoughts about the Reidsville WTP toxicity issue are listed below.
Boyd Hawley needs to be designated as a BORC.
I know you all mentioned this as well but they may want to consider going to one of the sodium dechlor chemicals. This
is the first plant I've come across that uses calcium thiosulfate for dechlor.
Are they using the proper amount of calcium thiosulfate to neutralize the amount of chlorine in the water being
discharged? Mr. Jewel indicated the need to develop a quick reference chart to determine and set dechlor feed rates. It
is suggested that the plant have a fully automated system that is tied into its existing SCADA system but has manual
backup systems as well, which the operators are fully capable of operating manually. The system would ideally
determine the amount of chlorine in the water just prior to discharge and then automatically set the dechlor feed rate
according to the amount of chlorine in the water, the specific dechlor chemical in use and how much dechlor chemical it
takes to neutralize the existing chlorine.
They should doublecheck the contact time needed for calcium thiosulfate.
1

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
They are using aluminum sulfate for a coagulant. Should we consider having samples run for aluminum and or other
metals that may be toxic to the CD?
Flow meter should be calibrated annually. The flow meter was last calibrated several years back. This is a violation of the
permit.
The contact chamber should be cleaned out.
Installation of sluice gates and related equipment in settlement lagoons to better facilitate sludge settling and
dewatering is underway.
May want to consider split samples with another lab that does toxicity or have them take separate samples at the same
time for two different labs certified to do tox testing. May want to have another agency actually take samples.
The water is drawn from the lagoon thru a pipe of unknown size, but estimated to be 8 to 12 inch, thru a manually
operated telescoping gate valve. The water may have dissolved metals in it, especially if being drawn from near bottom
of lagoon at a high rate that causes turbulence and disruption of settled material. The operator's concerns of their ability
to efficiently separate and dewater sludge may provide even more credibility to this assertion.
The lagoon may need to be cleaned out for often.
Best Regards,
Ronald C. Boone, Environmental Program Consultant
NC Department of Environmental Quality, Division of Water Resources, Water Quality Regional Operations Section,
Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Main: 336-776-9800
Direct: 336-776-9690
Mobile: [phone]
Fax [phone]
[e-mail]
http://deq.nc.gov/about/divisions/water-resources
From: Graznak, Jenny [e-mail]>
Sent: Wednesday, April 7, 2021 2:41 PM
To: Boone, Ron <[e-mail]>
Subject: FW: Reidsville WTP info (NC0046345)
Jenny Graznak
Assistant Regional Supervisor
Winston Salem Regional Office
Division of Water Resources
Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem NC 27105
2

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
336-776-9695 office
336-403-7388 mobile
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Young, Brianna A <[e-mail]>
Sent: Thursday, March 25, 2021 10:07 AM
To: Graznak, Jenny <[e-mail]>
Subject: Reidsville WTP info (NC0046345)
Info is attached for permit renewal. Let me know if you have any questions! As we discussed, I haven't updated the tox
sampling yet, but that will be coming. The 2 main concerns are the inconsistent results reporting on DMRs (ug/L vs
mg/L) and failing tox tests.
Brianna Young, MS
Environmental Specialist II
Compliance and Expedited Permitting Unit
NC DEQ/ Division of Water Resources
Office: 919-707-3619
[e-mail] (e-mail preferred during State of Emergency)
Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.
3

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
From:
To:
Cc:
Subject:
Date:
Scott,
Young, Brianna A
Scott Jewell; Boone, Ron; Thomas, Zachary T; Moore, Cindy
Bovd Hawley; Jesse S. Barnes; Summer Woodard; Graznak, Jenny; Richards, Emily; Hennessy, John
RE: [External] Lagoon Toxicity Update
Tuesday, August 31, 2021 9:05:03 AM
Thank you for providing this update. If you have further questions or communications concerning
the Reidsville WTP NPDES permit, please reach out to Emily Richards (cc'd on this email). I accepted
a new position and no longer work with the Compliance and Expedited Permitting Unit. Emily has
taken over the renewal of the Reidsville WTP permit.
Thank you,
Brianna Young, MS (she/her)
Environmental Program Consultant
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Youngc ncdenr.gov (e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely
or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public
access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able
to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during
this challenging time.
From: Scott Jewell <[e-mail]>
Sent: Tuesday, August 31, 2021 8:48 AM
To: Young, Brianna A <[e-mail]>; Boone, Ron <[e-mail]>;
Thomas, Zachary T <[e-mail]>; Moore, Cindy <[e-mail]>
Cc: Boyd Hawley <[e-mail]>; Jesse S. Barnes <[e-mail]>;
Summer Woodard <[e-mail]>
Subject: [External] Lagoon Toxicity Update
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DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Brianna, Cindy, Zach and Ron,
I wanted to provide you with a quick update on our lagoon toxicity. Today
we will begin some non-compliance testing on our lagoon. We will grab
samples and run multiple dilutions on 3 locations. Outfall 002, just prior
to the unnamed tributary and the upstream will be where we are focusing
our efforts. Hopefully these data points will provide additional information
and will help us to determine at what level of dilution we are failing. Of
course we realize that temperature can play a major role in this process.
We will continue to investigate this until we determine the reason we are
failing and what we must do to remedy in the coming cooler temperatures
as well.
The other item we are going to do is install aeration. Jesse Barnes has
been instrumental in located some EPA documents that specify water
turnover, increased DO, etc to increase beneficial bacteria. We will
purchase an aeration system and install on one side of our lagoon.
Increasing beneficial bacteria may result in those bacteria consuming
toxins that adversely affect the Ceriodaphnia.
Lastly, I will begin working on prior DMR's that have been previously
submitted incorrectly and prior to me becoming the ORC. We will need
some additional time to make these corrections.
In communication,
Scott
e scar wee
SCOTT JEWELL
SUPERINTENDENT/ORC
WATER TREATMENT PLANT
CITY OF REIDSVILLE
PUBLIC WORKS DEPARTMENT
278 Reid Lake Road 1 Reidsville, NC 27320
w:336-342-40011 c: 336-213-73731 fax: [phone]
SJeweIIPReidsvillenc.gov 1 http://reidsvillenc.gov
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DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
From: Scott Jewell
To: Thomas, Zachary T; Moore, Cindy; Richards, Emily; Graznak, Jenny; Hennessy, John; Boone. Ron
Cc: Water Plant Distribution; Summer Woodard; Phillips, Chris; Haywood Cloud
Subject: [External] FW: Reidsville wtp toxicity
Date: Thursday, September 9, 2021 1:16:13 PM
Attachments: 20210909103016312.pdf
20210909103028560.pdf
20210909103041731.odf
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All,
Please see the attached results from our multiple dilution toxicity sampling. It looks like our failure is
just shy of 40% IWC. I will set up multiple dilutions with ETS next week. We are hauling sludge from
our lagoon over the next several weeks beginning Monday, Sept 13, 2021, so it may be late Oct
before I have the results from that sampling. The chlorine that Mike Reed mentions in our upstream
sample could be an interference element such as manganese and is providing a false reading. It
passed at greater than 90%. I don't believe that it could pass at greater than 90% with 0.16 and 0.32
parts of chlorine respectively. I do not believe that he runs interference testing for ultra -low
chlorine as we do in our lab. I mentioned the interference to him and he said , it is what it is. FYI... I
am meeting with an electrician on Monday, Sept 13, 2021 to discuss installation of an aeration
device.
Any feedback is greatly appreciated.
Scott
e scar wee
SCOTT JEWELL
SUPERINTENDENT/ORC
WATER TREATMENT PLANT
TIFF. CITY OF
Reidsville
rtiv'1 r l r' 5 17 (l r
CITY OF REIDSVILLE
PUBLIC WORKS DEPARTMENT
278 Reid Lake Road 1 Reidsville, NC 27320
w:336-342-40011 c: 336-213-73731 fax: [phone]
SJeweII( Reidsvillenc.gov http://reidsvillenc.gov
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From: Mike Reed[mailto:[e-mail]]
Sent: Thursday, September 9, 2021 10:51 AM
To: Scott Jewell
Subject: Reidsville wtp toxicity
Let me know if you have any questions.
Upstream looks fine apart from some weird chlorine numbers which raises concerns about what is
happening upstream from you.
002 and Tributary look almost identical with only minor mortality differences.

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
Mike Reed
Lab Supervisor
Meritech Labs, Inc.
336-342-4748: Office
[e-mail]
www.meritechlabs.com
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DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
From:
To:
Subject:
Date:
Attachments:
Scott Jewell
Richards, Emily
RE: [External] RE: Reidsville WTP DMR corrections
Monday, January 3, 2022 1:25:15 PM
image002.pnq
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Thank you!
Scott Jewell
Superintendent
Water Treatment
TI-rF CITY OF
Reidsville
NORTH ('•tRrnTom'
From: Richards, Emily [mailto:emily.richards©ncdenr.gov]
Sent: Monday, January 3, 2022 10:39 AM
To: Scott Jewell
Subject: RE: [External] RE: Reidsville WTP DMR corrections
Hi Scott,
Per your request I have waited until the first of the year to continue preparing your final permit. You
can look forward to its issuance soon.
Best,
Emily
From: Scott Jewell <[e-mail]>
Sent: Monday, November 22, 2021 3:47 PM
To: Richards, Emily <[e-mail]>
Cc: Boyd Hawley <[e-mail]>
Subject: [External] RE: Reidsville WTP DMR corrections
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Thank you Emily for your email. We are still working on this. It is a mess! Also, the electrical work
for the lagoon aeration has been ordered. The aerator has been ordered and is currently scheduled
to ship Jan 7, 2022. I think if we had until the first of the year, we could work through all of the
DMR's.
Thank you for working with us to resolve the problems. I will be out of my office because my wife is

DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
having knee replacement surgery. I will be in and out and returning full time Dec 6.
Thank you again,
Scott
Scott Jewell
Superintendent
Water Treatment
T11 I` CITY 01
Reidsville
fJRT1I CAROLII A
From: Richards, Emily[mailto:emily.richardsncdenr.gov]
Sent: Tuesday, November 16, 2021 2:41 PM
To: Scott Jewell
Subject: Reidsville WTP DMR corrections
Hi Scott,
Previously, the permit for NC0046345/ Reidsville WTP was being reviewed by Brianna Young, but it
was passed along to me when she moved to another position. Looking through some notes and
saved emails in the permit file, I saw that you had intended to submit modified DMRs to correct
issues with data that had brought about new limits for copper, zinc, and fluoride. I downloaded your
DMR data to re -run the reasonable potential analysis, but it does not look like anything has changed.
Have you submitted modified data?
It's possible I could be missing some information, so I apologize for any inconvenience! If I am
missing something, please let me know.
Best,
Emily DelDuco Richards (she/her)
Environmental Specialist II
Division of Water Resources
Department of Environmental Quality
919-707-9125
emily.delducoPncdenr.gov
0 Nothing Compares,
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DocuSign Envelope ID: 3BE7FAB7-8681-4DAF-AED2-EC4B109934A8
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