NC0021903_Fact Sheet_20220406

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO021903
2022 Renewal
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).
Facility and Stream Information
Applicant/Facility Name:
Town of Warsaw Warsaw WWTP
Applicant Address:
PO Box 464; Warsaw, NC 28398
Facility Address:
384 East Best Street; Warsaw, NC 28398
Facility Class/Permit Status:
Grade III Biolo ical WPCS / Renewal
Permitted Flow (as
built
0.915 MGD
Type of Waste
100% Domestic
Receiving Stream
Stewarts Creek
Stream Class / ID
C; Sw/ 18-68-2-10
River Basin
Cape Fear
Subbasin
03-06-19
HUC
030300060505
USGS Too
Warsaw South H26NE
7Q10 Sum Win cfs
0.12 0.22
30Q2 cfs
0.3
Avg. Stream Flow cfs
2
IWC % S/W
0.02 0.01
County
Duplin
Regional Office
WiRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / April 6, 2022, 2022
Does permit need daily max NH3 limits?
Already in permit
Does permit need TRC limits/language?
Already in permit
Does permit have toxicity testing?
No
Does permit have Special Conditions?
Yes Instream Monitoring Waiver and Nutrient
Reo ener
Does permit have instream monitoring?
Yes - DO and Temp
Stream on 303 d List? For w arameter?
No - Mercury statewide issue only
Any compliance concerns?
Only a few minor violations, see below
Any modifications since lastpermit?
Yes - Ongoing construction from two A to Cs
New expiration date:
January 31, 2027
FACILITY OVERVIEW:
This facility is 100% domestic waste and serves the Town of Warsaw. The WWTP provides treatment for a
service population of around 3,120 people. The facility has a permitted and as built flow rate of 0.915 MGD.
The treatment system includes the following wastewater treatment components:
• Mechanical & manual bar screen • Gas chlorine disinfection
• Triplex influent pump station • Post -aeration
• Aerated grit chamber
• Flow splitter
• Three (3) oxidation ditches - each
457,500 gallons
• Four (4) secondary clarifiers
• Dual tertiary filters
• Continuous flow measurement
• Aerated sludge digester
• Aerated sludge holding tank
• Two (2) of seven (7) sludge drying beds
• Standby electrical generator

APPLICATION
• The application cover letter includes a request from the permittee for reduction in monitoring
frequencies for BOD, TSS, NH3-N and Fecal Coliform. The request points to the October 2012 Division
Guidance memo on allowing reductions. The cover letter also included an evaluation of monitoring data
to show compliance with the conditions in the memo.
This request for monitoring reduction will be denied in this renewal process. As discussed in other
areas of this Fact Sheet, the permittee has been found to require implementation of a pretreatment
program to handle an existing Significant Industrial User (SIU) and allow for another planned SIU. This
decision is discussed in more detail in a separate section of this Fact Sheet - Monitoring Reduction
Request.
• The application package notes an ongoing WWTP Improvement Project. Improvements were approved
in an October 3, 2019, Authorization to Construct (ATC) approving installation of a new influent
pumping station and the addition of two dual media tertiary filters. Correspondence with the Town now
indicates that this construction is scheduled for completion by June 30, 2022. In addition, the Town
received an ATC on September 1, 2021 for the demolition of two offline secondary clarifiers and
construction of one 40 ft. diameter clarifier along with mixers, piping, etc. The Town anticipates
completion of this construction by March 31, 2023.
• The facility is also tied to Collection System Permit WQCS00159.
• WWTP serves a population of 3,120 people.
• Maximum daily flow rates are noted as around 2.4 MGD which is well over the 0.915 MGD flow limit, but
monthly average flow rates are below the flow limit (0.52MGD).
• Average daily I/I is listed at 5,700 GPD. The application notes a Collection System Rehabilitation
process on one section of the collection system. This would impact approximately 3,000 feet of system
and involve manhole and line repair/replacement. Does appear they are seeking loan/grant assistance
for the project.
• Treatment system is described as having Advanced treatment with design removal rates of 97% for
BOD, 93% for TSS, 80% for Phosphorus and 92% for Ammonia.
• The application indicates no Significant Industrial Users (SIUs). However, a letter submitted by the
Town along with an updated sewer use ordinance indicated that it appeared that the town had
significant industrial users. An email requesting additional information on this from the Town resulted
in verification that the Town does have an SIU and has a new industry under construction that will be
another SIU and that the Town is working toward getting a pretreatment program application
submitted. See further discussion later in this Fact Sheet.
• The application includes a narrative description of the treatment process and components. This
information indicates that the Oxidation Ditch size should be updated in the permit to reflect that each
ditch has a capacity of 457,500 gallons. This change has been made in the draft permit.
INSPECTION
The most recent inspection (12/04/2020) found the facility was in compliance and no issues were found. The
report did note that the grit chamber was not in use due to issues with the blowers, 2 clarifiers were not
operational and one of the oxidation ditches was being used as an equalization basin. The inspection report
indicated ongoing construction at the facility to implement improvements.
COMPLIANCE:
During the permit cycle this facility had two (2) NODs, and one (1) NOV for flow violations. There was one (1)
enforcement actions over the permit cycle for NH3-N violations. The total amount assessed in this enforcement
Town of Warsaw WWTP Fact Sheet
NPDES Renewal 2022 — February 7, 2022
Page 2

was $ 887.75. The Town received remission of the full penalty assessment of $750 and paid only the
enforcement cost of $ 137.75. Issues in the remission included cold weather and an electrical issue at the
facility that led to problems with one of their oxidation ditches.
The Town has collection system permit WQCS00159. Over the permit term they received five (5) notices of
discharge without a permit. Four (4) of these were due to weather issues (hurricane / tropical storm) and one
was the result of debris in the line.
MONITORING DATA REVIEW
Parameter Units
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.12
2.5
0.51
0.915 MGD
Three 3 MA values exceeded
BOD (mg/L) - Summer
< 2
9
1.26
5.0 MA
Average removal at 99%
7.5 WA
BOD m L Winter
( g/)
< 2
11.4
1.43
10.0 MA
15.0 WA
TSS (mg/L)
< 2.5
19.6
2.47
30 MA
Average removal at 99%
45 DM
Temp (°C) - Effluent
4
28
19.05
-
NH3-N m L Summer
( g/)
< 0.2
7
0.215
1.0 MA
3.0 DM
NH3-N (mg/L) - Winter
< 0.2
12.95
0.42
2.0 MA
1 WA and 2 MA values exceeded
6.0 DM
DO (mg/L) - Effluent
6.4
14.5
8.98
>_6 DA
Fecal Coliform (#/ml)
< 1
5,900
N/A
200 MA
400 DM
TRC (µg/L)
I < 15
< 15
< 15
17 DM
693 values all reported as < 15
pH (su)
6
7.5
N/A
>_6 and <_9
Total Nitrogen (mg/L)
8.1
50
24.8
-
Total Phosphorous (mg/L)
0.3
5.08
2.31
-
MA -Monthly Average DA - Daily Average WA - Weekly Average Summer - April through Oct Winter - Nov through March
* Instream monitoring required in the permit for DO and Temperature but waived due to participation in the Lower Cape Fear
Monitoring Program.
The data reviewed for the renewal is from August 2017 through December 2021.
NEED FOR PRETREATMENT PROGRAM:
As noted in the Application discussion section above, the Town of Warsaw has verified that they have an
existing SIU and anticipate connection of a second SIU in the near future. They are currently working with their
consultant in the development of a pretreatment program for submittal. Discussions with the Town's
consultant (phone call with Cecil Madden - March 15, 2022) indicated that the Town currently has a facility
(Villari Brothers) that processes already slaughtered meats to produce specialty meats. This facility has oil and
grease separation and a Dissolved Air Flotation (DAF) unit to remove fats before the waste stream enters the
collection system. This waste stream started small but over the years has grown to 80,000 to 100,000 gallons
per day which would place them in the SIU category. It does not appear that the Town has ever made the
Division aware of the increase in flow to the level it is at today.
The Town is also currently working with Carbon Cycle - North Carolina (C2-NC), a new bio-waste processing
facility that could eventually discharge up to 250,000 gallons per day into the Town's system. The proposed
facility will convert hog wastes and food wastes through anaerobic digestion to methane gas for energy.
Pretreatment of the waste prior to discharge to the Town's system will be required. The Town has
acknowledged that addition of this flow will push their average flow above the 80% threshold and their
consultants are also looking at the alternatives to address their treatment plant capacity.
Town of Warsaw WWTP Fact Sheet
NPDES Renewal 2022 - February 7, 2022
Page 3

Discussions with the Pretreatment Program staff in the Municipal Permitting Unit have led to adding a
Compliance Schedule in the permit for the Town to move toward establishment of an appropriate
pretreatment program. Section A. (4) Schedule of Compliance for Pretreatment Program has been added to
the permit. This schedule includes development and implementation of a Short Term Monitoring Plan,
Development of a Sewer Use Ordinance and Enforcement Response Plan, Development of an Industrial
Waste Survey, Development of a design -based Headworks Analysis, Development of local Industrial User
Permits an submittal and approval of a Pretreatment Program in accordance with 15A NCAC 02H .0906.
REVIEW OF PERMIT LIMITS:
Flow - The facility has had only three (3) Monthly Average flow numbers exceed the permitted flow of 0.915
MGD over the permit cycle. However, there have been over one hundred and thirty (130) individual days where
the daily discharge was over the flow limit. The facility indicates I/I issues in some areas and appears to be
working on plans for rehabilitation of a portion of the sewer system. This has been an ongoing issue for years
with this facility. The 2012 permit application indicated 334,000 gpd in estimated I/1, the 2017 application
showed estimate of 418,00 gpd but in the 2021 application this estimate had dropped to 5,700 gpd. Overall, the
average flow (0.50MGD) has been significantly lower than the allowed limit. As noted above, addition of an
industrial discharge of up to 250,000 GPD will lead to the Town working to assess potential alternatives to
handle the increase flow.
Ammonia -Nitrogen Limits - The facility has had three exceedances of the winter NH3-N limit. This does not
appear to be a major issue but has resulted in violations being issued (see Compliance discussion).
BOD and TSS - Looking at the average values for influent and effluent it appears that the average removal for
each of these parameters is above 99%. There were no limit violations in the permit cycle.
Fecal Coliform Limits - While there have been some fairly high individual values reported, there have been no
weekly or monthly average violations resulting from these. The facility has sometimes monitored more
frequently to get the mean values down.
Total Residual Chlorine Limits - There have been no violations of the 17 µg/L limit. All values (693) have been
reported at < 15.
REVIEW OF PERMITTEES MONITORING REDUCTION REQUEST:
As noted above, the Town of Warsaw has requested reduction of their monitoring frequencies for BOD, TSS,
NH3-N and Fecal Coliform as allowed in the Division's Guidance Memo of October 22, 2012 (copy attached to
Fact Sheet). The town provided an analysis of their data from May 2018 through April 2021 as verification of
meeting the criteria for reduction.
Criteria
Response
No More than one civil penalty for target parameters
Only enforcement was for a flow
violation
No criminal violations
None
Not under SOC
Not under SOC
Not on EPA's QNCR report for target parameters
Not on QNCR
Town of Warsaw WWTP Fact Sheet
NPDES Renewal 2022 — February 7, 2022
Page 4

Criteria
Parameter
MA
50%
3-Yr
Response
Limit
of MA
Avg
For BOD, TSS and NH3-N - 3-yr
BOD
5
2.5
1.41
Meets Criteria
TSS
30
25
2.33
Meets Criteria
mean < 50% of monthly average
NH3-N
1
0.5
0.22
Meets Criteria
permit Limit
For Fecal - 3-yr geometric mean <
50% of monthly average permit Limit
Fecal
200
100
1.75
Meets Criteria
Criteria
Response
For BOD, TSS and NH3-N no more than 15 daily
BOD — 0; TSS — 0; NH3-N — 8
results > 200% of monthly average limit
For Fecal - no more than 20 daily results > 200% of
15 Values > 200%
monthly average limit
Not more than 2 non -monthly average violations
None for BOD, TSS and Fecal; 2 for
NH3-N
Monitoring reduction can't impair assessment of
N/A
downstream uses
Appears that the monitoring reduction would be acceptable. However, Pretreatment staff from the Municipal
Permitting Unit have indicated that maintaining the monitoring levels as they are (3/Week) will provide
additional information to inform the process of review and approval of the Town's upcoming request for a
pretreatment program. With this in mind, the request for reduction in monitoring will be denied at this time.
FILE HISTORY REVIEW SUMMARY
• The Waste Load Allocations (WLA) done in 1981 and 1983 were for 0.61 MGD flow Limits set at (S/W):
BOD - 5/12; NH3-N - 2/3; DO - 5/5; TSS - 30; Fecal - 1,000; pH - 6-8.5. Original permit -1979.
• March 16, 1981- Authorization to Construct (A to C) to modify the existing package type treatment system
to an aerobic digester.
• 1984 WLA - Based on a new permitting policy limits were changed to: BOD -10; NH3-N - 4; DO -6; TSS - 30;
Fecal-1,000; pH - 6-8.5.
• 1990 - Instream assessment for an SOC request to allow expansion of flow. It was determined that there
were ongoing oxygen issues in the stream and no expansion should be allowed beyond what could be offset
with correction of 1/1 issues.
• 1991 WLA and Permit included 0.61 MGD flow and limits of (MA/WA): BOD-10/15; TSS - 30/45; Fecal -
200/400; NH3-N limits (MA) for S/W - 1.1/2.2; DO daily average of 6; pH - 6-9 and monitoring for TRC,
Temp, TN and TP. Monitoring was set at daily for all parameters except TN an TP were quarterly. The
Town adjudicated the 1992 permit and monitoring frequency was lowered to 3/week.
• 1992 -1999 -there were ongoing reviews as the town sought to expand. There were issues with the
expansion due to concerns that the discharge is essentially to a zero flow stream and also due to the town's
recurring issues with 1/1. In 1999 after the town's commitment to work on the 1/1 issues a permit
modification was issued with a second effluent page set at a flow of 0.915 MGD.
• February 12, 2001- A to C for modifications to the treatment plant to expand to 0.915 MGD.
• April 3, 2001- Letter associated with Class III designation of the treatment system.
• 2002 Permit Renewal - Included reviews of the 1998 Facilities Plan from DWQ staff noting the need for the
plan to include approaches to address their 1/1 issues beyond just a request for expansion. Over half of the
flow volume was estimated to accommodate 1/I. Ultimately the town developed a proposal to reduce 1/1
and the expansion was approved. Permit issued with the 0.915 MGD flow only along with added TRC limit
of 17. The permit also waived instream monitoring due to the Town's membership in the Lower Cape Fear
Monitoring Program.
Town of Warsaw WWTP Fact Sheet
NPDES Renewal 2022 — February 7, 2022
Page 5

• 2006 Permit Renewal (permit not effective until Feb 2007) - Included updates to the treatment system
components, addition of a Nutrient Reopener and addition of NH3-N weekly average limits at 3 and 6.
• July 1, 2011 - Renewal letter on MCA for Lower Cape Fear Monitoring Program.
• 2012 Permit Renewal - Added TRC compliance level footnote.
• 2017 Permit Renewal - Added electronic submittal of DMRs along with regulatory citations and map
updates.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added regulatory citations throughout the permit as needed.
• Corrected treatment system components in the permit to reflect sizing of oxidation ditches as described in
the narrative provided in the renewal application.
• Nutrient Reopener language updated.
• Addition of Compliance Schedule for the creation of a Pretreatment Program.
• Updated the permit map.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: April 19, 2022
Permit Scheduled Effective Date: July 1, 2022
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
bradley.bennettOncdenr.gov or [phone].
Town of Warsaw WWTP Fact Sheet
NPDES Renewal 2022 — February 7, 2022
Page 6

ff A NJ
Media of Eastern North Carolina
The Daily Reflector - The Daily Advance - The Rocky Mount Telegram
Bertie Ledger - Chowan Herald - Duplin Times - Farmville Enterprise - Perquimans Weekly
Standard Laconic - Tarboro Weekly - Times Leader - Williamston Enterprise
PO Box 1967. Greenville NC 27835
[phone]
NCDEQ - DIVISON OF WATER RESOURCES
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH NC 27699
Account: 133315
Ticket: 418109
PAID VIA
❑ Cash ❑ Credit Card
❑Check # tJ, ,
.
Date Paid Li 'k__J
Copy Line: Town of Warsaw
Lines: 47
Total Price: $82.25
PUBLISHER'S AFFIDAVIT
NORTH CAROLINA
plin County
L\" 20g?z— affirms that he/she is clerk of The
Duplin Times, a newspaper published weekly at Kenansville, Duplin County,
North Carolina, and that the advertisement, a true copy of which is hereto at-
tached, entitled Town of Warsaw was published in said The Duplin Times on the
following dates:
Thursday, April 28, 2022
and that the said newspaper in which such notice, paper, document or legal
advertisement was published, was at the time of each and every publication, a
newspaper meeting all of the requirements and qualifications of Chapter 1, Sec-
tion 597 of the General Statutes of North Carolina and was a qualified newspaper
witbin.the m ning of Chapter 1, Section 597 of the General Statutes of North
,roli a.
A rmed an ubscribed before me this 28th day of April 2022
(Notary Public Sig ature)
(Notary Public Printed Name)
My commission expires U — C) —� 1
J`GGpN.
AUGUST 21,
2024
i
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 NC0021903 Town
of Warsaw WWTP
The North Carolina Environmental
Management Commission proposes to
issue a NPDES wastewater discharge
permit to the person(s) listed below.
Written comments regarding the pro-
posed permit will be accepted until 30
days after the publish date of this no-
tice. The Director of the INC Division
of Water Resources (DWR) may hold a
public hearing should there be a signif-
icant degree of public interest. Please
mail comments and/or information re-
quests to DWR at the above address.
Interested persons may visit the DWR
at 512 N. Salisbury Street, Raleigh, NC
27604 to review information on file.
Additional information on NPDES per-
mits and this notice may be found on
our website: http://deq.nc.gov/about/
divisions/water-resources/water-re-
sources-permits/wastewater-branch/
npdes-wastewater/public-notices, or
by calling [phone]. The Town
of Warsaw [P.O. Box 464, Warsaw, NC
283981 has requested renewal of NP-
DES permit NCO021903 for the Town
of Warsaw WWTP, located in Duplin
County. This permitted facility dis-
charges wastewater to Stewarts Creek,
a class QSW water in the Cape Fear Riv-
er Basin. Some of the parameters in the
permit are water quality limited. This
discharge may affect future allocations
in this segment of Stewarts Creek. As
part of this renewal the Division is also
noticing the permittee's requirement
to complete a pretreatment program
under 15A NCAC 02H .0900.
418109 4/282022

Bennett, Bradley
From: Mcgee, Keyes
Sent: Monday, May 9, 2022 9:53 AM
To: Bennett, Bradley; Montebello, Michael J
Subject: RE: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NCO021903
Hello Bradley,
I had a phone conversation with Cecil Madden last week about the STMP and I think he's on track to having it ready to
go soon. I know of no reason to rearrange the order of required pretreatment requirements.
The rhetorical device of connecting "the WWTP has not observed any adverse effects," and the long-time receiving of,
that which is, SIU wastewater is not a valid point of discussion. Having avoided pretreatment regulations for so long is
reason enough for haste, rather than continuing disregard.
Regards,
Keyes
From: Bennett, Bradley <[e-mail]>
Sent: Monday, May 9, 2022 8:41 AM
To: Mcgee, Keyes <[e-mail]>; Montebello, Michael J <[e-mail]>
Subject: FW: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NCO021903
Hey Guys,
The Town of Warsaw submitted comments on the draft NPDES permit renewal. Their comments are related to things
that we did in the draft associated with the pretreatment process. So, I wanted to get your feedback on responding to
them on these issues. The first is that they still wanted to get the monitoring reduction. You guys had wanted to
maintain the monitoring to help inform the pretreatment review process. Second, they had concerns about the dates in
the pretreatment compliance schedule that you guys put together. Take a look at their attached comments and give me
your thoughts.
Thanks
M9.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett(@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Scotty Summerlin <[e-mail]>
Sent: Friday, May 6, 2022 11:50 AM
To: Bennett, Bradley <bradley.ben [e-mail]>

Cc: [e-mail]; ajconnorsmayor <[e-mail]>
Subject: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett:
Good morning. In the essence of time, I wanted to provide comments on our pending NPDES permit renewal We may
have additional comments, while the comment period is open.
Sincerely,
Scotty Summerlin
Town Manager
Town of Warsaw
PO Box 464
Warsaw, NC 28398
[phone] ext. 105 phone
[phone] mobile
[e-mail]
1
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Friday, April 22, 2022 8:25 AM
To: Scotty Summerlin <[e-mail]>
Cc:'[e-mail]' <[e-mail]>; Lea Turner <[e-mail]>; cgm@mcdavid-
inc.com; [e-mail]; [e-mail]; Mcgee, Keyes <[e-mail]>
Subject: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
Mr. Summerlin,
As mentioned in my recent email on April 5, 2022 we have moved forward to draft your permit renewal with a
compliance schedule for implementing a pretreatment program. Attached is the draft permit that will be going to public
notice within the next few days in a local paper. Please review the draft and let me know if you have any comments or
questions. See the cover letter for additional information on the changes in the draft and responses to requests in your
application. If you need us to forward you a hard copy of this draft please let me know and we can mail one to you.
Please respond to this email to verify that you received the draft permit and where able to open, read, download and
print the file for your records.

Thanks for your help in the renewal process.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Mayor: A.J. Connors
Town ASanager: Scott) Sunmterlin
T mtvt Clerk /!•'finance Officer: Lea Turner
Tax Collector: Dianne Benson
Deputy Clerk. Carnen Gonzalez
Chief of Police: Patrick Giddeons
Public I!'orks Director: Craig Armstrong
Town Attorney: Jene Thompson
Commissioners:
Russell Eason
Jack Hares
Dr. Owen Martin
Scotgp S,nith
Ebony (hills
May 63 2022
NC DWR/Compliance and Expedited Permitting Unit
Attn: Mr. Bradley Bennett
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Town of Warsaw NPDES Permit No. NC0021903Permit Renewal Comments
The Town of Warsaw has received the draft permit for the Town of Warsaw WWTP. We have
reviewed the draft permit and would like to offer the following comments:
The Division acknowledges that the facility meets the criteria for reduced monitoring for
exceptionally performing facilities but denied the request to implement the reduced
monitoring. The denial is tied to the implementation of the pretreatment program. The
industries that are discharging flow to the facility have been contributors to the facility for
years and the WWTP has not observed any adverse effects as evidenced by the data for
reduced monitoring request. Implementation of the pretreatment program would not
necessarily mean that any pollutants of concern would be regulated or even reduced from
the industries. If the discharge of industrial pollutants is limited, the WWTP should be
even more likely to maintain the current level of exceptional quality effluent. We do not
see any possibility that implementing a pretreatment program would negatively affect the
performance of the facility and ask that the request for reduced monitoring be implemented.
The draft permit also contains a compliance schedule for implementation of an Industrial
Pretreatment Program. The compliance schedule contains several milestone dates for
different activities associated with the pretreatment program. Given our understanding of
the pretreatment program and the date lines given, we think there are several conflicts in
the compliance schedule. Examples include:
o Within one month we are to submit a STMP (a) and also in the same time period
we are to implement monitoring per the STMP (b). Our concerns are: that one
121 S. Front Street • P.O. Box 464 • Warsaw, NC 28398
Phone:[phone]•Fax:(9I0)293-7701
An Lgnal Opporhmity Emplo��r

month is a very short period for starting the process as we either have to familiarize
ourselves with the many nuances of the pretreatment program or contract the
development of the program to some other entity; that even if the STMP is complete
in the first month, we would not want to start the monitoring until the STMP has
been approved by the Division which has 30 days to review and comment; should
the IWS be completed and reviewed prior to development of the STMP so we can
better understand the parameters we should monitor; and that other aspects of the
schedule require us to issue permits (e) prior to requesting and receiving approval
of the pretreatment program (g).
We request that you confirm that the timelines in the compliance schedule are in
the proper order and that additional time be allocated for beginning implementation.
Alternately, remove items a — f and just have a date by which the pretreatment
program must be submitted to the Division (g).
We thank you for your assistance in these matters. If you have any questions, please contact me
at: 910/293-7814 ext. 105 or [e-mail]
Sincerely,
Scotty ummerlin, Warsaw Town Manager
cc: Cecil Madden, P.E.; McDavid Associates, Inc.
Dr. A.J. Connors, Warsaw Mayor

Bennett, Bradley
From: Scotty Summerlin <[e-mail]>
Sent: Friday, May 6, 2022 11:50 AM
To: Bennett, Bradley
Cc: [e-mail]; ajconnorsmayor
Subject: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
Attachments: Warsaw NPDES Permit Renewal Comments.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett:
Good morning. In the essence of time, I wanted to provide comments on our pending NPDES permit renewal We may
have additional comments, while the comment period is open.
Sincerely,
Scotty Summerlin
Town Manager
Town of Warsaw
PO Box 464
Warsaw, NC 28398
[phone] ext. 105 phone
[phone] mobile
[e-mail]
From: Bennett, Bradley <[e-mail]>
Sent: Friday, April 22, 2022 8:25 AM
To: Scotty Summerlin <[e-mail]>
Cc: '[e-mail]' <[e-mail]>; Lea Turner <[e-mail]>; cgm@mcdavid-
inc.com; [e-mail]; [e-mail]; Mcgee, Keyes <[e-mail]>
Subject: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
Mr. Summerlin,

As mentioned in my recent email on April 5, 2022 we have moved forward to draft your permit renewal with a
compliance schedule for implementing a pretreatment program. Attached is the draft permit that will be going to public
notice within the next few days in a local paper. Please review the draft and let me know if you have any comments or
questions. See the cover letter for additional information on the changes in the draft and responses to requests in your
application. If you need us to forward you a hard copy of this draft please let me know and we can mail one to you.
Please respond to this email to verify that you received the draft permit and where able to open, read, download and
print the file for your records.
Thanks for your help in the renewal process.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Monday, April 25, 2022 10:13 AM
To: Cecil Madden; Summerlin, Scotty S
Cc: cahughes4l @gmail.com'; Lea Turner; Tyndall Lewis; Trey Gurley; Mcgee, Keyes
Subject: RE: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
Cecil,
Thanks for the comments. If we receive the certification of completion on some of the construction prior to issuing the
final permit we can make the adjustment in system components in the final permit. Activities that are completed would
have to wait for an update in the next permit renewal. On alternative is to just take out the references to number of
components in the treatment system component list so that those corrections aren't needed. For example we would
just include bullets for:
• Secondary Clarifiers
• Tertiary Filters
f3:3
Bradley Bennett Phone: [phone]
Compliance and Expedited Permitting
Division of Water Resources email: [e-mail]
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: Cecil Madden [mailto:[e-mail]]
Sent: Friday, April 22, 2022 1:35 PM
To: Bennett, Bradley <[e-mail]>; Summerlin, Scotty S <[e-mail]>
Cc: '[e-mail]' <[e-mail]>; Lea Turner <[e-mail]>; Tyndall Lewis
<[e-mail]>; Trey Gurley <[e-mail]>; Mcgee, Keyes <[e-mail]>
Subject: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hello Bradley,
I have reviewed the draft NPDES Permit and offer the following comments.
• The Town has two construction projects underway which are supported by individual Authorizations to Construct.
The first Project adds two additional tertiary filters. The total will be four filters each measuring 12' x 12'. A
certification of the completion of the filters is soon to be provided.
Currently, the Town has 4 secondary clarifiers. Two have a 40' diameter with 14' SWD. Two have a 20' dia. with
10' SWD. The second project eliminates the two smaller clarifiers and builds a new 40' dia. 14' SWD clarifier.

Upon the completion of the second project there will be three 40' dia. 14' SWD clarifiers. The new clarifier
associated with the second project will likely be in place by the end of the year.
We are currently working to establish the Short Term Monitoring requirements for the Towns Industrial
Pretreatment Program.
Regards,
Cecil
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Friday, April 22, 2022 8:25 AM
To: Summerlin, Scotty S <[e-mail]>
Cc: '[e-mail]' <[e-mail]>; Lea Turner <[e-mail]>; Cecil Madden
<[e-mail]>; Tyndall Lewis <[e-mail]>; Trey Gurley <[e-mail]>; Mcgee, Keyes
<[e-mail]>
Subject: Permit Draft for Notice - Town of Warsaw WWTP - NCO021903
Mr. Summerlin,
As mentioned in my recent email on April 5, 2022 we have moved forward to draft your permit renewal with a
compliance schedule for implementing a pretreatment program. Attached is the draft permit that will be going to public
notice within the next few days in a local paper. Please review the draft and let me know if you have any comments or
questions. See the cover letter for additional information on the changes in the draft and responses to requests in your
application. If you need us to forward you a hard copy of this draft please let me know and we can mail one to you.
Please respond to this email to verify that you received the draft permit and where able to open, read, download and
print the file for your records.
Thanks for your help in the renewal process.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Scotty Summerlin <[e-mail]>
Sent: Friday, April 22, 2022 1:07 PM
To: Bennett, Bradley
Cc: cahughes4l @gmail.com'; Lea Turner; [e-mail]; [e-mail];
[e-mail]; Mcgee, Keyes
Subject: [External] RE: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett,
Good afternoon. Thank you for all your assistance, thus far. The requirement to maintain certain monitoring frequencies
through the Pre-treatment Program process is noted. I have spoken with our consultant engineer and our operator. I
was able to open, read, download and print the draft permit. We will review the draft permit and send any comments
back to you. Thanks, again and have a pleasant weekend.
Sincerely,
Scotty Summerlin
Town Manager
Town of Warsaw
PO Box 464
Warsaw, NC 28398
[phone] ext. 105 phone
[phone] mobile
[e-mail]
From: Bennett, Bradley <[e-mail]>
Sent: Friday, April 22, 2022 8:25 AM
To: Scotty Summerlin <[e-mail]>
Cc: '[e-mail]' <[e-mail]>; Lea Turner <[e-mail]>; cgm@mcdavid-
inc.com; [e-mail]; [e-mail]; Mcgee, Keyes <[e-mail]>
Subject: Permit Draft for Notice - Town of Warsaw WWTP - NC0021903

Mr. Summerlin,
As mentioned in my recent email on April 5, 2022 we have moved forward to draft your permit renewal with a
compliance schedule for implementing a pretreatment program. Attached is the draft permit that will be going to public
notice within the next few days in a local paper. Please review the draft and let me know if you have any comments or
questions. See the cover letter for additional information on the changes in the draft and responses to requests in your
application. If you need us to forward you a hard copy of this draft please let me know and we can mail one to you.
Please respond to this email to verify that you received the draft permit and where able to open, read, download and
print the file for Your records.
Thanks for your help in the renewal process.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Kinney, Maureen
Sent: Monday, April 25, 2022 8:18 AM
To: Bennett, Bradley
Subject: RE: Draft Permit - Town of Warsaw WWTP - NCO021903
Thank you Bradley!
Maure Av Kbn*,Ley
NCDEQ / DWR / PWS
NC Wastewater Operator Certification Program
919-707-9038
Correspondence to and from this address is subject to the NC Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Bennett, Bradley <[e-mail]>
Sent: Friday, April 22, 2022 8:28 AM
To: Kinney, Maureen <[e-mail]>
Subject: Draft Permit - Town of Warsaw WWTP - NCO021903
Maureen,
Hope you are doing well. Just wanted to pass along this permit renewal. One major change in this one is that we are
setting a compliance schedule for them to establish and implement a pretreatment program.
Thanks
No
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Friday, April 22, 2022 8:34 AM
To: Mcgee, Keyes
Cc: Montebello, Michael J; Hennessy, John
Subject: Draft Permit for Town of Warsaw WWTP - NCO021903
Attachments: NC0021903_Draft Permit and Cover Ltr_2022.pdf; NC0021903_Fact Sheet Binder_
2022.pdf; NC0021903_Public Notice Language_2022.docx
Hey Keyes,
I just copied you on the draft permit for this one that I sent to the Town. This one is going to public notice this week.
have also attached the permit, fact sheet and public notice language here. The notice includes language giving notice
about their pretreatment program as we discussed so you guys don't have to notice that in the future. In our last
discussion you and Mike also indicated that you would be touching base with the current industrial user about permit
issues for them (local limits, etc.) down the road. I also forwarded information about the pretreatment program that
you provided to me earlier in an email to them on April 5t". I copied you on that email as well I believe.
Thanks for your help on this one. Let me know if there is anything else I need to do with this one. At this point I'll be
waiting for any comments and then we will move forward to issue the renewal.
L3.3
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.ben nettcDncdenr.gov
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Friday, April 22, 2022 8:40 AM
To: Tharrington, Tom; Hunkele, Dean; Perez, Helen I
Subject: Draft Permit Renewal - Town of Warsaw WWTP - NCO021903
Attachments: NC0021903_Draft Permit and Cover Ltr_2022.pdf; NC0021903_Fact Sheet Binder_
2022.pdf, NC0021903_Public Notice Language_2022.docx
Hey Guys,
Just wanted to forward along the draft permit for the Warsaw WWTP (NC0021903). This one is going to public notice
this week. If you have any questions/comments, please let me know. As mentioned before, this one includes a
compliance schedule for establishing and implementing a pretreatment program. Also, the public notice includes
language giving notice that they are establishing the pretreatment program so that the municipal group will not have to
make a second notice when they are coming online with that.
Thanks for all your help on this one! Let me know if you have any comments.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.ben nett()ncdenr.gov
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Monday, April 18, 2022 8:24 AM
To: Thedford, Wren
Subject: Permit for Public Notice - Town of Warsaw - NCO021903
Attachments: NC0021903_Draft Permit and Cover Ltr_2022.pdf; NC0021903_Public Notice Language_
2022.docx
Hey Wren,
Here is one permit for public Notice this week. This one has a little different public notice language because the
pretreatment group wanted me to include info in the notice about them getting a pretreatment program in place
have updated the language in the Access Database and I have also attached a word document with the Notice
language. Let me know if you have any questions or see anything that needs to be changed.
I may also have a second renewal for notice if I get it back from internal review. What is that latest I can get that one to
you and still get it in?
One last thing, sorry I haven't gotten back with you about entering stuff in the Access database. I think you had asked
me to set up a time to go through that with you at our last staff meeting. Do you have any time today to talk about
that?
Thanks
MM
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.ben nett(aMcdenr.gov
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Thursday, April 14, 2022 8:53 PM
To: Carpenter, Sydney
Subject: RE: Permit Renewal for Review - Town of Warsaw WWTP (NC0021903)
Thanks for looking at the draft Sydney. I will take a look at the issues you noted below. I definitely meant to include a
response about the reduced monitoring in the letter. Thanks for catching that.
No
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradlev.ben nettCaMcdenr.pov
Email correspondence to and from this address may be subject to public records laws
From: Carpenter, Sydney <[e-mail]>
Sent: Monday, April 11, 2022 5:15 PM
To: Bennett, Bradley <[e-mail]>
Subject: RE: Permit Renewal for Review - Town of Warsaw WWTP (NC0021903)
Hey Bradley,
I only have two comments for you on the draft.
1) The outfall coordinates on the map are incorrect.
2) The cover letter doesn't address their request for reduced monitoring. If you've already responded to their
request directly with the permittee then it's not a big deal. I saw it was documented in the fact sheet and in
emails with DEQ staff, but it might be a good idea to include it in the cover letter as well.
Everything else looks good!
Sydney Carpenter (she/her)
Environmental Specialist I
Compliance and Expedited Permitting Branch
Division of Water Resources
NC Department of Environmental Quality
Office: 919-707-3712
sydney.carpenter(o)ncdenr.gov
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: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Wednesday, April 6, 2022 1:09 PM
To: Carpenter, Sydney <[e-mail]>
Subject: Permit Renewal for Review - Town of Warsaw WWTP (NC0021903)
Hey Sydney,
I have a draft permit for review. I have the files on my OneDrive folder that you have access to. The link is below. I'll go
ahead and prepare you that this one may have a number of comments. I was pretty much finished with the draft when I
found a letter on Laserfiche that indicated that they might have an SIU discharging to their system. There was no info or
this in the application or files, etc. So I checked with them and they confirmed that the appear to have one and another
new one on the way. So I had to go through some review with the Municipal Permitting Unit to get a compliance
schedule set up for them to get a pretreatment program. Once all this happened I had to go in and modify the permit,
the fact sheet etc. so you might find that thing seem a little jumbled as I added sections, etc.
71 NCO021903 - Town of Warsaw WWTP
Thanks
L3.3
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nettcDncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Bennett, Bradley
Sent: Tuesday, April 5, 2022 3:47 PM
To: Summerlin, Scotty S; cahughes41 @gmail.com; [e-mail]; cgm@mcdavid-
inc.com
Cc: Mcgee, Keyes
Subject: Update on Permit Renewal - Town of Warsaw - NCOO219O3
Attachments: Warsaw Pretreatment Development Info.docx
I just wanted to touch base on the permit renewal process for the Town of Warsaw WWTP. After discussions with staff
in our Municipal Permitting Unit it appears that our best path forward at this time is to go ahead with the renewal
process for your NPDES Discharge permit (NCOO219O3). The renewal will include a modification to include a Compliance
Schedule for the Town to complete the tasks necessary to come into compliance with the addition of an approved
Pretreatment Program. This is a necessary step for the Town considering that it appears that there may already be an
SIU discharging to the Town's system and there are plans for connection of a new SIU that is currently under
construction. This reissued permit and establishment of a Pretreatment Program are required for any potential
connection of a new SIU.
Attached is a document with several references (weblinks) to information from the Division's Pretreatment Program for
the process associated with obtaining an approved Pretreatment Program. If you have questions about the process
Keyes McGee, Pretreatment Coordinator in our Municipal Permitting Unit, can provide additional information. He is
copied on this email so you will have his contact information.
We anticipate the draft permit renewal going to public notice sometime the week of April 18". We will be forwarding
you a copy of the draft for your review and comment at that time.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Tharrington, Tom
Sent: Tuesday, April 5, 2022 10:10 AM
To: Bennett, Bradley; Perez, Helen I
Cc: Hunkele, Dean; King, Morella s
Subject: RE: Warsaw Pretreatment
Sounds good Bradley, thanks for your work on this.
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, April 5, 2022 9:48 AM
To: Tharrington, Tom <[e-mail]>; Perez, Helen I <[e-mail]>
Cc: Hunkele, Dean <[e-mail]>
Subject: RE: Warsaw Pretreatment
Hey Guys,
Just wanted to give you a heads up on the process with Warsaw. After talking with staff in the Municipal Unit (Mike and
Keyes) I am going to continue with the issuance of this renewal. It will go over to their group for the next cycle. They
have given me information to develop a Compliance Schedule to include in the renewal to get them moving toward the
pretreatment program that they need. I have included the language below for any comments you might have on it. We
are going to go ahead and move forward with the renewal and not ask for any additional information at this point. Most
of what we need will be part of submittals required in the compliance schedule. From the info from their group Warsaw
needs to get the permit renewed with the schedule so they can start to come into compliance — with the SIU they
apparently already have and to allow them to eventually tie in the new SIU they are working with. Also, in our
discussions, Mike felt that we should not allow the reduction in monitoring frequency that Warsaw requested at this
time. He wants to be able to gather additional monitoring data to help with the process in establishing their
pretreatment program.
I will send Warsaw staff and their consultants an email to let them know next steps, etc. Let me know if you have any
comments on the language below.
A.(#.) Schedule of Compliance for Implementation of a Pretreatment Program
[G.S. 143-215.1(b)]
(a) Within one (1) month of the effective date of the permit the permittee shall submit to the Division a Short
Term Monitoring Plan (STMP).
(b) Within one (1) month of the effective date of the permit the permittee shall begin implementation of the
STMP. Monitoring shall take place for one year, and all data shall be submitted to the Division within 15
months of the start of data collection.
(c) Within three (3) months of the effective date of the permit the permittee shall submit to the Division a
Sewer Use Ordinance (SUO) & Enforcement Response Plan (ERP).
(d) Within nine (9) months of the effective date of the permit the permittee shall submit to the Division an
Industrial Waste Survey (IWS).
(e) Within fifteen (15) months of the effective date of the permit the permittee shall submit to the Division a
completed design -based Headworks Analysis (HWA) for development of permit limits for Significant
Industrial User(s) (SIUs).

(f) Within fifteen (15) months of the effective date of the permit the permittee shall issue Industrial User
Permit(s) (IUPs) (using the limits allocations from the HWA).
(g) Within eighteen (18) months of the effective date of the permit the permittee shall implement and submit a
complete pretreatment program approval request as per 15A NCAC 02H .0906.
fi:1
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Tharrington, Tom <[e-mail]>
Sent: Tuesday, March 22, 2022 10:25 AM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Perez, Helen I <[e-mail]>; Hunkele, Dean <[e-mail]>
Subject: Warsaw Pretreatment
Hey Bradley, I was able to speak with Helen in our office and she reminded me of an email in our files that kind of
refreshed my memory on this topic. I have attached it for your review. Also the town has been sent guidance for
developing the program as well. Given this information I can't think of much to include in the add info letter besides...
• What is the status of their program development and what is the estimated completion date to have the
program components in place?
• Do they have any additional data that characterizes the wastewater stream from the potential SIU (C2-NC)?
• Is any S & J Villari/Villari Food Group site going to be included in the Pretreatment Program?
Tom Tharrington
Assistant Regional Supervisor
Wilmington Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
[phone] Office
tom.tharrington @ncdenr.gov

From: Tyndall Lewis <[e-mail]>
Sent: Friday, February 28, 2020 11:36 AM
To: Lievre, Bryan K; Tharrington, Tom; Hassan, Monti
Cc: Trey Gurley; Madden, Cecil, P.E. (McDavid Associates, Inc.); Summerlin, Scotty S; 'Greg
Hughes'
Subject: [External] Town of Warsaw Pretreatment Program
Attachments: Warsaw-NC0021903_Final Permit_20170630.pdf
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
The purpose of this email is to coordinate the development and implementation of a Pretreatment Program for the
Town of Warsaw. It is my understanding the Town is required to have a State approved Pretreatment Program if the
Town sewer system has a Significant Industrial User (SIU). The Town anticipates an SIU beginning construction in the
very near future. Information describing the Town's sewer system, proposed SIU and schedule is presented below:
Town of Warsaw WWTP:
Town operates its Class WW-3 WWTP via NPDES Permit NC0021903 (copy attached) issued June 30, 2017 with
expiration date January 31, 2022. The WWTP has a capacity of 0.915 MGD and includes preliminary screening, three
oxidation ditches, clarifiers, tertiary filters and effluent disinfection. Discharge is to Stewarts Creek, Class C; Swamp
Waters in Subbasin 03-06-19 in the Cape Fear River Basin.
Average Daily Flows in 2016, 2017, 2018 and 2019 were .563, .427, .628, and .526 MGD, respectively.
The Town has recently advertised two contracts for bids. The first is for collection system improvements designed to
reduce 1/1. The second is for construction of a new influent pump station and expansion of the WWTP tertiary
filters. The town is also currently preparing plans for the construction of a new secondary clarifier which it expects to
advertise for bids within the next 9 months.
Proposed New Industry:
The Town has been working with Carbon Cycle North Carolina LLC (hereinafter C2-NC) for the past several years
planning construction and operation of a waste to energy facility on Penny Branch Road approximately one mile west of
Warsaw. The proposed facility will convert hog wastes and food wastes through anaerobic digestion to methane gas for
energy. C2-NC expects to generate approximately 250,000 gpd of wastewater to be discharged to the Warsaw sewer
system. The Town has obligated 250,000 gpd of its WWTP capacity to C2-NC with the caveat instantaneous discharge
flow rates to the Warsaw sewer system shall not exceed 195 gpm and that pretreatment of the wastewater will be
provided to lower pollutants to a level equivalent to domestic wastewater. Expected C2-NC wastewater characteristics
include TSS of 100 mg/I; BODs of 300 mg/I; NH3 of 20 mg/I and Total Phosphorous of 5 mg/l.
The Town recognizes the additional 250,000 gpd of wastewater will increase the average daily flow above the 80%
threshold that requires the Town initiate efforts to increase the WWTP capacity. The Town plans to make application
for an increase in its NPDES flow limit in the near future. It is recognized the planning, permitting and construction
process of expanding the WWTP capacity will require several years.
The industry is in the final stages of securing financing and anticipates starting construction within the next 45
days. Construction of the pretreatment and pumping facilities on -site will be the responsibility of C2-NC. C2-NC expects

to begin operations and discharge to the Town's sewer system by May, 2021. Estimated cost of the C2-NC facilities
amounts to approximately $65,000,000. Approximately 45 jobs will be created.
Proposed Improvements to Warsaw Sewer System to Accept C2-NC Wastewater Discharge:
C2-NC's pretreated discharge will connect to a force main in front of the C2-NC site. The Town will be responsible for
the off -site improvements associated with getting C2-NC's pretreated wastewater from the C2-NC site to the Town's
WWTP. The Town is currently working to specifically identify improvements to the sewer system necessary to
accomplish this task. It is anticipated plans for construction of these improvements will be prepared by June and
construction completed by May of 2021.
Pretreatment Program:
Inasmuch as the proposed C2-NC facility will be an SIU, the Town plans to immediately begin the process of
implementing a State approved Pretreatment Program. Accordingly, the Town plans to consider adoption of a
Pretreatment Sewer Use Ordinance at its March 10 Board meeting. Following adoption of the SUO, the Town intends to
aggressively pursue the steps required to implement the Pretreatment Program and obtain NCDEQ approval of the
program.
Questions:
The Town understands plans and various NCDEQ permits will be required for all off -site modifications/improvements to
the Town sewer system associated with the C2-NC project. It further understands these permits must be obtained prior
to the Town beginning construction of any modifications/improvements to the Town sewer system.
C2-NC will be responsible for whatever permits are required on their property. The Town understands C2-NC will be
required to obtain the Town -issued Pretreatment Permit before it discharges to the Town sewer system. Is C2-NC
required to obtain any NCDEQ or Town pretreatment permit(s) prior to C2-NC beginning construction of on -site
wastewater pretreatment facilities? Inasmuch as C2-NC intends to begin construction of its $65,000,000 project
within the next 45 days, it is imperative we clearly understand what pretreatment permits C2-NC must obtain and what
party(ies) will be tasked with issuance of the permits. Assuming the Town is the only entity that will issue the
Pretreatment Permit to C2-NC, what oversight, if any, does NCDEQ provide/require regarding issuance of the Permit by
the Town to C2-NC?
We look forward to working with the DEQ staff while assisting the Town with implementation of the Pretreatment
Program. thanks

Bennett, Bradley
From: Hunkele, Dean
Sent: Thursday, March 24, 2022 12:48 PM
To: Bennett, Bradley; Tharrington, Tom
Cc: Perez, Helen I
Subject: RE: Warsaw Pretreatment
We were still coming out of the reorganization back then with limited staff, thus guess it got overlooked.
The sewer permit issued on 4-15-96 & certified 5-8-97 to serve the old Cold Storage facility was WQ0012085 and only
625 gpd of flow was allocated for 25 employees @ 25 gpd/ea, thus yes nothing but domestic back then and they never
updated permit and guess never got PT approval if it's the same location.
Dean Hunkele ([e-mail])
Environmental Program Consultant
Water Quality Regional Operations Section
Division of Water Resources/Department of Environmental Quality
DWR Website: http://www.ncwater.org
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
910.796.7215 Reception Desk
910.796.7380 Direct
910.620.1685 Field/Telework Mobile
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
ALERT: New Fast Track application is available; older version will not be accepted after September 2021
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from application receipt. Please use the
DEQ's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the
reviewer's name. Once issued, the record stays on the site for 30 days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the DWR's Sewer Extension Permit
Tracker. Confirmation usina this method will replace letters and emails: it is recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deg.nc.goy/about/divisions/water-resources/water-resources
Perm its/peres/col lection-system s-perm its
From: Bennett, Bradley
Sent: Tuesday, March 22, 2022 7:53 AM
To: Hunkele, Dean <[e-mail]>;
Cc: Perez, Helen I <[e-mail]>
Subject: RE: Warsaw Pretreatment
Hey Dean,
Tharrington, Tom <[e-mail]>

You indicate in the message below that they have been tied on since at least 5-2014. From our discussion yesterday I
just wanted to make sure I understood that while you knew they were connected, you guys thought it was just domestic
wastewater and didn't know they had any process waste streams tied in like we seem to be hearing now. Is that
correct?
C:3 M
Bradley Bennett
Compliance and Expedited Permitting
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
email: [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: Hunkele, Dean
Sent: Monday, March 21, 2022 12:02 PM
To: Bennett, Bradley <bradley.ben [e-mail]>; Tharrington, Tom <[e-mail]>
Cc: Perez, Helen I <[e-mail]>
Subject: RE: Warsaw Pretreatment
Importance: High
FYI - The Villari Meat Smoking/Packing facility (1012 US Hwy 117 S Off Carter Best Rd) has been tied on since at least 5-
2014 as that is when I was there for an unknown spill which is entered under incident # 201400933 in BIMS incident
database for which we issued a NOV-2014-DV-0163 for -- both of which can be found in main BIMS.
I think this was formally a US Cold Storage warehouse.
Dean Hunkele ([e-mail])
Environmental Program Consultant
Water Quality Regional Operations Section
Division of Water Resources/Department of Environmental Quality
DWR Website: http://www.ncwater.org
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
910.796.7215 Reception Desk
910.796.7380 Direct
910.620.1685 Field/Telework Mobile
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
ALERT: New Fast Track application is available; older version will not be accepted after September 2021.
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from application receipt. Please use the
DEQ's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the
reviewer's name. Once issued, the record stays on the site for 30 days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the DWR's Sewer Extension Permit
Tracker. Confirmation using this method will replace letters and emails; it is recommended that confirmation be printed and/or saved.

Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources-
Permits/peres/collection-systems-perm its
From: Hunkele, Dean
Sent: Thursday, March 17, 2022 9:24 AM
To: Bennett, Bradley <bradley. ben [e-mail]>; Tharrington, Tom <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
Yep she is our current PT person
Dean Hunkele ([e-mail])
Environmental Program Consultant
Water Quality Regional Operations Section
Division of Water Resources/Department of Environmental Quality
DWR Website: http://www.ncwater.org
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
910.796.7215 Reception Desk
910.796.7380 Direct
910.620.1685 Field/Telework Mobile
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
ALERT: New Fast Track application is available; older version will not be accepted after September 2021
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from application receipt. Please use the
DEQ's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the
reviewer's name. Once issued, the record stays on the site for 30 days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the DWR's Sewer Extension Permit
Tracker. Confirmation using this method will replace letters and emails; it is recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources-
permits/peres/collection-systems-perm its
From: Bennett, Bradley
Sent: Thursday, March 17, 2022 9:22 AM
To: Hunkele, Dean <[e-mail]>; Tharrington, Tom <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
Okay, I'll try and set something up for Monday with if I can find a time slot that works. I'll include Helen (that's Helen
Perez right?).
m
Bradley Bennett

Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Hunkele, Dean <[e-mail]>
Sent: Thursday, March 17, 2022 8:54 AM
To: Tharrington, Tom <[e-mail]>; Bennett, Bradley <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
I would imagine Helen should be in on it. I'll be working Monday, then out most if not rest of week.
Dean Hunkele ([e-mail])
Environmental Program Consultant
Water Quality Regional Operations Section
Division of Water Resources/Department of Environmental Quality
DWR Website: http://www.ncwater.org
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
910.796.7215 Reception Desk
910.796.7380 Direct
910.620.1685 Field/Telework Mobile
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
ALERT: New Fast Track application is available; older version will not be accepted after September 2021
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from application receipt. Please use the
DEQ's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the
reviewer's name. Once issued, the record stays on the site for 30 days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the DWR's Sewer Extension Permit
Tracker. Confirmation using this method will replace letters and emails; it is recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources-
Permits/peres/collection-systems-perm its
From: Tharrington, Tom
Sent: Wednesday, March 16, 2022 5:34 PM
To: Bennett, Bradley <bradley.ben [e-mail]>; Hunkele, Dean <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
Sounds like a plan Bradley, It will have to be next week as I'm out until Monday
From: Bennett, Bradley
Sent: Wednesday, March 16, 2022 2:17 PM

To: Hunkele, Dean <[e-mail]>; Tharrington, Tom <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
Dean, Tom
When you guys have a chance sometime maybe we can talk and I can give you an update on things with Warsaw. Let
me know when you might be available and we can set up a Teams Call.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradlev.bennett([e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Hunkele, Dean <[e-mail]>
Sent: Tuesday, February 15, 2022 10:40 AM
To: Tharrington, Tom <[e-mail]>; Bennett, Bradley <[e-mail]>
Cc: King, Morella s <[e-mail]>; Coburn, Chad <[e-mail]>
Subject: RE: Warsaw Pretreatment
Importance: High
To my knowledge they only accept domestic waste from Villari via a tap on gravity feeding the pump station (#11)
nearby originally approved under [WQ0012085 (625 gpd) or WQ0013176 (0 gpd)] both of which do not allocate enough
flow for what is connected. That PS is being modified under WQ0043109 for C2NC Biogas being constructed across the
road from it and Villari. Perhaps C2NC may need PT.
They do accept slaughtering waste from Parks Family Meats (WQ0003717) which was connected years back and was
determined to not be a SIU and requiring them to have a PT program.
That is all I know.
Dean Hunkele ([e-mail])
Environmental Program Consultant
Water Quality Regional Operations Section
Division of Water Resources/Department of Environmental Quality
DWR Website: http://www.ncwater.org
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
910.796.7215 Reception Desk
910.796.7380 Direct
910.620.1685 Field/Telework Mobile
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties
ALERT: New Fast Track application is available; older version will not be accepted after September 2021.

The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from application receipt. Please use the
DEQ's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the
reviewer's name. Once issued, the record stays on the site for 30 days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the DWR's Sewer Extension Permit
Tracker. Confirmation using this method will replace letters and emoils; it is recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources-
Permits/peres/collection-systems-perm its
From: Tharrington, Tom
Sent: Tuesday, February 15, 2022 9:59 AM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: Hunkele, Dean <[e-mail]>; King, Morella s <[e-mail]>; Coburn, Chad
<[e-mail]>
Subject: RE: Warsaw Pretreatment
Just let us know
From: Bennett, Bradley
Sent: Tuesday, February 15, 2022 9:55 AM
To: Tharrington, Tom <[e-mail]>
Cc: Hunkele, Dean <[e-mail]>; King, Morella s <[e-mail]>; Coburn, Chad
<[e-mail]>
Subject: RE: Warsaw Pretreatment
Thanks Tom, I have asked the Town to send more info on the industry and waste stream. It sounds like they are
working with their consultant to get a pretreatment program going. I have a message in to Mike Montebello to see if he
wants to have this permit renewal moved over to his group. I'm not sure how that will work out. I had a draft pretty far
along before I noticed one statement in a file on LF about them possibly having SIUs. I guess that might lead to some
adjustments in the permit. I may want to talk with you and Dean to get some thoughts from you on this when you guys
have some time available.
::
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nettCaMcdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Tharrington, Tom <[e-mail]>
Sent: Tuesday, February 15, 2022 9:37 AM
To: Bennett, Bradley <[e-mail]>
Cc: Hunkele, Dean <[e-mail]>; King, Morella s <[e-mail]>
Subject: Warsaw Pretreatment

Hey Bradley, yeah Warsaw receives wastewater from the S&J Vallari processing and packaging facility there in Warsaw.
This is the sister site to the animal processing (swine slaughter) site further away. The town has been in several meetings
with them concerning their discharge which is high BOD and has had some elevated zinc levels. Both sites are looking to
expand their processing volume in the near term. The town doesn't know if I has any additional flow/treatment capacity
to give them.
Tom Tharrington
Assistant Regional Supervisor
Wilmington Regional Office
Water Quality Regional Operations Section
NCDEQ-Division of Water Resources
[phone] Office
tom.tha rrington @ncdenr.gov

Bennett, Bradley
From: Tyndall Lewis <[e-mail]>
Sent: Thursday, February 17, 2022 7:09 AM
To: Bennett, Bradley; Summerlin, Scotty S
Cc: cahughes41 @gmail.com; Cecil Madden; Trey Gurley; Lea Turner
Subject: RE: [External] RE: Permit Renewal for Town of Warsaw WWTP - NCO021903
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Cecil and I plan to assist the Town with addressing the SIUs. Will be in touch.
From: Bennett, Bradley <[e-mail]>
Sent: Monday, February 14, 2022 3:28 PM
To: Summerlin, Scotty S <[e-mail]>
Cc: [e-mail]; Cecil Madden <[e-mail]>; Tyndall Lewis <[e-mail]>; Trey
Gurley <[e-mail]>; Lea Turner <[e-mail]>
Subject: RE: [External] RE: Permit Renewal for Town of Warsaw WWTP - NCO021903
Mr. Summerlin,
We will need additional information on the SIUs to complete our renewal review. There are other areas of the
application form that should be completed with information about them and sent to us.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Scotty Summerlin <[e-mail]>
Sent: Thursday, February 10, 2022 6:17 PM
To: Bennett, Bradley <bradley.ben [e-mail]>
Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail]; finance
<finance(@townofwarsawnc.com>
Subject: [External] RE: Permit Renewal for Town of Warsaw WWTP - NCO021903
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett,
Yes sir. My apologies for the delay. We are working with McDavid Associates, Inc. (Cecil Madden, PE; consultant
engineer and others) to answer these questions. We utilized the assistance of NCRWA staff to produce and submit the

permit renewal application. It appears I overlooked the box and we do have at least one significant industrial user and
one on the way. McDavid Associates, Inc. is assisting Warsaw in our preliminary work to put the appropriate
Pretreatment Program together. Please advise if you need additional information concerning the SIUs.
Work authorized via the 2019 Authorization to Construct (021903A01) is currently in progress with an anticipated
completion date of June 30, 2022. Construction authorized by another Authorization to Construct (021903A02) issued
September 1, 2021 (copy attached) recently started with an expected completion date of March 31, 2023.
I look forward to completing this process and getting permit renewal approval.
Thanks so much,
Scotty Summerlin
Town Manager
Town of Warsaw
PO Box 464
Warsaw, NC 28398
[phone] ext. 105 phone
[phone] mobile
[e-mail]
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Wednesday, February 9, 2022 8:50 AM
To: Scotty Summerlin <[e-mail]>
Cc: [e-mail]
Subject: RE: Permit Renewal for Town of Warsaw WWTP - NCO021903
Mr. Summerlin,
I just wanted to check in and see if you had received my email from last week. I am hoping to finalize your draft permit
soon but needed to get your responses on the questions I sent as I am finishing things up. Let me know if you have any
questions.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources

1617 Mail Service Center
Raleigh, NC 27699-1617
Email: bradley.ben nett()ncdenr.gov
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Wednesday, February 2, 2022 10:14 AM
To: Summerlin, Scotty S
Cc: [e-mail]
Subject: Permit Renewal for Town of Warsaw WWTP - NCO021903
Mr. Summerlin,
I just wanted to touch base and let you know that I am the permit writer for the renewal of the Warsaw WWTP NPDES
Discharge Permit. I am currently working on the draft for the renewal and hope to have it ready for public notice soon.
apologize for the time it has taken to get to this. We have been a little backed up with permit renewals. Below you will
find a couple of requests for your review and response as we move through the renewal process. Please look at these
and provide responses.
Additional Information from Document Review:
In 2020 you submitted an updated sewer use ordinance for review by our Division's Pretreatment Program. In
the submittal letter from your consultant (March 13, 2020) they indicated that "It appears the Town may have
one or more Significant Industrial Users." I'm not sure if this was just an indication of potential new users in the
future? The application for permit renewal indicates that the Town does not have any SIUs. I just wanted to
touch base on this and verify that there are currently no SIU's to the system.
In your application cover letter and other application information you noted the ongoing construction
associated with your 2019 Authorization to Construct (021903A01). You indicated completion of the
improvements by the end of 2021. Could you provide me with an update on the status of the construction? Is it
completed and in operation?
You can provide any feedback on these questions directly to me through this email address.
Electronic Submittal of Documents:
In order to provide more convenience, control, and security to our permittees and assist them in processing
their transactions, The Division of Water Resources is currently transitioning towards electronic
correspondence. This will hopefully provide more efficient service to our permittees and other partners and will
allow us to more effectively process and track documents. We are writing to ask you for your approval of the
transmittal of documents related to your permitting and related activities with the Division in an electronic
format. Documents will be emailed to the appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of your documents in an electronic manner
is acceptable to you. If you have any questions, please feel free to contact me.
Thank you for your review of this information and response. If you have any questions please feel free to contact
me. At this point contacting me through this email address is the most efficient way of getting in touch.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: bradley.ben nett&ncdenr.gov
Email correspondence to and from this address may be subject to public records laws

DWQ Guidance Regarding the Reduction of Monitoring Frequencies in
NPDES Permits for Exceptionally Performing Facilities
October 22, 2012
A. Purpose
In its efforts to reduce the regulatory burden upon permittees while maintaining adequate compliance
oversight over point source discharges, DWQ has developed the following guidance for the reduction
of monitoring frequencies in NPDES permits for specific target parameters. Standard minimum
NPDES monitoring frequencies are established in 15A NCAC 2B .0508 for discharges from facilities
with specific Standard Industrial Classification (SIC) categories. However, 2B .0508(b)(1) states: "If it
is demonstrated to the satisfaction of the Director that any of the tests and measurements, sampling
points, or frequency of sampling requirements, as required in this Rule for a particular SIC group, are
not applicable to the discharge of a particular water pollution control facility, or if it can be
demonstrated that the objectives of this Section can be achieved by other acceptable means then
such requirements may be waived or modified to the extent that the Director determines to be
appropriate." This document identifies criteria to be used by DWQ that satisfies the regulatory
standard for the allowance of reduced monitoring frequencies for facilities included in SIC 4952.
This guidance applies to facilities with outstanding NPDES program compliance histories, exhibiting
effluent discharges that are excellent in both quality and consistency. Such performance will
demonstrate that compliance for particular parameters can be adequately evaluated with less
monitoring. Facilities demonstrating consistent, long-term treatment performance at levels far below
effluent limitations (<50%) may be considered for a reduction in monitoring from existing permit
frequencies to a 2/week minimum frequency for the parameters BOD5, CBOD5 TSS, NH3-N and fecal
coliform/enterococci (the "target parameters").
B. Approval Criteria
Individual NPDES facilities shall submit a written request to modify their NPDES permit specifying
which parameters are to be considered for reduced monitoring . Permit holders must include with
their requests sufficient data, statistical analyses, and other information to support the justification for
reduced monitoring. NPDES permit staff shall review the application and supporting information.
Approval of reduced monitoring frequency shall be granted if all the criteria below are met:
• The facility has no more than one civil penalty assessment for permit limit violations for each
target parameter during the previous three years.
• Neither the permittee nor any of its employees have been convicted of criminal violations of the
Clean Water Act within the previous five years.
• The facility is not currently under an SOC for target parameter effluent limit noncompliance.
• The facility is not on EPA's Quarterly Noncompliance Report for target parameter limit violations.
• For BOD5, CBOD5, TSS, NH3-N and TSS, the three year arithmetic mean of effluent data must be
less than fifty percent of the monthly average permit limit. For fecal coliform or enterococci, the

three year geometric mean must be less than 50 percent of the monthly average permit limit. For
parameters with summer and winter limits, an annual arithmetic mean of the seasonal limits may
be used in the calculation.
• With the exception of fecal coliform or enterococci, no more than 15 daily sampling results over
the 3-year review period can be over 200% of the monthly average limit for BOD5, CBOD5, TSS,
or NH3-N . Values associated with documented impacts of extreme weather or events beyond the
control of the permittee will not be included.
• For fecal coliform or enterococci, no more than 20 daily sampling results may be over 200% of the
weekly average limit. Values associated with documented impacts of extreme weather or events
beyond the control of the permittee will not be included.
• For the four target parameters, sampling results shall not show more than two non -monthly
average limit violations during the previous year.
• Reduced effluent monitoring must not impair assessment of sensitive downstream uses, such as
endangered species.
C. Implementation
After DWQ review and approval, the facility's NPDES permit will be reissued with reduced monitoring
frequencies for qualified parameters. Additional NPDES permit requirements will include:
• Eligible facilities may be granted a reduction from existing permit monitoring frequencies to a
2/week minimum frequency for the four target parameters. Reductions will be made for both
effluent and influent sampling.
• Where monitoring is reduced to twice per week, it must occur on any two non-consecutive days
during the calendar week (Sunday through Saturday).
• Required monitoring frequency reductions establish new permit minimums for monitoring. As
always, facilities may monitor more often than required in the permit.
• If a reportable event, as defined by the permit [e.g., Part II (E) (6 & 9)] occurs, any facility granted
reduced monitoring frequencies will be encouraged to monitor on a daily basis until the episode is
resolved.
Monitoring frequency reduction from the minimum frequencies reductions established by the rules are
based upon consistent, exceptional performance. DWQ may revoke on a case -by -case basis these
reductions if the facility begins to perform in noncompliance with permit limits. If a facility's monitoring
reduction for a specific parameter is removed through permit modification, reconsideration of
monitoring frequency reduction will only occur three years following the revocation/permit modification
action, or at the next permit renewal.