NC0021717_Fact Sheet_20240506

Fact Sheet
NPDES Permit No. NCO021717
Permit Writer/Email Contact:Nick Coco,[e-mail]
Date: May 6,2024
Division/Branch:NC Division of Water Resources/NPDES Municipal Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑ Renewal
® Renewal with Expansion
❑ New Discharge
❑ Modification(Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers,EPA Form 2A or 2D requirements,Engineering Alternatives Analysis,Fee
• For Existing Dischargers (POTW),EPA Form 2A, 3 effluent pollutant scans,4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW),EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable,enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name: Town of Wilkesboro/Cub Creek Wastewater Treatment Plant(WWTP)
Applicant Address: PO Box 1056,Wilkesboro,NC 28697
Facility Address: 700 Snyder Street,Wilkesboro,NC 28697
Permitted Flow: 4.9 MGD,with expansion flow tiers at 6.6 MGD and 8.0 MGD
Facility Type/Waste: MAJOR Municipal; 35%domestic, 65%industrial*
Facility Class: Grade IV Biological Water Pollution Control System
Treatment Units: Influent lift station,Aerated equalization basin,Aeration basin,
Clarifiers,Aerated digester,Ultraviolet disinfection, Sludge drying
beds, Sludge screw press,Flow measurement
Pretreatment Program(Y/N) Y
County: Wilkes
Region Winston-Salem
*Based on permitted flows
Briefly describe the proposed permitting action and facility background.• The Town of Wilkesboro
initially applied for an NPDES permit renewal at 4.9 MGD for the Cub Creek WWTP on April 9, 2019.
The Division submitted an additional information request on January 21,2021 and worked with the Town
and their consultant engineers at HDR to ensure a complete package was submitted. During this time,the
Town and HDR informed the Division of plans to expand the plant due to flows experienced at the
facility reaching 80-90%of the plant's capacity,resulting in a sewer moratorium imposed on July 1,
2021. Prior to this imposition,the Division provided speculative limits for expanded flow tiers at 8.0
MGD and 10.0 MGD on October 28,2020. On January 21,2022,the Town submitted a request for
renewal with modification of their permit to add a 9.0 MGD expanded flow tier. The Division reviewed
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this request and supporting documentation and submitted an additional information request on July 21,
2022, asking for further justification of the 9.0 MGD flow request and reassessment of projected flows.
The Town and HDR submitted additional information and a revised modification request on September
27,2022,this time asking for 8.0 MGD and providing justification of this flow, including a letter from
their major industrial user,Tyson Foods, identifying future flow demand.
This facility serves a population of approximately 4,400 residents. The facility also accepts waste from 3
significant industrial users(SIUs)including 1 categorical(CIU)via their pretreatment program. Treated
domestic and industrial wastewater is discharged via Outfall 001 into the Yadkin River, a class C water in
the Yadkin-Pee Dee River Basin. Outfall 001 is located approximately 8.3 miles upstream of waters
designated as WS-V waters.
In their modification request,the Town indicated that the treatment works is currently experiencing a
volume of approximately 0.8 MGD of 1/1. The Town also notes, "In 2018,WK Dickson conducted a
Wastewater System Asset Inventory and Condition Assessment of the Town of Wilkesboro's collection
and treatment system. This report identified the condition of every component of the system and
identified a risk and replacement priority. One of the key considerations that aided in the priority were
components that would decrease 1/1. As of today,the recommended replacement schedule is being
followed."
Sludge Disposal: Sludge is handled at the plant and disposed of at the landfill.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s): Outfall 001 —Yadkin River
Stream Index: 12-(38)
Stream Classification: C
Drainage Area(miz): 525
Summer 7Q10(cfs) 196
Winter 7Q10(cfs): 267
30Q2 (cfs): -
Average Flow(cfs): 682
IWC (%effluent): 3.7%@ 4.9 MGD, 5.0% @ 6.6 MGD, 6.0% @ 8.0 MGD,
2022 303(d) listed/parameter: Yes; exceeding criteria for pH
Subject to TMDL/parameter: Yes- State wide Mercury TMDL implementation.
River Basin/HUC: 03-07-01/03040101
USGS Topo Quad: C14NW
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3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of June 2019 through November 2023.
Table 1. Effluent Data Summary Outfall 001
Parameter Units Average Max Min Permit Limit
Flow MGD 4.3 8.504 1.023 MA 4.9
BOD mg/1 13.0 93.8 0.8 WA 45.0
MA 30.0
TSS mg/1 17.0 165 1.3 WA 45.0
MA 30.0
NH3N(summer) mg/1 12.6 54.1 0.1 WA 35.0
MA 21.0
NH3N(winter) mg/1 11.2 41.6 0.1 Monitor&Report
DO mg/1 7.5 10.6 4.5 Monitor&Report
(geometric)
14.0
Fecal coliform #/100 ml (ge 2419.6 < 1 WA 400
4.0 MA 200
Temperature ° C 18.1 27.3 2.6 Monitor&Report
pH SU 7.3 8.5 6 6.0<pH<9.0
Oil&Grease mg/l 5.0 6 < 5 WA 45.0
MA 30.0
TN mg/1 15.1 66.3 0.31 Monitor&Report
TP mg/1 7.0 28.7 0.6 Monitor&Report
MA-Monthly Average,WA-Weekly Average
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1)to verify model predictions
when model results for instream DO are within 1 mg/l of instream standard at full permitted flow;2)to
verify model predictions for outfall diffuser; 3)to provide data for future TMDL;4)based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee(in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
Is this facility a member of a Monitoring Coalition with waived instream monitoring(YIN): Y
Name of Monitoring Coalition: Yadkin-Pee Dee River Basin Association
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen,temperature and
conductivity upstream at the bridge between North Wilkesboro and Wilkesboro and downstream 100
yards below the outfall. Instream sampling is conducted three times per week during the months of June,
July,August and September and once per week during the remainder of the year. The Town is a member
of the Yadkin-Pee Dee River Basin Association(YPDRBA) and their instream requirements are
provisionally waived as long as they maintain membership. YPDRBA does not have any monitoring
stations upstream of the discharge. There are three Ambient Monitoring System stations upstream in the
W. Kerr Scott Reservoir,but each is inactive. While no upstream monitoring station exists,YPDRBA
station Q0450000 exists approximately 1 mile downstream of the outfall. Downstream data from June
2019-June 2023 are summarized in Table 2,below.
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Table 2. Downstream Data Summary
Parameter Units
Q0450000
Average Max Min
NH3N mg/1 0.13 0.39 0.02
DO mg/1 9.25 12.8 6.5
Fecal coliform #/100 ml (ge lm6ean) 6300 21
Temperature ° C 16.4 25.6 3.9
Turbidity NTU 20.3 360 4.4
pH SU 6.1 7.3 1.5
NO2+NO3 mg/l 0.43 4.32 0.22
TKN mg/1 0.52 1.73 0.24
TP mg/1 0.07 0.56 0.02
Downstream concentrations for ammonia and TKN at YPDRBA station Q0450000 have trended upward
from 2013 to present,
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while downstream concentrations for pH have trended downward during the same period.
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ActivityStartDate
As the receiving stream is listed in the 2022 303(d)list as impaired for pH, instream pH monitoring has
been added to the permit. As the segment of the Yadkin River to which the Town discharges comprises
part of the headwaters of High Rock Lake,which is impaired for chlorophyll a and turbidity, instream
monitoring for turbidity, total nitrogen(TKN+NO2+NO3), ammonia and total phosphorous monitoring
has been added to the permit. Additionally, as WS-V waters exist approximately 8.3 miles below the
discharge and facility has reported multiple fecal coliform limit violations, instream fecal coliform
monitoring has been added to the permit.
As the facility is pursuing expansion and considering the stream impairment for pH,tracking effluent
impact on the receiving stream is critical.As such,the provisional waiver for instream monitoring has
been revised and is only applicable if the YPDRBA conducts representative upstream sample collection.
Instream sampling is to be conducted by Town of Wilkesboro in the event that YPDRBA does not
accomplish the necessary revisions for conducting sampling that is representative of this facility's
discharge. Additionally,the upstream monitoring location identified in the permit has been revised to the
Yadkin River at Wilkesboro Blvd,just below Reddies River and 0.5 miles above the outfall. See Figure 1
below for a map of monitoring locations.
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Figure 1. Monitoring Station and Effluent Locations
th
Q0450000
North
Wilkesboro
Thurman
azl Street WWTP
O u tfa 11001
I
Upstream Cub Creek WWTTP
s
WIKc'.]DSJIO A
y i
A
t
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): In 2019,the facility reported
2 fecal coliform, 1 flow, 1 ammonia and 1 TSS limit violation resulting in Notices of Violation(NOVs),
as well as 1 ammonia and 1 TSS limit violation resulting in a Notice of Deficiency(NOD). The facility
reported 1 fecal coliform, 3 flow, and 1 TSS limit violations resulting in NODS and 2 TSS limit violations
resulting in NOVs. In 2021,the facility reported 1 TSS and 2 ammonia limit violations resulting in NODS
and 1 TSS and 1 ammonia limit violation resulting in NOVs. The facility reported 4 ammonia limit
violations resulting in NOVs in 2022.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 15 of 15 quarterly chronic toxicity tests as well as 4 of 4 second species
toxicity tests from March 2020 to September 2023.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in September 2023 reported that the facility was out of compliance with NPDES permit NC0021717. The
inspection report noted the following:
1. Many components of the POTW are out of service and have been for—3 years(one mechanical
bar screen,the grit system, a surface aerator, digester, clarifier)
2. Overall the WWTP is having difficulty screening solids at headworks. The buildup of debris can
be seen past bar screen process. Ineffective screening can and will have impacts on post
headwork processes of WWTP.
3. Ongoing issues with DO levels in the aeration basin. DO readings are below 1.0 mg/1
4. Floating solids and scum in the pre-UV channel. POTW is using water hose to disperse scum.
However,the effluent is clear with no floating solids. The use of the water hose was noted during
the last inspection.
The facility upgrades included as part of the expansion construction will address the concerns at the
facility.
The last pretreatment compliance inspection conducted in September 2023 reported that the facility was
compliant with their pretreatment program.
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6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 213.0206,the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow(acute Aquatic Life); 7Q10 streamflow(chronic Aquatic
Life;non-carcinogen HH); 30Q2 streamflow(aesthetics); annual average flow(carcinogen,HH).
If applicable, describe any other dilution factors considered(e.g., based on CORMIX model results):NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA
Oxygen-Consuming Waste Limitations
Limitations for oxygen-consuming waste(e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen(DO)water quality standard. Secondary TBEL limits
(e.g., BOD=30 mg/1 for Municipals)may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: BOD limits are
secondary technology-based effluent limits(TBELs)based on the results of a 1992 Level B analysis and
later 1998 speculative limits provided for expansion to 6.6 MGD have been applied to the 4.9 MGD and
6.6 MGD flow tiers. BOD limits were developed for the requested 8.0 MGD flow tier in the October 2020
speculative limits provided by the Division by freezing the mass-loadings from the currently permitted
levels.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/l (summer)and 1.8 mg/1(winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non-Municipals.
Limitations for Total Residual Chlorine(TRC) are based on the NC water quality standard for protection
of aquatic life(17 ug/1) and capped at 28 ug/l(acute impacts). Due to analytical issues,all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: TRC limits and
monitoring requirements were removed from the permit as the facility uses UV disinfection. However, in
the event of an emergency where chlorination is required as a backup or temporary means of disinfection
at the facility, a TRC limit and monitoring requirement have been added back into the permit based on the
review in the attached WLA spreadsheet. Please note that TRC monitoring is only required in the event
that chlorine is used at the plant and as part of the regular Effluent Pollutant Scans.
The current ammonia limits for both the 4.9 MGD and 6.6 MGD flow tiers were implemented in the
permit based on toxicity-based calculations. Ammonia-nitrogen limits have been reviewed in the attached
WLA and have been found to be protective.No changes are proposed to ammonia limits at these tiers. An
additional 8.0 MGD flow tier has been incorporated in the permit with summer ammonia limits of 13.3
mg/L and 35.0 mg/L based on the October 2020 Speculative limits provided by the Division. These limits
have been reviewed in the attached WLA and found to be protective.
Reasonable Potential Analysis(RPA)for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44(d) (i). The NC
RPA procedure utilizes the following: 1)95% Confidence Level/95%Probability; 2)assumption of zero
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background; 3)use of%detection limit for"less than"values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6,2016,NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10,2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between June 2019
through November 2023 Pollutants of concern included toxicants with positive detections and associated
water quality standards/criteria. Based on this analysis,the following permitting actions are proposed for
this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality-based
effluent limit(WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Total Selenium(all flow tiers)
• Monitoring Only. The following parameters will receive a monitor-only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was>50%of the allowable concentration: N/A
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was<50%of the allowable
concentration: Total Arsenic, Total Cadmium, Total Chromium,Total Copper,Total Lead, Total
Molybdenum, Total Nickel,Total Silver,Total Zinc
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s)will receive a water quality-based effluent limit(WQBEL)
with monitoring, since as part of a limited data set,two samples exceeded the allowable
discharge concentration: N/A
o The following parameter(s)will receive a monitor-only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: N/A
o The following parameters will not receive a limit or monitoring, since they did not
demonstrate reasonable potential to exceed applicable water quality standards/criteria and
the maximum predicted concentration was<50%of the allowable concentration: Total
Beryllium,Total Cyanide,Total Dissolved Solids,Nitrate (assessed using Nitrate+
Nitrite data)
As the discharge is approximately 8.3 miles above WS-V waters,WS standards were considered in the
review.No detections of chlorinated phenolic compounds were reported in the submitted effluent
pollutant scans. While effluent total hardness was reported at levels greater than 100 mg/L during the
period reviewed,the IWC is low enough, even at the highest flow tier,that no impact is anticipated.
Nitrate+Nitrite data from the submitted effluent pollutant scans were used to assess the WS Nitrate
standard.No reasonable potential for excursions above the WS standard were observed for Nitrate.
The 2020-2022 Surface Water Triennial Review proposed several amendments to the 15A NCAC 2B
.0200 rules,including changes to the freshwater dissolved selenium standard,which has been adopted
into rule. The facility discharges to lotic waters and a dissolved selenium standard of 3.1 µg/L has been
applied. The data available are for total selenium and the new standard is for dissolved selenium. At
present,no translator exists for dissolved to total selenium in freshwater. The EPA Form 2A NPDES
application requires selenium be reported for the application as"total recoverable,"which is reflected in
the Effluent Pollutant Scan special condition of the permit.Additionally,the acute criterion applied for
selenium is for total selenium,not dissolved. Until a translator is identified for dissolved to total selenium,
a translator of 1.0 is assumed and total selenium data will be collected and applied against the dissolved
and total selenium limits in the permit. Based on the RPA assessment, limits and monthly monitoring
have been added at all flow tiers.
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If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity(WET)have been established in
accordance with Division guidance(per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging"complex"wastewater(contains anything other than
domestic waste)will contain appropriate WET limits and monitoring requirements,with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits,using single concentration screening tests,with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: The permit requires quarterly chronic toxicity testing at
3.7%effluent concentration at 4.9 MGD, 5.0%effluent concentration at 6.6 MGD.No changes are
proposed for these flow tiers. Quarterly chronic toxicity testing at 6.0%effluent concentration at 8.0
MGD has been added to the permit. Please note that the toxicity IWC provided in the October 28, 2020
included a rounding error which has been corrected for the final permit.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria(0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year(81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources(^2%of total load),the TMDL emphasizes mercury minimization plans (MMPs)for point source
control. Municipal facilities>2 MGD and discharging quantifiable levels of mercury(>1 ng/1)will
receive an MMP requirement. Industrials are evaluated on a case-by-case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/l.
Table 3. Mercury Effluent Data Summary(4.9 MGD)
2020 2021 2022 2023
#of Samples 3 4 2 2
Annual Average Conc.n /L 1.5 1.4 2.7 3.1
Maximum Conc.,n /L 1.75 2.61 4.90 3.72
TBEL,n /L 47
WQBEL,n /L 321.68 @ 4.9 MGD,241.91 @ 6.6 MGD, 201.7 @ 8.0 MGD
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL,no mercury
limit is required. Since the facility is>2 MGD and reported multiple detections(> 1 ng/L), a mercury
minimization plan(MMP) is required. The MMP requirement will be maintained.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: The segment of the Yadkin River to which the Town discharges comprises part of the
headwaters of High Rock Lake,which is impaired for chlorophyll-a and turbidity. A TMDL is currently
in development for High Rock Lake. Per Session Law 2005-190 Senate Bill 981, "If the Environmental
Management Commission determines either that water quality in all or in any part of a drinking water
supply reservoir to which this section applies does not meet current water quality standards or that it is
likely that water quality will not meet water quality standards at any time prior to 1 July 2010, the
Commission shall not make any new or increased nutrient loading allocation to any person who is
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required to obtain a permit under G.S. 143-215 for an individual wastewater discharge directly or
indirectly into that reservoir. This limitation on new or increased nutrient loading allocation shall not be
construed to prohibit a person who holds a permit for a wastewater discharge into a drinking water supply
reservoir from purchasing a nutrient loading allocation from another person who holds a permit for a
wastewater discharge into the same drinking water supply reservoir."
As the Town has requested modification to their permit to incorporate an additional 8.0 MGD expanded
flow tier, and as explained in the October 28,2020 Speculative Effluent Limits letter, Total Nitrogen
(TN) and Total Phosphorus(TP)mass-loading have been added to the permit for the 8.0 MGD flow tier,
held to current discharge levels based on the last three years annual average (2017-2020). These limits
may change based on rulemaking, adoption of a High Rock Lake TMDL, or other nutrient strategy
implemented in the future. Total monthly flow reporting and a special condition have been added to the
permit outlining how annual nutrient loading is to be calculated.
The effluent limitations provided in the 2020 speculative limits letter are provided Table 4, shown below.
Table 4. Speculative Limits for Cub Creek WWTP (8.0 MGD)
Effluent Characteristic Effluent Limitations
Monthly Weekly Daily Maximum
Average Average
Flow 8.0 MGD
OD5 24.4 mg1L 36.6 m
NH3 asN' 13.3m L 35.0m
SS 30.0 mg/L 45.0 m
RC(if used for 28 µg/L
disinfection)
N-' 205,476lbs/ ear
P 109,872lbs/ ear
Fecal coliform(geometric. 200/100 mL 400/100 mL
mean)
Chronic Toxicity,Pass/Fall 5.9%
(Quarterly test)
Notes:
1. Based on current permitted critical flows,flows will be updated through USGS upon receipt of
permit modification application.Values are subject to change.
2. Equivalent to a concentration of 8.4 mg/L.
3. Equivalent to a concentration of 4.5 mg/L.
The High Rock Lake nutrient reopener special condition has been maintained in the permit.
See Toxicity Testing Limitations for more information regarding the chronic toxicity requirements.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs:
The current permit has Oil&Grease(O&G)requirements of a 30.0 mg/L monthly average limit and 45.0
mg/L weekly average limit with monthly monitoring,based on BPJ. O&G is a parameter of concern in
the pretreatment program,based in part on its regulation in the Industrial User Permits for the SIU Tyson
Farms,which has O&G limits. Based on review of the data, consistent compliance with permit limits, and
that O&G is being tracked through the pretreatment program, O&G limits and monitoring have been
removed from the permit.
As required by Session Law 2018-5, Senate Bill 99, Section 13.1(r), every applicant shall submit
documentation of any additional pollutants for which there are certified methods with the permit
application if their discharge is anticipated. The Town of Wilkesboro informed the Division that no
monitoring for additional pollutants has been conducted(see attached chemical addendum)and therefore
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no additional pollutants of concern have been identified in their effluent. However,the Town has
conducted and reported to the Division sampling conducted at the 2 landfills from which the Cub Creek
WWTP accepts wastewater. One analysis was conducted at each landfill for a suite of PFAS compounds
and 1,4-dioxane. While the 1,4-dioxane samples came back as non-detected, a number of PFAS
compounds were identified in the leachate at both landfills.
As only 2 samples were collected,one from each of the 2 landfills, additional analysis of 1,4-dioxane at
the Cub Creek WWTP,which discharges approximately 8.3 miles upstream of WS-V waters, is
warranted. Quarterly effluent monitoring of 1,4-dioxane and a 1,4-dioxane permit reopener has been
added to the permit. After a 24-month sampling period,the Permittee may request the Division conduct a
review of submitted data for assessment and approval of a 1,4-dioxane monitoring frequency reduction
from quarterly to annually.Note that,based on an AAF of 682 cfs and the WS ISTV of 0.35 µg/L,the
allowable discharge concentrations for 1,4-dioxane at this facility are 31.7 µg/L,23.6 µg/L and 19.6 µg/L
for the 4.9 MGD, 6.6 MGD and 8.0 MGD flow tiers,respectively.
As the facility has identified PFAS compounds in its effluent and discharges approximately 8.3 miles
upstream of WS-V waters, influent and effluent PFAS monitoring has been added to the permit at a
quarterly frequency. EPA Method 1633 was finalized on January 31, 2024. However, the methodology
has yet to be published in the Federal Register. Sampling using the method shall take effect the first full
calendar quarter following 6 months after the effective date of the permit to provide the Permittee time to
select a laboratory, develop a contract, and begin collecting samples. Effective 6 months after EPA has
the method in 40 CFR 136 published in the Federal Register,the Permittee shall conduct influent and
effluent monitoring using the approved Method 1633.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal:NA
7. Technology-Based Effluent Limitations (TBELs)
Municipals (if not applicable,delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l
BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES
If NO,provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85%removal requirements for BODS/TSS included in the permit? YES
If NO,provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non-discharge alternatives per 15A NCAC 2H.0105(c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: The proposed expansion is subject to review
under the State of North Carolina Environmental Policy Act(SEPA). A Finding of No Significant Impact
(FONSI)was issued on January 29,2024.
Page 11 of 17

An Engineer's Alternatives Analysis (EAA)was submitted by HDR,the consulting firm hired by the
Town of Wilkesboro, on January 21, 2022. The Division reviewed this EAA and supporting
documentation and submitted an additional information request on July 21,2022, asking for further
justification of the 9.0 MGD flow request and reassessment of projected flows. The Division noted
specifically the approximated 1.5 MGD of I/I that is being experienced in the system. The Town and
HDR submitted additional information and a revised modification request on September 27, 2022,this
time asking for 8.0 MGD and providing justification of this flow, including a letter from their major
industrial user,Tyson Foods, identifying future flow demand. The Town also noted that efforts to
mitigate I/I will be undertaken alongside the expansion of the facility. After reviewing the revised request
and analysis,Division staff concurred with the projected flow justification as well as the alternatives
analysis. Division staff concurred with the projected flow needs based on a 20-year planning horizon. The
Cub Creek WWTP treats wastewater for a population of approximately 66,000 residents. While Wilkes
County has demonstrated a slight decrease in population from 2010—2022,the Town's residential status
has remained relatively consistent over the same time period. The flow projections provided by HDR
incorporate the expected municipal demand based on the population projections as well as the industrial
demand,which considers both the noted growth at Tyson Foods and anticipated additional industries.
HDR projects demand out to 2042. Division staff concurs with the modelled growth provided by HDR as
it is consistent with the 2010—2020 North Carolina Office of State Budget and Management population
growth extrapolated out to 2040, and the Town has provided written correspondence of plans to expand
production at Tyson Foods.
The following alternatives were evaluated for the expanded flow:
Alternative Description Total Cost
No Action. N/A
Connection to an Existing WWTP $494,600,000
Land Application $146,786,688
Wastewater Reuse Not viable—consumption demand of nearby facilities is insufficient
Expansion of facility $68,769,086 calculated as 20- ear Net Present Value
Connection to an Existing WWTP: The Town of Wilkesboro would convey approximately 12.3 MGD
of peak flows(4.1 MGD of max month flows)to another WWTP according to 20-year projected growth
in the service area. The closest facility to the Town of Wilkesboro is the North Wilkesboro WWTP. The
North Wilkesboro WWTP has 2.0 MGD of permitted capacity. The plant currently utilizes 1.2 MGD and
has 0.8 MGD of available plant capacity. It would not be feasible therefore to construct a force main to
the Town of North Wilkesboro since North Wilkesboro's plant would be able to provide only about one-
quarter of the needed capacity in Wilkesboro. The next closest facility that would have the capacity to
treat Wilkesboro's additional flows would be in Winston-Salem,NC. Winston-Salem/Forsyth County
Utilities operates two wastewater treatment facilities: the Archie Elledge WWTP and the Muddy Creek
WWTP with capacities of 30 MGD and 21 MGD,respectively. The cost estimate provided for this
alternative considers approximately 307,000 linear feet of 24-inch ductile iron pipe. The total cost,
including standard fees was estimated at approximately$494,600,000.
Land Application: The closest substantial facility to Wilkesboro that land applies to similar soils in the
project area is the Weyerhaeuser facility in Surry County. The Weyerhaeuser land application rates and
ratio of usable to unusable area was used to determine the amount of overall land needed to be purchased
by Wilkesboro for a land application alternative. Weyerhaeuser loading rates associated with older fields
that may have been damaged by past land management practices (those listed as 20 in/yr)were not
considered in estimating a loading rate for Wilkesboro. A loading rate of 31.8 in/yr was used for
Wilkesboro based on Fields A,B, CN, and CS. The Town also provided land application sites and limits
from permits for Wayne Farms,LLC (WQ0009826),Venture Properties,LLC (WQ0029195), and Kotis
Page 12 of 17

Properties,Inc. (WQ0013808),which are all smaller facilities. All the soils for these permits are soils
from the piedmont/upper piedmont. Loading rates in these permits vary between 12 to 52 inches per
year. While a few fields are rated higher in these permits than 31.8 inches per year,many are also
permitted for a lower rate. For a general evaluation of this alternative, a loading of approximately 30
inches per year seems reasonable. To determine the needed acreage Wilkesboro would need to purchase
to obtain an effective irrigatable 3,800 acres, a polygon was created around the spray fields associated
with the Weyerhaeuser permit. Even though this probably does not reflect the nature of putting together
thousands of acres across multiple parcels of land, it provides the necessary multiplier for screening
purposes to see if further analysis is needed. That is, it is likely Wilkesboro would require multiple sites
that would increase unusable areas versus the single site at Weyerhaeuser. The polygon around the
Weyerhaeuser site is approximately 70 acres. Given the loading rates and accounting for unusable
acreage, it is estimated Wilkesboro would need more than 10,700 acres.A sample of land costs for larger
parcels in Wilkes County was approximately$6,200 per acre. This likely undervalues land as there are
not many large parcels near Wilkesboro and the town would need to buy smaller parcels with structures
that would dictate a higher price.Nonetheless,this would put the entire land application costs of the entire
8 MGD facility to approximately$147 million.
Wastewater Reuse: Wastewater reuse was deemed an infeasible option since consumption demand of
nearby facilities is insufficient for the treated effluent from the Cub Creek WWTP.
Direct Discharge to Surface Waters: The total construction cost to expand the Cub Creek WWTP to 8.0
MGD is approximately$60 million not including soft costs associated with the project. The most
economically feasible and chosen option was the expansion of the Cub Creek WWTP. The Division
has reviewed the alternatives and concurs with this decision.
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4)of the CWA and federal regulations at 40 CFR 122.44(1)prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit,with some exceptions where limitations
may be relaxed(e.g.,based on new information,increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit(YES/NO): YES
If YES, confirm that antibacksliding provisions are not violated: The current permit has monthly average
and weekly average limits for oil and grease based on previous history with the parameter due to an
industrial user. During the period reviewed(past 4.5 years),the facility has only reported 3 detections of
oil and grease,once at 6 mg/L and twice 5 mg/L. Additionally,no permit violations have been issued for
oil and grease during the period reviewed. As such,the permit limits and monitoring requirements have
been removed.
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500;2)
NPDES Guidance,Monitoring Frequency for Toxic Substances(7/15/2010 Memo); 3)NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance(10/22/2012 Memo); 4)Best
Professional Judgement(BPJ). Per US EPA(Interim Guidance, 1996),monitoring requirements are not
considered effluent limitations under Section 402(o)of the Clean Water Act, and therefore anti-
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring,refer to Section 4.
Page 13 of 17

Based on discussion with the DWR Basin Planning Branch,to support planning efforts,and as the two
parameters are used in calculating TN,monthly monitoring and reporting for TKN and NO2+NO3 has
been added to the permit.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21,2015. Effective
December 21, 2016,NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. While NPDES regulated facilities would initially be required to submit additional
NPDES reports electronically effective December 21,2020,EPA is proposing to extend this deadline
from December 21,2020,to December 21, 2025. This permit contains the requirements for electronic
reporting, consistent with Federal requirements. The current compliance date will be extended if the
implementation date is extended as a final regulation change in the federal register.
12.Summary of Proposed Permitting Actions:
Table 4. Current Permit Conditions and Proposed Changes 4.9 MGD
Parameter Current Permit Proposed Change Basis for Condition/Change
Flow MA 4.9 MGD with No change to 4.9 MGD 15A NCAC 2B .0505;EAA review
expansion flow tier 6.6 and 6.6 MGD flow tiers; and expansion request approval
MGD add 8.0 MGD flow tier
per modification request
Total Monthly No requirement No change to 4.9 MGD For calculation of TN Load
Flow and 6.6 MGD flow tiers;
Add Monitor and Report
monthly @ 8.0 MGD
flow tier:
BOD5 @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD TBEL for 4.9 MGD and 6.6 MGD
tiers: and 6.6 MGD flow tiers; tiers-based on 1992 Level B
MA 30.0 mg/l @ 8.0 MGD flow tier: analysis; WQBEL for 8.0 MGD
WA 45.0 mg/1 MA 24.4 mg/l flow tier-2020 Speculative
Daily monitoring WA 36.6 mg/1 Limits/Freezing mass-loading;
Monitor and Report Surface Water Monitoring, 15A
Daily NCAC 2B. 0500
NH3-N Summer: No change to 4.9 MGD WQBEL. Based on ammonia
@ 4.9 MGD flow tier: and 6.6 MGD flow tiers; toxicity; 2020 Speculative Limits
MA 21.0 mg/l and 2022 WLA spreadsheet;
WA 35.0 mg/l @ 8.0 MGD flow tier: Surface Water Monitoring, 15A
Monitor and Report Daily Summer: NCAC 2B. 0500
@ 6.6 MGD flow tier: MA 13.3 mg/l
MA 16.0 mg/l WA 35.0 mg/l
WA 24.0 mg/1 Monitor and Report
Monitor and Report Daily Daily
Winter: Winter:
@ 4.9 MGD and 6.6 MGD Monitor and Report
tiers: Daily
Monitor and Report Daily
TSS @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD TBEL. Secondary treatment
tiers: and 6.6 MGD flow tiers; standards/40 CFR 133 / 15A
MA 30 mg/l NCAC 2B .0406; 2020 Speculative
WA 45 mg/l @ 8.0 MGD flow tier: Limits; Surface Water Monitoring,
Daily monitoring MA 30.0 mg/l 15A NCAC 2B. 0500
Page 14 of 17

WA 45.0 mg/l
Monitor and Report
Dail
Fecal coliform @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD WQBEL. State WQ standard, 15A
tiers: and 6.6 MGD flow tiers; NCAC 2B; Surface Water
MA 200/100ml @ 8.0 MGD flow tier: Monitoring, 15A NCAC 2B. 0500
WA 400/100ml MA 200/100ml
Daily monitoring WA 400/100ml
Daily monitoring
DO @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD Surface Water Monitoring, 15A
tiers: and 6.6 MGD flow tiers; NCAC 2B. 0500
Daily monitoring @ 8.0 MGD flow tier:
Daily monitoring
Temperature @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD Surface Water Monitoring, 15A
tiers: and 6.6 MGD flow tiers; NCAC 2B. 0500
Daily monitoring @ 8.0 MGD flow tier:
Daily monitoring
pH @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD WQBEL. State WQ standard, 15A
tiers: and 6.6 MGD flow tiers; NCAC 2B; Surface Water
6-9 SU @ 8.0 MGD flow tier: Monitoring, 15A NCAC 2B. 0500
Daily monitoring 6-9 SU
Daily monitoring
Total Residual No requirement All flow tiers: WQBEL. 2023 WLA review.
Chlorine DM 28 ug/L Based on potential for emergency
Monitor and Report chlorination-only effective if
Daily chlorination used.
Oil and Grease MA 30.0 mg/L Remove requirement DMR data review and compliance
WA 45.0 mg/L evaluation
Monitor and Report
Monthly
Total Selenium No requirement 4.9 MGD: Based on results of RPA; RP
MA 83.1 µg/L shown @ all flow tiers-add limits
DM 1,230 µg/L with monthly monitoring
6.6 MGD:
MA 62.5 µg/L
DM 927.6 µg/L
8.0 MGD:
MA 52.1 µg/L
DM 775.1 µg/L
Monthly monitoring at
all flow tiers
Total Hardness No requirement All flow tiers: Hardness-dependent dissolved
Quarterly monitoring metals water quality standards
Upstream and in approved in 2016
Effluent
TKN No requirement All flow tiers: For calculation of Total Nitrogen
Monitor and Report
Monthly
Page 15 of 17

NO2+NO3 No requirement All flow tiers: For calculation of Total Nitrogen
Monitor and Report
Monthly
Total Nitrogen @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD Surface Water Monitoring, 15A
tiers: and 6.6 MGD flow tiers; NCAC 2B. 0500
Monitor and Report @ 8.0 MGD flow tier:
Monthly Monitor and Report
Monthly
TN Load No requirement No change to 4.9 MGD WQBEL. Session Law 2005-190
and 6.6 MGD flow tiers; Senate Bill 981; Discharge to High
Rock Lake; 2020 Speculative
@ 8.0 MGD flow tier: limits—loading based on previous
Monitor and Report 3 years of TN data
Monthly(as lb/mo)
Annual TN mass limit of
205,476 lb/yr
Total @ 4.9 MGD and 6.6 MGD No change to 4.9 MGD Monitoring, 15A NCAC 2B. 0500
Phosphorous tiers: and 6.6 MGD flow tiers;
Monitor and Report @ 8.0 MGD flow tier:
Monthly Monitor and Report
Monthly
TP Load No requirement No change to 4.9 MGD WQBEL. Session Law 2005-190
and 6.6 MGD flow tiers; Senate Bill 981; Discharge to High
@ 8.0 MGD flow tier: Rock Lake; 2020 Speculative
Monitor and Report limits loading based on previous
Monthly(as lb/mo) 3 years of TN data
Annual TP mass limit of
109,872 lb/yr
Instream Monitor DO,conductivity Add monthly instream Surface Water Monitoring;
monitoring and temperature upstream monitoring for TKN, discharge—8.3 miles above WS-V
and downstream NO2+NO3,TN, waters, discharge into headwaters
Provisional waiver— ammonia,TP,pH, of High Rock Lake, stream
YPDRBA turbidity and fecal impaired for pH,noncompliance
coliform; Provisional with fecal coliform limits; Facility
waiver further expanding
conditioned upon
upstream sampling
1,4-dioxane No requirement All flow tiers: Monitoring; Based on Pretreatment
Add quarterly program—SIUs with potential for
monitoring and reopener 1,4-dioxane
condition
PFAS No requirement Facility receives wastewater from
Add quarterly industries recognized as potential
monitoring
PFAS sources,plus several
detections reported from an
effluent sample.
Chronic Chronic limit, No change to 4.9 MGD WQBEL. No toxics in toxic
Toxicity and 6.6 MGD flow tiers; amounts. 15A NCAC 2B
Chronic limit,
Page 16 of 17

3.7% effluent @ 4.9 6.0%effluent @ 8.0
MGD, and 5.0%effluent MGD
@ 6.6 MGD
Effluent Three times per permit No change; 2025,2026, 40 CFR 122
Pollutant Scan cycle 2027
Mercury MMP Special Condition No change Consistent with 2012 Statewide
Minimization Mercury TMDL Implementation
Plan(MMP)
Electronic Electronic Reporting No change In accordance with EPA Electronic
Reporting Special Condition Reporting Rule 2015.
MGD—Million gallons per day,MA- Monthly Average,WA—Weekly Average,DM—Daily Max, QA
—Quarterly Average,DA—Daily Average,AA—Annual Average
13. Public Notice Schedule:
Permit to Public Notice: March 14, 2024
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice.Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit,please
contact Nick Coco at(919) 707-3609 or via email at [e-mail].
15. Fact Sheet Addendum (if applicable):
The draft permit was submitted to the Town of Wilkesboro, EPA Region IV, HDR Inc,the Division of
Water Infrastructure, and the Division of Water Resources' Winston-Salem Regional Office,Pretreatment
Program,Aquatic Toxicology Branch,Ecosystems Branch and Operator Certification Program for
review.No comments were received from any party.
Were there any changes made since the Draft Permit was public noticed(Yes/No): YES
If Yes, list changes and their basis below:
• Downstream monitoring for total hardness was mistakenly added to the draft permit and has been
removed.
• Downstream monitoring for dissolved oxygen was mistakenly omitted from the draft permit and
has been added.
16. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• BOD and TSS Removal
• Monitoring Reduction Frequency Spreadsheet
• Dissolved Metals Implementation/Freshwater
• Waste Load Allocation Spreadsheet
• Mercury TMDL Spreadsheet
• Toxicity Summary
• Instream Monitoring Summary
• Renewal Application Addendum
Page 17 of 17

Public Notice
AFFP
NOT- WASTEWATER- CUBCREEK North Carolina
Environmental Management
Comm IssiortfINPIDES Unit
Affidavit of Publication 1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of 'Intent to Issue a NP-
STATE OF NCJ DES Wastewater Permit
COUNTY OF J 1` es SS NC0021'717 Cub Creek WWTP
The North Carolina Enulron-
mental Management Commis-
Betty Denny, being duly sworn, says: slon proposes to issue a NP-
DES wastewater discharge mit to the person(s) listed be per
That she is Billing Clerk of the Wilkes Journal-Patriot, a low. Written comments regard-
newspaper of general circulation, printed and ing the proposed permit will be
published in North Wilkesboro, County, NC; that the accepted until 3Li days after the
publication, a copy of which is attached hereto, was publish date of this notice. The
published in the said newspaper on the following dates: Director of the NBC t3lulSton of
March 14, 2024 Water Resources (D R) may
hold a public hearing should
there be a significant dogree of
public interest. Please mail
comments and/or Information
requests to D R at the above
address. Interested persons
That said newspaper was regularly issued and circulated may visit. the D R at 512 N.
on those dates. Salisbury Street. Raleigh, NC
SIGNED: 27604 to review the informa=
tion on file.. Additional informa-
tion on NPOES, permits and this
noticer may be found on our
Billing Clerk website: https.,/tdeqnc.gov/.,,,pub-
Subscribed to and sworn to me this 14th day of March lic-notices-hearings;or by call-
2024. ling (91 g) 707-3601. The Town
of Wilkesboro (PO Box 1056,
Wilkesboro, NC 26697] has re-
quested renewal and eer m
hJ sian of PD- ES permit
NCO0 1717 for Its Cub Creek
Michael C. Lambert Sr., NOTARY Burke, County, NC Wastewater Treatment Plant,
My commission expires:June 04% a ��� located in Wiikes� County. This
� �M6 permitted facility discharges
treated municipal and industrial
:: t�OTA9 U, wastewater to the Yadkin River,
Y ': y a� class 0 water in 'the Yadkin
a Pee Dee River Basin. Our-
rently BOO, ammonia, focal co-
.pU
(WJP) WREN THEDFORD ,� `--- _ ��' iiform, pH, total residual �chlcrr-
NCDEQ-DIVISION OF WATER '`. ine, total -solenlum, total nitro-
1617 MAIL SERVICE CENTER "rrrs,+FE"t gen loading and' total phosphor-
RALEIGH, NC27699 ous. loading are water quality
limited. This discharge may of-
feet future allocations in this
segment of the 'Yadkin River.
March 14, 2024

Wilkesboro WRF > Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators QW = 4.9 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 4.9000 WWTP/WTP Class: IV COMBINED HARDNESS (mg/L)
1Q10S (cfs) = 159.23 IWC% @ 1Q10S = 4.552674959 Acute = 2 8.3 7 mg/L
7Q10S (cfs) = 196.00 IWC% @ 7QIOS = 3.730445247 Chronic= 27.76 mg/L
7QIOW (cfs) = 267.00 IWC% @ 7Q10W= 2.765891586 YOU HAVE DESIGNATED THIS RECEIVING
30Q2 (cfs) = 196.00 IWC% @ 30Q2 = 3.730445247 STREAM AS WATER SUPPLY
Avg. Stream Flow, QA(cfs) = 682.00 IW%C @ QA= 1.101371095 Effluent Hard: 48 value > 100 mg/L
Receiving Stream: Yadkin River HUC 03040101 Stream Class: C default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L)
PARAMETER NC STANDARDS OR EPA CRITERIA J co REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
CY
TYPE Chronic Standard Acute n #Det. Max Pred Cw Allowable Cw
Acute (FW): 7.468.1
Arsenic C 150 FW(7QIOs) 340 ug/L _
17 0 5.0 Chronic (FW) 4,021.0 No RP, Predicted Max< 50% of Allowable Cw- No
Max MDL= 10 Monitoring required
--------- -----------------------------
Arsenic C 10 HH/WS(Qavg) ug/L NO DETECTS Chronic (HH) 908.0
Max MDL 10
Acute: 1,427.73
Beryllium NC 6.5 FW(7QIOs) 65 ug/L 2 0 9.48
Note: n< 9 C.V. (default) Chronic: 174.24 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 5 Monitoring required
Acute: 79.464
Cadmium NC 0.6385 FW(7QIOs) 3.6177 ug/L 17 0 1.000
Chronic: 17.116 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 2 Monitoring required
Acute: 22,048.9
Chromium III NC 128.2776 FW(7010s) 1003.8156 ua/L 0 0 N/A
Chronic: 3,438.7
Acute: 351.4
Chromium VI NC 11 FW(701Os) 16 ua/L 0 0 N/A
--Chronic: -----294.9--- ---------------------------
Tot Cr value(s) > 5 but< Cr VI Allowable Cw a: No monitoring required if all Total Chromium
Chromium, Total NC µg/L 17 2 11.0 Max reported value = 8 samples are < 5 tag/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Acute: 259.12
Copper NC 8.6185 FW(7QIOs) 11.7967 ug/L 16 16 44.50
Chronic: 231.03 [Monitoring
o RP, Predicted Max< 50% of Allowable Cw- No
No value>Allowable Cw required
Acute: 483.2
Cyanide NC 5 FW(7QIOs) 22 10 ug/L 5 0 11.6
Note: n< 9 C.V. (default) Chronic: 134.0 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 10 Monitoring required
Acute: 1,911.465
Lead NC 3.3095 FW(7QIOs) 87.0228 ug/L 17 0 5.000
Chronic: 88.717 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 10 Monitoring required
Acute: NO WQS
Molybdenum NC 160 WS(7QIOs) ug/L 14 1 6.1 ------------------- -----------------------------
Chronic: 4,289.0 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
21717 RPA, rpa
Page 1 of 2 2/2/2024

Wilkesboro WRF Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 4.9 MGD
Acute (FW): 8,194.0
Nickel NC 40.6810 FW(7Q10s) 373.0472 µg/L ___
17 2 39.5 Chronic (FW) 1,090.5
No-value >Allowable Cw --- -----------------------------
Nickel NC 25.0000 WS(7Q10s) µg/L Chronic (WS) 670.2 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
Acute: 1,230.0
Selenium NC 3.1 FW(7Q10s) 56 ug/L 17 2 135.0
--Chronic: ----- 83.1 ---No value >Allowable Cw ---------------------------
RP shown - apply Monthly Monitoring with Limit
Acute: 8.092
Silver NC 0.06 FW(7Q10s) 0.3684 ug/L 17 0 2.500
------------------- -----------------------------
Chronic: 1.608 All values non-detect< 5 ug/L; No monitoring added;
Permittee shall use PQL < 1 ug/L
NO DETECTS Max MDL= 5
Acute: 3,073.3 No RP, Predicted Max< 50% of Allowable Cw- No
Zinc NC 138.4947 FW(7Q10s) 139.9179 ug/L 10 10 487.5 Monitoring required
--Chronic: ----3,712.E -- ---------------------------
No value >Allowable Cw
Acute: NO WQS
TDS NC 500 WS(7Q10s) mg/L 3 3 1,944.00000
Note: n<9 C.V. (default) Chronic: 13403.226 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set No value >Allowable Cw Monitoring required
Acute: NO WQS
Nitrate NC 10 WS(7Q 10s) mg/L 3 2 90.60000 __
Note: n<9 C.V. (default) Chronic: 268.06452 No RP , Predicted Max >_ 50% of Allowable Cw
Limited data set No value > Allowable Cw Monthly Monitoring for NO3-N + NO2-N added
21717 RPA, rpa
Page 2 of 2 2/2/2024

Wilkesboro WRF > Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators QW = 6.6 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 6.6000 WWTP/WTP Class: IV COMBINED HARDNESS (mg/L)
1Q10S (cfs) = 159.23 IWC% @ 1Q10S = 6.036822849 Acute = 29.47 mg/L
7Q10S (cfs) = 196.00 IWC% @ 7QIOS = 4.960481016 Chronic= 28.67 mg/L
7QIOW (cfs) = 267.00 IWC% @ 7Q10W= 3.690076832 YOU HAVE DESIGNATED THIS RECEIVING
30Q2 (cfs) = 196.00 IWC% @ 30Q2 = 4.960481016 STREAM AS WATER SUPPLY
Avg. Stream Flow, QA(cfs) = 682.00 IW%C @ QA= 1.477832512 Effluent Hard: 48 value > 100 mg/L
Receiving Stream: Yadkin River HUC 03040101 Stream Class: C default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L)
PARAMETER NC STANDARDS OR EPA CRITERIA J co REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
CY
TYPE Chronic Standard Acute n #Det. Max Pred Cw Allowable Cw
Acute (FW): 5.632.1
Arsenic C 150 FW(7QIOs) 340 ug/L _
17 0 5.0 Chronic (FW) 3,023.9 No RP, Predicted Max< 50% of Allowable Cw- No
Max MDL= 10 Monitoring required
--------- -----------------------------
Arsenic C 10 HH/WS(Qavg) ug/L NO DETECTS Chronic (HH) 676.7
Max MDL 10
Acute: 1,076.73
Beryllium NC 6.5 FW(7QIOs) 65 ug/L 2 0 9.48
Note: n< 9 C.V. (default) Chronic: 131.04 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 5 Monitoring required
Acute: 61.948
Cadmium NC 0.6543 FW(7QIOs) 3.7397 ug/L 17 0 1.000
Chronic: 13.190 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 2 Monitoring required
Acute: 17,153.6
Chromium III NC 131.7123 FW(7010s) 1035.5333 ua/L 0 0 N/A
Chronic: 2,655.2
Acute: 265.0
Chromium VI NC 11 FW(701Os) 16 ua/L 0 0 N/A
--Chronic: -----221.8--- ---------------------------
Tot Cr value(s) > 5 but< Cr VI Allowable Cw a: No monitoring required if all Total Chromium
Chromium, Total NC µg/L 17 2 11.0 Max reported value = 8 samples are < 5 tag/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Acute: 202.53
Copper NC 8.8594 FW(7QIOs) 12.2265 ug/L 16 16 44.50
Chronic: 178.60 [Monitoring
o RP, Predicted Max< 50% of Allowable Cw- No
No value>Allowable Cw required
Acute: 364.4
Cyanide NC 5 FW(7QIOs) 22 10 ug/L 5 0 11.6
Note: n< 9 C.V. (default) Chronic: 100.8 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 10 Monitoring required
Acute: 1,504.3 55
Lead NC 3.4317 FW(7QIOs) 90.8153 ug/L 17 0 5.000
Chronic: 69.181 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 10 Monitoring required
Acute: NO WQS
Molybdenum NC 160 WS(7QIOs) ug/L 14 1 6.1 ------------------- -----------------------------
Chronic: 3,225.5 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
21717 RPA, rpa
Page 1 of 2 2/2/2024

Wilkesboro WRF Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 6.6 MGD
Acute (FW): 6,381.3
Nickel NC 41.8066 FW(7Q10s) 385.2293 µg/L
17 2 39.5 Chronic (FW)----842.8---No-value >Allowable Cw --- -----------------------------
Nickel NC 25.0000 WS(7Q10s) µg/L Chronic (WS) 504.0 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
Acute: 927.6
Selenium NC 3.1 FW(7Q10s) 56 ug/L 17 2 135.0
--Chronic: ----- 62.5 ---1 value(s) >Allowable Cw ---------------------------
RP shown - apply Monthly Monitoring with Limit
Acute: 6.514
Silver NC 0.06 FW(7Q10s) 0.3933 ug/L 17 0 2.500
------------------- -----------------------------
Chronic: 1.210 All values non-detect< 5 ug/L; No monitoring added;
Permittee shall use PQL < 1 ug/L
NO DETECTS Max MDL= 5
Acute: 2,393.5 No RP, Predicted Max< 50% of Allowable Cw- No
Zinc NC 142.3328 FW(7Q10s) 144.4941 ug/L 10 10 487.5 Monitoring required
--Chronic: ----2,869.3 -- ---------------------------
No value>Allowable Cw
Acute: NO WQS
TDS NC 500 WS(7Q10s) mg/L 3 3 1,944.00000
Note: n<9 C.V. (default) Chronic: 10079.668 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set No value >Allowable Cw Monitoring required
Acute: NO WQS
Nitrate NC 10 WS(7Q 1 Os) mg/L 3 2 90.60000 __
Note: n<9 C.V. (default) Chronic: 201.59335 No RP , Predicted Max >_ 50% of Allowable Cw
Limited data set No value > Allowable Cw Monthly Monitoring for NO3-N + NO2-N added
21717 RPA, rpa
Page 2 of 2 2/2/2024

Wilkesboro WRF > Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators QW = 8 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 8.0000 WWTP/WTP Class: IV COMBINED HARDNESS (mg/L)
1Q10S (cfs) = 159.23 IWC% @ 1Q10S = 7.224844141 Acute = 30.35 mg/L
7Q10S (cfs) = 196.00 IWC% @ 7QIOS = 5.950095969 Chronic= 29.4 mg/L
7QIOW (cfs) = 267.00 IWC% @ 7Q10W= 4.438081603 YOU HAVE DESIGNATED THIS RECEIVING
30Q2 (cfs) = 196.00 IWC% @ 30Q2 = 5.950095969 STREAM AS WATER SUPPLY
Avg. Stream Flow, QA(cfs) = 682.00 IW%C @ QA= 1.785714286 Effluent Hard: 48 value > 100 mg/L
Receiving Stream: Yadkin River HUC 03040101 Stream Class: C default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L)
PARAMETER NC STANDARDS OR EPA CRITERIA J co REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
CY
TYPE Chronic Standard Acute n #Det. Max Pred Cw Allowable Cw
Acute (FW): 4.706.0
Arsenic C 150 FW(7Q10s) 340 ug/L _
17 0 5.0 Chronic (FW) 2,521.0 No RP, Predicted Max< 50% of Allowable Cw- No
Max MDL= 10 Monitoring required
--------- -----------------------------
Arsenic C 10 HH/WS(Qavg) ug/L NO DETECTS Chronic (HH) 560.0
Max MDL 10
Acute: 899.67
Beryllium NC 6.5 FW(7Q10s) 65 ug/L 2 0 9.48
Note: n< 9 C.V. (default) Chronic: 109.24 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 5 Monitoring required
Acute: 53.108
Cadmium NC 0.6669 FW(7Q10s) 3.8369 ug/L 17 0 1.000
Chronic: 11.208 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 2 Monitoring required
Acute: 14,682.2
Chromium III NC 134.4613 FW(7010s) 1060.7684 ua/L 0 0 N/A
Chronic: 2,259.8
Acute: 221.5
Chromium VI NC l 1 FW(701Os) 16 ua/L 0 0 N/A
--Chronic: -----184.9--- ---------------------------
Tot Cr value(s) > 5 but< Cr VI Allowable Cw a: No monitoring required if all Total Chromium
Chromium, Total NC µg/L 17 2 11.0 Max reported value = 8 samples are < 5 tag/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Acute: 173.98
Copper NC 9.0524 FW(7Q10s) 12.5699 ug/L 16 16 44.50
Chronic: 152.14 [Monitoring
o RP, Predicted Max< 50% of Allowable Cw- No
No value>Allowable Cw required
Acute: 304.5
Cyanide NC 5 FW(7Q10s) 22 10 ug/L 5 0 11.6
Note: n< 9 C.V. (default) Chronic: 84.0 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set NO DETECTS Max MDL= 10 Monitoring required
Acute: 1,299.150
Lead NC 3.5303 FW(7Q10s) 93.8615 ug/L 17 0 5.000
Chronic: 59.332 No RP, Predicted Max< 50% of Allowable Cw- No
NO DETECTS Max MDL 10 Monitoring required
Acute: NO WQS
Molybdenum NC 160 WS(7Q10s) ug/L 14 1 6.1 ------------------- -----------------------------
Chronic: 2,689.0 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
21717 RPA, rpa
Page 1 of 2 2/2/2024

Wilkesboro WRF Outfall 001
NCO021717 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 8 MGD
Acute (FW): 5,466.3
Nickel NC 42.7082 FW(7Q10s) 394.9304 µg/L
17 2 39.5 Chronic (FW)----717.8---No-value >Allowable Cw --- -----------------------------
Nickel NC 25.0000 WS(7Q10s) µg/L Chronic (WS) 420.2 No RP, Predicted Max< 50% of Allowable Cw- No
No value >Allowable Cw Monitoring required
Acute: 775.1
Selenium NC 3.1 FW(7Q10s) 56 ug/L 17 2 135.0
--Chronic: ----- 52.1 ---1 value(s) >Allowable Cw ---------------------------
RP shown - apply Monthly Monitoring with Limit
Acute: 5.726
Silver NC 0.06 FW(7Q10s) 0.4137 ug/L 17 0 2.500
------------------- -----------------------------
Chronic: 1.008 All values non-detect< 5 ug/L; No monitoring added;
Permittee shall use PQL < 1 ug/L
NO DETECTS Max MDL= 5
Acute: 2,050.4 No RP, Predicted Max< 50% of Allowable Cw- No
Zinc NC 145.4072 FW(7Q10s) 148.1385 ug/L 10 10 487.5 Monitoring required
--Chronic: ----2,443.8 -- ---------------------------
No value>Allowable Cw
Acute: NO WQS
TDS NC 500 WS(7Q10s) mg/L 3 3 1,944.00000
Note: n<9 C.V. (default) Chronic: 8403.226 No RP, Predicted Max< 50% of Allowable Cw- No
Limited data set No value >Allowable Cw Monitoring required
Acute: NO WQS
Nitrate NC 10 WS(7Q l Os) mg/L 3 2 90.60000 __
Note: n<9 C.V. (default) Chronic: 168.06452 No RP , Predicted Max >_ 50% of Allowable Cw
Limited data set No value > Allowable Cw Monthly Monitoring for NO3-N + NO2-N added
21717 RPA, rpa
Page 2 of 2 2/2/2024

REASONABLE POTENTIAL ANALYSIS
H1 H2 Use"PASTE SPECIAL Use"PASTE SPECIAL
Effluent Hardness Values"then"COPY" Upstream Hardness Values"then"COPY"
Maximum data .Maximum data
points=58 points=58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 6/5/2019 160 160 Std Dev. 33.3932 1 Default 25 25 Std Dev. N/A
2 7/17/2019 192 192 Mean 130.5789 2 Mean 25.0000
3 8/21/2019 144 144 C.V. 0.2557 3 C.V. 0.0000
4 9/18/2019 152 152 n 57 4 n 1
5 10/16/2019 56 56 10th Per value 72.80 mg/L 5 10th Per value 25.00 mg/L
6 11/6/2019 188 188 Average Value 99.00 mg/L 6 Average Value 25.00 mg/L
7 12/16/2019 68 68 Max. Value 200.00 mg/L 7 Max. Value 25.00 mg/L
8 1/15/2020 140 140 8
9 2/26/2020 127 127 9
10 3/25/2020 156 156 10
11 4/15/2020 132 132 11
12 5/6/2020 56 56 12
13 6/16/2020 56 56 13
14 7/15/2020 88 88 14
15 8/19/2020 112 112 15
16 9/16/2020 84 84 16
17 10/21/2020 52 52 17
18 11/18/2020 120 120 18
19 12/15/2020 76 76 19
20 1/6/2021 140 140 20
21 2/3/2021 122 122 21
22 3/3/2021 64 64 22
23 4/21/2021 140 140 23
24 5/19/2021 140 140 24
25 6/2/2021 124 124 25
26 7/20/2021 128 128 26
27 8/3/2021 152 152 27
28 9/16/2021 148 148 28
29 10/19/2021 120 120 29
30 11/29/2021 120 120 30
31 12/6/2021 136 136 31
32 1/3/2022 152 152 32
33 2/15/2022 152 152 33
34 3/1/2022 140 140 34
35 4/5/2022 136 136 35
36 5/31/2022 156 156 36
37 6/22/2022 148 148 37
38 7/19/2022 140 140 38
39 8/2/2022 144 144 39
40 9/28/2022 148 148 40
41 10/19/2022 116 116 41
42 11/30/2022 132 132 42
43 12/21/2022 108 108 43
44 1/17/2023 128 128 44
45 2/14/2023 156 156 45
46 3/15/2023 132 132 46
47 4/4/2023 136 136 47
48 5/23/2023 146 146 48
49 6/21/2023 132 132 49
50 7/5/2023 164 164 50
51 8/2/2023 200 200 51
52 9/6/2023 148 148 52
53 10/4/2023 144 144 53
54 11/15/2023 156 156 54
55 148 148 55
56 120 120 56
57 168 168 57
58 58
21717 RPA, data
- 1 - 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Use"PASTE SPECIAL
Arsenic Values"then"COPY"
Maximum data
points=58
Date Data BDL=1/2DL Results
1 7/17/2019 < 10 5 Std Dev. 0.0000
2 10/16/2019 < 10 5 Mean 5.0000
3 12/16/2019 < 10 5 C.V. 0.0000
4 2/26/2020 < 10 5 n 17
5 5/20/2020 < 10 5
6 1/20/2021 < 10 5 Mult Factor= 1.00
7 4/21/2021 < 10 5 Max. Value 5.0 ug/L
8 1/4/2022 < 10 5 Max. Pred Cw 5.0 ug/L
9 4/5/2022 < 10 5
10 5/2/2018 < 10 5
11 11/21/2018 < 10 5
12 12/15/2020 < 10 5
13 7/20/2021 < 10 5
14 7/19/2022 < 10 5
15 12/21/2022 < 10 5
16 8/2/2023 < 10 5
17 11/15/2023 < 10 5
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
21717 RPA, data
-2 - 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par03 Par04
Use"PASTE SPECIAL Use"PASTE SPECIAL
Beryllium Values"then"COPY" Cadmium Values"then"COPY"
Maximum data .Maximum data
points=58 points=58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 12/7/2018 < 5 2.5 Std Dev. 0.0000 1 7/17/2019 < 2 1 Std Dev. 0.0000
2 12/16/2019 < 5 2.5 Mean 2.5000 2 10/16/2019 < 2 1 Mean 1.0000
3 C.V. (default) 0.6000 3 12/16/2019 < 2 1 C.V. 0.0000
4 n 2 4 2/26/2020 < 2 1 n 17
5 5 5/20/2020 < 2 1
6 Mult Factor= 3.79 6 7/15/2020 < 2 1 Mult Factor= 1.00
7 Max. Value 2.50 ug/L 7 12/15/2020 < 2 1 Max. Value 1.000 ug/L
8 Max. Pred Cw 9.48 ug/L 8 1/20/2021 < 2 1 Max. Pred Cw 1.000 ug/L
9 9 4/21/2021 < 2 1
10 10 1/4/2022 < 2 1
11 11 7/19/2022 < 2 1
12 12 5/2/2018 < 2 1
13 13 11/21/2018 < 2 1
14 14 7/20/2021 < 2 1
15 15 4/5/2022 < 2 1
16 16 12/21/2022 < 2 1
17 17 11/15/2023 < 2 1
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
-3- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par10 Pal
Use"PASTE SPECIAL Use"PASTE SPECIAL
Chromium, Total Values"then"COPY" Copper Values"then"COPY"
Maximum data .Maximum data
points=58 points=58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 7/17/2019 < 5 2.5 Std Dev. 1.5357 1 7/17/2019 3 3 Std Dev. 5.5494
2 10/16/2019 < 5 2.5 Mean 3.0294 2 10/16/2019 3 3 Mean 5.5625
3 12/16/2019 < 5 2.5 C.V. 0.5069 3 12/16/2019 5 5 C.V. 0.9976
4 2/26/2020 < 5 2.5 n 17 4 2/26/2020 3 3 n 16
5 5/20/2020 < 5 2.5 5 5/20/2020 4 4
6 7/15/2020 < 5 2.5 Mult Factor= 1.37 6 7/15/2020 4 4 Mult Factor= 1.78
7 12/15/2020 < 5 2.5 Max. Value 8.0 pg/L 7 12/15/2020 5 5 Max. Value 25.00 ug/L
8 1/20/2021 < 5 2.5 Max. Pred Cw 11.0 pg/L 8 1/20/2021 25 25 Max. Pred Cw 44.50 ug/L
9 4/21/2021 6 6 9 4/21/2021 2 2
10 1/4/2022 < 5 2.5 10 1/4/2022 4 4
11 7/19/2022 < 5 2.5 11 7/19/2022 3 3
12 5/2/2018 < 5 2.5 12 5/2/2018 7 7
13 11/21/2018 < 5 2.5 13 11/21/2018 4 4
14 7/20/2021 8 8 14 7/20/2021 2 2
15 4/5/2022 < 5 2.5 15 4/5/2022 5 5
16 12/21/2022 < 5 2.5 16 12/21/2022 10 10
17 11/15/2023 < 5 2.5 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
-4- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par12 Par14
Use"PASTE SPECIAL Use"PASTE SPECIAL
Cyanide Values"then"COPY" Lead Values"then"COPY"
Maximum data .Maximum data
points=58 points=58
Date Data BDL=1/2DL Results Date BDL=1/2DL Results
1 12/15/2020 < 5 5 Std Dev. 0.0000 1 7/17/2019 < 10 5 Std Dev. 0.0000
2 4/5/2022 < 5 5 Mean 5.00 2 10/16/2019 < 10 5 Mean 5.0000
3 12/21/2022 < 5 5 C.V. (default) 0.6000 3 12/16/2019 < 10 5 C.V. 0.0000
4 8/2/2023 < 5 5 n 5 4 2/26/2020 < 10 5 n 17
5 11/15/2023 < 5 5 5 5/20/2020 < 10 5
6 Mult Factor= 2.32 6 7/15/2020 < 10 5 Mult Factor= 1.00
7 Max. Value 5.0 ug/L 7 12/15/2020 < 10 5 Max. Value 5.000 ug/L
8 Max. Pred Cw 11.6 ug/L 8 1/20/2021 < 10 5 Max. Pred Cw 5.000 ug/L
9 9 4/21/2021 < 10 5
10 10 1/4/2022 < 10 5
11 11 5/2/2018 < 10 5
12 12 11/21/2018 < 10 5
13 13 7/20/2021 < 10 5
14 14 4/5/2022 < 10 5
15 15 7/19/2022 < 10 5
16 16 12/21/2022 < 10 5
17 17 11/15/2023 < 10 5
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
- 5- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par16 Use"PASTE SPECIAL Par17 & Par18 use"PASTE
Values"then"COPY" SPECIAL-Values"
Molybdenum
.Maximum data Nickel hen"COPY".
points=58 Maximum data
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results points=58
1 7/17/2019 < 5 2.5 Std Dev. 0.6682 1 7/17/2019 < 10 5 Std Dev. 5.3879
2 10/16/2019 < 5 2.5 Mean 2.6786 2 10/16/2019 < 10 5 Mean 6.8235
3 12/16/2019 < 5 2.5 C.V. 0.2494 3 12/16/2019 < 10 5 C.V. 0.7896
4 2/26/2020 < 5 2.5 n 14 4 2/26/2020 < 10 5 n 17
5 5/20/2020 < 5 2.5 5 5/20/2020 < 10 5
6 7/15/2020 < 5 2.5 Mult Factor= 1.21 6 7/15/2020 < 10 5 Mult Factor= 1.58
7 12/15/2020 < 5 2.5 Max. Value 5.0 ug/L 7 12/15/2020 < 10 5 Max. Value 25.0 tag/L
8 1/20/2021 < 5 2.5 Max. Pred Cw 6.1 ug/L 8 1/20/2021 < 10 5 Max. Pred Cw 39.5 tag/L
9 4/21/2021 5 5 9 4/21/2021 16 16
10 1/4/2022 < 5 2.5 10 7/20/2021 25 25
11 4/5/2022 < 5 2.5 11 1/4/2022 < 10 5
12 7/19/2022 < 5 2.5 12 4/5/2022 < 10 5
13 12/21/2022 < 5 2.5 13 7/19/2022 < 10 5
14 11/15/2023 < 5 2.5 14 12/21/2022 < 10 5
15 15 7/5/2023 < 10 5
16 16 8/2/2023 < 10 5
17 17 11/15/2023 < 10 5
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
-6- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par19 Par20
Use"PASTE SPECIAL- Use"PASTE SPECIAL-
Selenium Values"then"COPY". Silver Values"then"COPY".
Maximum data points Maximum data points=
=58 58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 7/17/2019 < 10 5 Std Dev. 14.2926 1 7/17/2019 < 5 2.5 Std Dev. 0.0000
2 10/16/2019 < 10 5 Mean 8.8235 2 10/16/2019 < 5 2.5 Mean 2.5000
3 12/16/2019 < 10 5 C.V. 1.6198 3 12/16/2019 < 5 2.5 C.V. 0.0000
4 2/26/2020 < 10 5 n 17 4 2/26/2020 < 5 2.5 n 17
5 5/20/2020 < 10 5 5 5/20/2020 < 5 2.5
6 7/15/2020 < 10 5 Mult Factor= 2.11 6 7/15/2020 < 5 2.5 Mult Factor= 1.00
7 12/15/2020 < 10 5 Max. Value 64.0 ug/L 7 12/15/2020 < 5 2.5 Max. Value 2.500 ug/L
8 1/20/2021 < 10 5 Max. Pred Cw 135.0 ug/L 8 1/20/2021 < 5 2.5 Max. Pred Cw 2.500 ug/L
9 4/21/2021 < 10 5 9 4/21/2021 < 5 2.5
10 1/4/2022 < 10 5 10 7/20/2021 < 5 2.5
11 7/19/2022 64 64 11 1/4/2022 < 5 2.5
12 5/2/2018 < 10 5 12 4/5/2022 < 5 2.5
13 11/21/2018 < 10 5 13 7/19/2022 < 5 2.5
14 7/20/2021 11 11 14 12/21/2022 < 5 2.5
15 4/5/2022 < 10 5 15 7/5/2023 < 5 2.5
16 12/21/2022 < 10 5 16 8/2/2023 < 5 2.5
17 11/15/2023 < 10 5 17 11/15/2023 < 5 2.5
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
-7- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par21 Par22 use"PASTE
Use"PASTE SPECIAL
Values"then"COPY" SPECIAL-Values"
Zinc Maximum data TDS then"COPY".
.
points=58 Maximum data points
=58
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 7/17/2019 42 42 Std Dev. 54.4908 1 8/19/2022 556 556 Std Dev. 47.1593
2 10/16/2019 25 25 Mean 47.5100 2 12/5/2017 648 648 Mean 596.0000
3 5/20/2020 20 20 C.V. 1.1469 3 12/6/2016 584 584 C.V. (default) 0.6000
4 7/15/2020 37 37 n 10 4 n 3
5 12/15/2020 41 41 5
6 1/20/2021 195 195 Mult Factor= 2.50 6 Mult Factor= 3.00
7 7/19/2022 1.1 1.1 Max. Value 195.0 ug/L 7 Max. Value 648.000000 mg/L
8 7/20/2021 23 23 Max. Pred Cw 487.5 ug/L 8 Max. Pred Cw ########## mg/L
9 4/5/2022 26 26 9
10 12/21/2022 65 65 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
21717 RPA, data
-8- 2/2/2024

REASONABLE POTENTIAL ANALYSIS
Par23 use"PASTE
SPECIAL-Values"
Nitrate then"COPY".
Maximum data
Date Data BDL=1/2DL Results points=58
1 8/17/2022 < 0.1 0.05 Std Dev. 16.4434
2 12/5/2017 26.5 26.5 Mean 18.9167
3 12/6/2016 30.2 30.2 C.V. (default) 0.6000
4 n 3
5
6 Mult Factor= 3.00
7 Max. Value 30.200000 mg/L
8 Max. Pred Cw 90.60000 mg/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
21717 RPA, data
-9- 2/2/2024

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY CHECK WQS
Table 1. Project Information Table 2. Parameters of Concern
❑ CHECK IF HQW OR ORW WQS Name WQS Type Chronic Modifier Acute PQL Units
Facility Name Wilkesboro WRF Par01 Arsenic Aquactic Life C 150 FW 340 ug/L
WWTP/WTP Class IV Par02 Arsenic Human Health C 10 HH/WS N/A ug/L
Water Supply
NPDES Permit NCO021717 Par03 Beryllium Aquatic Life NC 6.5 FW 65 ug/L
Outfall 001 Par04 Cadmium Aquatic Life NC 0.6385 FW 3.6177 ug/L
Flow, Qw (MGD) 4.900 Par05 Chlorides Aquatic Life NC 230 FW mg/L
Receiving Stream Yadkin River Par06 Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L
HUC Number 03040101 Par07 Total Phenolic Compounds Aquatic Life NC 300 A ug/L
Stream Class C Par08 Chromium III Aquatic Life NC 128.2776 FW 1003.8156 ug/L
❑J Apply WS Hardness WQC Par09 Chromium VI Aquatic Life NC 11 FW 16 tag/L
7Q10s (cfs) 196.000 Par10 Chromium, Total Aquatic Life NC N/A FW N/A pg/L
7Q10w (cfs) 267.00 Par11 Copper Aquatic Life NC 8.6185 FW 11.7967 ug/L
30Q2 (cfs) 196.00 Par12 Cyanide Aquatic Life NC 5 FW 22 10 ug/L
QA(cfs) 682.00 Par13 Fluoride Aquatic Life NC 1,800 FW ug/L
1Q10s (cfs) 159.23 Par14 Lead Aquatic Life NC 3.3095 FW 87.0228 ug/L
Effluent Hardness I default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L) Par15 Mercury Aquatic Life NC 12 FW 0.5 ng/L
-------------•Upstream Hardness Hardness 25 mg/L (Avg) I Par16 Molybdenum Water Supply NC 160 WS ug/L
Combined Hardness Chronic 27.76 mg/L I Par17 Nickel Aquatic Life NC 40.6810 FW 373.0472 tag/L
------------- ----Combined Hardness Hardness Acute —_- 28.37 mg/L ____- I Par18 Nickel Water Supply NC 25.0000 WS N/A tag/L
Data Source(s) 7Q10s used as conservative estimate for 30Q2. Par19 Selenium Aquatic Life NC 3.1 FW 56 ug/L
❑ CHECK TO APPLY MODEL Note: mixture of dissolved and total metals sampling Par20 Silver Aquatic Life NC 0.06 FW 0.3684 ug/L
was conducted. Permittee shall report total metals in
their DMRs. Outfall is -8.3 miles upstream of WS Par21 Zinc Aquatic Life NC 138.4947 FW 139.9179 ug/L
waters; WS considered. NO2+NO3 data used for Par22 TDS Water Supply NC 500 WS mg/L
nitrate assessment Par23 Nitrate Water Supply NC 10 WS mg/L
21717 RPA, input
2/27/2024

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY CHECK WQS
Table 1. Project Information Table 2. Parameters of Concern
❑ CHECK IF HQW OR ORW WQS Name WQS Type Chronic Modifier Acute PQL Units
Facility Name Wilkesboro WRF Par01 Arsenic Aquactic Life C 150 FW 340 ug/L
WWTP/WTP Class IV Par02 Arsenic Human Health C 10 HH/WS N/A ug/L
Water Supply
NPDES Permit NCO021717 Par03 Beryllium Aquatic Life NC 6.5 FW 65 ug/L
Outfall 001 Par04 Cadmium Aquatic Life NC 0.6543 FW 3.7397 ug/L
Flow, Qw (MGD) 6.600 Par05 Chlorides Aquatic Life NC 230 FW mg/L
Receiving Stream Yadkin River Par06 Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L
HUC Number 03040101 Par07 Total Phenolic Compounds Aquatic Life NC 300 A ug/L
Stream Class C Par08 Chromium III Aquatic Life NC 131.7123 FW 1035.5333 ug/L
❑� Apply WS Hardness WQC Par09 Chromium VI Aquatic Life NC 11 FW 16 tag/L
7Q10s (cfs) 196.000 Par10 Chromium, Total Aquatic Life NC N/A FW N/A pg/L
7Q10w (cfs) 267.00 Par11 Copper Aquatic Life NC 8.8594 FW 12.2265 ug/L
30Q2 (cfs) 196.00 Par12 Cyanide Aquatic Life NC 5 FW 22 10 ug/L
QA(cfs) 682.00 Par13 Fluoride Aquatic Life NC 1,800 FW ug/L
1Q10s (cfs) 159.23 Par14 Lead Aquatic Life NC 3.4317 FW 90.8153 ug/L
Effluent Hardness I default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L) Par15 Mercury Aquatic Life NC 12 FW 0.5 ng/L
-------------•Upstream Hardness Hardness 25 mg/L (Avg) I Par16 Molybdenum Water Supply NC 160 WS ug/L
------------- ----Combined Hardness Hardness Chronic 28.67 mg/L I Par17 Nickel Aquatic Life NC 41.8066 FW 385.2293 tag/L
------------- ----Combined Hardness Hardness Acute ——- 29.47 mg/L ————— I Par18 Nickel Water Supply NC 25.0000 WS N/A tag/L
Data Source(s) 7Q10s used as conservative estimate for 30Q2. Par19 Selenium Aquatic Life NC 3.1 FW 56 ug/L
❑ CHECK TO APPLY MODEL Note: mixture of dissolved and total metals sampling Par20 Silver Aquatic Life NC 0.06 FW 0.3933 ug/L
was conducted. Permittee shall report total metals in
their DMRs. Outfall is -8.3 miles upstream of WS Par21 Zinc Aquatic Life NC 142.3328 FW 144.4941 ug/L
waters; WS considered. NO2+NO3 data used for Par22 TDS Water Supply NC 500 WS mg/L
nitrate assessment Par23 Nitrate Water Supply NC 10 WS mg/L
21717 RPA, input
2/27/2024

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY CHECK WQS
Table 1. Project Information Table 2. Parameters of Concern
❑ CHECK IF HQW OR ORW WQS Name WQS Type Chronic Modifier Acute PQL Units
Facility Name Wilkesboro WRF Par01 Arsenic Aquactic Life C 150 FW 340 ug/L
WWTP/WTP Class IV Par02 Arsenic Human Health C 10 HH/WS N/A ug/L
Water Supply
NPDES Permit NCO021717 Par03 Beryllium Aquatic Life NC 6.5 FW 65 ug/L
Outfall 001 Par04 Cadmium Aquatic Life NC 0.6669 FW 3.8369 ug/L
Flow, Qw (MGD) 8.000 Par05 Chlorides Aquatic Life NC 230 FW mg/L
Receiving Stream Yadkin River Par06 Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L
HUC Number 03040101 Par07 Total Phenolic Compounds Aquatic Life NC 300 A ug/L
Stream Class C Par08 Chromium III Aquatic Life NC 134.4613 FW 1060.7684 ug/L
❑J Apply WS Hardness WQC Par09 Chromium VI Aquatic Life NC 11 FW 16 tag/L
7Q10s (cfs) 196.000 Par10 Chromium, Total Aquatic Life NC N/A FW N/A pg/L
7Q10w (cfs) 267.00 Par11 Copper Aquatic Life NC 9.0524 FW 12.5699 ug/L
30Q2 (cfs) 196.00 Par12 Cyanide Aquatic Life NC 5 FW 22 10 ug/L
QA(cfs) 682.00 Par13 Fluoride Aquatic Life NC 1,800 FW ug/L
1Q10s (cfs) 159.23 Par14 Lead Aquatic Life NC 3.5303 FW 93.8615 ug/L
Effluent Hardness I default 99 mg/L-WS (Eff Hard Avg = 130.58 mg/L) Par15 Mercury Aquatic Life NC 12 FW 0.5 ng/L
-------------•Upstream Hardness Hardness 25 mg/L (Avg) I Par16 Molybdenum Water Supply NC 160 WS ug/L
Combined Hardness Chronic 29.4 mg/L I Par17 Nickel Aquatic Life NC 42.7082 FW 394.9304 tag/L
------------- ----Combined Hardness Hardness Acute —_- 30.35 mg/L ____- I Par18 Nickel Water Supply NC 25.0000 WS N/A tag/L
Data Source(s) 7Q10s used as conservative estimate for 30Q2. Par19 Selenium Aquatic Life NC 3.1 FW 56 ug/L
❑ CHECK TO APPLY MODEL Note: mixture of dissolved and total metals sampling Par20 Silver Aquatic Life NC 0.06 FW 0.4137 ug/L
was conducted. Permittee shall report total metals in
their DMRs. Outfall is -8.3 miles upstream of WS Par21 Zinc Aquatic Life NC 145.4072 FW 148.1385 ug/L
waters; WS considered. NO2+NO3 data used for Par22 TDS Water Supply NC 500 WS mg/L
nitrate assessment Par23 Nitrate Water Supply NC 10 WS mg/L
21717 RPA, input
2/27/2024

Permit No. NCO021717
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 Q ality Standards/A uatic Life Protection
Parameter Acute FW, µg/l Chronic FW, µg/l Acute SW, µg/1 Chronic SW, µg/1
(Dissolved) (Dissolved) (Dissolved) (Dissolved)
Arsenic 340 150 69 36
Beryllium 65 6.5 --- ---
Cadmium Calculation Calculation 40 8.8
Chromium III Calculation Calculation --- ---
Chromium VI 16 11 1100 50
Copper Calculation Calculation 4.8 3.1
Lead Calculation Calculation 210 8.1
Nickel Calculation Calculation 74 8.2
Silver Calculation 0.06 1.9 0.1
Zinc Calculation Calculation 90 81
Table 1 Notes:
1. FW=Freshwater, SW= Saltwater
2. Calculation=Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
2B.0200(e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2.Dissolved Freshwater Standards for Hardness-Dependent Metals
The Water Effects Ratio(WER)is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph(11)(d)
Metal NC Dissolved Standard, µg/I
Cadmium,Acute WER*{1.136672-[ln hardness](0.041838)} e^10.9151 [ln hardness]-3.1485}
Cadmium,Acute Trout waters WER*{1.136672-[ln hardness](0.041838)} e^{0.9151[In hardness]-3.62361
Cadmium,Chronic WER*{1.101672-[ln hardness](0.041838)} •e^{0.7998[ln hardness]-4.445 11
Chromium III,Acute WER*0.316 e^{0.8190[ln hardness]+3.7256}
Chromium III,Chronic WER*0.860 e^{0.8190[ln hardness]+0.6848}
Copper,Acute WER*0.960 e^{0.9422[ln hardness]-1.700}
Copper,Chronic WER*0.960 e^{0.8545[ln hardness]-1.702}
Lead,Acute WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead,Chronic WER*{1.46203-[ln hardness](0.145712)} •e^{1.273[ln hardness]-4.705)
Nickel,Acute WER*0.998 e^{0.8460[ln hardness]+2.255}
Nickel,Chronic WER*0.997 e^{0.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NCO021717
Silver,Acute WER*0.85 •e^{1.72[ln hardness]-6.59}
Silver,Chronic Not applicable
Zinc,Acute WER*0.978 e^{0.8473[ln hardness]+0.884}
Zinc,Chronic WER*0.986 e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness-dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness-based standards require some knowledge of the effluent and instream(upstream)hardness
and so must be calculated case-by-case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge-specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal(more on that
below),but it is also possible to consider case-specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WOBELs for Hardness-Dependent Metals -Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations,based on applicable
standards and the critical low-flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value(chronic or acute),the
discharge has reasonable potential to exceed the standard,which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present(i.e. consistently below
detection level),then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness-dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10(the spreadsheet automatically calculates
the 1 Q 10 using the formula 1 Q 10=0.843 (s7Q 10, cfs)0.993
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness-dependent metal of concern and for
each individual discharge,the Permit Writer must first determine what effluent and instream
(upstream)hardness values to use in the equations.
The permit writer reviews DMR's,Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values,upstream of the discharge.
If no hardness data is available,the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L(CaCO3 or(Ca+Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L,respectively.
If the use of a default hardness value results in a hardness-dependent metal showing reasonable
potential,the permit writer contacts the Permittee and requests 5 site-specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NCO021717
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)+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 IQ 10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal,using the EPA Default Partition Coefficients(DPCs)or site-specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the"Fraction Dissolved"converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in-stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996)and the
equation:
Cdiss - 1
Ctotal I + { [Kpo] [ss('+a)] [10-6] }
Where:
ss=in-stream suspended solids concentration [mg/1],minimum of 10 mg/L used,
and
Kpo and a=constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness-dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient(or
site-specific translator)to obtain a Total Recoverable Metal at ambient conditions.
In some cases,where an EPA default partition coefficient translator does not exist(ie. silver),the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits)for each pollutant using the following equation:
Ca=(s7Q 10+Qw)(Cwgs)—(s7Q 10) (Cb)
Qw
Where: Ca=allowable effluent concentration(µg/L or mg/L)
Cwqs=NC Water Quality Standard or federal criteria(µg/L or mg/L)
Cb=background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw=permitted effluent flow(cfs,match s7Q 10)
s7Q 10=summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on-going with EPA on how best to address background concentrations
Flows other than s7Q 10 may be incorporated as applicable:
IQ 10=used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0021717
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) 125.46 Average from April 2018 to
[Total as, CaCO3 or(Ca+Mg)] September 2022 samples
Average Upstream Hardness (mg/L) 25 Default used
[Total as, CaCO3 or(Ca+Mg)]
7Q 10 summer(cfs) 196 Previous Fact Sheet; historical file
1Q10(cfs) 159.23 Calculated in RPA
Permitted Flow(MGD) 4.9,with NPDES Files; 2022 Modification
expansions at Request
6.6 and 8.0
Date: 11/4/2022
Permit Writer: Nick Coco
Page 4 of 4

NH3/TRC WLA Calculations
Facility: Wilkesboro W RF
PermitNo. NC0021717
Prepared By: Nick Coco
Enter Design Flow (MGD): 4.9
Enter s7Q10 (cfs): 196
Enter w7Q10 (cfs): 267
Total Residual Chlorine (TRC) Ammonia (Summer)
Daily Maximum Limit(ug/1) Monthly Average Limit(mg NH3-N/1)
s7Q10 (CFS) 196 s7Q10 (CFS) 196
DESIGN FLOW (MGD) 4.9 DESIGN FLOW (MGD) 4.9
DESIGN FLOW (CFS) 7.595 DESIGN FLOW (CFS) 7.595
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22
IWC (%) 3.73 IWC (%) 3.73
Allowable Conc. (ug/1) 456 Allowable Conc. (mg/1) 21.1
Cap at 28 ug/L. Consistent with current permit limit.Maintain limit.
Facility currently uses UV and has no limit.
Add limit for emergency use. Ammonia (Winter)
Monthly Average Limit(mg NH3-N/1)
Fecal Coliform w7Q10 (CFS) 267
Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 4.9
(If DF >331; Monitor) DESIGN FLOW (CFS) 7.595
(If DF<331; Limit) STREAM STD (MG/L) 1.8
Dilution Factor(DF) 26.81 Upstream Bkgd (mg/1) 0.22
IWC (%) 2.77
Allowable Conc. (mg/1) 57.3
>35 mg/L,monitor only
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 =Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 =400/100 ml =Weekly Avg limit (Municipals) = Daily Max limit(Non-Muni)

NH3/TRC WLA Calculations
Facility: Wilkesboro W RF
PermitNo. NC0021717
Prepared By: Nick Coco
Enter Design Flow (MGD): 6.6
Enter s7Q10 (cfs): 196
Enter w7Q10 (cfs): 267
Total Residual Chlorine (TRC) Ammonia (Summer)
Daily Maximum Limit(ug/1) Monthly Average Limit(mg NH3-N/1)
s7Q10 (CFS) 196 s7Q10 (CFS) 196
DESIGN FLOW (MGD) 6.6 DESIGN FLOW (MGD) 6.6
DESIGN FLOW (CFS) 10.23 DESIGN FLOW (CFS) 10.23
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22
IWC (%) 4.96 IWC (%) 4.96
Allowable Conc. (ug/1) 343 Allowable Conc. (mg/1) 15.9
Cap at 28 ug/L. Consistent with current permit limit.Maintain limit.
Facility currently uses UV and has no limit.
Add limit for emergency use. Ammonia (Winter)
Monthly Average Limit(mg NH3-N/1)
Fecal Coliform w7Q10 (CFS) 267
Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 6.6
(If DF >331; Monitor) DESIGN FLOW (CFS) 10.23
(If DF<331; Limit) STREAM STD (MG/L) 1.8
Dilution Factor(DF) 20.16 Upstream Bkgd (mg/1) 0.22
IWC (%) 3.69
Allowable Conc. (mg/1) 43.0
>35 mg/L,monitor only
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, Monitor Only
2. Monthly Avg limit x 3 =Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
Fecal Coliform
1. Monthly Avg limit x 2 =400/100 ml =Weekly Avg limit (Municipals) = Daily Max limit(Non-Muni)

2/28/24 WQS= 12 ng/L MERCURY WQBEL/TBEL EVALUATION V:2013-6
Facility Name Wilkesboro WRF/NC0021717 No Limit Required
/Permit No.
MMP Required
Total Mercury 1631E PQL=0.5 ng/L 7Q10s = 196.000 cfs WQBEL= 201.68 ng/L
Date Modifier Data Entry Value Permitted Flow= 8.000 47 ng/L
6/1/20 1.62 1.62
11/1/20 1.03 1.03
12/1/20 1.75 1.75 1.5 ng/L-Annual Average for 2020
2/1/21 1.07 1.07
6/1/21 2.61 2.61
9/1/21 < 1 0.5
12/1/21 1.27 1.27 1.4 ng/L-Annual Average for 2021
3/1/22 4.9 4.9
9/1/22 < 1 0.5 2.7 ng/L-Annual Average for 2022
6/15/23 3.72 3.72
11/1/23 2.52 2.52 3.1 ng/L-Annual Average for 2023

Wilkesboro WRF/NC0021717
Mercury Data Statistics (Method 1631E)
2020 2021 2022 2023
#of Samples 3 4 2 2
Annual Average, ng/L 1.5 1.4 2.7 3.12
Maximum Value, ng/L 1.75 2.61 4.90 3.72
TBEL, ng/L 47
WQBEL, ng/L 201.7

NCO021717 Cub Creek WWTP 2/28/2024
BOD monthly removal rate TSS monthly removal rate
Month RR(%) Month RR(%) Month RR(%) Month RR(%)
June-19 95.87 December-21 96.07 June-19 92.18 December-21 93.88
July-19 95.79 January-22 97.41 July-19 95.67 January-22 95.20
August-19 95.03 February-22 1.28 August-19 94.90 February-22 0.15
September-19 93.67 March-22 93.13 September-19 92.99 March-22 91.69
October-19 94.25 April-22 94.70 October-19 91.94 April-22 96.03
November-19 92.31 May-22 93.94 November-19 91.98 May-22 94.11
December-19 90.78 June-22 94.24 December-19 89.08 June-22 94.57
January-20 91.99 July-22 92.09 January-20 86.90 July-22 92.03
February-20 92.17 August-22 93.29 February-20 87.79 August-22 94.07
March-20 90.26 September-22 94.36 March-20 89.36 September-22 95.68
April-20 91.04 October-22 92.47 April-20 90.20 October-22 90.99
May-20 92.72 November-22 93.72 May-20 91.75 November-22 93.07
June-20 90.88 December-22 96.25 June-20 91.22 December-22 92.82
July-20 92.41 January-23 July-20 91.64 January-23
August-20 92.10 February-23 August-20 91.91 February-23
September-20 95.47 March-23 September-20 95.92 March-23
October-20 94.99 April-23 October-20 94.68 April-23
November-20 93.30 May-23 November-20 93.11 May-23
December-20 95.45 June-23 December-20 93.07 June-23
January-21 93.11 July-23 January-21 89.02 July-23
February-21 93.17 August-23 February-21 91.22 August-23
March-21 93.43 September-23 March-21 90.53 September-23
April-21 96.38 October-23 April-21 96.00 October-23
May-21 96.63 November-23 May-21 97.32 November-23
June-21 94.88 December-23 June-21 94.11 December-23
July-21 94.61 January-24 July-21 94.27 January-24
August-21 96.84 February-24 August-21 97.80 February-24
September-21 96.80 March-24 September-21 97.88 March-24
October-21 96.13 April-24 October-21 97.83 April-24
November-21 97.00 May-24 November-21 96.34 May-24
Overall BOD removal rate 91.92 Overall TSS removal rate 91.00

JNPD
CD E F G H J K L M N O P
Pollutants of Concern (POC) Review Form Version:2022.09.28
1.Facility's General Information
r(draft)Review 2/2/2024 c.POC review due to: e.Contact Information
f(final)Review Municipal NPDES renewal 17 Regional Office(RO) Winston-Salem
S Permit Writer(pw) Nick Coco HWA-AT/LTMP Review, ❑ RO PT Staff Alex Lowe RO NPDES Staff Tricia Lowery
6
Permiltee-Facility Name W ilkesboro W RF New Industries El Facility PT Staff,email Amber Garwood.aaarwoodlobwilkesboronc.ore
7 NPDES Permit Number NCO021717 W WTP expansion p f.Receiving Stream
8 NPDES Permit Effective Date Stream redass./adjustment 1-1 Outfall
9 Chemical Addendum Submittal Date 11/4/2022 Outfall relocation/adjustment 1-1 ReceivingStream: Yadkin River OA,cfs: 682
10 NPDES Permit Public Notice Date 7Q10 update ❑ Stream Class C 7Q10(S),cfs: -
11
eDMR data evaluated from: 4/1/20 tt 1 to s/1/2o22 Other POC review trigger,explain: Oufall Lat. 36°09'11"N Outfall Long. 81°08'5-W
12 a.WWTP Capacity Summary Outfall ll
13 Current Permitted Flaw,mgd 1 49 m iigned Flow, 49 Receiving Stream: QA,cfs:
14 Permitted SIU Flow,mgd 3.20 d.IU Summary Stream Class 7Q10,cfs:
15 b.PT Docs.Summary #IUs 3 Oufall Lat. Outfall Long.
16
IW S approval date 3/27/2020 #SIUs 2 Is there a PW S intake downstream of the Facility's Outfall(s)? 0 YES ❑ NO
17 2LJSTMP approval date: 3/11/2021 #Clue 1 Comments:
18 #NSCIUs
HW A-AT approval data 4/27/2020 #IUS /Local 3 Permlttw has expanded flow her at 6.6 MGD and has requested addition of 8.0 MGD flow tier.Discharge-8.3 miles above W 5-V waters
Permits or Other
19 to Types
20 a 2. Industrial Users'Information.
21 Z# Industrial User(IU)Name IU Activity IU Non Conventional Pollutans&Toxic Pollutant IUP Effective Date
I Ashe County Landfill Leachate oil&grease,mercury,cadmium,chromium,copper,nickel,cyanide,zinc,lead 3/2/2020
22
23 2 Tyson Farms Poultry oil&grease,mercury,cadmium,chromium,copper,nickel,cyanide,zinc,lead,arsenic,selenium,molybdenum 10/31/2019(updated 3/12/2020)
3 Wilkes County Landfill Leachate oil&grease,mercury,cadmium,chromium,copper,nickel,cyanide,zinc,lead 10/31/2019(updated 1/28/2020)
24
4
25
s
26
Comment: Town received leachate sample results from both Ashe County and Wilkes County landfills reporting detertahle,levels of PFAS.Recommend both landfills continue to monitor PFAS in leachate.Monitoring proposed in NPDES permit for W RF effluent.
31
32 3.Status of Pretreatment Program(check all that apply)
33 Status of Pretreatment Program(check all that apply)
34 1)facility has no SIU's,does have Division approved Pretreatment Program that is INACTIVE
35 2)facility has no SIU's,does not have Division approved Pretreatment Program
36 3)facility has SIUs and DWQ approved Pretreatment Program
37 _a 3a)Full Program with LTMP
38 ❑ 3b)Modified Program with STMP
39 4)additional conditions regarding Pretreatment attached or listed below
40 5)facility's sludge is being land applied or composted
41 6)facility's sludge is incinerated(add Beryllium and Mercury sampling according to §503.43)
42 Lj 7)facility's sludge is taken to a landfill,if yes which landfill:
43 8)other
44 Sludge Disposal Plan:
45
46
47 Sludge Permit No:
48 4.LTMP/STMP and HWA Review
49 PW:Find L/STMP document,HWA spreadsheet,DMR,previous and new NPDES permit for next section.
a Parameter of Concern New Previous Required by POC due to POC due to POTW % L/STMP NPDES Comment
N (POC)Check List NPDES NPDES EPA PT(1) Sludge(2) SIU(3) POC (4)Removal Effluent Freq. Effluent Freq.
POC POC Rate PQLs review
c
50 U
a. PQL from Required PQL Recomm.
L/STMP,ug/I per NPDES PQL,ug/I
51 permit
52 ❑2 Flow ❑ ❑p ❑ ❑
53 1] BQD Li i] ❑ ❑ 2000.0
54 ❑' TSS ❑ ❑2 ❑ ❑ 2000.0
55 0 NH3 ❑ 17 ❑ ❑ 100.0
56 ❑� Arsenic ❑ ❑ ❑, ❑ ❑ 2.0 2.0
57 ❑ Barium ❑ ❑ ❑ ❑ ❑
58 ❑ Beryllium(5) ❑ ❑ ❑ ❑ ❑
59 0 Cadmium(1) ❑ ❑ p p ❑ ❑ 0.5 0.5
60 O Chromium(1) ❑ ❑ 0 ❑ ❑ ❑ 10.0 5.0
61 O Copper(1) ❑ ❑, 0 0 ❑ ❑ 2.0 2.0
62 [Z Cyanide ❑ ❑ ❑ ❑ ❑ 10.0
63 ❑� Lead(1) ❑ ❑ o o ❑ ❑ 2.0 2.0
64 0 Mercury(5) ❑ ❑ p ❑ ❑ 0.001 0.001
65 0 Molybdenum ❑ ❑ p ❑ ❑ 10.0 10.0
66 O Nickel(1) ❑ ❑ p p ❑ ❑ 10.0
67 p Selenium ❑ ❑ p ❑ ❑ 5.0 1.0
68 0 Silver ❑ ❑ ❑ ❑ ❑ 1.0 1.0
69 O Zinc(1) ❑ p 0 0 ❑ ❑ 10.0 10.0
70 O Sludge Flow to Disposal ❑p ❑ ❑
71 ❑p %Solids to Disposal ❑p ❑ ❑
72 p Oil&Grease p ❑ ❑ 5000.0
73 [Z TN ❑ ❑� ❑ ❑
74 O TP ❑ ❑' ❑ ❑
75 ❑p PFAS 1633 1Z ❑ ❑ ❑
76 ❑ 1,4 Dioxane ❑ ❑ ❑ ❑
77 ❑ ❑ ❑ ❑ ❑
78 ❑ ❑ ❑ ❑ ❑
79 ❑ ❑ ❑ ❑ ❑
80 ❑ ❑ ❑ ❑ ❑
81 ❑ 1 ❑ ❑ ❑ ❑
Bz Footnotes:
83 (1)Always in the LTMP/STMP due to EPA-PT requirement
84 (2)Only in LTMP/STMP if listed in sludge permit
85 (3)Only in LTMP/STMP while SIU still discharges to POTW
86 (4)Only in LTMP/STMP when pollutant is of concern to POTW
87 (5)In LTMP/STMP,if sewage sludge is incinerated
88 Please use blue font for the info updated by pw
89 Please use red font for POC that need to be added/modal ed In L/STMP sampling plan
90
91 Blue shaded cell(D60:1181): Parameters usually included under that POC list
92
Facility Summary/background information/NPDES-PT regulatory action:
POC to be added/modified in IJSTMP:
93
ORC's comments on IU/POC:
94
POC submitted through Chemical
Addendum or Supplemental Chemical
95 Datashest:
Additional pollutants added to USTMP due
96 to POTWs concerns:
97 NPDES pw's comments on W/POC:
98 S.Pretreatment updates in response to NPDES permit renewal
gg NPDES Permit Effective Date 180 days after effective(date): Permit writer,please add list of required/recommended PT updates in NPDES permit cover letter.
Page 1 21717 POC Review Form

MONITORING REPORT(MR)VIOLATIONS for: Report Date: 02/02/24 Page 1 of 2
Permit: NCO021717 MRS Betweei 2 - 2019 and 2 - 2024 Region: % Violation Category:Limit Violation Program Category:
Facility Name:% Param Nam(% County: % Subbasin:% Violation Action:%
Major Minor: %
PERMIT: NCO021717 FACILITY: Town of Wilkesboro-Cub Creek WWTP COUNTY: Wilkes REGION: Winston-Salem
Limit Violation
MONITORING VIOLATION UNIT OF CALCULATED %
REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION
02-2019 001 Effluent Coliform, Fecal MF, MFC 02/16/19 5 X week #/100ml 400 1,552.33 288.1 Weekly Geometric Mean Proceed to NOV
Broth,44.5 C Exceeded
04-2019 001 Effluent Coliform, Fecal MF, MFC 04/20/19 5 X week #/100ml 400 1,015.3 153.8 Weekly Geometric Mean Proceed to NOV
Broth,44.5 C Exceeded
07-2020 001 Effluent Coliform, Fecal MF, MFC 07/18/20 5 X week #/100ml 400 850.73 112.7 Weekly Geometric Mean Proceed to NOD
Broth,44.5 C Exceeded
08-2019 001 Effluent Flow,in conduit orthru 08/31/19 Continuous mgd 4.9 5.02 2.5 Monthly Average Proceed to NOV
treatment plant Exceeded
08-2020 001 Effluent Flow,in conduit orthru 08/31/20 Continuous mgd 4.9 5.01 2.2 Monthly Average Proceed to NOD
treatment plant Exceeded
09-2020 001 Effluent Flow,in conduit or thru 09/30/20 Continuous mgd 4.9 5.08 3.6 Monthly Average Proceed to NOD
treatment plant Exceeded
10-2020 001 Effluent Flow,in conduit orthru 10/31/20 Continuous mgd 4.9 5 2.0 Monthly Average Proceed to NOD
treatment plant Exceeded
07-2019 001 Effluent Nitrogen,Ammonia Total(as 07/31/19 5 X week mg/I 21 24.49 16.6 Monthly Average Proceed to NOD
N)-Concentration Exceeded
08-2019 001 Effluent Nitrogen,Ammonia Total(as 08/31/19 5 X week mg/I 21 26.12 24.4 Monthly Average Proceed to NOV
N)-Concentration Exceeded
06-2021 001 Effluent Nitrogen,Ammonia Total(as 06/26/21 5 X week mg/I 35 36.72 4.9 Weekly Average Proceed to NOD
N)-Concentration Exceeded
06-2021 001 Effluent Nitrogen,Ammonia Total(as 06/30/21 5 X week mg/I 21 26.66 26.9 Monthly Average Proceed to NOD
N)-Concentration Exceeded
07-2021 001 Effluent Nitrogen,Ammonia Total(as 07/03/21 5 X week mg/I 35 42.84 22.4 Weekly Average Proceed to NOV
N)-Concentration Exceeded
07-2022 001 Effluent Nitrogen,Ammonia Total(as 07/23/22 5 X week mg/I 35 42.42 21.2 Weekly Average Proceed to NOV
N)-Concentration Exceeded
07-2022 001 Effluent Nitrogen,Ammonia Total(as 07/31/22 5 X week mg/I 21 33.38 59.0 Monthly Average Proceed to NOV
N)-Concentration Exceeded
08-2022 001 Effluent Nitrogen,Ammonia Total(as 08/31/22 5 X week mg/I 16 25.22 57.6 Monthly Average Proceed to NOV
N)-Concentration Exceeded

MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/02/24 Page 2 of 2
Permit: NCO021717 MRS Betweel 2 - 2019 and 2 - 2024 Region: % Violation Category:Limit Violation Program Category:
Facility Name:% Param Nam(% County: % Subbasin:% Violation Action:%
Major Minor: %
PERMIT: NCO021717 FACILITY: Town of Wilkesboro-Cub Creek WWTP COUNTY: Wilkes REGION: Winston-Salem
Limit Violation
MONITORING VIOLATION UNIT OF CALCULATED %
REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION
09-2022 001 Effluent Nitrogen,Ammonia Total(as 09/30/22 5 X week mg/I 16 29.57 84.8 Monthly Average Proceed to NOD
N)-Concentration Exceeded
02-2019 001 Effluent Solids,Total Suspended- 02/28/19 5 X week mg/I 30 32.42 8.1 Monthly Average Proceed to NOV
Concentration Exceeded
12-2019 001 Effluent Solids,Total Suspended- 12/31/19 5 X week mg/I 30 31.26 4.2 Monthly Average Proceed to NOD
Concentration Exceeded
01-2020 001 Effluent Solids,Total Suspended- 01/31/20 5 X week mg/I 30 30.86 2.9 Monthly Average Proceed to NOD
Concentration Exceeded
12-2020 001 Effluent Solids,Total Suspended- 12/26/20 5 X week mg/I 45 47.3 5.1 Weekly Average Proceed to NOV
Concentration Exceeded
12-2020 001 Effluent Solids,Total Suspended- 12/31/20 5 X week mg/I 30 31.94 6.5 Monthly Average Proceed to NOV
Concentration Exceeded
01-2021 001 Effluent Solids,Total Suspended- 01/02/21 5 X week mg/I 45 46.03 2.3 Weekly Average Proceed to NOD
Concentration Exceeded
01-2021 001 Effluent Solids,Total Suspended- 01/31/21 5 X week mg/I 30 31.66 5.5 Monthly Average Proceed to NOD
Concentration Exceeded

United States Environmental Protection Agency Form Approved.
EPA Washington,D.C.20460 OMB No.2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 2 u 3 I NC0021717 I11 121 23/09/08 I17 18 j ] 19I G I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
67 70 J 71 Ity 72 L-J 73 1 74 79 I I I I 80
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 01:OOPM 23/09/08 16/02/01
Cub Creek WWTP
701 Snyder St Exit Time/Date Permit Expiration Date
Wilkesboro NC 28697 03:OOPM 23/09/08 19/09/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dustin Colburn,PO Box 1056 Wilkesboro NC 286971056/ORC/336-981-1078/
No
Section C:Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Patricia Lowery DWR/WSRO WQ/336-776-9691/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NCO021717 I11 12I 23/09/08 117 18 I G
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On 9/8/2023 a Pretreatment Audit Inspection (PAI)was performed by Tricia Lowery of the
Winston-Salem Regional Office. Amber Garwood and Glenn Clark were present for the inspection.
The purpose of this audit was to determine the effectiveness of the Control Authority's pretreatment
program regarding SIU inspections., which includes the initial interview, tour of SIU facility, sampling
review, and an exit interview.
Background
This is a 4.9 MGD permitted facility. The Town has 3 Significant Industrial Users (SIUs), none of which
are categorical. The publicly owned treatment works (POTW) had 3 violations in July, August and
September of 2022 for Ammonia.
POTW Interview
The POTW is in the process of upgrading. The POTW has many issues removing solids, obtaining
proper DO levels in aeration basin and many components in the facility are out of service. Once
upgrades are complete, this will improve many elements of the pretreatment program.
Pretreatment Program Elements Review
The Headworks Analysis (HWA)was last approved on 4/27/2020. The next HWA is due 4/1/2024.
The IWS was last approved on 3/27/2020. The next IWS is due 12/1/2024.
The Sewer Use Ordinance (SUO)was approved on 1/2/2013.
The Enforcement Response Plan (ERP)was submitted on 2/24/2020 and approved on 3/14/2020.
The Long-Term Monitoring Plan (LTMP)was submitted 9/29/2020 and approved on 3/11/2021.
LTMP File Review
The Long-Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies
(2/year).
Industrial User Permit (IUP) File Review
A review of the file for Tyson (IU#1003) revealed that the monitoring data was well organized and
compliant.
The slug control plan for Tyson (IU#1003)was in good order.
Action Items
No other action items were noted.
Page# 2

Permit: NC0021717 Owner-Facility: Cub Creek WWTP
Inspection Date: 09/08/2023 Inspection Type: Pretreatment Audit
Yes No NA NE
Page# 3

Whole Effluent Toxicity Testing and Self Monitoring Summary
Western Wake Regional WRF NCO088846/001 County: Chatham Region: RRO Basin: CPF07 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 9/1/2023 ChrLim: 7.4%@18 NonComp: 70,10: PF: 18 IWC: Freq: Q
J F M A M J J A S O N D
2020 - Pass - - >29.6(P)Pass - - Pass - - Pass -
2021 - Pass - - Pass - - >29.6(P)Pass - - Pass -
2022 - INVALID Pass - - Pass - - Pass - - >29.6 Pass -
2023 - Pass >29.6 - Pass - - Pass - - Pass -
WestPoint Stevens-Wagram WWTP NC0005762/001 County: Scotland Region: FRO Basin: LUM51 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 11/1/2014 chr lim:9%@ 7MGD NonComp: Single 70,10: 117 PF: 7.0 IWC: 9.0 Freq: Q
J F M A M J J A S O N D
2020 - H - - H - - - - - - -
Whiteville-WhitemarshWWTP NCO021920/001 County: Columbus Region: WIRO Basin: LUM58 Jan Apr Jul Oct SOC JOC:
Ceri7dPF Begin: 2/1/2021 chr lim:50% NonComp: Single 70,10: 4.7 PF: 3.0 IWC: 50 Freq: Q
J F M A M J J A S O N D
2020 Pass - - Pass - - Pass - - Pass - -
2021 Pass - - Pass>100(P) - - Pass - - Pass - -
2022 Pass - - Pass>100(P) - - Pass - - Pass - -
2023 Pass>100 - - INVALID Pass - Pass - - Pass - -
Wilkesboro Cub Creek WWTP NCO021717/001 County: Wilkes Region: WSRO Basin: YAD01 Mar Jun Sep Dec SOC JOC:
Ceri7dPF Begin: 2/1/2016 chr lim:3.7%; if PF 6. NonComp: Single 7Q10: 196 PF: 4.9 IWC: 3.72 Freq: Q
J F M A M I J A S O N D
2020 - - Pass - - Pass - - Pass - - Pass
2021 - - Pass>14.8(P) - - Pass>14.8(P) - - Pass>14.8(P) - - Pass>14.8(P)
2022 - - Pass - - Pass - - Pass - - Pass
2023 - - Pass - - Pass - - Pass - - -
Williamston WWTP NCO020044/001 County: Martin Region: WARO Basin: ROA09 Mar Jun Sep Dec SOC JOC:
Ceri7dPF Begin: 9/1/2023 chr lim:2.0 MGD @ 0 NonComp: Single 7Q10: 1170 PF: 2.4 IWC: 0.26 Freq: Q
J F M A M J J A S O N D
2020 - - Pass - - Pass - - >1.08(P)Pass - - 0.76(P)Pass
2021 - - Pass>1.08(P) - - >1.08(P)Pass - - Pass - - Pass
2022 - - Pass - - Pass - - Pass - - Pass
2023 - - Pass - - Pass - - Pass - - -
Wilson-Hominy Crk WRF-Contentnea NCO023906/001 County: Wilson Region: RRO Basin: NEU07 Feb May Aug Nov SOC JOC:
Ceri7dPF Begin: 3/1/2021 chr lim:90% NonComp: Single 7Q10: 0.5 PF: 14.0 IWC: 97.37 Freq: Q
J F M A M J J A S O N D
2020 - Pass - - Pass - - Pass - - Pass>100(P) -
2021 - Pass - - Pass - - Pass - - Pass>100(P) -
2022 - >100(P)Pass - - Pass - - Pass - - Pass -
2023 - Pass - >100 INVALID Pass - - Pass - - Pass -
Leeend: P=Fathead minnow(Pimohales oromelas).H=No Flow(facilitv is active).s=Split test between Certified Labs Page 93 of 95

NORTH CAROLINA 2022 INTEGRATED REPORT
Upper Yadkin Yadkin-Pee Dee River Basin
AU Name AU Number Classification AU LengthArea AU Units
AU ID Description
YADKIN RIVER 12-(38)b C 3.3 FW Miles
13189 From Reddies River to Mulberry Creek
2022 Water Quality Assessments
PARAMETER IR CATEGORY CRITERIA STATUS
pH (6 su, AL, FW) 5 Exceeding Criteria
Water Temperature (292C, AL, MT&UP) 1 Meeting Criteria
Dissolved Oxygen (4 mg/I, AL, FW) 1 Meeting Criteria
pH (9.0, AL, FW) 1 Meeting Criteria
Turbidity (50 NTU, AL, FW miles) 1 Meeting Criteria
Fecal Coliform (GM 200/400, REC, FW) 1 Meeting Criteria
YADKIN RIVER 12-(47.5) WS-IV 9.7 FW Miles
1332 From a point 0.2 mile upstream of Big Bugaboo Creek to a point 0.9 mile upstream of mouth of Elkin
Creek (River)
2022 Water Quality Assessments
PARAMETER IR CATEGORY CRITERIA STATUS
Water Temperature (292C, AL, MT&UP) 1 Meeting Criteria
Dissolved Oxygen (4 mg/I, AL, FW) 1 Meeting Criteria
pH (6 su, AL, FW) 1 Meeting Criteria
pH (9.0, AL, FW) 1 Meeting Criteria
NO2+NO3-N (10 mg/I, WS, WS) 1 Meeting Criteria
Turbidity (50 NTU, AL, FW miles) 1 Meeting Criteria
Zinc (50 µg/I, AL, FW) 5 Exceeding Criteria
Fecal Coliform (GM 200/400, REC, FW) 1 Meeting Criteria
6/7/2022 NC 2022 INTEGRATED REPORT-Category 5 Approved by EPA 4/30/2022 Page 1180 of 1346

ROY COOPER
Governor
ELIZABETH S.BISER4
Secretary *
SHADI ESKAF NORTH CAROLINA
Director Environmental Quality
January 29, 2024
Mr. Ken Noland, Town Manager
Town of Wilkesboro
PO Box 1056
Wilkesboro, NC 28697
SUBJECT: Finding of No Significant Impact
Town of Wilkesboro
Cub Creek WWTP Expansion
Project No. CS370829-02
SRP-W-0208
Dear Mr. Noland:
This is to inform you that the Finding of No Significant Impact (FONSI) and the
Environmental Assessment have been submitted to the State Clearinghouse. The
documents will be advertised for thirty (30) calendar days in the N.C. Environmental
Bulletin. Advertising the FONSI is required prior to a local unit of government receiving
financial support from the State Revolving Loan program. You will be informed of any
significant comment or public objection when the advertisement period is completed.
A copy of the documents is transmitted for your record. The documents should be
made available to the public.
If there are any questions, please contact me at [phone].
Sincerely,
/l awz�-' .�QI42ClL�%G=
Kavitha Ambikadevi, Section Chief
Water Infrastructure Fund Section
Division of Water Infrastructure
SCK
Attachment (all cc's)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N.Salisbury Street 1 1633 Mail Service Center I Raleigh,North Carolina 27699-1633
Novain cnr,o�_ir�n �
D�of F oWm�l OwIftt /`� 919.707.9160

Mr. Ken Noland, Town Manager
Town of Wilkesboro
Finding of No Significant Impact
Project No.: CS370829-02 &SRP-W-0208
January 29, 2024
Page 2 of 2
cc: Wes Bramlett, PE, HDR Engineering, Inc. of the Carolinas,Winston-Salem
Ali Ajami, PhD, DWI (via email)
Mark Hubbard, PE, DWI (via email)
DWQ-WSRO
SRF File (CDWSRF ER/EID)
D EQ North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N.Salisbury Street 1 1633 Mail Service Center I Raleigh,North Carolina 27699-1633
Nora r+cnrvo_wn
919.707.9160

Coco, Nick A
From: Grotz, Lara <[e-mail]>
Sent: Friday, November 4, 2022 10:15 AM
To: Coco, Nick A
Cc: Bramlett, Wes
Subject: RE: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
Attachments: Attachment E - Wilkesboro 2022 Priority Pollutant Analysis.pdf, Attachment I - Chemical Addendum
to the NPDES Renewal App Wilkesboro.pdf,Attachment J - Wilkesboro 2022 Mercury Testing Results
Meritech.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Nick,
I've summarized the information that you've asked for. I've copy and pasted your asks in red and my responses in black.
1. Sorry for the quick follow-up, but would you also look into the February 2022 influent TSS and BOD data from the
plant?1 just want to make sure I'm not crazy, but both parameters come in quite low for that month and are
skewing the 85%removal rate requirement.
a. I've summarized the February 2022 monthly BOD and TSS data. As a reminder, since the Town has 2
influent sources,they generate a weighted influent based on flows. When asked about the February
2022 influent data,the Town let me know that Tyson's influent BOD of 20 mg/I was reported as a lab
error in the DMR.This value was still included in the spreadsheet that generated the averages listed
below. Once the Town removed the BOD lab transcription error, it changed the BOD averages to:Tyson
303 mg/l, and the weighted to 300 mg/l.There were no errors in the reporting of TSS. In the table below
I've summarized the data:
February 2022
Influent Source Monthly Average Monthly Average Monthly Average
Flow(MGD) BOD(mg/L) TSS(mg/L)
Municipal 0.6 280.2 236.3
Tyson Foods Influent 2.3 288.6 (303 with error 287.4
removed)
Weighted Average 2.9 289 (300 with error 274
Influent I I removed)
2. As required by Session Law 2018-5, Senate Bill 99, Section 13.1(r), every applicant shall now submit
documentation of any additional pollutants for which there are certified methods with the permit application if
their discharge is anticipated. The list of pollutants may be found in 40 CFR Part 136, which is incorporated by
reference. If there are additional pollutants with certified methods to be reported,please submit the Chemical
Addendum to NPDES Application table with your application and, if applicable, list the selected certified
analytical method used. If no additional sampling was conducted and/or there are no additional pollutants to
report, please note as much on the form itself. This requirement applies to all NPDES facilities. The Chemical
Addendum to NPDES Application will be required for any type of facility with an NPDES permit, depending on
whether those types of pollutants are found in your wastewater. Please fill out, sign and submit the Chemical
Addendum to NPDES Application.
1

a. As of the most recent priority pollutant analysis (2022)the Town did not report any new industrial
contributors. Both the filled out chemical addendum and priority pollutant scan are attached.
3. When you have sometime, please send me the 3 total mercury sample results that were used to summarize total
mercury in Table C of the revised application. The DMRs have reported total mercury using a variety of PCS
codes, so I'm hesitant to use this for my evaluation.Additionally, I'm hesitant to use the PPA data since it's so old
(2016-2017).
a. The Town tests for mercury quarterly. Low level Mercury results are below and most recent lab reports
for mercury are attached.
Date LL Hg
Feb-20 <.0002 mg/I
Jun-20 1.62 ng/L
Nov-20 1.03 ng/L
Dec-20 1.75 ng/L
Feb-21 1.07 ng/L
Jun-21 2.61 ng/L
Sep-21 < 1.0 ng/L
Dec-21 1.27 ng/L
Mar-22 4.90 ng/L
Sep-22 < 1.0 ng/L
Lara Grotz, PE
D 704.248.3622
hdrinc.com/follow-us
From: Coco, Nick A<[e-mail]>
Sent: Friday, November 4, 2022 9:52 AM
To: Grotz, Lara <[e-mail]>
Cc: Bramlett, Wes<[e-mail]>
Subject: Re: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Hi Lara,
Thank you so much for getting this info! To make our lives easier, emailing just the additional information is perfectly ok.
I can attach to the fact sheet as an addendum to the application if need be. This way we don't have to worry about
things getting lost in transit, and it's not like the entire application was affected.
Thanks,
Nick Coco, PE (he/him/his)
Engineer///
NPDES Municipal Permitting Unit
NC DEQ/Division of Water Resources/Water Quality Permitting
2

Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
From: Grotz, Lara <[e-mail]>
Sent: Friday, November 4, 2022 9:47:08 AM
To: Coco, Nick A<[e-mail]>
Cc: Bramlett, Wes<[e-mail]>
Subject: RE: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Nick,
I've got all of the data that you've asked for clarification on. How should I get this information back to you?
Should I generate a new renewal application PDF with the excel sheet attached in the appendix as a PDF?And the same
thing as the mercury results and PPA?
Or, should I attach those items to you in a PDF without re-sending our renewal application?
Thank you,
Lara
Lara Grotz, PE
D 704.248.3622
hdrinc.com/follow-us
From: Coco, Nick A<[e-mail]>
Sent: Friday, October 28, 2022 3:08 PM
To: Grotz, Lara <[e-mail]>
Subject: RE: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Hi Lara,
3

I'm working through the renewal process for the Wilkesboro WRF currently and wanted to request the following:
• As required by Session Law 2018-5, Senate Bill 99, Section 13.1(r), every applicant shall now submit
documentation of any additional pollutants for which there are certified methods with the permit application if
their discharge is anticipated.The list of pollutants may be found in 40 CFR Part 136,which is incorporated by
reference. If there are additional pollutants with certified methods to be reported, please submit the Chemical
Addendum to NPDES Application table with your application and, if applicable, list the selected certified
analytical method used. If no additional sampling was conducted and/or there are no additional pollutants to
report, please note as much on the form itself. This requirement applies to all NPDES facilities. The Chemical
Addendum to NPDES Application will be required for any type of facility with an NPDES permit, depending on
whether those types of pollutants are found in your wastewater. Please fill out, sign and submit the Chemical
Addendum to NPDES Application.
• When you have some time, please send me the 3 total mercury sample results that were used to summarize
total mercury in Table C of the revised application.The DMRs have reported total mercury using a variety of PCS
codes, so I'm hesitant to use this for my evaluation.Additionally, I'm hesitant to use the PPA data since it's so
old (2016-2017).
1 appreciate all of your help with this. Please let me know if you have any questions of need me to clarify anything.
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/Division of Water Resources/Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
DE Q:>
No)I'I H CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Grotz, Lara <[e-mail]>
Sent: Wednesday, September 28, 2022 8:37 AM
To: Coco, Nick A<[e-mail]>
Subject: RE: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Nick,
4

You're welcome! And, we are happy to mail a physical copy to you if you would prefer. How many copies would you
like?
And, should we mail to the address below(1617 Mail Service Center)?
Lara
Lara Grotz, PE
D 704.248.3622 M 434.996.0856
hdrinc.com/follow-us
From: Coco, Nick A<[e-mail]>
Sent:Tuesday, September 27, 2022 11:24 AM
To: Grotz, Lara <[e-mail]>
Subject: RE: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Thank you Lara! I have downloaded the file you've shared. Do you know if a physical package is also being mailed?
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/Division of Water Resources/Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
D- E
NORTH CAHOLINA
kl ;
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Grotz, Lara <[e-mail]>
Sent:Tuesday, September 27, 2022 11:12 AM
To: Coco, Nick A<[e-mail]>
Cc: Montebello, Michael J <[e-mail]>; Graznak,Jenny<[e-mail]>; Pohlig,
Ken <[e-mail]>;Ajami, Ali<[e-mail]>; Kubacki, Susan <[e-mail]>;
Bramlett, Wes<[e-mail]>; Saunders, David <[e-mail]>; Colson, Kim
<[e-mail]>; Sam Call <[e-mail]>; Noland, Ken <[e-mail]>;
5

Amber Garwood <[e-mail]>; Dustin Colburn <[e-mail]>
Subject: [External] NCO021717 Wilkesboro WWTP Renewal and Expansion Updated Package
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Nick,
In this email you will find linked HDR's submission package to NC DWR that includes information in support of
Wilkesboro's expansion request and renewal application. Included in the cover letter are your comments on both the
renewal and expansion application and HDR's responses to each of them. Additionally, we have prepared a submission
package which includes the following items:
1. Revised flow projections that indicate the Town's minimum need for an 8 MGD facility.
2. The NPDES Renewal Application using the current version of EPA Form 2A.
At present, we are still waiting for the letter from Tyson Foods on their requested expansion flow. Upon receiving the
letter from Tyson Foods, we will submit their letter as an addendum.
Our Teams Page contains the Submission Package.
Thank you for your review.
Lara
Lara Grotz, PE
Water/Wastewater Engineer
HDR
440 S Church St, Suite 1200
Charlotte, NC 28202
D 704.248.3622 M 434.996.0856
lara.grotz(a)hdrinc.com
hdrinc.com/follow-us
6

EPA Identification Number NPDES Number Facility Name Outfall Number
110022571055 NC0021717 Wilkesboro Cub Creek WWTP 1
Method Number(if Estimated Concentration (If
Pollutant(Required) CAS number Applicable) Reason Pollutant Believed Present in Discharge Known)
In a statement from November 2022,there are no new industry
connections as of the most recent industrial waste survey.For this
reason,the Chemical Addendum was not completed.Wilkesboro's
None N/A N/A 2022 Priority Pollutant Analysis is attached. N/A

FINDING OF NO SIGNIFICANT IMPACT
AND ENVIRONMENTAL ASSESSMENT
TOWN OF WILKESBORO
WILKESBORO CUB CREEK WASTEWATER TREATMENT PLANT EXPANSION
RESPONSIBLE AGENCY: NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
CONTACT: KAVITHA AMBIKADEVI, SECTION CHIEF
WATER INFRASTRUCTURE FUND SECTION
DIVISION OF WATER INFRASTRUCTURE
1633 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1633
[phone]
January 29, 2024

(This page intentionally left blank.)

FINDING OF NO SIGNIFICANT IMPACT
Article I, Chapter 113A of the North Carolina General Statutes requires an action to be subject to
the requirements of the North Carolina Environmental Policy Act(NCEPA) if it involves the
expenditure of public funds and if a potential impact is anticipated to the environment. The
project has been evaluated for compliance with the NCEPA and is determined to be a major
agency action, which will affect the environment.
Project Applicant: Town of Wilkesboro,North Carolina
Project Description: The proposed project will upgrade major components and
increase the capacity of the existing Wilkesboro Cub Creek
Wastewater Treatment Plant from 4.9 million gallons per day
(MGD) maximum month flow to 8 MGD maximum month flow.
Improvements will include upgraded influent pump station,
upgraded headworks, conversion of aeration basin to equalization
basin, influent buffering, addition of secondary treatment, tertiary
disk filtration, new UV disinfection system, new effluent flow
metering, improved aerobic digestion and thickening, replacement
of sludge dewatering unit, and a new operations building.
Project Number: CS370829-02 & SRP-W-0208
Project Cost: $72,000,000
Clean Water State $42,000,000
Revolving Loan Fund:
Wastewater State Reserve $18,000,000
Program:
Local Funds: $12,000,000
The review process indicated that significant adverse environmental impacts should not occur if
mitigative measures are implemented, and an environmental impact statement will not be
required. The decision was based on information in the Engineering Report/Environmental
Information Document (ER/EID) submitted by the applicant and reviews by governmental
agencies. The attached Environmental Assessment(EA),prepared by the Division based on the
ER/EID, supports this action and outlines mitigative measures that must be followed. This
Finding of No Significant Impact(FONSI) completes the environmental review record,which is
available for inspection at the State Clearinghouse.
No administrative action will be taken on the proposed project for at least 30 days after
notification that the FONSI has been published in the North Carolina Environmental Bulletin.
Sincerely,
16X1444U�
Kavitha Ambikadevi, Section Chief
Water Infrastructure Fund Section
Division of Water Infrastructure

(This page intentionally left blank.)

ENVIRONMENTAL ASSESSMENT
A. Proposed Facilities and Actions
The proposed project will upgrade major components and increase the capacity of the existing
Wilkesboro Cub Creek Wastewater Treatment Plant (WWTP) from 4.9 million gallons per day
(MGD)maximum month flow to 8 MGD maximum month flow. Improvements will include the
following components:
• Upgrade the influent pump station to increase the total pumping capacity of the municipal
flow.
• Retrofitted and upgrade the existing headworks including new screens and new grit
classifier.
• Convert the existing aeration basin to a wet weather flow equalization basin.
• Convert secondary clarifier 4 to an influent buffer tank to converge the municipal and
industrial flows upstream of secondary treatment and install pumps to convey the flow to
the biological treatment system.
• Upgrade secondary treatment by constructing three AquaNereda aerobic granular sludge
(AGS)tanks and converting secondary clarifier 3 to a dual sludge buffer(SB) and water
level correction(WLC) tank, which will serve to thicken the WAS before pumping to the
aerobic digesters; existing secondary clarifier 1 and 2,which are located in the
floodplain,will be decommissioned.
• A set of two tertiary disc filter may be installed as needed based on future nutrient
removal limits in the High Rock Lake basin.
• The existing UV system in the floodplain will be decommissioned, and a new UV
disinfection system will be installed outside of the floodplain.
• The existing effluent Parshall flume in the floodplain will be decommissioned, and a new
Parshall Flume will be constructed just downstream of the new UV disinfection system.
• The existing aerobic digesters will remain operational, and new disc thickening units will
be installed in 10 years or approximately by 2032. The timing of the disc thickening unit
is dependent on expected growth in the area and on the expenses of landfill tipping fees.
• The existing Huber Q-Press 800 sludge dewatering unit is nearing the end of its service
life and will be replaced with another unit of the same model. A second unit will be
installed to increase capacity.
• A new operations building will be constructed outside of the floodplain and near the
secondary treatment process for the plant operations staff.
Funding Status: The estimated total cost for the project is $72,000,000. The Town is applying for
a Clean Water State Revolving Fund(CWSRF) loan of$42,000,000 including $1,000,000 of
principal forgiveness and has been awarded a State Reserve Program (SRP) grant of
$18,000,000. The Town will fund the remainder of the project, including closing
costs/administrative fees of$1,110,0000,through local funds. The City may apply for additional
CWSRF funding.
1

B. Existiniz Environment
Topography and Soils. Wilkesboro is located in the Piedmont physiographic province. The
elevation of the project area ranges from 946 feet mean sea level (msl) to 1,038 feet msl.
Portions of the project site are located within the 100-year flood plain.
The project site includes the following soil units: Banister fine sandy loam, 1 to 6 percent slopes,
rarely flooded(BaB), moderately well drained or somewhat poorly drained soils; characterized
as strongly acidic; Codorus loam, 0 to 2 percent slopes, frequently flooded (CoA), consist of very
deep, moderately well drained and somewhat poorly drained soils; Dan River loam, 0 to 4
percent slopes, occasionally flooded(DaA)very deep, well drained soils, characterized as very
strongly acidic in the upper parts through slightly acidic in the lower parts; Danripple sandy clay
loam, 8 to 15 percent slopes, moderately eroded(DpC2), very deep, well drained soils,
characterized as very strongly acidic to moderately acidic; Fairview sandy loam, 15 to 25 percent
slopes (FaD), very deep,well drained soils, characterized as extremely acidic to moderately
acidic throughout; Fairview sandy clay loam, 8 to 15 percent slopes, moderately eroded(FcC2)
soils, similar to Fairview sandy loam located in less steep terrain; Fairview-Urban land complex,
2 to 15 percent slopes (FrC) soils, also similar to Fairview sandy loam typically including built
upon urban lands; and Rhodhiss fine sandy loam, 25 to 60 percent slope (RdE), very deep, well-
drained soil characterized by very strongly acidic to slight acidic throughout.
Surface Water. The project area is located in the Yadkin Headwaters Subbasin of the Yadkin-
Pee-Dee River Basin(HUC 0304010103). Surface waters in the area include Cub Creek, Little
Cub Creek, and the Yadkin River. All are rated Class C. Cub Creek is impaired for poor fish
community.
Water Soply. The Town's public water supply draws water from the Yadkin River.
C. Existing Wastewater Treatment Facilities
The Town owns and operates the Club Creek WWTP, which is an activated sludge plant with a
permitted capacity of 4.9 MGD under NPDES Permit Number NC0021717 discharging to the
Yadkin River. The WWTP was constructed in 1965 with various improvements made since
construction. The plant has been maintained in good condition overall but is nearing capacity.
Some service components are nearing the end of their useful life. The liquids train consists of an
influent pumping station, screening and grit removal, an aeration basin with surface mixers,
secondary clarification, and UV disinfection. The solids train consists of aerobic digestion,
dewatering by a Huber screw press, and landfilling of dewatered solids. The average daily
effluent flows in 2019 and 2020 were 4.44 MGD and 4.77 MGD, respectively. The WWTP
receives 70 to 80 percent of its flow from Tyson Foods, Inc., and the WWTP site contains
Tyson's influent pump station and two of Tyson's pretreatment basins. The 2021 current average
daily flow is 4.21 MGD, which is approximately 86% of the plant's permitted capacity. The
Town has received 22 Notices of Violations (NOVs) for effluent permit exceedances between
December 2016 and December 2021. Several components are located within the 100-year
floodplain.
2

In addition to the WWTP, the Town owns and operates a wastewater collection system
consisting of 67 miles of gravity sewer, 1,383 manholes, 10 miles of force main, and 13 pump
stations. An asset inventory and assessment study was recently completed including a 10-year
rehabilitation and replacement plan for the collection system.
D. Need for Proposed Facilities and Actions
The Town's existing WWTP is aging and under capacity. Upgrades are needed to replace aging
equipment, improve treatment, and provide additional capacity for anticipated demand. The
Town's NPDES Permit previously included requirements to monitor nutrients but did not specify
numerical nutrient limits. The speculative permit includes numerical limits for both TN and TP
which will require improved treatment, and the Town is experiencing industrial and commercial
growth.Nutrient limits to the Yadkin River may change depending on the final nutrient strategy
developed for High Rock Lake. The Town has received 22 Notices of Violations (NOVs) for
effluent permit exceedances between December 2016 and December 2021. In July 2021, the
Town received a Sewer Line Moratorium from NCDEQ. The moratorium was issued because in
the previous calendar year when the Town's effluent from the WWTP flow averaged 4.8 MGD
representing 97.2 percent of the plant's current treatment capacity.
The purpose of this proposed project there is to provide an upgraded and expanded facility that
will enable Wilkesboro to meet future permit limits while accommodating future growth.
E. Alternatives Analysis
No-Action: The No-action alternative would continue operation of the WWTP with aging
equipment, components located in the floodplain, exceeding flow limits, and unable to meet
future effluent water quality standards for total nitrogen and phosphorus. This alternative is
infeasible and was rejected.
Alternative 1 —AquaNereda Aerobic Granular Sludge (AGS) (Preferred): This alternative
consists of upgrading the secondary treatment process using an AquaNereda aerobic granular
sludge (AGS) system operating in three new sequencing batch reactors and increasing the
capacity of the WWTP from 4.9 MGD to 8 MGD. Associated improvements to the plant include
influent pump station upgrades, the existing headworks will be retrofitted and upgraded,
conversion of existing Clarifier No. 4 to an AGS influent buffer tank, construction of new tanks
required for the Nereda process, construction of a new UV disinfection system and effluent
measurement/monitoring facilities, and the addition of a new solids dewatering screw press. A
new operations building is also included in this alternative. The existing aerobic digesters will
remain in-use. This alternative is preferred because it meets the desired treatment flows for the
plant with the lowest treatment cost per gallon, greatest energy savings, and smallest spatial
footprint compared to other alternatives.
Alternative 2—Oxidation Ditch with Mobile Organic Biofilm Process: This alternative would
also upgrade treatment and increase the plant capacity using an oxidation ditch with Mobile
Organic Biofilm(MOB)process by Nuvoda. The oxidation ditch would be filled with Kenaf
3

media to enhance treatment and settling, and a media retention screen would be included to filter
out any wasted media and return it to the biological process. Associated plant upgrades would
include updates to the influent pump station,rehabilitation of existing headworks system,
construction of a new ultraviolet(UV) disinfection system, construction of a high river effluent
pump station, addition of a new effluent flow meter,upgrades to the existing RAS pump station,
and addition of a new solids dewatering unit. This alternative was rejected due to higher
treatment cost per gallon, higher energy demand, and larger spatial footprint compared to the
preferred alternative. Additionally,this alternative would include constructing new treatment
components within the floodplain.
Alternative 3 —Conventional Sequencing Batch Reactor(SBR): This alternative consists of a
conventional SBR system with four tanks located adjacent to the existing maintenance building.
Associated plant improvements would include upgrades to the influent pump station,
construction of new headworks north of Tyson's pretreatment basins, construction of a new UV
disinfection system, addition of a new effluent flow meter, and addition of new solids thickening
and dewatering units. A new plant operations/control building would also be included in this
alternative. This alternative was rejected due to higher treatment cost per gallon, higher energy
demand, and larger spatial footprint compared to the preferred alternative.
F. Environmental Consequences and Mitigative Measures
Topography and Soils: Significant impacts to topography and soils are not anticipated. The
WWPT site has already been disturbed. Minimal grading will be required. Total impervious area
will change from 14 percent to 17 percent. Disturbed areas that are not within building footprints
will be re-seeded after construction. Impacts to the floodplain will include removing and
demolishing the existing aeration basin and Tyson influent pump station, adding rock to existing
access roads, and temporary erosion control devices. There will be no permanent changes to
existing elevations within the 100-yea floodplain. The project will comply with local FEMA
regulations including appropriate permits. The project will expand the WWTP, and secondary
and cumulative impacts (SCI) are possible due to future wastewater lines and development in the
service area. These impacts will be minimized through adherence to Town of Wilkesboro and
Wilkes County ordinances addressing floodplain development, flood damage prevention, sewer
use, and watershed development.
Land Use: Significant impacts to land use are not anticipated. The project is located within sites
owned by the Town of Wilkesboro and Tyson Foods and used for wastewater treatment. SCI will
be managed through the Town's Comprehensive Land Use Plan, which includes provisions for
preserving open spaces.
Wetlands: Significant impacts to wetlands are not anticipated. There are no wetlands on the
project site and therefore no direct impacts anticipated. SCI related to future growth will be
minimized through the Wilkes County Watershed Ordinance, which limits certain development
and places impervious surface limits on certain developments to project wetlands and streams.
Important Farmlands: Significant impacts to important farmlands are not anticipated. The project
area does include soils designated as prime and unique farmland, but the site is already disturbed
4

and not in agricultural use. Potential SCI will be minimized through the NC Agricultural
Development and Farmland Preservation Fund, which promotes farmland preservation.
Public Lands and Scenic, Recreational, and State Natural Areas: Significant impacts to public
lands, scenic, recreational, or state natural areas are not expected. Parks and public lands in the
surrounding area may experience increase in noise during construction activities,but these
impacts will be minor and temporary.
Cultural Resources: Direct impacts to cultural and historic resources are not anticipated. The
Downtown Wilkesboro Historic District is located within a mile of the project area,but impacts
are not anticipated. Five previously recorded archaeological sites are located within one mile of
the project site and are not expected to be impacted due to construction activities occurring at
previously disturbed locations. The North Carolina State Historic Preservation Office (SHPO)
conducted a review of the project and is aware of no historic resources which will be impacted
by the project(July 29, 2022, ER 21-2531). Potential SCI will be minimized through
Wilkesboro's Historic Preservation Committee's guidelines.
Air Quality: No significant impacts to air quality are anticipated. Construction activities may
cause a temporary increase in emissions and will cease when construction is complete. Dust
control measures will be implemented, and open burning of materials will not be allowed.
Testing of emergency generators may cause temporary, short-term emissions. Otherwise, the
project will not result in new sources of air pollution. SCI to air quality are not anticipated.
Noise Levels: No significant noise impacts are anticipated. Noise from construction activities
will be temporary with construction hours restricted under the Town's Noise Ordinance.
Operational noise impacts may increase slightly as a result of additional components and new
technologies at the WWTP. Forested areas surrounding the project site create natural noise
buffers to minimize any noise for surrounding residences. SCI may include construction noise
for wastewater line installation and residential and industrial development. These impacts will be
minimized through compliance with Wilkes County's High Impact Land Use Ordinance.
Water Resources: No significant negative impacts to water resources are anticipated. A
sedimentation and erosion control plan will be implemented to minimize impacts to surface
water from construction activities. The project will provide a benefit to nearby surface waters by
removing several components from the floodplain and improving the treatment process and
qualify of effluent from the WWTP. SCI related to future develop will be minimized through the
Wilkes County Watershed Ordinance and stormwater provisions in the Town's Subdivision
Ordinance.
Forest Resources: Significant impacts to forest resources are not expected. The project site
includes scattered wooded areas. A small area of approximately 0.18 acre of upland forest will
be cleared. SCI from future development will be minimized through the Town's Tree,
Subdivision, and Zoning ordinance and Wilkes County Watershed Ordinance.
Shellfish or Fish and Their Habitats: Impacts to shellfish, fish, and their habitats are not expected
to be significant. There are no known occurrences of threatened or endangered aquatic species in
5

the project site or immediate surrounding area. Impacts to aquatic species from construction
activities will be minimized through adherence to a sediment and erosion control plan. Aquatic
species will benefit from improved wastewater effluent quality. SCI related to future develop
will be minimized through the Wilkes County Watershed Ordinance and stormwater provisions
in the Town's Subdivision Ordinance.
Wildlife and Natural Vegetation: No significant impacts to wildlife and natural vegetation are
expected. No threatened or endangered species have been identified within one mile of the
project site. Suitable habitat exists for the Northern long-eared bat and tricolored bat. To protect
these species, the recommendation from the U.S. Fish& Wildlife Service (USFWS)to avoid tree
removal between March 15th and November 15t1i will be followed. Impacts to other terrestrial
species are not anticipated. Most of the project is located in previously disturbed and maintained
areas. SCI related to future development will be minimized through County and Town
development ordinances.
Introduction of Toxic Substances: The project is not expected to introduce toxic substances into
the environment. Construction specifications will include provisions for fuel, oil, and lubricants
to be contained and equipment to be properly maintained to prevent leakage and spills.
Chemicals used on-site will be controlled and maintained as currently required at the WWTP.
The U.S. Fish and Wildlife Service was consulted and provided guidance (June 2, 2023). The
North Carolina Wildlife Resources Commission,Natural Heritage Program, and DWR Winston-
Salem Regional Office do not object to the proposed project. The U.S. Army Corps of Engineers
was consulted and did not object to the project. The North Carolina Department of Natural and
Cultural Resources is aware of no historic resources which will be impacted by the proposed
project(July 29, 2022, ER 21-2531).
G. Public Participation, Sources Consulted
The Town of Wilkesboro held a public meeting on November 6, 2023. The meeting included a
presentation about the proposed project and opportunity for public comments. The Town also
provided a 30-day period for submission of written comments. Comments at the meeting
included support for the project from a councilman and a question about publishing time. No
written comments were received.
The current user charge for a typical residential customer is $30.77 per month for sewer and
water combined,based on consumption of 5,000 gallons per month. The proposed project will
increase the bill by $9.62, for a future sewer bill of$40.39. The Town intends to raise rates
through a series of smaller annual increases.
Sources consulted about this project for information or concurrence included:
1) City of Wilkesboro
2) Wilkes County
3) North Carolina Department of Environmental Quality
-Wildlife Resources Commission
6

-Natural Heritage Program
-DEQ Winston-Salem Regional Office
-Division of Air Quality
-Division of Water Resources
-Division of Forest Resources
-Division of Environmental Assistance and Customer Service
-Division of Waste Management
4) North Carolina Department of Natural and Cultural Resources
5) North Carolina State Clearinghouse
6) North Carolina Department of Public Safety
7) U.S. Fish and Wildlife Service
8) U.S. Army Corps of Engineers
7

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Town of Wilkesboro I Cub Creek CCWWTP Expansion Project ER-EID 1 ��
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Existing,to be taken New Nereda
_ out of service " � Process
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conversion to Sludge Buffer
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L ""G ""' PROJECT LOCATION D6 i N MAP
0 Figure 2
CUB CREEK WASTEWATER TREATMENT PLANT EXPANSION
Figure 1.2. Project Location Map
7

ROY COOPER
Governor
ELIZABETH S.BISER4
Secretary *
SHADI ESKAF NORTH CAROLINA
Director Environmental Quality
January 29, 2024
Mr. Ken Noland, Town Manager
Town of Wilkesboro
PO Box 1056
Wilkesboro, NC 28697
SUBJECT: Finding of No Significant Impact
Town of Wilkesboro
Cub Creek WWTP Expansion
Project No. CS370829-02
SRP-W-0208
Dear Mr. Noland:
This is to inform you that the Finding of No Significant Impact (FONSI) and the
Environmental Assessment have been submitted to the State Clearinghouse. The
documents will be advertised for thirty (30) calendar days in the N.C. Environmental
Bulletin. Advertising the FONSI is required prior to a local unit of government receiving
financial support from the State Revolving Loan program. You will be informed of any
significant comment or public objection when the advertisement period is completed.
A copy of the documents is transmitted for your record. The documents should be
made available to the public.
If there are any questions, please contact me at [phone].
Sincerely,
/l awz�-' .�QI42ClL�%G=
Kavitha Ambikadevi, Section Chief
Water Infrastructure Fund Section
Division of Water Infrastructure
SCK
Attachment (all cc's)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N.Salisbury Street 1 1633 Mail Service Center I Raleigh,North Carolina 27699-1633
Novain cnr,o�_ir�n �
D�of F oWm�l OwIftt /`� 919.707.9160

Mr. Ken Noland, Town Manager
Town of Wilkesboro
Finding of No Significant Impact
Project No.: CS370829-02 &SRP-W-0208
January 29, 2024
Page 2 of 2
cc: Wes Bramlett, PE, HDR Engineering, Inc. of the Carolinas,Winston-Salem
Ali Ajami, PhD, DWI (via email)
Mark Hubbard, PE, DWI (via email)
DWQ-WSRO
SRF File (CDWSRF ER/EID)
D EQ North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N.Salisbury Street 1 1633 Mail Service Center I Raleigh,North Carolina 27699-1633
Nora r+cnrvo_wn
919.707.9160

LKFSBO TOWN OF WILKESBORO
• 0 P.O.Box 1056.203 West Main Street
�. Wilkesboro,North Carolina 28697
Tory0ak ��° www.wilkesboronc.org
O�PORAT Phone [phone] • Fax[phone]
February 11, 2022
Mr. Michael Montebello
Municipal Unit Supervisor, Water Quality Permitting Section
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Attachment C—Sampling Result
Major Modification Request for NCO021717
Wilkesboro WWTP Expansion
Wilkes County, NC
Dear Mr. Montebello:
The Town of Wilkesboro (Wilkesboro) submitted a major modification request, dated January
21, 2022, to the North Carolina Department of Environmental Quality's Division of Water
Resources (DWR) to modify our pending NPDES permit renewal application to include an
expansion request.
In the cover letter it was noted that additional sampling of landfill leachate, as requested by the
Municipal Unit, would be submitted under separate cover once results are obtained. Please find
enclosed Attachment C with the sampling results.
If you have a need for additional information or have any questions, please do not hesitate to
contact me at [phone], Ext. 1050 or Wes Bramlett, PE with HDR at [phone].
Sincerely,
Kenneth Noland, Town Manager
Town of Wilkesboro
Attachments:
Attachment C - Wilkesboro Sampling Results for PFAS and 1,4-Dioxane
MIKE INSCORE KENNETH D.NOLAND JAMES K.BYRD NELLIE ARCHIBALD RUSSELL F.FERREE
Mayor Town Manager Town Clerk JIMMY HAYES Mayor Pro Tern
[e-mail] ANDREW"ANDY"SOOTS
Council Members

Attachment — Wilkesboro
Sampling Results for PFAS
and 1 ,4-Dioxane

Town of Wilkesboro WWTP
700 Snyder Street
Wilkesboro, NC 28697
On-Site WWTP
Client Project: Landfill Leachates
Samples Received: 12/10/21
Analytical Report
1221 -747
Isotope Dilution Method
PFAS — Draft 1633
Enthalpy Analytical, LLC — Ultratrace
Mark Hager
M: 910-520-2526/ F: 910-212-5866
ENTHALPY mark.hag er(o-)-e nth al py.com /www.enthalpy.com
ANALYTICAL 2714 Exchange Drive, Wilmington, NC 28405

I certify that to the best of my knowledge all analytical data presented in this report:
• Have been checked for completeness
• Are accurate, error-free, and legible
• Have been conducted in accordance with approved protocol, and that all deviations and
analytical problems are summarized in the appropriate narrative(s)
This analytical report was prepared in Portable Document Format(.PDF) and contains 25
pages.
f
QA Revi w Performed by: Laura K. Boivin
1/25/2022
Report Issued Date:
��
ENTHALPY
EU#1221-747 Page 2 of 25

Summary of Results
��
ENTHALPY
A ti A L Y f I C A L
EU#1221-747 Page 3 of 25

Enthalpy Analytical
Job No.: 1221-747-1 PFAS by Isotope Dilution (non-potable water) Draft 1633
Town of Wilkesboro WWTP Client Proj.: Landfill Leachates Site: On Site WWTP
Summary
Ashe County Leachate Wilkes County
Compound CAS ng/L Leachate
n /L
PFBA 375-22-4 492 445
PFPeA 2706-90-3 546 423
PFHxA 307-24-4 1540 1110
PFHpA 375-85-9 117 141
PFOA 335-67-1 249 418
Acids PFNA 375-95-1 4.27 18.3
PFDA 335-76-2 <LOD(0.704) U 4.30
PFUnDA 2058-94-8 <LOD(1.54) U <LOD(1.54) U
PFDoDA 307-55-1 <LOD(1.68) U <LOD(1.68) U
PFTrDA 72629-94-8 <LOD(1.26) U <LOD(1.26) U
PFTeDA 376-06-7 <LOD(1.82) U <LOD(1.82) U
PFBS 375-73-5 33.7 61.8
PFPeS 2706-91-4 <LOD(1.72) U 12.5
PFHxS 355-46-4 40.0 170
PFHpS 375-92-8 1.54 J <LOD(1.13) U
PFOS 1763-23-1 3.91 36.1
Sulfonates
PFNS 68259-12-1 <LOD(0.720) U <LOD(0.720) U
PFDS 335-77-3 <LOD(1.60) U <LOD(1.60) U
4:2 FTS 757124-72-4 2.74 3.40
6:2 FTS 27619-97-2 26.7 16.4
8:2 FTS 39108-34-4 <LOD(1.43) U <LOD(1.43) U
PFOSA 754-91-6 <LOD(1.08) U <LOD(1.08) U
N-McFOSAA 2355-31-9 2.29 J 1.77 J
N-EtFOSAA 2991-50-6 1.26 J <LOD(0.908) U
HFPO-DA 13252-13-6 <LOD(1.90) U <LOD(1.90) U
PFMOPrA 377-73-1 <LOD(2.00) U <LOD(2.00) U
ADONA 919005-14-4 <LOD(1.00) U <LOD(1.00) U
9CI-PF3ONS 756426-58-1 <LOD(1.00) U <LOD(1.00) U
11CI-PF3OUdS 763051-92-9 1.04 J 1.11 J
3:3 FTCA 356-02-5 161 170
Other 5:3 FTCA 914637-49-3 362 321
7:3 FTCA 812-70-4 <LOD(18.7) U <LOD(18.7) U
N-EtFOSA 4151-50-2 <LOD(2.00) U <LOD(2.00) U
N-EtFOSE 1691-99-2 <LOD(60.0) U <LOD(60.0) U
NFDHA 151772-58-6 <LOD(2.00) U <LOD(2.00) U
N-McFOSA 31506-32-8 <LOD(2.00) U <LOD(2.00) U
N-McFOSE 24448-09-7 <LOD(60.0) U <LOD(60.0) U
PFDoS 79780-39-5 <LOD(18.7) U <LOD(18.7) U
PFEESA 113507-82-7 <LOD(2.00) U <LOD(2.00) U
PFMOBA 863090-89-5 1 <LOD(12.0) U <LOD(12.0) U
EU#1221-747 Page 4 of 25

Detailed Results
� -
ENTHALPY
A ti A L Y f I C A L
EU#1221-747 Page 5 of 25

Enthalpy Analytical
Job No.:1221-747-1 PFAS by Isotope Dilution(non-potable water)Draft 1633
Town of Wilkesboro WWTP Client Proj.:Landfill Leachates Site:On Site WWTP
Enthalpy ID 1221-747-001-2 Prep Batch EU12729 Sample Vol(mL) 30
Sample Name Ashe County Leachate Prep Date 2021-12-15 14:36 Extract Vol(mL) 0.4
Matrix Aqueous Analysis Date 2021-12-18 02:56 Dilution Factor 1
Sampling Date 20211116 00:00 Analyst rappelle Method Code WM-026
Received Date 2021-12-10 13:41 Instrument Kili Sample Type Sample
Extract Sample Formatted LOD LOQ Recovery
Compound CAS Concentration Concentration Result Recovery Flags
ng/L ng/L ng/L ng/L ng/L Limits
PFBA 375-22-4 36876.06 492 492 1.28 2.53
PFPeA 2706-90-3 40937.23 546 546 1.42 2.53
PFHxA 307-24-4 115543.40 1541 1540 1.61 2.53
PFOA 335-67-1 18698.28 249 249 1.48 2.53
Acids PFNA 375-95-1 320.62 4.27 4.27 0.634 2.53
PFUnDA 2058-94-8 ND ND <LOD 1.54 2.53 U
PFDoDA 307-55-1 116.88 1.56 <LOD 1.68 2.53 U
PFTrDA 72629-94-8 9.90 0.132 <LOD 1.26 2.53 U
PFTeDA 376-06-7 ND ND <LOD 1.82 2.53 U
PFPeS 2706-91-4 ND ND <LOD 1.72 2.39 U
PFHpS 375-92-8 115.52 1.54 1.54 1.13 2.41 J
PFOS 1763-23-1 293.53 3.91 3.91 1.33 2.35
PFNS 68259-12-1 ND ND <LOD 0.720 2.44 U
Sulfonates
PFDS 335-77-3 102.91 1.37 <LOD 1.60 2.44 U
4:2 FTS 757124-72-4 205.41 2.74 2.74 0.983 2.37
6:2 FTS 27619-97-2 2000.95 26.7 26.7 0.967 2.41
8:2 FTS 39108-34-4 0.28 0.00372 <LOD 1.43 2.43 U
PFOSA 754-91-6 ND ND <LOD 1.08 2.53 U
N-McFOSAA 2355-31-9 171.91 2.29 2.29 1.20 2.53 J
N-EtFOSAA 2991-50-6 94.72 1.26 1.26 0.908 2.53 J
HFPO-DA 13252-13-6 ND ND <LOD 1.90 2.53 U
PFMOPrA 377-73-1 NO ND <LOD 2.00 2.53 U
ADONA 919005-14-4 12.31 0.164 <LOD 1.00 2.40 U
9CI-PF3ONS 756426-58-1 3.25 0.0434 <LOD 1.00 2.36 U
11CI-PF3OUdS 763051-92-9 77.98 1.04 1.04 1.00 2.39 J
3:3 FTCA 356-02-5 12101.83 161 161 147 147
Other 5:3 FTCA 914637-49-3 27178.97 362 362 17.3 17.3
7:3 FTCA 812-70-4 459.81 6.13 <LOD 18.7 18.7 U
N-EtFOSA 4151-50-2 ND ND <LOD 2.00 2.53 U
N-EtFOSE 1691-99-2 ND ND <LOD 60.0 60.0 U
NFDHA 151772-58-6 ND ND <LOD 2.00 2.53 U
N-McFOSA 31506-32-8 ND NO <LOD 2.00 2.53 U
N-McFOSE 24448-09-7 ND ND <LOD 60.0 60.0 U
PFDoS 7978039-5 ND ND <LOD 18.7 18.7 U
PFEESA 113507-82-7 ND ND <LOD 2.00 2.53 U
PFMOBA 863090-89-5 ND ND <LOD 12.0 12.0 U
MPFBA 2836.38 37.8 20-150% 56.7%
MSPFPeA 4180.35 55.7 20-150% 83.6%
M2-4:2 FTS 9610.23 128 20-150% 192.2%Q
MSPFHxA 3185.19 42.5 20-150% 63.7%
M3HFPO-DA 4138.18 55.2 20-150% 82.8%
M2-6:2 FTS 4580.93 61.1 20-150% 91.6%
MBPFOA 3562.20 47.5 20-150% 71.2%
M9PFNA 2747.82 36.6 20-150% 55.0%
ES
MBPFOS 3680.40 49.1 20-150% 73.6%
M2-8:2 FTS 12481.02 166 20-150% 249.6%Q
MBFOSA-I 2836.28 37.8 20-150% 56.7%
d3-N-McFOSAA 3206.71 42.8 20-150% 64.1%
d5-N-EtFOSAA 3098.37 41.3 20-150% 62.0%
M7PFUdA 4243.63 56.6 20-150% 84.9%
MPFDoA 4070.01 54.3 20-150% 81.4%
M2PFTeDA 2727.65 36.4 20-150% 54.6%
EU#1221-747 Page 6 of 25

Enthalpy Analytical
Job No.:1221-747-1 PFAS by Isotope Dilution(non-potable water)Draft 1633
Town of Wilkesboro WWTP Client Proj.:Landfill Leachates Site:On Site WWTP
Enthalpy ID 1221-747-001-3 Prep Batch EU12863 Sample Vol(mL) 30
Sample Name Ashe County Leachate Prep Date 2022-01-18 13:43 Extract Vol(mL) 0.4
Matrix Aqueous Analysis Date 2022-01-20 03:00 Dilution Factor 1
Sampling Date 20211116 00:00 Analyst rappelle Method Code WM-026
Received Date 2021-12-10 13:41 Instrument Fill Sample Type Sample
Extract Sample Formatted LOD LOQ Recovery
Compound CAS Concentration Concentration Result Recovery Flags
ng/L ng/L ng/L ng/L ng/L Limits
Acids PFHpA 375-85-9 8778.78 117 117 1.02 2.53
PFDA 335-76-2 25.17 0.336 <LOD 0.704 2.53 U
PFBS 375-73-5 2526.60 33.7 33.7 2.96 2.96
Sulfonates
PFHxS 355-46-4 2997.89 40.0 40.0 1.59 2.32
M3PFBS 14092.96 188 20-150% 281.9% Q
ES M4PFHpA 4365.09 58.2 20-150% 87.3%
M3PFHxS 4845.78 64.6 20-150% 96.9%
M6PFDA 4817.59 64.2 20-150% 96.4%
EU#1221-747 Page 7 of 25

Enthalpy Analytical
Job No.:1221-747-1 PFAS by Isotope Dilution(non-potable water)Draft 1633
Town of Wilkesboro WWTP Client Proj.:Landfill Leachates Site:On Site WWTP
Enthalpy ID 1221-747-002-2 Prep Batch EU12729 Sample Vol(mL) 30
Sample Name Wilkes County Leachate Prep Date 2021-12-15 14:36 Extract Vol(mL) 0.4
Matrix Aqueous Analysis Date 2021-12-18 03:20 Dilution Factor 1
Sampling Date 20211116 00:00 Analyst rappelle Method Code WM-026
Received Date 2021-12-10 13:41 Instrument Kili Sample Type Sample
Extract Sample Formatted LOD LOQ Recovery
Compound CAS Concentration Concentration Result Recovery Flags
ng/L ng/L ng/L ng/L ng/L Limits
PFBA 375-22-4 33338.01 445 445 1.28 2.53
PFPeA 2706-90-3 31708.36 423 423 1.42 2.53
PFHxA 307-24-4 82983.54 1106 1110 1.61 2.53
PFOA 335-67-1 31366.81 418 418 1.48 2.53
Acids PFNA 375-95-1 1373.22 18.3 18.3 0.634 2.53
PFUnDA 2058-94-8 46.99 0.627 <LOD 1.54 2.53 U
PFDoDA 307-55-1 79.32 1.06 <LOD 1.68 2.53 U
PFTrDA 72629-94-8 67.63 0.902 <LOD 1.26 2.53 U
PFTeDA 376-06-7 ND ND <LOD 1.82 2.53 U
PFPeS 2706-91-4 936.31 12.5 12.5 1.72 2.39
PFHpS 375-92-8 ND ND <LOD 1.13 2.41 U
PFOS 1763-23-1 2707.22 36.1 36.1 1.33 2.35
PFNS 68259-12-1 30.36 0.405 <LOD 0.720 2.44 U
Sulfonates
PFDS 335-77-3 ND ND <LOD 1.60 2.44 U
4:2 FTS 757124-72-4 255.15 3.40 3.40 0.983 2.37
6:2 FTS 27619-97-2 1229.95 16.4 16.4 0.967 2.41
8:2 FTS 39108-34-4 6.28 0.0838 <LOD 1.43 2.43 U
PFOSA 754-91-6 61.26 0.817 <LOD 1.08 2.53 U
N-McFOSAA 2355-31-9 132.38 1.77 1.77 1.20 2.53 J
N-EtFOSAA 2991-50-6 ND ND <LOD 0.908 2.53 U
HFPO-DA 13252-13-6 ND ND <LOD 1.90 2.53 U
PFMOPrA 377-73-1 NO ND <LOD 2.00 2.53 U
ADONA 919005-14-4 ND ND <LOD 1.00 2.40 U
9CI-PF3ONS 75642658-1 5.75 0.0767 <LOD 1.00 2.36 U
11CI-PF3OUdS 763051-92-9 83.05 1.11 1.11 1.00 2.39 J
3:3 FTCA 356-02-5 12717.63 170 170 147 147
Other 5:3 FTCA 914637-49-3 24051.17 321 321 17.3 17.3
7:3 FTCA 812-70-4 380.01 5.07 <LOD 18.7 18.7 U
N-EtFOSA 4151-50-2 ND ND <LOD 2.00 2.53 U
N-EtFOSE 1691-99-2 ND ND <LOD 60.0 60.0 U
NFDHA 151772-58-6 ND ND <LOD 2.00 2.53 U
N-McFOSA 31506-32-8 ND NO <LOD 2.00 2.53 U
N-McFOSE 24448-09-7 ND NO <LOD 60.0 60.0 U
PFDoS 7978039-5 ND ND <LOD 18.7 18.7 U
PFEESA 113507-82-7 ND ND <LOD 2.00 2.53 U
PFMOBA 863090-89-5 ND ND <LOD 12.0 12.0 U
MPFBA 1794.67 23.9 20-150% 35.9%
MSPFPeA 3456.16 46.1 20-150% 69.1%
M2-4:2 FTS 6799.19 90.7 20-150% 136.0%
MSPFHxA 3591.80 47.9 20-150% 71.8%
M3HFPO-DA 4389.74 58.5 20-150% 87.8%
M2-6:2 FTS 3475.13 46.3 20-150% 69.5%
MBPFOA 3822.35 51.0 20-150% 76.4%
M9PFNA 2799.28 37.3 20-150% 56.0%
ES
MBPFOS 3155.37 42.1 20-150% 63.1%
M2-8:2 FTS 12658.88 169 20-150% 253.2%Q
MBFOSA-I 2641.24 35.2 20-150% 52.8%
d3-N-McFOSAA 2446.02 32.6 20-150% 48.9%
d5-N-EtFOSAA 3278.70 43.7 20-150% 65.6%
M7PFUdA 3868.38 51.6 20-150% 77.4%
MPFDoA 3533.42 47.1 20-150% 70.7%
M2PFTeDA 2168.31 28.9 20-150% 43.4%
EU#1221-747 Page 8 of 25

Enthalpy Analytical
Job No.:1221-747-1 PFAS by Isotope Dilution(non-potable water)Draft 1633
Town of Wilkesboro WWTP Client Proj.:Landfill Leachates Site:On Site WWTP
Enthalpy ID 1221-747-002-3 Prep Batch EU12863 Sample Vol(mL) 30
Sample Name Wilkes County Leachate Prep Date 2022-01-18 13:43 Extract Vol(mL) 0.4
Matrix Aqueous Analysis Date 2022-01-20 03:24 Dilution Factor 1
Sampling Date 20211116 00:00 Analyst rappelle Method Code WM-026
Received Date 2021-12-10 13:41 Instrument Fill Sample Type Sample
Extract Sample Formatted LOD LOQ Recovery
Compound CAS Concentration Concentration Result Recovery Flags
ng/L ng/L ng/L ng/L ng/L Limits
Acids PFHpA 375-85-9 10598.82 141 141 1.02 2.53
PFDA 335-76-2 322.83 4.30 4.30 0.704 2.53
PFBS 375-73-5 4633.90 61.8 61.8 2.96 2.96
Sulfonates
PFHxS 355-46-4 12766.27 170 170 1.59 2.32
M3PFBS 12361.14 165 20-150% 247.2% Q
ES M4PFHpA 5420.74 72.3 20-150% 108.4%
M3PFHxS 5214.21 69.5 20-150% 104.3%
M6PFDA 5097.98 68.0 20-150% 102.0%
EU#1221-747 Page 9 of 25

Narrative Summary
� -
ENTHALPY
A ti A L Y f I C A L
EU#1221-747 Page 15 of 25

Enthalpy Analytical Narrative Summary
Company Town of Wilkesboro WWTP
Job No. 1221-747-1 PFAS by Isotope Dilution (non-potable water) Draft 1633
Client ID. Landfill Leachates Site: on site WWTP
1. Custody
Lois Walton received the samples on December 10, 2021 at 1.8 °C after being relinquished by
Town of Wilkesboro WWTP. The samples were received in good condition.
Prior to, during, and after analysis, the samples were kept under lock with access only to
authorized personnel by Enthalpy Analytical, LLC
Table 1 -Sample Inventory
EU Lab Sample ID Client Sample ID Matrix
1221-747-001-2 Ashe County Leachate Aqueous
1221-747-001-3 Ashe County Leachate Aqueous
1221-747-001-1
1221-747-002-2 Wilkes County Leachate Aqueous
1221-747-002-3 Wilkes County Leachate Aqueous
1221-747-002-1
2. Methods and Analytes
A list of analytes of interest and corresponding methods of analysis is shown in Table 3.
Abbreviations are defined in the listed Appendices.
Table 3 - Methods and Analytes
EU Method Analytes Cleanup Method
EU-047 PFAS Draft 1633 ENVI-Carb
3.Analysis
The samples were analyzed using Waters Acquity UPLC equipped with Xevo TQ MS (LC/MS/
MS "Fili" and "Kili").
For aqueous samples, the sample volume was measured gravimetrically by the laboratory, and
spiked with Extraction Standard (ES). The sample was then mixed well and centrifuged, if
needed. The samples were then extracted via SPE, and the extracts were cleaned up using
ENVI-Carb.
Each final sample extract was transferred to an autosampler vial, spiked with Injection Standard
(IS), and brought to a final volume of 400pL prior to analysis.
Samples were initially screened by direct inject by using a 120 uL aliquot fortified with ES and IS,
then analyzed to determine extraction volume.
Due to acquisition requirements for analytes requested, the sample was analyzed in more than
one sequence. Supplemental compounds were reported using a single point calibration forced
through zero.
EU#1221-747 Page 16 of 25

Enthalpy Analytical Narrative Summary
Company Town of Wilkesboro WWTP
Job No. 1221-747-1 PFAS by Isotope Dilution (non-potable water) Draft 1633
Client ID. Landfill Leachates Site: on site WWTP
4. Calibration
In the initial calibration, the reported analytes exhibited R A 2 of> 0.99. The reported analytes in
the calibration standards, continuing calibration (concal) and Initial Calibration Verification (ICV)
met the 30% accuracy criterion for native analytes.
5. QC Notes
Except where noted below, the QC sample analyses passed all method criteria.
QC samples that did not meet method acceptance criteria were:
OPR-12729-PFAS PFNS and PFTrDA fell above method critieria. These analytes were not
detected in the samples; therefore, the data is reported with no adverse impact.
OPR-12729-PFAS PFHpA, PFHxS, PFDA, and PFBS fell above method criteria in initial analysis
and confirmed upon reinjection. Samples were re-extracted and reported for these analytes.
The samples were extracted outside the 28-day from collection holding time and client has been
made aware and approved reporting as-is. The samples were analyzed within the 28-day from
extraction to analysis holding time required by the method.
6. Reporting Notes
Some labeled extraction standards in the sample analyses fell outside the control limits for ES
recovery, as denoted by the "Q" qualifier. The target analytes are quantified based on their ratio
to their labeled standard analogs.As a result, low or high labeled standard recovery do not
cause any change to ratios or contribute any additional error in the measurement of the target
analytes. The data have been accepted and reported with no further actions.
The results presented in this report are representative of the samples as provided to the
laboratory.
These analyses met the requirements of the TNI Standard.Any deviations from the
requirements of the reference method or TNI Standard have been stated above.
Enthalpy Analytical, LLC in Wilmington NC is accredited by the Louisiana Department of
Environmental Quality to the 2009 TNI Standard under certificate number 05075.
EU#1221-747 Page 17 of 25

.0
hwkood�l General Reporting Notes — Data Qualifiers
ENTHALPY
ANALYTICAL
The following are general reporting notes that are applicable to all Enthalpy Analytical,LLC -
Wilmington,NC data reports,unless specifically noted otherwise.
General Data Qualifiers
• B—The analyte was found in the method blank,at a concentration that was at least 10% of the
amount in the sample.
• Cxx—Two or more congeners co-elute. In EDDs, C denotes the lowest IUPAC congener in a co-
elution group and additional co-eluters for the group(`xx')are shown with the number of the
lowest IUPAC co-eluter.
• E—The reported concentration exceeds the calibration range(upper point of the calibration
curve). For FIRMS data,this condition does not imply additional measurement uncertainty. For
LC-MS/MS data,these values should be considered as having measurement uncertainty higher
than values within the calibration range.
• EDL—Estimated Detection Level: The EDL is unique to isotope dilution methods and reflects
the conditions of analysis at the time of analysis, including the equipment used. Where the MDL
is a static value,the EDL is a dynamic value.
• EMPC—Estimated Maximum Possible Concentration: EMPC is specific to Dioxin/Furan tests to
indicate the determined ion-abundance ratio was outside the allowed theoretical range(usually
due to being near the detection limit, although it can very rarely be caused by a co-eluting
interference). The EMPC concentration is adjusted to reflect the value at the theoretical ion-
abundance ratio.
• IR—The ion ratio between the primary and secondary ions was observed to be outside the
method criteria. The analyte concentration may be inaccurate due to interference.
• J—The analyte has a concentration below the minimum calibration level(LOQ value)but greater
than the LOD. These values should be considered as having measurement uncertainty higher than
values within the calibration range
• L-Indicates that an analyte has a concentration below the Minimum Detection Limit(MDL).
The reported concentration is not recommended for regulatory use as the analyte signal may have
a signal-to-noise ratio less than the criteria deemed necessary to be considered a detected analyte.
• LOD—Limit of Detection: For reports conforming to the DOD ELAP QSM,this is the QSM-
defined LOD. For reports conforming to TNI requirements(but not DOD ELAP QSM
requirements),this value is the minimum detection limit(MDL). The LOD is adjusted for sample
weight or volume.
• LOQ—Limit of Quantitation: For reports conforming to the DOD ELAP QSM,this is the QSM-
defined LOQ. For reports conforming to TNI requirements(but not DOD ELAP QSM
requirements),this value is the reporting limit(RL). The LOQ is adjusted for sample weight or
volume.
EU116 v6(General Reporting Notes-Data Qualifiers) Enthalpy Analytical,LLC—Wilmington,NC
EU#1221-747 Page 18 of 25

.0
hwkood�l General Reporting Notes — Data Qualifiers
ENTHALPY
ANALYTICAL
• <LODQ—Analyte was not found at a concentration high enough to be reported as detected. It is
reported as less than the LOD, and the LOD is given in the parentheses.
• <LOQQ—Analyte was not found at a concentration high enough to be reported as above the
QSM-defined LOQ or TNI defined Reporting Limit. It is reported as less than the LOQ, and the
LOQ is given in the parentheses.
• ND—Indicates a non-detect.
• NR—Indicates a value that is not reportable due to issues observed in sample preparation or
analysis.
• PR—The associated congener(s)is(are)poorly resolved.
• QI—Indicates the presence of a quantitative interference.
• RL—Reporting Limit.Lowest reportable value. The level is higher than the MDL.
• SI—Denotes"Single Ion Mode"and is utilized for PCBs where the secondary ion trace has a
significantly elevated noise level due to background PFK. Responses for such peaks are
calculated using an EMPC approach based solely on the primary ion area(s)and may be
considered estimates.
• U—The analyte was not detected.
• V/Q—The labeled standard recovery is not within method control limits.
• X—Indicates the result is from re-injection/repeat/second-column analysis.
Lab Identifiers/Data Attributes
• AR—Indicates use of the archived portion of the sample extract.
• CU—Indicates a sample that required additional clean-up prior to HRMS injection/processing.
• D—Dilution Data. Result was obtained from the analysis of a dilution. The number that follows
the"D"indicates the dilution factor.
• DE—Indicates a dilution performed with the addition of ES(Extraction Standard) solution.
• DUP—Designation for a duplicate sample.
• MS—Designation for a matrix spike.
• MSD—Designation for a matrix spike duplicate.
• R—Indicates a re-extraction of the sample.
• RJ—Indicates a reinjection of the sample extract.
EU116 v6(General Reporting Notes-Data Qualifiers) Enthalpy Analytical,LLC—Wilmington,NC
EU#1221-747 Page 19 of 25

.0
hwkood�l General Reporting Notes — Data Qualifiers
ENTHALPY
ANALYTICAL
• S—Indicates a sample split. The number that follows the"S"indicates the split factor.
• SAT—Indicates an analyte saturated the detector.
EU116 v6(General Reporting Notes-Data Qualifiers) Enthalpy Analytical,LLC—Wilmington,NC
EU#1221-747 Page 20 of 25

HAS Compound Acronym List
Acronym CAS# Compound Name
s
*Analyte is not accredited
PFBA 375-22-4 Perfluorobutanoic Acid
PFPeA 2706-90-3 Perfluoropentanoic Acid
PFHxA 307-24-4 Perfluorohexanoic Acid
PFHpA 375-85-9 Perfluoroheptanoic Acid
PFOA 335-67-1 Perfluorooctanoic Acid
PFNA 375-95-1 Perfluorononanoic Acid
PFDA 335-76-2 Perfluorodecanoic acid
PFUnA(PFUnDA) 2058-94-8 Perfluoroundecanoic acid
PFDoA(PFDoDA) 307-55-1 Perfluorododecanoic acid
PFTrDA(PFTriA) 72629-94-8 Perfluorotridecanoic acid
PFTeDA(PFTA) 376-06-7 Perfluorotetradecanoic acid
PFBS 375-73-5 Perfluorobutane sulfonic acid
PFPeS 2706-91-4 Perfluoropentane sulfonic acid
PFHxS 355-46-4 Perfluorohexane sulfonic acid
PFHpS 375-92-8 Perfluoroheptane sulfonic acid
PFOS 1763-23-1 Perfluorooctane sulfonic acid
PFNS 68259-12-1 Perfluorononane sulfonic acid
PFDS 335-77-3 Perfluorodecane sulfonic acid
4:2 FTS 757124-72-4 4:2 fluorotelomer sulfonic acid
6:2 FTS 27619-97-2 6:2 fluorotelomer sulfonic acid
8:2 FTS 39108-34-4 8:2 fluorotelomer sulfonic acid
PFOSA(FOSA) 754-91-6 Perfluorooctane sulfonamide
N-McFOSAA 2355-31-9 N-methyl perfluorooctane sulfonamido acetic acid
N-EtFOSAA 2991-50-6 N-ethyl perfluorooctane sulfonamido acetic acid
HFPO-DA 13252-13-6 2,3,3,3-Tetrafluoro-2-(1,1,2,2,3,3,3-heptafluoropropoxy)-propanoic acid(Gen-X)
11CI-PF3OUdS 763051-92-9 11-chloroeicosafluoro-3-oxaundecane-l-sulfonic acid
9CI-PF30NS 756426-58-1 9-chlorohexadecafluoro-3-oxanonane-l-sulfonic acid
ADONA 919005-14-4 4,8-dioxa-3H-perfluorononanoic acid
* PFMOAA 674-13-5 Perfluoro-2-methoxyacetic acid
PFMOPrA(PFMPA) 377-73-1 Perfluoro-3-methoxypropanoic acid
* PF02HxA 39492-88-1 Perfluoro(3,5-dioxahexanoic)acid
* PF030A 39492-89-2 Perfluoro(3,5,7-trioxaoctanoic)acid
* PF04DA 39492-90-5 Perfluoro(3,5,7,9-tetraoxadecanoic)acid
* PF05DA 39492-91-6 Perfluoro(3,5,7,9,11-pentaoxadodecanoic)acid
* Nafion Byproduct 1 29311-67-9 Nafion Byproduct 1
* Nafion Byproduct 2 749836-20-2 Nafion Byproduct 2
PFEESA 113507-82-7 Perfluoro(2-ethoxyethane)sulphonic acid
PFMOBA(PFMBA) 863090-89-5 Perfluoro-4-methoxybutanic acid
NFDHA 151772-58-6 Nonafluoro-3,6-dioxaheptanoic acid
* PEPA 267239-61-2 Perfluoro-2-ethoxypropanoic acid
* PMPA 13140-29-9 Perfluoro-2-methoxypropanoic acid
* 10:2 FTS 120226-60-0 Fluorotelomer sulfonate 10:2
* N-EtFOSA 4151-50-2 N-ethylperfluoro-l-octanesulfonamide
* N-EtFOSE 1691-99-2 2-(N-m ethyl perfluoro-l-octanesuIfonamido)-ethanol
* N-McFOSA 31506-32-8 N-methylperfluoro-l-octanesulfonamide
* N-McFOSE 24448-09-7 2-(N-methylperfluoro-l-octanesulfonamido)-ethanol
* PFECA-G 801212-59-9 4-(Heptafluoroisopropoxy)hexafluorobutanoic acid
* PFHxDA 67905-19-5 Perfluorohexadecanoic acid
* R-PSDA 2416366-18-0 Perfluoro-4-(2-sulfoethoxy)pentanoic acid
r
�0
ENTHALVY
EU#1221-747 Page 21 of 25

HAS Compound Acronym List
Acronym CAS# Compound Name
*Analyte is not accredited
* Hydrolyzed PSDA 2416366-19-1 2-fluoro-2-[1,1,2,3,3,3-hexafluoro-2-(1,1,2,2-tetrafluoro-2-sulfoethoxy)propoxy]-acetic acid
1,1,2,2-tetrafluoro-2-[1,2,2,3,3-pentafIuoro-1-(trifIuorom ethyl)pro poxy]ethanesulfonic
* R-PSDCA 2416366-21-5 acid
2,2,3,3-tetrafluoro-3-({1,1,1,2,3,3-hexafI uoro-3-[(1,2,2-trifIuoroethenyl)oxy]pro pan-2-
* EVE Acid 69087-46-3 yl)oxy)propionic acid
* FBSA 30334-69-1 Perfluorobutylsulfonamide
2,2,3,3-TetrafI uoro-3-{[1,1,1,2,3,3-hexafluoro-3-(1,2,2,2-tetrafI uoroethoxy)pro pa n-2-
* Hydro-EVE Acid 773804-62-9 yl]oxy)propanoic acid
* R-EVE Acid 2416366-22-6 4-(2-carboxy-1,1,2,2-tetrafluoroethoxy)-2,2,3,3,4,5,5,5-octafluoro-pentanoic acid
* NVHOS 1132933-86-8 Perfluoroethoxysulfonic acid
* PFDoS 79780-39-5 Perfluorododecane sulfonic acid
* PFODA 16517-11-6 Perfluorooctadecanoic acid
r
�0
ENTHALPY
EU#1221-747 Page 22 of 25

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Kimberly Green Report Date: 11/23/2021
Client: Town of Wilkesboro NPDES#: NCO023868
PO Box 1056
Wilkesboro, NC 28697 Date Sample Rcvd: 11/17/2021
Meritech Work Order# 111721122 Sample: Ashe Co.Leachate Grab 11/16/21
Parameters Results Analysis Date Reporting Limit Method
1,4 Dioxane+Trip Blank Attached 11/20/21 - EPA 624.1
Meritech Work Order# 111721123 Sample: Wilkes Co. Leachate Grab 11/16/21
Parameters Results Analysis Date Reporting Limit Method
1,4 Dioxane+Trip Blank Attached 11/20/21 - EPA 624.1
1 hereby certify that I have reviewed and approve these data. A cwu
Laboratory Representative
642 Tamco Road,Reidsville,North Carolina 27320
tel.[phone] fax.[phone]

MERITECH, INC.
_ Environmental Laboratories
7� Laboratory Certification#165
Client: Town of Wilkesboro Meritech ID#: 111721122
Project: 1,4-Dioxane Analysis: 11/20/2021
Client Sample ID: Ashe Co Lechate Analyst: VWV
Sample Collection: 11/16/2021 Dilution Factor: 10
Report Date: 11/22/2021
EPA 624.1 VOLATILE ORGANICS
Parameter Result
1,4-Dioxane(p-Dioxane) <10.0 ug/L
Trip Blank < 1.00 ug/L
Batch Blank =Below Reporting Limit (Yes)/No
Internal Standards method criteria acceptable (Yes)/No
Surrogate Recoveries Spike Conc Spike Recovery Limits
Toluene-d8 30 ug/L 87% 67-151%
Bromofluorobenzene 30 ug/L 88% 45-161%
*-If "no" is selected, see second page for details.
I hereby certify that I have reviewed and approve these data. �- or 1 9,�!
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]

MERITECH, INC.
Environmental Laboratories
Laboratory Certification#165
Client: Town of Wilkesboro Meritech ID#: 111721 123
Project: 1,4-Dioxane Analysis: 11/20/2021
Client Sample ID: Wilkes Co Lechate Analyst: VWV
Sample Collection: 1 1/16/2021 Dilution Factor: 10
Report Date: 1 1/22/2021
EPA 624.1 VOLATILE ORGANICS
Parameter Result
1,4-Dioxane(p-Dioxane) <10.0 ug/L
Trip Blank < 1.00 ug/L
Batch Blank =Below Reporting Limit (Yes)/No
Internal Standards method criteria acceptable (Yes)/No
Surrogate Recoveries Spike Conc Spike Recovery Limits
Toluene-d8 30 ug/L 89% 67-151%
Bromofluorobenzene 30 ug/L 94% 45-161%
*-If "no" is selected, see second page for details.
I hereby certify that I have reviewed and approve these data.
Laboratory Representative
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]

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T
Tyson
Tyson Farms, Inc. of Wilkesboro (Tyson) and the Town of Wilkesboro (Town) have enjoyed a
mutually beneficial relationship that extends back the better part of seven decades, and Tyson
looks forward to extending that relationship into the future. Tyson is one of the largest poultry
production complexes within the Tyson Foods network, with a total production rate of
approximately 507,291,057 pounds per year. Tyson is also the largest employer in Wilkes
County, employing more than 2,620 team members.
The Tyson Wilkesboro Complex is a network of facilities that includes the processing plant,
which is capable of processing 2,000,000 birds per week, and a Food Service Plant, which
produces primarily fully cooked products for restaurant and institutional customers. Along with
these two facilities, the Fresh Plant produces a variety of products ranging from chill pack and
club stores to distribution to the fast-food industry in a 330,000 sq.ft. processing facility. With
many processes within our organization, water is a vital part of our process to ensure that we
meet the United States Department of Agriculture (USDA) standards.
Presently, some of the above facilities are operating below their capable production rate, and it is
a goal of Tyson to fully utilize the investments made at the Wilkesboro Complex. In conjunction
with the planned expansion and upgrade of the Wilkesboro Cub Creek WWTP, we are
requesting an increase in our existing Industrial User Permitted flow of 0.5 MGD, which would
bring our total permitted weekly average flow to 3.5 MGD. This increase will provide Tyson
with greater flexibility in meeting future production goals for the Wilkesboro Complex for the
next 15-year period.
We appreciate your consideration of this request. For reference, Part 1 Section F (General
Conditions) of our existing permit is attached. If you have any questions or require any
additional information, please contact me at (336)-651-3836.
��.eurrL
James Brown
Tyson Foods Inc.
Complex Environmental Manager
704 Factory Street.
Wilkesboro,NC 28697
C: [phone]
O: [phone]
j ames.s.brown&tyson.com
Tyson Foods,Inc. Fresh Retail Division 704 Factory Wilkesboro,N.C.28697
336-651-3836 336.838.2171 Fax:33.651.386'7 www.tysonfoods.com

( T-f.).
Tyson
Industrial User Pretreatment Permit(IUP)
PART II
General Conditions
IUP Part 1 Section F ReceivingPOTWname—> Cub CreekWWTP iUname—> Tyson
Receiving POTW NPDES Al—> NCO021717 ]UP#—> 1003
Effluent Limits and Monitoring Requirements Effective date for these Limits—> 1 0/3 12 0 1 9 Pipe#—> 1
Expiration date for these Limits—> 10/302024 40 CFR#—> N/A
The Permittee may discharge from this specific ifnot applicable put NIA
Pipe number according to these specific dates, THE LIMITS ON THIS PAGE ARE,(Check one below):
effluent limits,and monitoring requirements LIMITS for ENTTRE per
period—> d
INTERIM Limits for period#I —>
INTERIM Limits for period#2—>
FINAL Limits Page—>
Concentration Limits Mass Limits Monitorin requency
n
Sample Required
Sun—Sat Collection Laboratory
Weekly Monthly Monthly Method Detection
Daily Max Average Average Units Daily Max Average Units By Industry B POTW Core Level
Flow 3.0 MGD MGD Continuously Continuously
Max
2 BOD 6255 Lbs Daily C 2 M
3 TSS 6255 Lbs Daily C 2 Mg/I
4 Temperature 65.5 C Daily G
5 PH 6.50-9.00 SU Daily G
OTHER PARAMETERS;Please List Alphabetic l
6 Ammonia 25 Mg/I 1 time per week C .1 Mg/I
7 Oil&Grease 30 MgA I time per month 1 per 6 months G 5 Mg/I
8 Mercury .0002 MgA I every 60 days I per 6 months C .0001 Mg/I
9 Cadmium—Cd .015 M /1 1 per 6 months I per 6 months C .0005 Mg/I
10 Chromium—Cr .I Mg/1 1 per 6 months I per 6 months C .0005 Mg/1
I I Copper—Cu .25 Mg/1 I per 6 months I per 6 months C .0005 Mg/I
12 Nickel—Ni .I MgA 1 per 6 months I per 6 months C .0010 Mg/1
13 Cyanide—Cn .011 M I I per 6 months 1 per 6 months I G .0005 Mg/I
14 Zinc—Zn .5 M 1 per 6 months I per 6 months C .0010 Mg/I
15 Lead-Pb 1 M 1 per 6 months 1 per 6 months C .0010 Mg/I
16 Arsenic-As N/A I er 6 months I per 6 months C
5
Tyson Foods,Inc. Fresh Retail Division 704 Factory Wilkesboro,N.C.28697
336-651-3836 336.838.2171 Fax:83.651.386'7 www.tysonfoods.com

December 14, 2022
Addendum #1
The Town of Wilkesboro Treatment Plant Expansion
Engineering Alternatives Analysis (EAA)
Dear Mr. Nick Coco:
HDR, in response to your November 9, 2022, email, has written the attached addendum to the
Town of Wilkesboro Engineering Alternatives Analysis (EAA) originally dated January 20, 2022.
HDR was asked to provide an estimate of the land application equipment costs as well as
provide the final cost of the land acreage and equipment to demonstrate why the land
application alternative was not the most economically feasible option.
For additional questions, please contact me at [phone].
Wes Bramlett, PE
Project Manager
HDR Engineering, Inc. of the Carolinas
hdrinc.com
100 North Main Street,Suite 1500,Winston-Salem,NC 27101-4015
[phone]

Addendum #1 Further Support of Land Application Costs
Land application of wastewater is regulated pursuant to 02T .0500 by the Nondischarge Unit in
the NC Department of Water Resources (DWR).
A cursory evaluation of the land costs to implement a nondischarge land application system was
prepared based on existing nondischarge facilities (see Table A.1). The closest substantial
facility to Wilkesboro that land applies to similar soils in the project area is the Weyerhaeuser
facility in Surry County. The Weyerhaeuser land application rates and ratio of usable to
unusable area was used to determine the amount of overall land needed to be purchased by
Wilkesboro for a land application alternative. Weyerhaeuser loading rates associated with older
fields that may have been damaged by past land management practices (those listed as 20
in/yr) were not considered in estimating a loading rate for Wilkesboro. A loading rate of 31.8
in/yr was used for Wilkesboro based on Fields A, B, CN, and CS.
Table A.1 Weyerhaeuser Land Application Loading Rates
Loading
Rate
Field Soil (in/yr)
1 Braddock-Fairview Complex 20
2 Braddock-Fairview Complex 20
3 Braddock-Fairview Complex 20
4 Braddock-Fairview Complex 20
5 Braddock-Fairview Complex 20
6 Braddock-Fairview Complex 20
7 Braddock-Fairview Complex 20
8 Braddock-Fairview Complex 20
A Braddock-Fairview Complex 31.8
B Braddock-Fairview Complex 31.8
CN Braddock-Fairview Complex 31.8
CS Braddock-Fairview Complex 31.8
These are also consistent with other, smaller land application systems in the piedmont of North
Carolina. Attached are land application sites and limits from permits for Wayne Farms, LLC
(WQ0009826), Venture Properties, LLC (WQ0029195), and Kotis Properties, Inc.
(WQ0013808), which are all smaller facilities. All the soils for these permits are soils from the
piedmont/ upper piedmont. Loading rates in these permits vary between 12 to 52 inches per
year. While a few fields are rated higher in these permits than 31.8 inches per year, many are
also permitted for a lower rate. For a general evaluation of this alternative, a loading of
approximately 30 inches per year seems reasonable.
The only known municipal land application system in North Carolina that is of similar size is the
City of Jacksonville which is permitted for 9 mgd. This system has much higher loading rates
(average rate is slightly over 50 inches per year) than is possible for Wilkesboro due to soil
characteristics in the respective areas. Jacksonville has 2,331.67 of active spray area (total land
including buffers and unusable land would be much higher).
2

To determine the needed acreage Wilkesboro would need to purchase to obtain an effective
irrigatable 3,800 acres, a polygon was created around the spray fields associated with the
Weyerhaeuser permit. Even though this probably does not reflect the nature of putting together
thousands of acres across multiple parcels of land, it provides the necessary multiplier for
screening purposes to see if further analysis is needed. That is, it is likely Wilkesboro would
require multiple sites that would increase unusable areas versus the single site at
Weyerhaeuser. The polygon around the Weyerhaeuser site is approximately 70 acres. Given
the loading rates and accounting for unusable acreage, it is estimated Wilkesboro would need
more than 10,700 acres. A sample of land costs for larger parcels in Wilkes County was
approximately $6,200 per acre. This likely under values land as there are not many large
parcels near Wilkesboro and the town would need to buy smaller parcels with structures that
would dictate a higher price. Nonetheless, this would put the entire land application costs of the
entire 8 mgd facility to approximately $147 million (see Table A.2).
The cost estimate prepared for this analysis considers:
• treatment plant upgrade costs
• wet weather storage
• pumping to the land application sites
• irrigation equipment.
Table A.2 Budgetary cost estimate of land wastewater treatment storage facilities and land application of
treated effluent for the Wilkesboro WWTP.
Cost item Quantity Unit Unit Price Total Cost
WWTP
Refurbished Aeration Basin
(Replace 7 Aerators and
Controls) 7 EA $80,000.00 $ 560,000
Refurbish Clarifiers 1 &2 2 $175,000.00 $ 350,000
Upgrade Existing UV
Disinfection 1 $1,350,000.00 $ 1,350,000
Pump Station at Existing
WWTP 1 LS $6,000,000.00 $ 6,000,000
Firm Pumping Capacity 14,000 gpm
No. of Pumps 4
HDPE Force Main from WWTP
to Land Application Site 28,000 feet $180.00 $ 5,040,000
FM Diameter 30 inch
PS Elevation 950 feet
Highest Pt. Elevation 1,190 feet
Field elevation 1,100 feet
45 Day Wet Weather Storage
Lagoon (gal) 360,000,000 gallons $0.15 $ 54,000,000
Land Costs (total including
buffers/unusable) $ 59,792,138
3

Cost item Quantity Unit Unit Price Total Cost
Irrigation Pump Station 1 LS $15,000,000.00 $ 15,000,000
•Firm Pumping Capacity 25,000 gpm
•No. of Pumps 6
•Generator
Irrigation Piping & Sprinkler
Heads
1" Sprinkler Heads 16,910 EA $125.00 $ 2,113,750
1-inch Sprinkler Riser Pipe
(Galv). 101,500 LF $9.00 $ 913,500
1-inch HDPE Pipe 94,700 LF $7.00 $ 662,900
3-inch HDPE Pipe 20,300 LF $18.00 $ 365,400
4-inch HDPE Pipe 30,450 LF $20.00 $ 609,000
Allowance for Isolation Valves 1.0 LS 30,000.00 $ 30,000
Total capital cost $ 146,786,688
As most of the treatment facilities would still need to be constructed to meet 02T .0505(b) for
effluent limits, the land application alternative would likely be at least double that of a discharge
alternative. Treatment facilities would be needed since the existing facilities have reached the
end of their respective useful life.
4

Attachment 1 : Land Application Permits for Wayne Farms, LLC
(WQ0009826), Venture Properties, LLC (WQ0029195), and Kotis
Properties, Inc. (WQ0013808),
5

�t SrnTE�,
ROY COOPER
Governor
MICHA£L S.REGAN ` _ 12�r
Secretary m
S.DANI£L SMITH NORTH CAROLINA
Director Environmental Quality
March 23, 2020
MATTHEw B.CARTNER-CONTRACTED OPERATOR
VENTURE PROPERTIES III,LLC
154 VAUGHN MILL ROAD
STATESVILLE,NORTH CAROLINA 28625-1441
Subject: Permit No. WQ0029195
Bradford Crossing Shopping
Center WWTF
Wastewater Irrigation System
Iredell County
Dear Mr. Cartner:
In accordance with your permit renewal request received January 6, 2020, we are forwarding
herewith Permit No. WQ0029195 dated March 23, 2020,to Venture Properties III, LLC for the continued
operation of the subject wastewater treatment and irrigation facilities. Please note that this renewed permit
shall become effective on June 1,2020(i.e.,the day after the expiration date of the existing permit).
The following modifications to the subject permit are as follows: Monitoring well MW-3 shall be
replaced with monitoring well MW-4. Please consult with staff at Mooresville Regional Office regarding
the replacement of the well.
This permit shall be effective from June 1, 2020 through January 31, 2026, shall void Permit No.
WQ0029195 issued May 28, 2015, and shall be subject to the conditions and limitations therein. The
Permittee shall submit a renewal application no later than August 4, 2025.
Please pay attention to the monitoring requirements listed Attachments A, B, and C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
The Division has removed the following permit condition since the last permit issuance dated
May 28,2015:
➢ Old Condition VL2. —This condition has been removed because the permit is not voidable.
The following permit conditions are new since the last permit issuance dated May 28,2015:
➢ Condition 1.1. — The Mooresville Regional Office shall approve monitoring well MW-4 as a
replacement well for MW-3 prior to its installation, and the monitoring well shall be installed
within 90 days of the effective date of this permit. The Mooresville Regional Office shall be
notified at least two business days in advance of construction of any monitoring well. The
monitoring well shall be constructed such that the water level in the well is never above or
below the screened portion of the well, and in accordance with 15A NCAC 02C .0108.
EQ
North Carolina Department of Environmental Quality I Division of water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
Nf IHTH(:4:?�"1!.INA '�
o•w •� «ro^��a•itv �� 919,707,9000

Mr.Matthew B. Cartner
March 23,2020
Page 2 of 2
➢ Condition L2. — Within 90 days of completing installation of monitoring well MW-4, the
Permittee shall submit updated copies of a site map with a scale no greater than 1-inch equals
100 feet.
➢ Condition L3. — Within 30 days of construction, a Well Construction Record (Form GW-I)
shall be completed for MW-4 and submitted to the Division.
➢ Condition L4. — Within 60 days of the effective date of this permit, monitoring well MW-3
shall be permanently abandoned. Within 30 days of abandonment, a Well Abandonment
Record(Form GW-30)shall be completed for each well abandoned,and mailed to the Division
➢ Condition II.12.—All setbacks applicable to 15A NCAC 02H.0219 have been added.
➢ Condition III.17. —Metering equipment shall be tested and calibrated annually.
➢ Condition IV.9. —The maintenance log shall now also include the dates of flow measurement
device calibration and irrigation equipment calibration.
➢ Condition IV.10. — Monitoring well MW-4 shall be sampled after construction, and within
three months prior to initiating wastewater irrigation operations. Monitoring well MW-4 shall
be sampled thereafter at the frequencies and for the parameters specified in Attachment C.
➢ Condition IV.12. —For initial sampling of monitoring well MW-4, the Permittee shall submit
a Compliance Monitoring Form(GW-59)and a Well Construction Record Form(GW-1)listing
this permit number and the appropriate monitoring well identification number. Initial
Compliance Monitoring Forms (GW-59) without copies of the Well Construction Record
Forms (GW-1)are deemed incomplete, and may be returned.
➢ Condition VI.10. —This permit shall not be renewed if the Permittee or any affiliation has not
paid the required annual fee.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh,NC 27699-6714. Otherwise,this permit shall be final and binding.
If you need additional information concerning this permit, please contact Poonam Giri at (919)
707-3656 or poonam.giri&ncdenr.gov.
Sincerely,
S. Daniel Smith,Director
Division of Water Resources
cc: Iredell County Health Department(Electronic Copy)
Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143,General Statutes of North Carolina as
amended, and other applicable Laws,Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Venture Properties III, LLC
Iredell County
FOR THE
continued operation of a 4,500 gallon per day(GPD)wastewater treatment and irrigation facility consisting
o£
a 10,000 gallon septic tank; a 4,200 gallon flow equalization basin with two 20 gallon per minute (GPM)
pumps; a 1,500 gallon grease trap to serve Food Lion; two floor flush grease traps (50 pound and 100
pound)with baffles to serve the China One restaurant; a flow splitter box; two Bioclere trickling filters in
series; a trickling filter; an ultraviolet(UV) disinfection unit; a 137,125 gallon synthetically-lined storage
pond;a 2,500 gallon irrigation pump tank;a 2.23 acre drip irrigation area with five zones; and all associated
piping,valves,controls, and appurtenances
to serve the Bradford Crossing Shopping Center WWTF, with no discharge of wastes to surface waters,
pursuant to the application received January 6, 2020, and in conformity with the Division-approved plans
and specifications considered a part of this permit.
This permit shall be effective from June 1, 2020 through January 31, 2026, shall void Permit No.
WQ0029195 issued May 28,2015, and shall be subject to the following conditions and limitations:
I. SCHEDULES
1. The Mooresville Regional Office, telephone number [phone], shall approve monitoring well
MW-4 prior to installation, and the monitoring well shall be installed within 90 days of the effective
date of this permit. The Mooresville Regional Office shall be notified at least two business days in
advance of construction of any monitoring well. The monitoring well shall be constructed such that
the water level in the well is never above or below the screened portion of the well,and in accordance
with 15A NCAC 02C .0108. The general location and Division-approved name for each monitoring
well is on Figure 1. [15A NCAC 02C .0108, 02T.0108(b)(1)(B)]
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2. Within 90 days of completing installation of monitoring well MW-4, the Permittee shall submit two
original copies and one digital copy of a site map with a scale no greater than 1-inch equals 100 feet;
however, special provisions may be granted upon prior approval for large properties. The map shall
include the following information:
a. Legend,north arrow, scale, and legible in black and white.
b. Topographic contour intervals not exceeding 10 feet or 25 percent of total site relief.
c. All habitable residences or places of assembly within 500 feet of the irrigation area.
d. Location of all wells, streams (ephemeral, intermittent, and perennial), springs, lakes, ponds,
ditches, and other surface drainage features within 500 feet of the irrigation area.
e. Location and identification of each monitoring well(identify any background/upgradient wells).
f. Latitude and longitude coordinates of each monitoring wells(decimal degrees to the sixth decimal
degree and in NAD83).
g. Location and identification of major components of the waste disposal system.
h. The perimeter of all irrigation areas with field names(named according to the approved permit)
i. Location and ownership of property boundaries within 500 feet of the irrigation area (including
road/rail right-of-ways and easements).
J. Latitude and longitude of the established horizontal control monument(decimal degrees to the sixth
decimal degree).
k. Elevation of the top of the well casing(i.e.,measuring point)relative to a common datum.
1. Depth of water below the measuring point at the time the measuring point is established.
in. Delineation of the compliance and review boundaries.
n. Distance measurements verifying all setbacks are being met.
o. Stormwater drainage controls.
p. 100-year floodplain.
q. The date the map is prepared and/or revised.
Boundaries and physical features not under purview of other licensed professions shall be provided by
a Professional Surveyor. Control monuments shall be installed in such a manner and made of such
materials that the monument will not be destroyed due to activities taking place on the property. The
map and any supporting documentation shall be sent to the Division of Water Resources, Non-
Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
Discharge.Reportskncdenr.gov. [15A NCAC 02C .0105(f), 02T.0108(b)(1)(B)]
3. Within 30 days of construction, a Well Construction Record (Form GW-I) listing this permit number
and the appropriate monitoring well identification number shall be completed for each well constructed,
and mailed to the Division of Water Resources, Non-Discharge Branch, 1617 Mail Service Center,
Raleigh, NC 27699-1617, or Non-Discharge.Reportskncdenr.gov. A North Carolina Certified Well
Contractor shall construct the monitoring wells according to the North Carolina Well Construction
Standards (15A NCAC 02C .0113) and local county rules. [15A NCAC 02C .0113, 02T
.0108(b)(1)(B)]
4. Within 60 days of the effective date of this permit, monitoring well MW-3 shall be permanently
abandoned. Within 30 days of abandonment, a Well Abandonment Record (Form GW-30) shall be
completed for each well abandoned, and mailed to the Division of Water Resources, Non-Discharge
Branch, 1617 Mail Service Center,Raleigh,NC 27699-1617,or Non-Discharge.Reportskncdenr.gov.
A North Carolina Certified Well Contractor shall abandon the monitoring wells according to the North
Carolina Well Construction Standards (15A NCAC 02C .0113) and local county rules. [15A NCAC
02C .0113, 02T.0 1 08(b)(1)(B)]
5. The Permittee shall request renewal of this permit on Division-approved forms no later than August 4,
2025. [15A NCAC 02T.0105(b), 02T.0109]
WQ0029195 Version 3.0 Shell Version 200201 Page 2 of 10

IL PERFORMANCE STANDARDS
1. The Permittee shall maintain and operate the subject non-discharge facilities so there is no discharge to
surface waters, nor any contravention of groundwater or surface water standards. In the event the
facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper
operation and maintenance, or failure of the irrigation areas to assimilate the effluent, the Permittee
shall take immediate corrective actions, including Division required actions, such as the construction
of additional or replacement wastewater treatment or disposal facilities. [15A NCAC 02T
.0108(b)(1)(A)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02T.0108(b)(1)(A)]
3. Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and
regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1)(A)]
5. Application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T.0108(b)(1)(A)]
6. The Permittee shall connect the irrigation system to a rain or moisture sensor designed to prevent
irrigation during precipitation events or wet conditions. [15A NCAC 02T.0505(x)]
7. Wastewater irrigation fields permitted on or after December 30, 1983 have a compliance boundary that
is either 250 feet from the wastewater irrigation area, or 50 feet within the property boundary,
whichever is closest to the wastewater irrigation area. Any exceedance of groundwater standards at or
beyond the compliance boundary shall require corrective action. Division-approved relocation of the
compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common
ownership and permitted for use as a disposal system shall be treated as a single property with regard
to determination of a compliance boundary. [15A NCAC 02L.0106(d)(2), 02L.0107(b),02T.0105(h),
G.S. 143-215.1(1), G.S. 143-215.1(k)]
8. The review boundary is midway between the compliance boundary and the wastewater irrigation area.
Any exceedance of groundwater standards at or beyond the review boundary shall require preventative
action. [15A NCAC 02L.0106(d)(1), 02L .0108]
9. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary(i.e.,parcel subdivision). [15A NCAC
02L .0107(c)]
10. No wells, excluding Division-approved monitoring wells, shall be constructed within the compliance
boundary except as provided for in 15A NCAC 02L.0107(g). [15A NCAC 02L .0107]
11. Except as provided for in 15A NCAC 02L .0107(g),the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Iredell
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[I5A NCAC 02L .0107(f)]
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12. The facilities herein were permitted per the following setbacks:
a. The irrigation sites were originally permitted October 6,2005. The setbacks for drip irrigation sites
originally permitted or modified from February 1, 1993 to August 31, 2006 are as follows (all
distances in feet):
i. Each private or public water supply source: 100
ii. Surface waters: 100
iii. Groundwater lowering ditches: 25
iv. Surface water diversions(upslope): 10
v. Surface water diversions (downslope): 25
vi. Each well with exception of monitoring wells: 100
vii. Each property line: 50 1
viii.Top of slope of embankments or cuts of two feet or more in vertical height: 15
ix. Each water line: 10
x. Each swimming pool: 100
xi. Public right of way: 50
xii. Nitrification field: 20
xiii.Each building foundation or basement: 15
' Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H.02190)(5)]
b. The storage and treatment units were originally permitted October 6, 2005. The setbacks for
storage and treatment units originally permitted or modified from February 1, 1993 to August 31,
2006 are as follows(all distances in feet):
i. Each private or public water supply source: 100
ii. Surface waters: 50
iii. Each well with exception of monitoring wells: 100
iv. Each property line: 50 1
v. Nitrification field: 20
' Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H.02190)(5)]
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III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the subject facilities as anon-discharge system. [15A NCAC
02T .0500]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational
functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02T
.0507(a)]
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities,the Permittee shall designate and employ a certified
operator in responsible charge(ORC),and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T
.0117]
4. The Permittee shall maintain vegetative cover on the irrigation sites, such that crop health is optimal,
allows even effluent distribution, and allows inspection of the irrigation system. [15A NCAC 02T
.0507(b)]
5. The Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites
listed in Attachment B. [15A NCAC 02T.0507(c)]
6. The Permittee shall not irrigate treated effluent during inclement weather, or when the soil is in a
condition that will cause ponding or runoff. [15A NCAC 02T.0505(x)]
7. Irrigation equipment shall be tested and calibrated once per permit cycle. [15A NCAC 02T.0507(d)]
8. Only treated effluent from the Bradford Crossing Shopping Center WWTF shall be irrigated on the
sites listed in Attachment B. [15A NCAC 02T.0501]
9. The Permittee shall not allow vehicles or heavy machinery on the irrigation area, except during
equipment installation or maintenance activities. [15A NCAC 02T.0507(e)]
10. The Permittee shall prohibit public access to the wastewater treatment,storage, and irrigation facilities.
[15A NCAC 02T.0505(q)]
11. The Permittee shall dispose or utilize generated residuals in a Division-approved manner. [15A NCAC
02T .0508, 02T.I 100].
12. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject
facilities. [15A NCAC 02T.05050)]
13. Freeboard in the 137,125 gallon synthetically-lined storage pond shall not be less than two feet at any
time. [15A NCAC 02T.0505(d)]
14. A gauge to monitor waste levels in the 137,125 gallon synthetically-lined storage pond shall be
provided. This gauge shall have readily visible permanent markings, at inch or tenth of a foot
increments,indicating the following elevations:maximum liquid level at the top of the temporary liquid
storage volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the
lowest point on top of the dam. [15A NCAC 02T.0507(f)]
15. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees,shrubs,and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T.0507(g)]
WQ0029195 Version 3.0 Shell Version 200201 Page 5 of 10

16. Metering equipment shall be tested and calibrated annually. [15A NCAC 02T.0507(d)]
17. A licensed pumper shall pump the grease traps once the solids reach one-third of the capacity of the
tank. The pumped solids shall be disposed pursuant to all applicable Federal, State, and Local
regulations. Documentation of the disposal site and permit number shall be provided with the contract
between the Permittee and the licensed pumper. [15A NCAC 02T.0108(b)(1)(A)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
facility's impact on groundwater and surface water. [15A NCAC 02T.0108(c)]
2. A Division-certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. [15A NCAC 02H.0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR. Facilities with a permitted flow less than 10,000 GPD may estimate their
flow from water usage records provided the water source is metered. [15A NCAC 02T .0105(k), 02T
.0108(c)]
4. The Permittee shall monitor the treated effluent at the frequencies and locations for the parameters
specified in Attachment A. [15A NCAC 02T.0108(c)]
5. The Permittee shall maintain records tracking the amount of effluent irrigated. These records shall
include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly,monthly, and year-to-date hydraulic (inches/acre)loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T.0108(c)]
6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 137,125 gallon synthetically-
lined storage pond shall be measured to the nearest inch or tenth of a foot,and recorded weekly. Weekly
freeboard records shall be maintained for five years, and shall be made available to the Division upon
request. [15A NCAC 02T.0108(c)]
7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.S. and
IV.6.)on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month,monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(1)]
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8. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. This record shall
include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal,or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T.0508(b)]
9. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Date of flow measurement device calibration;
b. Date of irrigation equipment calibration;
c. Visual observations of the plant and plant site; and
d. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings, etc.).
[15A NCAC 02T.0507(h)]
10. Monitoring well MW-4 shall be sampled after construction, and within three months prior to initiating
wastewater irrigation operations. Monitoring well MW-4 shall be sampled thereafter at the frequencies
and for the parameters specified in Attachment C. All mapping, well construction forms, well
abandonment forms, and monitoring data shall refer to the permit number and the well nomenclature
as provided in Attachment C and Figure 1. [15A NCAC 02T.0105(m)]
11. Monitoring wells MW-1 and MW-2 shall be sampled at the frequencies and for the parameters specified
in Attachment C. All mapping,well construction forms,well abandonment forms and monitoring data
shall refer to the permit number and the well nomenclature as provided in Attachment C and Figure 1.
[15A NCAC 02T.0105(m)]
12. For initial sampling of monitoring well MW-4, the Permittee shall submit a Compliance Monitoring
Form (GW-59) and a Well Construction Record Form (GW-1) listing this permit number and the
appropriate monitoring well identification number. Initial Compliance Monitoring Forms (GW-59)
without copies of the Well Construction Record Forms (GW-1) are deemed incomplete, and may be
returned to the Permittee without being processed. [15A NCAC 02T.0105(m)]
13. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form(GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
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14. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for five
years, and shall be made available to the Division upon request. Each Standard Soil Fertility Analysis
shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
[15A NCAC 02T.0108(c)]
15. Noncompliance Notification:
The Permittee shall report to the Mooresville Regional Office, telephone number [phone],
within 24 hours of first knowledge of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate wastewater treatment.
c. Any facility failure resulting in a discharge to surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Mooresville Regional Office within five
days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to
ensure the problem does not recur. [15A NCAC 02T.0108(b)(1)(A)]
V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater
treatment and irrigation facilities. [15A NCAC 02T.0507(i)]
2. The Permittee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions,
facility deterioration, and operator errors that may result in discharges of wastes to the environment,
threats to human health, or public nuisances. The Permittee shall maintain an inspection log that
includes the date and time of inspection, observations made, and maintenance, repairs, or corrective
actions taken. The Permittee shall maintain this inspection log for a period of five years from the date
of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T
.0507(h), 02T.0507(i)]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property,premises,or place related to the wastewater treatment and irrigation facilities permitted herein
at any reasonable time for determining compliance with this permit. Division authorized
representatives may inspect or copy records maintained under the terms and conditions of this permit,
and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]
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VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division-approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit,there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T.0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T.0105(c)(6)]
5. If the permitted facilities change ownership, or the Pennittee changes their name, the Permittee shall
submit a permit modification request on Division-approved forms. The Penmittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor-owner. [G.S. 143-
215.1(d3)]
6. The Penmittee shall retain a set of Division-approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T.0105(o)]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T.01050)]
8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
I. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T.0110]
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9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent,subsidiary,or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent,subsidiary,or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T.0120(b), 02T.0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T.0120(c)]
Permit issued this the 231d day of March 2020
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
S. Daniel Smith,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0029195
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ATTACHMENT A—LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0029195 Version: 3.0
PPI 001—WWTF Effluent
EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
PCs Parameter Description Units of Monthly Monthly Daily Minimum Daily Maximum Measurement Sample
Code Measure Average Geometric Mean Frequency Type
00310 BOD,5-Day(20°C) mg/L 3 x Year i Grab
00940 Chloride(as Cl) mg/L 3 x Year i Grab
31616 Coliform,Fecal MF,M-FC Broth,44.5°C #/100 mL 3 x Year 1 Grab
50050 Flow,in Conduit or thru Treatment Plant GPD 4,500 Monthly Estimated
00610 Nitrogen,Ammonia Total(as N) mg/L 3 x Year 1 Grab
00625 Nitrogen,Kjeldahl,Total(as N) mg/L 3 x Year i Grab
00620 Nitrogen,Nitrate Total(as N) mg/L 3 x Year i Grab
00600 Nitrogen,Total(as N) mg/L 3 x Year 1 Grab
00400 pH su Weekly Grab
00665 Phosphorus,Total(as P) mg/L 3 x Year 1 Grab
70300 Solids,Total Dissolved—180°C mg/L 3 x Year 1 Grab
00530 Solids,Total Suspended mg/L 3 x Year 1 Grab
1. 3 x Year sampling shall be conducted in February,June,and October.
WQ0029195 Version 3.0 Attachment A Page 1 of 1

THIS PAGE BLANK

ATTACHMENT B—APPROVED LAND APPLICATION SITES AND LIIVHTATIONS Permit Number: WQ0029195 Version: 3.0
Venture Properties III,LLC—Bradford Crossing Shopping Center WWTF
IRRIGATION AREA INFORMATION APPLICATION LIMITATIONS
Field Owner County Latitude Longitude Net Dominant Parameter Hourly Yearly Units
Acreage Soil Series Rate Max
1 Venture Properties III,LLC hedell 35.785365' -81.007174' 0.44 Cecil 01284—Non-Discharge Application Rate 0.4 28.6 inches
2 Venture Properties III,LLC Iredell 35.785202' -81.006746' 0.45 Cecil 01284—Non-Discharge Application Rate 0.4 28.6 inches
3 Venture Properties III,LLC Iredell 35.785146' -81.006429' 0.46 Cecil 01284—Non-Discharge Application Rate 0.4 28.6 inches
4 Venture Properties III,LLC Iredell 35.785836' -81.006935' 0.44 Cecil 01284—Non-Discharge Application Rate 0.4 28.6 inches
5 Venture Properties III,LLC hedell 35.786219' -81.007082' 0.44 Cecil 01284—Non-Discharge Application Rate 0.4 28.6 inches
Totals 2.23

THIS PAGE BLANK

ATTACHMENT C— GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0029195 Version: 3.0
Monitoring Wells: NM-1,MW-2, and NM-3
GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes
00680 Carbon,Tot Organic(TOC) mg/L 3 x Year Grab 1,6
00940 Chloride(as Cl) 250 mg/L 3 x Year Grab 1
31616 Coliform,Fecal MF,M-FC Broth,44.5°C #/100 mL 3 x Year Grab 1
00610 Nitrogen,Ammonia Total(as N) 1.5 mg/L 3 x Year Grab 1
00620 Nitrogen,Nitrate Total(as N) 10 mg/L 3 x Year Grab 1
00400 pH 6.5-8.5 su 3 x Year Grab 1,2
00665 Phosphorus,Total(as P) mg/L 3 x Year Grab 1
70300 Solids,Total Dissolved- 180°C 500 mg/L 3 x Year Grab 1
GWVOC Volatile Compounds(GW) Present:Yes/No Annually Grab L4,5
82546 Water Level,Distance from measuring point feet 3 x Year Calculated L2,3
1. 3 x Year monitoring shall be conducted in February,June,and October;Annual monitoring shall be conducted in October.
2. The measurement of water levels shall be made prior to purging the wells.The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points(top of well casing)of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points(top of
casing)of all monitoring wells shall be surveyed relative to a common datum.
4. Volatile Organic Compounds(VOC)-In October only,analyze by one of the following methods:
a. Standard Method 6230D,PQL at 0.5 gg/L or less
b. Standard Method 621 OD,PQL at 0.5 gg/L or less
c. EPA Method 8021,Low Concentration,PQL at 0.5 gg/L or less
d. EPA Method 8260,Low Concentration,PQL at 0.5 gg/L or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used shall meet the following qualifications:
a. A laboratory shall be DWR certified to run any method used.
b. The method used shall include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used shall provide a PQL of 0.5 gg/L or less that shall be supported by laboratory proficiency studies as required by the DWR Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 gg/L shall be qualified(estimated)and reported.
5. If any volatile organic compounds(VOC)are detected as a result of monitoring as provided in Attachment C,then the Mooresville Regional Office supervisor,telephone number(704)663-1699,
shall be contacted immediately for further instructions regarding any additional follow-up analyses required.
6. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well,additional sampling and analysis shall be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
7. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 1 and this attachment.
WQ0029195 Version 3.0 Attachment C Page 1 of 1

a4w�
NORTH CAROLINA:
Ploy COOPER JEhVhVlr ent&1 Quality
COV
MICHAEL S.REGAN
Semlary
UNDA CULPEPPER
August 29,2018
WILUAM KOTIS—PRESIDENT
KOTIS PROPERTIES,INC.
POST OFFICE BOX 9296
GREENSBORO,NORTH CAROLINA 27429-9296
Subject: Permit No. WQ0013808
Summerfield Shopping
Center WWTF
Wastewater Irrigation System
Guilford County
Dear Mr. Kotis:
In accordance with your permit renewal request received January 2, 2018, and subsequent
additional information received June 15,2018,we are forwarding herewith Permit No. WQ0013808 dated
August 29, 2018, to Kotis Properties, Inc. for the continued operation of the subject wastewater treatment
and irrigation facilities.
This permit shall be effective from the date of issuance until July 31, 2023, shall void Permit No.
WQ0013808 issued September 12,2008,and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements Iisted in Attachments A and B for
they may differ from the previous permit issuance. Failure to establish an adequate system for collecting
and maintaining the required operational information shall.result in future compliance problems.
Please note the following permit conditions are new since the last permit issuance dated
September 12,2008:
➢ Condition IV.8. — Requires a record to be maintained for all residuals removed from this
facility.
➢ Condition IV.9.—Requires a maintenance log to be maintained for this facility.
➢ Condition IV.1 Le.—Requires ponding in or runoff from the irrigation site to be reported as a
non-compliance notification.
➢ Condition VI.8.—States that this permit is subject to revocation or unilateral modification upon
60 days notice from the Division Director.
[�rv..a1'A tarrwid few
North Carolina Department of Environmental Quality I Division of Water Resources I Non-Discharge Branch
512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
919.707.3654

Mr. William Kotis
August 29,2018
Page 2 of 2
➢ Condition VI.9. —States that unless the Division Director grants a variance, expansion of the
permitted facilities contained herein shall not be granted if the Permittee exemplifies any of the
criteria in 15A NCAC 02T .0120(b).
➢ Attachment A—Total Nitrogen and Total Phosphorus have been added in PPI 002 for WWTF
Effluent monitoring parameters.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh,NC 27699-6714. Unless such demands are made,this permit shall be final and binding.
If you need additional information concerning this permit, please contact Ashley Kabat at (919)
707-3658 or ashley.kabayamcdenr.g.
Sincerely,
-Linda Culpepper,Interim Director
Division of Water Resources
cc: Guilford County Health Department(Electronic Copy)
Winston-Salem Regional Office,Water Quality Regional Operations Section(Electronic Copy)
Laserfiche File(Electronic Copy)
Digital Permit Archive(Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws,Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
Kotis Properties, Inc.
Guilford County
FOR THE
continued operation of a 3,600 gallon per day(GPD)wastewater treatment and irrigation facility consisting
of:
a 1,500 gallon grease trap; a 3,000 gallon baffled septic tank with an effluent filter; a 5,000 gallon septic
tank;a 9,000 gallon sand filter dosing pump station with two 3 horsepower(hp)pumps;a 2,500 square foot
(ft2) recirculating sand filtration system with a low-pressure pipe (LPP) distribution system; two wetland
cells; a level control/flow splitter box; a tablet chlorinator or ultraviolet (UV) disinfection system; a 360
gallon baffled chlorine contact chamber; a nine-foot diameter wet-well with duplex 70 gallon per minute
(GPM) pumps, and on-site visual/audible high-water alarms; an on-site emergency generator with an
automatic transfer switch; a level control/flow splitter downstream of the southern wetland unit; a 750
gallon wet weather storage pond pump station with 35 gallon per minute(GPM) submersible pumps, and
audible/visual high-water alarms; a 550,000 gallon lined wet-weather storage pond; a precipitation sensor;
three disc filters in series; a 1.40 acre drip irrigation system containing three zones; and all associated
piping,valves,controls and appurtenances
to serve Summerfield Shopping Center WWTF,with no discharge of wastes to surface waters,pursuant to
the application received January 2, 2018, and subsequent additional information received by the Division
of Water Resources, and in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environmental Quality and considered a part of this
permit.
This permit shall be effective from the date of issuance until July 31, 2023, shall void Permit No.
WQ0013808 issued September 12, 2008, and shall be subject to the following specified conditions and
limitations:
WQ0013808 Version 4.0 Shell Version 180711 Page 1 of 8

I. SCHEDULES
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted,will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T.0105(d)requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0105(d), 02T .0106, 02T .0109, 02T .0115(c)]
II. PERFORMANCE STANDARDS
1. The subject non-discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent,the Permittee shall take immediate corrective actions including Division required actions,such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G.S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02B .0200, 02L .0100]
3. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1), 02T .0505(b)]
4. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c), 02T .0505(n)]
5. The irrigation system shall be connected to a rain or moisture sensor,which shall indicate when effluent
application is not appropriate in accordance with Conditions III.4.and III.5.of this permit. [15A NCAC
02T .0108(b)(1)]
6. This disposal system was individually permitted on or after December 30, 1983; therefore, the
compliance boundary is established at either 250 feet from the effluent disposal area, or 50 feet within
the property boundary, whichever is closest to the effluent disposal area. An exceedance of
groundwater standards at or beyond the compliance boundary is subject to remediation action according
to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with North Carolina
General Statute 143-215.6A through 143-215.6C. [15A NCAC 02L .0106(d)(2), 02L .0107(b)]
7. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L .0106. [15A NCAC 02L
.0106, 02L.0108]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
9. In accordance with 15A NCAC 02L.0107(d),no wells,excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L .0107]
WQ0013808 Version 4.0 Shell Version 180711 Page 2 of 8

10. Except as provided for in 15A NCAC 02L .0107(g),the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the
Guilford County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites permitted under 15A NCAC 02H .0200 shall be as follows (all
distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Surface waters: 100
iii. Any well with exception of monitoring wells: 100
iv. Any property line: 50
v. Public right of way: 50
[15A NCAC 02H .02190)]
b. The setbacks for storage and treatment units permitted under 15A NCAC 02H .0200 shall be as
follows(all distances in feet):
i. Any well with exception of monitoring wells: 100
ii. Any property line: 50
[15A NCAC 02H .02190)]
c. The setbacks for storage and treatment units permitted under 15A NCAC 02T .0500 shall be as
follows(all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: 100
v. Any property line: 50
[I 5A NCAC 02T .0506(b)]
WQ0013808 Version 4.0 Shell Version 180711 Page 3 of 8

M. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non-discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge(ORC)and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .0117]
3. A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized,allows for even distribution of effluent and allows inspection of the irrigation system. [15A
NCAC 02T .0108(b)(1)]
4 Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T.0108(b)(1)]
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T.0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from Summerfield Shopping Center WWTF shall be irrigated on the sites listed in
Attachment B. [G.S. 143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T.0108(b)(1)]
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [15A NCAC 02T.0508, 02T .1100]
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T .05050)]
12. Freeboard in the wetland treatment cells and the 550,000 gallon lined wet-weather storage pond shall
not be less than two feet at any time. [15A NCAC 02T .0505(d)]
13. Gauges to monitor waste levels in the wetland treatment cells and the 550,000 gallon lined wet-weather
storage pond shall be provided. These gauges shall have readily visible permanent markings, at inch
or tenth of a foot increments, indicating the following elevations: maximum liquid level at the top of
the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid
storage volume; and the lowest point on top of the dam. [15A NCAC 02T .0108(b)(1)]
WQ0013808 Version 4.0 Shell Version 180711 Page 4 of 8

14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment),berms,pipe runs,erosion control areas,and surface water diversions. Trees,shrubs,and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring(including groundwater,plant tissue,soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through.the treatment facility shall be continuously monitored, and daily average flow values
shall be reported on Form NDMR. Flow may be estimated from water use records, provided the
Permittee's water use is metered. Daily average flow values shall be calculated by dividing the monthly
metered water usage by the number of days in the month. [15A NCAC 02T .0105(k), 02T .0108(c)]
4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum,
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly,and year-to-date hydraulic(inches/acre)loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T.0108(c)]
6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 550,000 gallon lined wet-
weather storage pond shall be measured to the nearest inch or tenth of a foot, and recorded weekly.
Weekly freeboard records shall be maintained at the facility for a period of no less than five years,and
shall be made available to the Division upon request. [15A NCAC 02T .0108(c)]
7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.)on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month,monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(1)]
WQ0013808 Version 4.0 Shell Version 180711 Page 5 of 8

8. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum,this record shall include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal,or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T.0108(b)(1)]
9. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum,this log shall include:
a. Visual observations of the plant and plant site; and
b. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings, etc.).
[15A NCAC 02T .0108(b)(1)]
10. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years,and shall be made available to the Division upon request. At a minimum,the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
[15A NCAC 02T.0108(c)]
11. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office,telephone number(336)
776-9800,as soon as,possible,but in no case more than 24 hours,or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting(e.g., discharges to surface waters, imminent failure of
a storage structure, etc.)outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number(800)662-7956,[phone],or(919)733-3300. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure the problem does not recur. [15A NCAC 02T .0105(1), 02T.0108(b)(1)]
WQ0013808 Version 4.0 Shell Version 180711 Page 6 of 8

V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T .0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment,a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this permit,
and may collect groundwater, surface water or leachate samples. [G.S. 143-21.5.3(a)(2)]
V1. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted,unless specifically requested and approved in this permit pursuant to 15A NCAC 02T.0105(n).
[G.S. 143-21.5.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local,state,and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCGO10000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15A NCAC 02T .0105(c)(6)]
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T .0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T.0108(b)(1)]
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.01050)]
WQ0013808 Version 4.0 Shell Version 180711 Page 7 of 8

8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director,in whole or part for the requirements listed in 15A NCAC 02T.0110. [15A NCAC 02T.0110]
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T .0120]
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 29a`day of August 2018
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Dmda Culpepper,Interim Director
ivision of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0013808
WQ0013808 Version 4.0 Shell Version 180711 Page 8 of 8

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PROPERTY MANAGEMENT AGREEMENT
Date: June 5.2003
Owners: Kotis Summerfield,LLC
P.O. Box 9296
Greensboro,NC 27429-9296
Kotis Summerfield Outparcel, LLC
P.O. Box 9296
Greensboro,NC 27429-9296
Agent: Kotis Properties, Inc.
P.O Box 9296
Greensboro,NC 27429-9296
In consideration of the mutual covenants and promises each to the other. Owners
hereby employ Agent exclusively,and hereby accepts employment to perform certain duties
as set out here in regarding the Property more particularly described below upon the following
terms and conditions:
ARTICLE I. DESCRIPTION
A.The Property: Located in the City of Greensboro, County of Guilford, State
of North Carolina being known and more particularly described as: Summerfield Renaissance
Shopping Center("Property"). (See legal description attached).
ARTICLE 11. PROPERTY MANAGEMENT
A. Agent's Authority: The Owners hereby authorize and empower Agent to perform
such acts and to take such steps as are necessary, in Agent's opinion, to manage
the Property on a day-to-day basis to Owners' advantage including:
1. Collecting all rentals and other charges and amounts due or to become due
under all leases covering the Property and given receipts for the amounts so
collected.
2. Causing to be made any repair the estimated cost of which shall be less than
250.00 which, in Agent's opinion, is necessary to preserve, maintain and
protect the Property
RECEIVED
1 NCDEQ/DWR
1'tap Ml�;me'�i�;r Klil•�!C 3I.11-Jmar 5,2d�1_EP't`
15 JUN 2018
Non-Discharge
Permitting Unit

3. Soliciting not less that two (2)competitive estimates for the cost of a repair
which exceeds the amount set out in A2 above and to present the lowest
responsible bid to Ownersfor Owners' review and authorization to proceed
with the work.
4. Unless so otherwise instructed by Owners, soliciting, on an annual basis,
not less than (2)competitive bids to perform regular preventive
maintenance work on the Property's heating, venting, air conditioning
system(s);janitorial services(if applicable);grounds maintenance(if
applicable);certain window cleaning(if applicable); elevator maintenance
(if applicable); alarm systems (if applicable);and any other services to the
tenants as required by their tenancies.
5. Complying with any duties or obligations imposed upon the Owners by any
Local, State or Federal law or regulation.
B. Anent Covenants_During the duration of this Agreement, Agent agrees:
1. To manage the Property to the best of his ability, devoting thereto such time
and attention as may necessary.
2. To furnish the services of Kotis Properties, Inc,for managing the Property
3. To collect all monthly rentals and other such charges due to Owners upon the
Property.
4. To cause to be made such repairs he deems appropriate in order to preserve and
maintain the Property.
5. To cause to be performed such preventive maintenance as he deems appropriate
in order to preserve and maintain the Property.
6. To cause to be performed such janitorial and groundskeeping activities as he
deems appropriate in order or preserve and maintain the Property.
7. To regularly make an on-site inspection to ensure that the Property remains in
satisfactory operation in an acceptable state of repair and that the interior and
exterior of the Property is clean end presentable to the recants and their
clientele.
8. To answer tenant requests and complaints and to perform the duties imposed
upon Owners by law or pursuant to the tenant leases covering the Property.
2

9. To keep and maintain at all times all necessary books and records relation to the
leasing, management and operation of the project and to prepare and render to
Owners monthly itemized accounts of receipts and disbursements incurred in
connection with its leasing, operating and management on or before the 1 oth
day pf the following month. If specifically requested by Owners,to cause to be
made at the close of the fiscal year upon which the described property shall be
operated, an annual audit report at Owners' expense, all in reasonable detail.
All books,correspondence and date pertaining to the leasing, management and
operation of the Property shall,at all times, be safely kept and preserved. Such
books,correspondence and data shall be available to Owners at all reasonable
times, and shall, upon the termination of this Agreement be delivered to
Owners in their entirety without cost or change therefor.
10.To compute,collect disburse, and reconcile a Common Area Maintenance
(CAM) Account.
11.To disburse such amounts as appropriate to maintain current accounts payable
including, but not limited to,contracted services, utilities, insurance and ad
valorem taxes.
12.To deliver to Owners, on a monthly basis,all net rental proceeds remaining
after disbursing such amounts as authorized under this Agreement/
C. Owners_Covenants:During the duration this Agreement the Owners agree:
1. To provide Agent with architectural drawings and specifications of the
Property, if available,
2. To advance to Agent such addition sums as may be necessary to cover the
costs of repairing the Property and maintaining in a safe, fit and habitable
condition as required by Federal, state and local codes.
3. To advance to Agent such additional sums as may be necessary to over the costs
ofrepaingthe Property but limited to general operating expenses,maintenance
and supply expenses, court costs and attorney fees.
4. To carry comprehensive general public liability and property damage
insurance against any and all claims or demands whatsoever out of,or in any
way connected with, the operation, leasing and maintenance of the Property,
which policies shall be written so as to protect Agent,as an additional insured.
3
Prcp Mlxnu fir.KP[-BG 3211.1 5,MIF Ir

D. Tenant Security Deposits: The Agent, shall require tenants of the Property to make
a security deposit in an amount as permitted by law to secure the tenant's
obligations under leases of the Property(such security deposits shall hereinafter be
referred to as"Tenant Security Deposits").
E. Agent's Fee:
1. Property Management: Owners shall pay to Agent each month during the
existence of this Agreement the following!
3%of gross base rentals
2. Additional duties: The Owners shall pay to Agent during the existence of
this Agreement the following fees for the duties set out below and for any
other duties not so specified in this agreement.
ARTICLE III.LEASING
A. Agent's Authority: Owners here by authorities and empowers Agent to perform
such acts to take such steps as are necessary, in Agent's opinion,to lease the
Property to Owner's advantage including:
1. Advertising the property using brochure, multiple listing or other means as
deemed appropriate by Agent.
2. Displaying real estate advertising signs on the Property if deemed
appropriate by Agent.
3. To become totally familiar with the Property's characteristic which would
include accurate measurements of usable and leasable areas, HVAC
capacity, pluming and electrical systems,zoning, construction methods and
interior finishes.
B. Agent Covenants: During the duration of this Agreement, Agent agrees:
1. To market the Property to the best of his ability devoting thereto such
time and attention as may be necessary.
2. To furnish the services of Kotis Properties,Inc.for marketing the Property.
3. To monitor the local real estate leasing market and to advise Owners of
conditions and trends which might affect or otherwis3e necessitate adjustment to the Property.
4. To conduct background investigation of all prospective tenants and report such
finding to Owners.
4

5. To offer the Property to the public for leasing in compliance with all state,
federal,and local laws, including but not limited to,federal and state law and regulations prohibiting
discrimination on the basis of race,color,religion,sex,familial status,handicap or national origin.
6. To negotiate leases based on parameters established by Owners in order to
arrive at terms and conditions favorable and acceptable to owner.
7. To administer the preparation of the formal lease documents to insure accuracy
and completeness and to present same to Owners and tenant for execution.
C. Owners'Convents: During the duration of this Agreement Owners agree:
1. To provide Agent with available measured drawings and/or architectural
drawings of the Property.
2. To provide Agent with any special terms and/or conditions that would apply to
any executed leases.
3. To refer to Agent any and all inquiries received with respect to or concerning
the Property.
D. A--ent's_Fee:Owners shall pay to Agent 4%of the total rent involving during the entire initial
term of the lease over the term of one year,for leases negotiated after the date of this Agreement.A 2%
override,thereby increasing the total commission to 6%,will be paid if a brokerage firm other that
Agent is involved in the lease transaction.
ARTICLE IV.Agency
A. Duration of Agency:This Agreement and the agency and employment created shall commence
and become effective on June 1,2003 and shall continue 1 year there after or until terminated as
provided herein.
B. Termination of Agency: Either Owner or Agent may terminate the agency and
employment created hereby by giving written notice to his intention to do so 3 days
prior to the desired termination date.Upon any termination of the Agreement by either
Owners or Agent,each shall take such steps as are necessary to settle all accounts
between them including the following: (1)Agent shall properly render to Ownesr all
rents then on hand after having deducted therefrom any Agent's fees then due; (2)
Agent shall render to Owner records showing all tenants who paid security deposits
under leases affecting the property; (3)Agent Shall deliver to Owners all tenant leases
and other related documents; (4)Owners shall, within 10 days after the termination, pay
to Agent any fees or amounts due Agent; and (5)Owners shall promptly notify all
current tenants of the termination of the agency status.
5

IN WITNESS WHEREOF,the parties hereto have set their hands and seals the day and
year first above written:
OWNERS: Kotis Summerfield, LLC
BY: Kotis Properties, Inc., Manager
By: !k
William M.Kotis,III,President
Kotis Summerfield Outparcel, LLC
BY: Kotis Properties, Inc., Manager
By: L�l.
William M.Kotis,III,President
Kotis Properties, Inc
BY. -
William M. Kotis,II1,President
6

Exhibit A
Legal Description
Lots I and 2 on the plat recorded in Plat Book 145, Page 333.
7

�t SrnTE�,
ROY COOPER
Governor
MICHA£L S.REGAN ` _ 12�r
Secretary m
S.DANI£L SMITH NORTH CAROLINA
Director Environmental Quality
September 16,2020
KEVIN MCDANIEL-VICE PRESIDENT
WAYNE FARMS LLC
4110 CONTINENTAL DRIVE
OAKWOOD,GEORGIA 30566-4110
Subject: Permit No. WQ0009826
Wayne Farms—Elkin
Hatchery WWTF
Wastewater Irrigation System
Surry County
Dear Mr. McDaniel:
In accordance with your permit major modification request received April 27,2020,and subsequent
additional information received August 10, 2020, we are forwarding herewith Permit No. WQ0009826
dated September 16, 2020, to Wayne Farms LLC for the construction and operation of the permitted
modifications, as well as the continued operation of the existing wastewater treatment and irrigation
facilities.
The following modifications to the subject permit are as follows: Installation of transfer tanks with
tablet chlorination, storage tanks, and new irrigation fields.
This permit shall be effective from the date of issuance through April 30, 2024, shall void Permit
No. WQ0009826 issued April 8, 2020, and shall be subject to the conditions and limitations therein. The
Permittee shall submit a renewal application no later than November 2,2023.
Please pay attention to the monitoring requirements listed Attachments A, B, and C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
The following permit conditions are new since the last permit issuance dated April 8,2020:
➢ Condition L3. —This condition requires that an Engineering Certification upon completion of
construction and prior to operation of the permitted modifications.
➢ Condition L4. — The Permittee shall notify the Winston-Salem Regional Office at least two
business days in advance of initial operation of the constructed facilities so that the Division
can conduct a startup inspection.
➢ Condition L5. — The Winston-Salem Regional Office shall approve monitoring wells MW-4,
MW-5, and MW-6 prior to installation, and the monitoring wells shall be installed prior to
beginning waste disposal operations on Fields 3 and 4.
North Carolina Department of Environmental Quality I Division of water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
Nf IHTH( 1(:A' DE11NA �
o•w •� «ro^ �a•itv �� 919,707,9000

Mr.Kevin McDaniel
September 16,2020
Page 2 of 2
➢ Condition L6.—Within 90 days of completing installation of monitoring wells MW-4, MW-5,
and MW-6,the Permittee shall submit an updated site map.
➢ Condition L7. — Within 30 days of construction, a Well Construction Record (Form GW-I)
listing this permit number and the appropriate monitoring well identification number shall be
completed for each well that is constructed.
➢ Condition L8.—Within 90 days of initial operation of the new facilities, a Final Operation and
Maintenance Plan detailing the overall system operations that includes both the existing and
new irrigation facilities shall be submitted for review.
➢ Condition IL6.—The Permittee shall connect the irrigation system to a rain or moisture sensor
designed to prevent irrigation during precipitation events or wet conditions.
➢ Condition 11.12.b. and d. — Setbacks for the new spray irrigation sites and treatment/storage
units have been added.
➢ Condition IV.10. — Monitoring wells MW-4, MW-5, and MW-6 shall be sampled after
construction, and within three months prior to initiating wastewater irrigation operations.
➢ Condition IV.12. — For initial sampling of monitoring wells MW-4, MW-5, and MW-6, the
Permittee shall submit a Compliance Monitoring Form (GW-59) and a Well Construction
Record Form (GW-1) listing this permit number and the appropriate monitoring well
identification number.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh,NC 27699-6714. Otherwise,this permit shall be final and binding.
One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this permit, please contact Erick Saunders at (919) 707-3659 or
enckson.saunders&ncdenr.gov.
Sincerely,
7L, �r
S. Daniel Smith,Director
Division of Water Resources
cc: Surry County Health Department(Electronic Copy)
Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Kevin D.Davidson,PE—Agri-Waste Technology,Inc. (Electronic Copy)
Beth Buffington—Protection and Enforcement Branch(Electronic Copy))
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143,General Statutes of North Carolina as
amended, and other applicable Laws,Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Wayne Farms LLC
Surry County
FOR THE
operation of a 5,000 gallon per day(GPD)wastewater treatment and irrigation facility consisting of the:
construction and operation of. a 2,500 gallon transfer tank and a 20 gallon per minute(GPM), 1 horsepower
(hp) transfer pump; a tablet chlorination unit with a 10 GPM chlorinator feed pump (affixed to the 2,500
gallon transfer tank); 4,129 linear feet(LF) of force main connecting the transfer tank to the storage tanks
at Fields 3 and 4; a 3,160 gallon septic tank; a 14,000 gallon storage/pump tank (Storage Tank 1) with a
16.92 GPM, 1 hp pump dosing fields 3A(Irrigation Pump A), a 23.6 GPM, 1.5 hp pump dosing Fields 3B
(Irrigation Pump B), a 29.3 GPM, 1.5 hp pump dosing field 4 (Irrigation Pump C), and high-water
audio/visual alarms,three 10,000 gallon storage tanks (Storage Tanks 2-4)hydraulically connected to the
storage/pump tank; 5.11 acres of additional spray irrigation area divided into six zones; and all associated
piping,valves,controls, and appurtenances; and the
continued operation of. a holding tank with dual pumps; a vibrating filter screen; a pump tank with dual 50
GPM pumps; a 4-inch force main; a 140,000 gallon clay lined effluent storage pond; a tablet chlorinator; a
chlorine contact tank; an effluent pump station with two 50 GPM pumps; a 1.5 acre spray irrigation area
consisting of two fields (Fields 1 and 2) with 15 irrigation spray heads each; and all associated piping,
valves, controls, and appurtenances
to serve the Wayne Farms—Elkin Hatchery WWTF,with no discharge of wastes to surface waters,pursuant
to the application received April 27, 2020, subsequent additional information received August 10, 2020,
and in conformity with the Division-approved plans and specifications considered a part of this permit.
This permit shall be effective from the date of issuance through April 30, 2024, shall void Permit No.
WQ0009826 issued April 8,2020, and shall be subject to the following conditions and limitations:
WQ0009826 Version 4.3 Shell Version 200201 Page 1 of 13

L SCHEDULES
1. Prior to April 1, 2021, the Permittee shall be in compliance with the agronomic loading rates of Plant
Available Nitrogen (PAN) for all of the fields listed on Attachment B. [15A NCAC 02T
.0108(b)(1)(B)]
2. Prior to expiration of this permit,the Permittee shall conduct a survey of the 140,000 gallon clay lined
effluent storage pond to determine the thickness of the residuals accumulation at the bottom of the
basin. The results of this survey shall be sent to the Division of Water Resources, Winston-Salem
Regional Office,Water Quality Regional Operations Section,585 Waughtown St.,Winston-Salem,NC
27107-2241. [15A NCAC 02T.0108(b)(1)(B)]
3. Upon completion of construction and prior to operation of the permitted modifications, the Permittee
shall submit an engineering certification from a North Carolina licensed Professional Engineer
certifying that the permitted facility has been constructed in accordance with G.S. 143-215.1,
Administrative Code Title 15A Subchapter 02T, this permit, and the Division-approved plans and
specifications. For phased and partially certified facilities,the Permittee shall retain the responsibility
to track further construction approved under this permit, and shall provide a final engineering
certification upon project completion. Mail the Engineering Certification to the Division of Water
Resources, Non-Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
Discharge.Reportskncdenr.gov. [15A NCAC 02T.0116(a)]
4. The Permittee shall notify the Winston-Salem Regional Office, telephone number(336) 776-9800, at
least two business days in advance of initial operation of the constructed facilities so that the Division
can conduct a startup inspection. [15A NCAC 02T.0108(b)(1)(B)]
5. The Winston-Salem Regional Office, telephone number [phone], shall approve monitoring
wells MW-4,MW-5, and MW-6 prior to installation, and the monitoring wells shall be installed prior
to beginning waste disposal operations on Fields 3 and 4. The Winston-Salem Regional Office shall
be notified at least two business days in advance of construction of any monitoring well. The
monitoring wells shall be constructed such that the water level in the well is never above or below the
screened portion of the well, and in accordance with 15A NCAC 02C .0108. The general location and
Division-approved name for each monitoring well is on Figure 2. [15A NCAC 02C .0108, 02T
.0108(b)(1)(B)]
WQ0009826 Version 4.3 Shell Version 200201 Page 2 of 13

6. Within 90 days of completing installation of monitoring wells MW-4,MW-5,and MW-6,the Permittee
shall submit two original copies and one digital copy of a site map with a scale no greater than 1-inch
equals 100 feet; however, special provisions may be granted upon prior approval for large properties.
The map shall include the following information:
a. Legend,north arrow, scale, and legible in black and white.
b. Topographic contour intervals not exceeding 10 feet or 25 percent of total site relief.
c. All habitable residences or places of assembly within 500 feet of the irrigation area.
d. Location of all wells, streams (ephemeral, intermittent, and perennial), springs, lakes, ponds,
ditches, and other surface drainage features within 500 feet of the irrigation area.
e. Location and identification of each monitoring well(identify any background/upgradient wells).
f. Latitude and longitude coordinates of each monitoring wells(decimal degrees to the sixth decimal
degree and in NAD83).
g. Location and identification of major components of the waste disposal system.
h. The perimeter of all irrigation areas with field names(named according to the approved permit)
i. Location and ownership of property boundaries within 500 feet of the irrigation area (including
road/rail right-of-ways and easements).
J. Latitude and longitude of the established horizontal control monument(decimal degrees to the sixth
decimal degree).
k. Elevation of the top of the well casing(i.e.,measuring point)relative to a common datum.
1. Depth of water below the measuring point at the time the measuring point is established.
in. Delineation of the compliance and review boundaries.
n. Distance measurements verifying all setbacks are being met.
o. Stormwater drainage controls.
p. 100-year floodplain.
q. The date the map is prepared and/or revised.
Boundaries and physical features not under purview of other licensed professions shall be provided by
a Professional Surveyor. Control monuments shall be installed in such a manner and made of such
materials that the monument will not be destroyed due to activities taking place on the property. The
map and any supporting documentation shall be sent to the Division of Water Resources, Non-
Discharge Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617, or Non-
Discharge.Reportskncdenr.gov. [15A NCAC 02C .0105(f), 02T.0108(b)(1)(B)]
7. Within 30 days of construction, a Well Construction Record (Form GW-1) listing this permit number
and the appropriate monitoring well identification number shall be completed for each well constructed,
and mailed to the Division of Water Resources, Non-Discharge Branch, 1617 Mail Service Center,
Raleigh, NC 27699-1617, or Non-Discharge.Reportskncdenr.gov. A North Carolina Certified Well
Contractor shall construct the monitoring wells according to the North Carolina Well Construction
Standards (15A NCAC 02C .0113) and local county rules. [15A NCAC 02C .0113, 02T
.0108(b)(1)(B)]
8. Within 90 days of initial operation of the new facilities, a Final Operation and Maintenance Plan
detailing the overall system operations that includes both the existing and new irrigation facilities shall
be submitted for review. The plan shall be sent to the Division of Water Resources, Non-Discharge
Branch, 1617 Mail Service Center, Raleigh,NC 27699-1617 or Non-Discharge.Reportskncdenr.gov.
[15A NCAC 02T.0108(b)(1)(B), 02T.0507(a)]
9. The Permittee shall request renewal of this permit on Division-approved forms no later than November
1, 2023. [15A NCAC 02T.0105(b), 02T.0109]
WQ0009826 Version 4.3 Shell Version 200201 Page 3 of 13

IL PERFORMANCE STANDARDS
1. The Permittee shall maintain and operate the subject non-discharge facilities so there is no discharge to
surface waters, nor any contravention of groundwater or surface water standards. In the event the
facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper
operation and maintenance, or failure of the irrigation areas to assimilate the effluent, the Permittee
shall take immediate corrective actions, including Division required actions, such as the construction
of additional or replacement wastewater treatment or disposal facilities. [15A NCAC 02T
.0108(b)(1)(A)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02T.0108(b)(1)(A)]
3. Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and
regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1)(A)]
5. Application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T.0108(b)(1)(A)]
6. The Permittee shall connect the irrigation system to a rain or moisture sensor designed to prevent
irrigation during precipitation events or wet conditions that would cause runoff. [15A NCAC 02T
.0505(x)]
7. Wastewater irrigation fields permitted on or after December 30, 1983 have a compliance boundary that
is either 250 feet from the wastewater irrigation area, or 50 feet within the property boundary,
whichever is closest to the wastewater irrigation area. Any exceedance of groundwater standards at or
beyond the compliance boundary shall require corrective action. Division-approved relocation of the
compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common
ownership and permitted for use as a disposal system shall be treated as a single property with regard
to determination of a compliance boundary. [15A NCAC 02L.0106(d)(2), 02L.0107(b),02T.0105(h),
G.S. 143-215.1(1), G.S. 143-215.1(k)]
8. The review boundary is midway between the compliance boundary and the wastewater irrigation area.
Any exceedance of groundwater standards at or beyond the review boundary shall require preventative
action. [15A NCAC 02L.0106(d)(1), 02L .0108]
9. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary(i.e.,parcel subdivision). [15A NCAC
02L .0107(c)]
10. No wells, excluding Division-approved monitoring wells, shall be constructed within the compliance
boundary except as provided for in 15A NCAC 02L.0107(g). [15A NCAC 02L .0107]
11. Except as provided for in 15A NCAC 02L .0107(g),the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Surry
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
WQ0009826 Version 4.3 Shell Version 200201 Page 4 of 13

[15A NCAC 02L .0107(f)]
12. The facilities herein were permitted per the following setbacks:
a. The irrigation sites(i.e.,Fields 1 and 2)were originally permitted October 26, 1994. The setbacks
for spray irrigation sites originally permitted or modified from February 1, 1993 to August 31,2006
are as follows (all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 4001
ii. Each private or public water supply source: 100
In. Surface waters: 100
iv. Groundwater lowering ditches: 100
v. Surface water diversions (upslope): 100
vi. Surface water diversions (downslope): 100
vii. Each well with exception of monitoring wells: 100
viii.Each property line: 150
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Each water line: 10
xi. Each swimming pool: 100
xii. Public right of way: 50
xiii.Nitrification field: 20
xiv.Each building foundation or basement: 15
' Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H.02190)(5)]
WQ0009826 Version 4.3 Shell Version 200201 Page 5 of 13

b. The irrigation sites (i.e., Fields 3 and 4) were originally permitted DATE OF PERMIT. The
setbacks for spray irrigation sites originally permitted or modified on or after September 1, 2018
are as follows (all distances in feet):
I. Each habitable residence or place of assembly under separate ownership: 400 '
ii. Each habitable residence or place of assembly owned by the Permittee: 200 3
iii. Each private or public water supply source: 100
iv. Surface waters: 100
v. Groundwater lowering ditches: 100
vi. Surface water diversions: 25
vii. Each well with exception of monitoring wells: 100
viii.Each property line: 150 2
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Each water line: 10
xi. Subsurface groundwater lowering drainage systems: 100
xii. Public right of way: 50
xiii.Nitrification field: 20
xiv.Each building foundation or basement: 15
' Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
3 Per a setback waiver recorded in the Surry County Register of Deeds, reduced setbacks from
the wetted area to any habitable residence or place of assembly under separate ownership are
as follows:
Parcel No. Deed Book/Page Setback Easement
4972-03-41-0161 1725 /222 50 feet 150 feet
[15A NCAC 02T.0506(a), 02T.0506(d), 02T.0506(e), 02T.0506(f)]
c. The storage and treatment units, except those noted in Paragraph d. below, were originally
permitted October 26, 1994. The setbacks for storage and treatment units originally permitted or
modified from February 1, 1993 to August 31, 2006 are as follows(all distances in feet):
I. Each private or public water supply source: 100
ii. Surface waters: 50
iii. Each well with exception of monitoring wells: 100
iv. Each property line: 50 '
v. Nitrification field: 20
' Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H .02190)(5)]
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d. The 2,500 gallon transfer tank, tablet chlorination unit, 3,000 gallon settling tank, 14,000 gallon
storage/pump tank, and the three 10,000 gallon storage tanks were originally permitted DATE OF
PERMIT. The setbacks for storage and treatment units originally permitted or modified on or after
September 1,2018 are as follows(all distances in feet):
I. Each habitable residence or place of assembly under separate ownership: 1001
ii. Each private or public water supply source: 100
iii. Surface waters: 50
iv. Each well with exception of monitoring wells: 100
v. Each property line: 50 z
' Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02T.0506(b), 02T.0506(e), 02T.0506(f)]
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the subject facilities as anon-discharge system. [15A NCAC
02T .0500]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational
functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02T
.0507(a)]
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities,the Permittee shall designate and employ a certified
operator in responsible charge(ORC),and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T
.0117]
4. The Permittee shall maintain vegetative cover on the irrigation sites, such that crop health is optimal,
allows even effluent distribution, and allows inspection of the irrigation system. [15A NCAC 02T
.0507(b)]
5. The Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites
listed in Attachment B. [15A NCAC 02T.0507(c)]
6. The Permittee shall not irrigate treated effluent during inclement weather, or when the soil is in a
condition that will cause ponding or runoff. [15A NCAC 02T.0505(x)]
7. Irrigation equipment shall be tested and calibrated once per permit cycle. [15A NCAC 02T.0507(d)]
8. Only treated effluent from the Wayne Farms LLC — Elkin Hatchery WWTF shall be irrigated on the
sites listed in Attachment B. [15A NCAC 02T.0501]
9. The Permittee shall not allow vehicles or heavy machinery on the irrigation area, except during
equipment installation or maintenance activities. [15A NCAC 02T.0507(e)]
10. The Permittee shall prohibit public access to the wastewater treatment,storage, and irrigation facilities.
[15A NCAC 02T.0505(q)]
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11. The Permittee shall dispose or utilize generated residuals in a Division-approved manner. [15A NCAC
02T .0508, 02T.1100].
12. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject
facilities. [15A NCAC 02T.05050)]
13. Freeboard in the 140,000 gallon clay lined effluent storage pond shall not be less than two feet at any
time. [15A NCAC 02T.0505(d)]
14. A gauge to monitor waste levels in the 140,000 gallon clay lined effluent storage pond shall be provided.
This gauge shall have readily visible permanent markings, at inch or tenth of a foot increments,
indicating the following elevations: maximum liquid level at the top of the temporary liquid storage
volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest
point on top of the dam. [15A NCAC 02T.0507(f)]
15. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees,shrubs,and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T.0507(g)]
16. Metering equipment shall be tested and calibrated annually. [15A NCAC 02T.0507(d)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
facility's impact on groundwater and surface water. [15A NCAC 02T.0108(c)]
2. A Division-certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. [15A NCAC 02H.0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR. Facilities with a permitted flow less than 10,000 GPD may estimate their
flow from water usage records provided the water source is metered. [15A NCAC 02T .0105(k), 02T
.0108(c)]
4. The Permittee shall monitor the treated effluent at the frequencies and locations for the parameters
specified in Attachment A. [15A NCAC 02T.0108(c)]
5. The Permittee shall maintain records tracking the amount of effluent irrigated. These records shall
include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly,monthly, and year-to-date hydraulic (inches/acre)loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T.0108(c)]
6. Freeboard (i.e., waste level to the lowest embankment elevation) in the 140,000 gallon clay lined
effluent storage pond shall be measured to the nearest inch or tenth of a foot, and recorded weekly.
Weekly freeboard records shall be maintained for five years,and shall be made available to the Division
upon request. [15A NCAC 02T.0108(c)]
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7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI,three copies of all operation and disposal records(as specified in Conditions IV.5. and IV.6.)
on Form NDAR-I, and three copies of all mass loading records on Form NDMLR for every site in
Attachment B shall be submitted on or before the last day of the following month. If no activities
occurred during the monitoring month,monitoring reports are still required documenting the absence
of the activity. All information shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[I5A NCAC 02T.0105(1)]
8. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. This record shall
include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal,or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T.0508(b)]
9. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Date of flow measurement device calibration;
b. Date of irrigation equipment calibration;
c. Visual observations of the plant and plant site; and
d. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings, etc.).
[15A NCAC 02T.0507(h)]
10. Monitoring wells MW-4, MW-5, and MW-6 shall be sampled after construction, and within three
months prior to initiating wastewater irrigation operations. Monitoring wells MW-4,MW-5,and MW-
6 shall be sampled thereafter at the frequencies and for the parameters specified in Attachment C. All
mapping, well construction forms, well abandonment forms, and monitoring data shall refer to the
permit number and the well nomenclature as provided in Attachment C and Figure 2. [15A NCAC 02T
.0105(m)]
11. Monitoring well MW-3 shall be sampled at the frequencies and for the parameters specified in
Attachment C. All mapping, well construction forms, well abandonment forms and monitoring.
shall refer to the permit number and the well nomenclature as provided in Attachment C and Figure.
[15A NCAC 02T.0105(m)]
12. For initial sampling of monitoring wells MW-4, MW-5, and MW-6, the Permittee shall submit a
Compliance Monitoring Form (GW-59) and a Well Construction Record Form (GW-1) listing this
permit number and the appropriate monitoring well identification number. Initial Compliance
Monitoring Forms (GW-59) without copies of the Well Construction Record Forms (GW-1) are
deemed incomplete, and may be returned to the Permittee without being processed. [15A NCAC 02T
.0105(m)]
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13. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form(GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(m)]
14. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for five
years, and shall be made available to the Division upon request. Each Standard Soil Fertility Analysis
shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
[15A NCAC 02T.0108(c)]
15. Noncompliance Notification:
The Permittee shall report to the Winston-Salem Regional Office, telephone number(336) 776-9800,
within 24 hours of first knowledge of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate wastewater treatment.
c. Any facility failure resulting in a discharge to surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Winston-Salem Regional Office within
five days of first knowledge of the occurrence, and this report shall outline the actions proposed or
taken to ensure the problem does not recur. [15A NCAC 02T.0108(b)(1)(A)]
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V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater
treatment and irrigation facilities. [15A NCAC 02T.0507(i)]
2. The Pennittee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions,
facility deterioration, and operator errors that may result in discharges of wastes to the environment,
threats to human health, or public nuisances. The Permittee shall maintain an inspection log that
includes the date and time of inspection, observations made, and maintenance, repairs, or corrective
actions taken. The Permittee shall maintain this inspection log for a period of five years from the date
of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T
.0507(h), 02T.0507(i)]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property,premises,or place related to the wastewater treatment and irrigation facilities permitted herein
at any reasonable time for determining compliance with this permit. Division authorized
representatives may inspect or copy records maintained under the terms and conditions of this permit,
and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Pennittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division-approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit,there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T.0105(n)]
4. The issuance of this permit does not exempt the Pennittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T.0105(c)(6)]
5. If the permitted facilities change ownership, or the Pennittee changes their name, the Permittee shall
submit a permit modification request on Division-approved forms. The Pennittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor-owner. [G.S. 143-
215.1(d3)]
6. The Penmittee shall retain a set of Division-approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T.0105(o)]
7. The Pennittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T.01050)]
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8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
In. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T.0110]
9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent,subsidiary,or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent,subsidiary,or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T.0120(b), 02T .0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T.0120(c)]
Permit issued this the 16'b day of September 2020
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
S. Daniel Smith,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0009826
WQ0009826 Version 4.3 Shell Version 200201 Page 12 of 13

Permit No. WQ0009826 Wastewater Irrigation System
Wayne Farms LLC September 16,2020
Wayne Farms—Elkin Hatchery WWTF Surry County
ENGINEERING CERTIFICATION
❑ Partial ❑ Final
I, , as a duly licensed North Carolina Professional
Engineer,having ❑ periodically/❑ fully observed the construction of the permitted facilities,do hereby
state to the best of my abilities that the facility was constructed in compliance with G.S. 143-215.1,
Administrative Code Title 15A Subchapter 02T, this permit, and the Division-approved plans and
specifications.
Documentation of any variation to this permit,and the Division-approved plans and specifications,is in the
attached as-built drawings.
Description of variations:
Professional Engineer's Name
Firm Name Finn No.
Address
City State Zip Code
Telephone Email mm Seal, Signature, and Date
THE COMPLETED ENGINEERING CERTIFICATION,INCLUDING ALL SUPPORTING
DOCUMENTATION,SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
NON-DISCHARGE BRANCH
By U.S. Postal Service By Courier/Special DelivM
1617 MAIL SERVICE CENTER 512 N. SALISBURY ST.
RALEIGH,NORTH CAROLINA 27699-1617 RALEIGH,NORTH CAROLINA 27604
WQ0009826 Version 4.3 Shell Version 200201 Page 13 of 13

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WQ0009826 Version 4.3 Shell Version 200201 Page 1 of 13

ATTACHMENT A—LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0009826 Version: 4.3
PPI 001—WWTF Effluent
EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS
PCs Parameter Description Units of Monthly Monthly Daily Minimum Daily Maximum Measurement Sample
Code Measure Average Geometric Mean Frequency Type
00310 BOD,5-Day(20°C) mg/L 3 x Year i Grab
00916 Calcium,Total(as Ca) mg/L 3 x Year i Grab
00940 Chloride(as Cl) mg/L 3 x Year i Grab
50060 Chlorine,Total Residual mg/L Weekly Grab
31616 Coliform,Fecal MF,M-FC Broth,44.5°C #/100 mL 3 x Year 1 Grab
50050 Flow,in Conduit or thru Treatment Plant GPD 5,000 Monthly Estimate
00927 Magnesium,Total(as Mg) mg/L 3 x Year i Grab
00610 Nitrogen,Ammonia Total(as N) mg/L 3 x Year 1 Grab
00625 Nitrogen,Kjeldahl,Total(as N) mg/L 3 x Year i Grab
00620 Nitrogen,Nitrate Total(as N) mg/L 3 x Year 1 Grab
00600 Nitrogen,Total(as N) mg/L 3 x Year 1 Grab
00400 pH su Weekly Grab
00665 Phosphorus,Total(as P) mg/L 3 x Year 1 Grab
WQ09C Plant Available Nitrogen—Concentration mg/L 3 x Year i Calculated
00931 Sodium Adsorption Ratio ratio 3 x Year 1 Calculated
00929 Sodium,Total(as Na) mg/L 3 x Year i Grab
70300 Solids,Total Dissolved—180°C mg/L 3 x Year 1 Grab
00530 Solids,Total Suspended mg/L 3 x Year 1 Grab
1. 3 x Year sampling shall be conducted in March,July,and November.
WQ0009826 Version 4.3 Attachment A Page 1 of 1

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ATTACHMENT B-APPROVED LAND APPLICATION SITES AND LIIVHTATIONS Permit Number: WQ0009826 Version: 4.3
Wayne Farms LLC-Wayne Farms-Elkin Hatchery WWTF
IRRIGATION AREA INFORMATION APPLICATION LIMITATIONS
Field Owner County Latitude Longitude Net Dominant Parameter Hourly Yearly Units
Acreage Soil Series Rate Max
1 Wayne Farms LLC Surry 36.276518° -80.776023° 0.75 FeC2-Fairview 01284-Non-Discharge Application Rate 0.2 52� Inches
sand clayloam WQ09-Plant Available Nitrogen' N/A 1581 lbs/acre
2 Wayne Farms LLC Surry 36.276345° -80.775900° 0.75 FeC2-Fairview 01284-Non-Discharge Application Rate 0.2 52� Inches
sand clayloam WQ09-Plant Available Nitrogen' N/A 1581 lbs/acre
3A1 Wayne Farms LLC Surry 36.265945° -80.785986° 0.63 FeB2-Fairview 01284-Non-Discharge Application Rate 0.2 12.92 Inches
sandy clay loam WQ09-Plant Available Nitrogen N/A 1882.1lbs/acre
3A2 Wayne Farms LLC Surry 36.265684° -80.785529° 0.60 FeB2-Fairview 01284-Non-Discharge Application Rate 0.2 13.582.1
3.58 Inches
sand cla loam WQ09-Plant Available Nitrogen' N/A 188 lbs/acre
3131 Wayne Farms LLC Surry 36.265367° -80.784936° 0.78 FeB2-Fairview 01284-Non-Discharge Application Rate 0.2 14.54 Inches
sandv clav loam WQ09-Plant Available Nitrogen' N/A 1882.1lbs/acre
3132 Wayne Farms LLC Surry 36.265042° -80.784477° 0.82 FeB2-Fairview 01284-Non-Discharge Application Rate 0.2 13.80 Inches
sandy clay loam WQ09-Plant Available Nitrogen N/A 1882.1lbs/acre
4A1 Wayne Farms LLC Surry 36.264839° -80.782104° 1.11 BbB-Braddock 01284-Non-Discharge Application Rate 0.2 12.60 Inches
fine sandy loam WQ09-Plant Available Nitrogen' N/A 2472,1lbs/acre
4A2 Wayne Farms LLC Surry 36.264571° -80.782322° 1.18 BbB-Braddock 01284-Non-Discharge Application Rate 0.2 12.07
Inches
fine sand loam WQ09-Plant Available Nitrogen' N/A 247 lbs/acre
Totals 6.62
1. Reporting shall be submitted on form NDMLR.
2. Limits have been obtained from the North Carolina State University Realistic Yield Expectations(RYE)calculator(https://realistiaields.ces.ncsu.edu/)using the soil types(FeB2,FeC2,and BbB)
and a cover crop of Fescue(Hay).The applicant may petition for a permit modification to apply above agronomic rates if predictive calculations are provided that demonstrate State groundwater
standards will be protected(15A NCAC 02T.0505(c)).
3. Compliance with this application limit has been suspended until April 1,2021.Any exceedances of the 12-month floating PAN limit caused by applications prior to this date shall be suspended as
long as no further application occurs after this date until such point as the 12-month floating total is no longer exceeded.
WQ0009826 Version 4.3 Attachment B Page 1 of 1

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ATTACHMENT C— GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0009826 Version: 4.3
Monitoring Wells: MW-3,MW-4,MW-5 &MW-6
GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes
00680 Carbon,Tot Organic(TOC) mg/L 3 x Year Grab 1,6
00940 Chloride(as Cl) 250 mg/L 3 x Year Grab 1
31616 Coliform,Fecal MF,M-FC Broth,44.5°C #/100 mL 3 x Year Grab 1
00610 Nitrogen,Ammonia Total(as N) 1.5 mg/L 3 x Year Grab 1
00620 Nitrogen,Nitrate Total(as N) 10 mg/L 3 x Year Grab 1
00400 pH 6.5-8.5 su 3 x Year Grab 1,2
00665 Phosphorus,Total(as P) mg/L 3 x Year Grab 1
70300 Solids,Total Dissolved- 180°C 500 mg/L 3 x Year Grab 1
82546 Water Level,Distance from measuring point feet 3 x Year Calculated L2,3
1. 3 x Year monitoring shall be conducted in March,July,and November;Annual monitoring shall be conducted in November.
2. The measurement of water levels shall be made prior to purging the wells.The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points(top of well casing)of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points(top of
casing)of all monitoring wells shall be surveyed relative to a common datum.
4. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well,additional sampling and analysis shall be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
5. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figures 1 and 2 and this attachment.
WQ0009826 Version 4.3 Attachment C Page 1 of 1

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ROY COOPER
�:' Governor
MICHAEL S. REGAN
Secretary
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL OLIALITY Director
May 9, 2017
RONALD F.MASSEY—DEPUTY CITY MANAGER
CITY OF JACKSONVILLE
POST OFFICE BOX 128
JACKSONVILLE,NORTH CAROLINA 28541-0128
Subject: Permit No. WQ0009267
City of Jacksonville WWTF
Wastewater Irrigation System
Onslow County
Dear Mr. Massey:
In accordance with your permit minor modification request received October 31, 2016, and
subsequent additional information received February 9, 2017, we are forwarding herewith Permit No.
WQ0009267 dated May 9, 2017, to the City of Jacksonville for the continued operation of the subject
wastewater treatment and irrigation facilities, as well as the construction and operation of the modified
wastewater treatment facilities.
The modifications to the subject permit are as follows:Replacement of the existing non-functional
mechanical bar screen and the existing dual screw auger conveyors and ram press. Please also note that the
permit expiration has been extended to April 30, 2022,
This permit shall be effective from the date of issuance until April 30, 2022, shall void Permit No.
WQ0009267 issued March 29, 2013, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements listed in Attachments A, B and C
for they may differ from the previous permit issuance. Failure to establish an adequate system for collecting
and maintaining the required operational information shall result in future compliance problems.
Please note the following permit conditions have been removed since the last permit issuance
dated March 29,2013:
➢ Old Condition U.—This Condition(site map submittal)has been satisfied.
Please note the following permit conditions and attachments are new or modified since the
last permit issuance dated March 29,2013:
➢ Condition I.I.—States requirements for certification by a North Carolina licensed Professional
Engineer.
➢ Condition 1.2. — States requirements for notification of the Regional Office in advance of
placing in operation the installed facilities.
• Nothing Compare%
State of North Carolina I Environmental Quality(Water Resources I Water Quality Permitting I Non-Discharge Permitting
1617 Mail Service Center I Raleigh,North Carolina 27699-1617
919-807-6332

Mr.Ronald F.Massey
May 9,2017
Page 2 of 2
➢ Condition IV.8. —Indicates the requirements for preparation and submittal to the Division of
an Annual Report summarizing the operation of the wastewater treatment and irrigation
facilities.
➢ Attachment A — The subject wastewater treatment facility has been classified as a passive
lagoon treatment system. Accordingly, the sampling frequency for BODs (00310), Fecal
Coliform (31616), and TSS (00530) has been reduced from 3 x Week to 2 x Month. The
sampling frequency for Ammonia (00610), TKN (00625), Nitrate (00620), and Total
Phosphorus(00665)has increased to 2 x Month. In addition,Total Nitrogen(00600)has been
added to the sampling regimen.
➢ Attachment C —Chloride (00940) and Total Phosphorus (00665) have been added, and TSS
(00530)has been removed from the sampling regimen.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center,Raleigh,NC 27699-6714. Unless such demands are made,this permit shall be final and binding.
One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this permit, please contact David Schlobohm at (919) 807-6384 or
[e-mail].
Sincerely,
4,7
Jay Zimmerman,P.G.,Duector
Division of Water Resources
cc: Onslow County Health Department(Electronic Copy)
Wilmington Regional Office, Water Quality Regional Operations Section(Electronic Copy)
Christopher L. Windley,PE—CJS Conveyance(Electronic Copy)
Beth Buffington—Protection and Enforcement Branch(Electronic Copy)
Digital Permit Archive(Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
City of Jacksonville
Onslow County
FOR THE
operation of a 9,000,000 gallon per day (GPD) wastewater treatment and irrigation facility consisting of
the:
construction and operation of the modified wastewater treatment facilities consisting o£the replacement of
the existing non-functional auxiliary mechanical bar screen with a Huber Technology 3 millimeter (mm)
step screen;replacement of the existing dual screw auger conveyors and ram press with three new shaftless
12-inch spiral screw conveyors; and all associated piping,valves, controls,and appurtenances;the
continued operation of the existing wastewater treatment facility consisting of:a hydrogen peroxide storage
and feed facilities for chemical pretreatment to provide raw-influent odor control;a magnetic influent flow
meter; a Huber Technology dual train stepper screen;a headworks structure with oil/grease separation,two
200 gallon per minute (GPM), 3 horsepower (hp) grit pumps, and a grit classifier system; three-train
mechanically aerated, multi-cellular biological treatment lagoons, each consisting of a 4.5 million gallon
(MG) aerated cell with 50 hp floating mixers followed by a 3.0 MG cell with 10 hp floating mixers,
separated by a curtain baffle, and constructed with fabriform-type slope protection and compacted clay
liners with low permeability not exceeding 101 centimeter per second (cm/sec); a combined East/West
Storage Lagoon of approximately 362 MG,constructed with compacted in-situ clay bottoms,clay/bentonite
perimeter slurry wall, and synthetically lined (HDPE) side slopes with permeability not exceeding 10-6
cm/sec;an approximately 360 MG South Storage Lagoon,with inside berm walls lined with 60 mil HPDE
liner and clay liner on the lagoon bottom with surrounding slurry wall keyed into top of bedrock with solar-
powered floating mixers in each lagoon; an effluent splitter box; an effluent irrigation pump station with
six 350 hp, 4,800 GPM variable speed vertical turbine pumps, and dual self-cleaning traveling screens to
remove debris prior to pumping; chlorine disinfection facilities including two 110 GPM, 15 hp chlorine
booster water pumps and associated chlorine feed piping; isolation valves for effluent distribution;
administration/maintenance building; generator facilities for emergency stand-by power for chlorine
scrubbers, administration/maintenance building; and all associated piping, valves, controls, and
appurtenances; and the
WQ0009267 Version 3.1 Shell Version 151201 Page 1 of 11

continued operation of the wastewater irrigation facility consisting of: a wooded spray irrigation land
treatment system of approximately 2,331 wetted acres(7,400 acres total), grouped into well-drained soils,
moderately well-drained soils, and seasonal soils; main irrigation and lateral piping consisting of
approximately 5,225 linear feet(LF)of 30-inch buried pipe, 2,943 LF of 24-inch buried pipe, 3,488 LF of
20-inch buried pipe, 3,056 LF of 16-inch buried pipe, 5,232 LF of 12-inch buried pipe, 10,842 LF of 10-
inch buried pipe, 12,138 LF of 8-inch buried pipe, 15,925 LF of 6-inch buried pipe, 4,487 LF of 4-inch
buried pipe, 1,314 LF of 3-inch buried pipe,830 LF of 2-inch buried pipe,315 LF of 12-inch exposed pipe,
6,230 LF of 10-inch exposed pipe, 20,724 LF of 8-inch exposed pipe, 21,628 LF of 6-inch exposed pipe,
41,209 LF of 4-inch exposed pipe, 57,625 LF of 3-inch exposed pipe, 134,152 LF of 2-inch exposed pipe
stick-up sprinkler heads; and all associated piping,valves,controls and appurtenances
to serve the City of Jacksonville WWTF, with no discharge of wastes to surface waters, pursuant to the
application received October 31, 2016, and subsequent additional information received by the Division of
Water Resources, and in conformity with the project plans, specifications, and other supporting data
subsequently filed and approved by the Department of Environmental Quality and considered a part of this
permit.
This permit shall be effective from the date of issuance until April 30, 2022, shall void Permit No.
WQ0009267 issued March 29, 2013, and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
1. Upon completion of construction and prior to operation of this permitted facility, a certification
(attached) shall be submitted from a licensed North Carolina Professional Engineer certifying that the
permitted facility has been installed in accordance with this permit, Division approved plans and
specifications, and other supporting documentation, including the location of all monitoring wells as
applicable. If this project is to be completed in phases and partially certified the Permittee shall retain
the responsibility to track further construction approved under the same permit and shall provide a
final certificate of completion once the entire project has been completed. Mail the Certification to the
Division of Water Resources, Water Quality Permitting Section, 1617 Mail Service Center, Raleigh,
NC 27699-1617. [15A NCAC 02T .0116(a)]
2. The Wilmington Regional Office,telephone number(910)796-7215, shall be notified at least 48 hours
in advance(excluding weekends and holidays) of operation of the installed facilities such that an in-
place inspection can be made. Notification to the regional supervisor shall be made from 8:00 a.m.
until 5:00 p.m. on Monday through Friday,excluding State Holidays. [15A NCAC 02T.0108(b)(2)]
3. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted,will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T.0105(d)requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T.0105(d),02T .0106,02T .0109, 02T.0115(c)]
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H. PERFORMANCE STANDARDS
1. The subject non-discharge facilities shall be effectively maintained and operated at all times so there is
no discharge to surface waters, nor any contravention of groundwater or surface water standards. In
the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due
to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the
effluent,the Permittee shall take immediate corrective actions including Division required actions,such
as the construction of additional or replacement wastewater treatment or irrigation facilities. [G.S. 143-
215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.4108(b)(1), 02T .0505(b)]
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505(c),02T .0505(n)]
6. This disposal system was individually permitted on or after December 30, 1983; therefore, the
compliance boundary is established at either 250 feet from the effluent disposal area, or 50 feet within
the property boundary, whichever is closest to the effluent disposal area. An exceedance of
groundwater standards at or beyond the compliance boundary is subject to remediation action according
to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with North Carolina
General Statute 143-215.6A through 143-215.6C. [15A NCAC 02L .0106(d)(2), 02L .0107(b)]
7. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L .0106. [15A NCAC 02L
.0106, 02L .0108]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
9. In accordance with 15A NCAC 02L.0107(d),no wells,excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [15A NCAC 02L.0107]
10. Except as provided for in 15A NCAC 02L .0107(g),the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Onslow
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary;and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
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11. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for irrigation sites permitted under 15A NCAC 02T .0500 shall be as follows (all
distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 400
ii. Any habitable residence or place of public assembly owned by the Permittee: 200
iii. Any private or public water supply source: 100
iv. Surface waters: 100
v. Groundwater lowering ditches: 100
vi. Surface water diversions: 25
vii. Any well with exception of monitoring wells: 100
viii.Any property line: 150
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Any water line from a disposal system: 10
xi. Subsurface groundwater lowering drainage systems: 100
xii. Any swimming pool: 100
xiii.Public right of way: 50
xiv.Nitrification field: 20
xv. Any building foundation or basement: 15
[15A NCAC 02T.0506(a)]
b. The setbacks for storage and treatment units permitted under 15A NCAC 02T .0500 shall be as
follows(all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: 100
v. Any property line: 50
[15A NCAC 02T .0506(b)]
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non-discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0507]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge(ORC)and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .0117]
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3. A suitable year round vegetative cover shall be maintained at all times, such that crop health is
optimized, allows for even distribution of effluent and allows inspection of the irrigation system. For
guidance on operation and maintenance practices to support crop health,refer to the 2011 Review
of the Jacksonville LTS,Summary of Recommendations for the Jacksonville LTS and 2012 External
Review of the Jacksonville LTS documents attached to this permit. The Permittee shall implement
measures from these reports as necessary to maintain the health and function of all spray field
crops. Steps taken and observed results shall be documented annually and available to the
Division for inspection. [15A NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed
in Attachment B. [15A NCAC 02T .0108(b)(1)]
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. [15A NCAC 02T .0108(b)(1)]
6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
7. Only effluent from the City of Jacksonville WWTF shall be irrigated on the sites listed in Attachment
B. [G.S. 143-215.1]
8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment
installation or while maintenance is being performed. Adequate steps shall be taken to prevent
compaction of irrigation sites during maintenance and logging activities and any damage to irrigation
sites that occurs during logging operations (e.g., rutting, compaction, erosion, etc.) shall be repaired
immediately following completion of logging activities. [15A NCAC 02T .0108(b)(1)]
9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. [15A NCAC
02T .0505(q)]
10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0508. [15A NCAC 02T.0508, 02T .1100]
11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T .05050)]
12. Freeboard in the treatment and effluent storage lagoons shall not be less than two feet at anytime. [15A
NCAC 02T .0505(d)]
13. Gauges to monitor waste levels in the treatment and effluent storage lagoons shall be provided. These
gauges shall have readily visible permanent markings, at inch or tenth of a foot increments, indicating
the following elevations: maximum liquid level at the top of the temporary liquid storage volume;
minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest point on
top of the dam. [15A NCAC 02T .0108(b)(1)]
14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment),berms,pipe runs,erosion control areas,and surface water diversions. Trees,shrubs,and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)]
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15. A Forester(or similar professional)shall be designated for all forest management responsibilities. The
name of this person shall be provided to the Division of Water Resources Wilmington Regional Office.
Any changes in the assignment of crop management responsibilities shall be promptly reported to the
Wilmington Office. [15A NCAC 02T .0108(b)(1)]
16. Blocks receiving post-harvest irrigation during the second and third years following tree planting
activities shall be irrigated at rates not exceeding 1/3 design rate and 2/3 design rate,respectively. [15A
NCAC 02T .0108(b)(1)]
17. The Emergency Action Plan must be adhered to in the following emergency situations:
a. Loss of electrical power to the effluent pump station for an extended period of time,
b. Landfall of a major tropical storm predicted for the Jacksonville area while storage lagoon water
levels are close to maximum permitted levels,
c. Lagoon water level in one of both lagoons exceeding permitted maximum level (i.e., minimum
freeboard is not present),
d. Embankment stability issue on either the East/West or South Storage Lagoon which requires the
rapid drawdown of the affected lagoon.
Upon activation of the Emergency Action Plan, the Wilmington Regional Office, telephone number
[phone],must be notified as soon as possible,but in no cases more than 24 hours or on the next
working day. Note that under special circumstances (see Section 4 of the Emergency Action Plan),
increased surface water monitoring will be required. Any changes to the Emergency Action Plan must
be approved by the Wilmington Regional Office prior to their activation. [15A NCAC 02T.0108(b)(1)]
18. Connection or disconnection of any sewer piping or equipment shall be made in a manner to maintain
continuous flow. Where flow must be interrupted,no diversion or overflow of sewage to a storm drain,
ditch, or surface waters shall be permitted. [15A NCAC 02T .0108(b)(1)]
19. Mounding of groundwater shall not occur to the point where the water table is in the active soil
treatment zone (about one foot below the ground surface) for periods longer than two days between
irrigation events. [15A NCAC 02T .0108(b)(1)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring(including groundwater,plant tissue,soil and surface water analyses)
necessary to ensure groundwater and surface water protection shall be established, and an acceptable
sampling reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
[15A NCAC 02T .0105(k)]
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4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum,
these records shall include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic(inches/acre)loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions;and
h. Maintenance of cover crops.
[15A NCAC 02T .0108(c)]
6. Freeboard(i.e.,waste level to the lowest embankment elevation) in the treatment and effluent storage
lagoons shall be measured to the nearest inch or tenth of a foot,and recorded weekly. Weekly freeboard
records shall be maintained at the facility for a period of no less than five years, and shall be made
available to the Division upon request. [15A NCAC 02T.0108(c)]
7. Three copies of all monitoring data(as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.)on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month,monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T .0105(1)]
8. Pursuant to§ 143-215.1 C.,the Permittee shall provide to its users and the Division of Water Resources
an annual report summarizing the performance of the wastewater treatment and irrigation facility and
the extent to which the facility has violated this permit, or federal or State laws, regulations, or rules
related to the protection of water quality. This report shall be prepared on either a calendar or fiscal
year basis and shall be provided no later than 60 days after the end of the calendar or fiscal year. Two
copies of the annual report provided to the Permittee's users shall be submitted to:
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[G.S. 143-215.1C]
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9. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum,this record shall include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal,or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T.0108(b)(1)]
10. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum,this log shall include:
a. Date and results of power interruption testing on alternate power supply;
b. Date of calibration of flow measurement device;
c. Visual observations of the plant and plant site; and
d. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings,etc.).
[I 5A NCAC 02T.0108(b)(1)]
11. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All mapping, well construction forms, well abandonment forms and monitoring data shall refer to
the permit number and the well nomenclature as provided in Attachment C. [15A NCAC 02T
.0105(m)]
12. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form(GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(m)]
13. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period
of no less than five years,and shall be made available to the Division upon request. At a minimum,the
Standard Soil Fertility Analysis shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
The results shall be reviewed by a North Carolina agronomist annually. The Permittee shall
perform any work recommended by the agronomist as necessary to maintain the health and
function of all spray field crops.
[15A NCAC 02T .0108(c)]
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14. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number(910)
796-7215,as soon as possible,but in no case more than 24 hours,or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its pen-nit
limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting(e.g., discharges to surface waters, imminent failure of
a storage structure, etc.)outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number(800)662-7956,[phone],or(919)733-3300. Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure the problem does not recur. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and irrigation facilities. [15A NCAC 02T.0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment,a threat to human health or a public nuisance. The Permittee shall
maintain an inspection log that includes, at a minimum, the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this
inspection log for a period of five years from the date of the inspection, and this log shall be made
available to the Division upon request. [15A NCAC 02T.0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and irrigation facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions ofthis permit,
and may collect groundwater, surface water or leachate samples. [G.S. 143-21.5.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [15A NCAC 02T.0110]
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted,unless specifically requested and approved in this permit pursuant to 15A NCAC 02T.0105(n).
[G.S. 143-21.5.1]
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4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g.,local,state,and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under General Permit NCGO10000; any requirements pertaining to wetlands under 15A NCAC 02B
.0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the
General Statutes. [15A NCAC 02T .0105(c)(6)]
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms,and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T .0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0108(b)(1)]
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.01050)]
8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director,in whole or part for the requirements listed in 15A NCAC 02T.0110. [15A NCAC 02T.0110]
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T.0120]
10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 9'day of May 2017
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
?-S Jay Zimmerman,P.G.,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0009267
WQ0009267 Version 3.1 Shell Version 151201 Page 10 of 11

Permit No. WQ0009267 Wastewater Irrigation System
City of Jacksonville May 9, 2017
City of Jacksonville WWTF Onslow County
ENGINEERING CERTIFICATION
❑ Partial ❑ Final
In accordance with 15A NCAC 02T .0116,I,_ ,as
a duly registered Professional Engineer in the State of North Carolina,having the Permittee's authorization
to❑periodically❑weekly❑fully observe the construction of the permitted facility,hereby state to the
best of my abilities that due care and diligence was used in the observation of the construction, such that
the facility was built within substantial compliance and intent of this permit,the Division-approved plans
and specifications,and other supporting documentation.
❑ Any variation to this permit, the Division-approved plans and specifications, and other supporting
documentation has been documented in the attached as-built drawings, and shall serve as the
Permittee's minor modification request to amend the permit accordingly.
Provide a brief narrative description of any variations:
Professional Engineer's Name
Engineering Firm
Mailing Address
City State Zip
Telephone E-mail NC PE Seal, Signature&Date
THE COMPLETED ENGINEERING CERTIFICATION,INCLUDING ALL SUPPORTING
INFORMATION AND MATERIALS,SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON-DISCHARGE PERMITTING UNIT
By U.S.Postal Service: By Courier/Special DeliveU:
1617 MAIL SERVICE CENTER 512 N. SALISBURY ST.
RALEIGH,NORTH CAROLINA 27699-1617 RALEIGH,NORTH CAROLINA 27604
WQ0009267 Version 3.1 Shell Version 151201 Page 11 of 11

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CITY OF JACKSONVILLE
PERMIT NO. WQ0009267
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34046'26.0"N 77033'18.0"W
34.773900,-77.555000
https://www.google.com/maps/place/34%C2%BO46'26.0%22N+77%C2%BO33'18.0%22W/@34.7739,-77.5571887,753m/data=!3m2!1 e3!4b1!4m5!3m4!1 sOxO:Ox... 1/1

�.
n
ROY COOPER ,..,
Governor
MICHAEL S.REGAN „ •� ,
secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
December 31, 2019
ROSS GARDNER—MILL MANAGER
WEYERHAEUSER NR COMPANY
524 PRIDE WAY
ELKIN,NORTH CAROLINA 28621
Subject: Permit No. WQ0005555
Weyerhaeuser—Elkin OSB Mill WWTF
Wastewater Irrigation System
Surry County
Dear Mr. Gardner:
In accordance with your permit minor modification request received November 4, 2019, we are
forwarding herewith Permit No. WQ0005555 dated December 31, 2019, to Weyerhaeuser NR Company
for the continued operation of the subject wastewater treatment and irrigation facilities.
This permit shall be effective from the date of issuance through August 31,2025,shall void Permit
No. WQ0005555 issued September 11, 2019,and shall be subject to the conditions and limitations therein.
The Permittee shall submit a renewal application no later than March 4,2025.
Please pay attention to the monitoring requirements listed Attachments A, B, and C for they may
differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
The following Attachments have been modified since the last permit issuance dated
September 11,2019:
➢ Attachment A—4 x Year sampling frequencies have been reduced to 3 x Year,and Weekly has
changed to Per Event.
➢ Attachment B—PAN limits for Fields A,B, CN,and CS have been removed.
➢ Attachment C—Chromium limit has been changed to reflect current 02L standards.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition,conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center,Raleigh,NC 27699-6714. Otherwise,this permit shall be final and binding.
.._QPNorth Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
Norrnicaaouru y
a /"`� 919.707.9000

Mr.Ross Gardner
December 31,2019
Page 2 of 2
If you need additional information concerning this permit, please contact Tessa Monday at (919)
707-3660 or tessa.monday(,@,ncdenr.gov.
Sincerely,
A
nda Culpepper,Director
Division of Water Resources
cc: Surry County Health Department(Electronic Copy)
Winston-Salem Regional Office, Water Quality Regional Operations Section(Electronic Copy)
Laserfiche File(Electronic Copy)
Digital Permit Archive(Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
WASTEWATER IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended,and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Weyerhaeuser NR Company
Surry County
FOR THE
continued operation of a 28,800 gallon per day(GPD)wastewater treatment and irrigation facility for the
treatment and disposal of cooling tower blow-down, clean-up waters from the wet electrostatic
precipitators,domestic wastewater,wastewater from the operation of a biofilter,non-contact cooling water,
mobile equipment wash water, demister drop-out box wastewater, periodic wash-down water from the
regenerative thermal oxidizer, and wastewater from the oil/water separator installed on the mill air
compressors,and consisting of:
three sidehill screens; a pre-fabricated McCrometer UltraMag influent flow meter; a pH control system to
buffer pH up or down; a defoaming system; a 4,800 gallon surge tank; polymer addition system for solids
removal; a static mixer; a 93,508 gallon flocculating clarifier; a 1,400 gallon sludge storage tank; a
Dissolved Air Floatation (DAF) unit; a belt press system for solids dewatering; a 420,000 gallon settling
pond connected with an 840,000 gallon settling pond connected with a 420,000 gallon spray irrigation pond
(i.e., a 230,000 gallon pond and a 190,000 gallon pond); a 250 gallon per minute (GPM)vertical chopper
pump; a 24.66 acre spray irrigation area; and all associated piping,valves,controls, and appurtenances
to serve the Weyerhaeuser — Elkin OSB Mill WWTF, with no discharge of wastes to surface waters,
pursuant to the application received November 4,2019,and in conformity with the Division-approved plans
and specifications considered a part of this permit.
This permit shall be effective from the date of issuance through August 31, 2025, shall void Permit No.
WQ0005555 issued September 11,2019,and shall be subject to the following conditions and limitations:
L SCHEDULES
1. The Permittee shall request renewal of this permit on Division-approved forms no later than March 4,
2025. [15A NCAC 02T .0105(b), 02T .0109]
WQ0005555 Version 4.1 Shell Version 181105 Page 1 of 10

H. PERFORMANCE STANDARDS
1. The Permittee shall maintain and operate the subject non-discharge facilities so there is no discharge to
surface waters, nor any contravention of groundwater or surface water standards. In the event the
facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper
operation and maintenance, or failure of the irrigation areas to assimilate the effluent, the Permittee
shall take immediate corrective actions, including Division required actions, such as the construction
of additional or replacement wastewater treatment or disposal facilities. [15A NCAC 02T
.0108(b)(1)(A)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02T .0108(b)(1)(A)]
3. Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and
regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T.0505(b)]
5. Application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0108(b)(1)(A)]
6. Wastewater irrigation fields permitted on or after December 30, 1983 have a compliance boundary that
is either 250 feet from the wastewater irrigation area, or 50 feet within the property boundary,
whichever is closest to the wastewater irrigation area. Any exceedance of groundwater standards at or
beyond the compliance boundary shall require corrective action. Division-approved relocation of the
compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common
ownership and permitted for use as a disposal system shall be treated as a single property with regard
to determination of a compliance boundary. [15A NCAC 02L.0106(d)(2),02L.0107(b),02T.0105(h),
G.S. 143-215.1(i), G.S. 143-215.1(k)]
7. The review boundary is midway between the compliance boundary and the wastewater irrigation area.
Any exceedance of groundwater standards at or beyond the review boundary shall require preventative
action. [15A NCAC 02L.0106(d)(1), 02L .0108]
8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary(i.e.,parcel subdivision). [15A NCAC
02L .0107(c)]
9. No wells, excluding Division-approved monitoring wells, shall be constructed within the compliance
boundary except as provided for in 15A NCAC 02L .0107(g). [15A NCAC 02L .0107]
10. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Surry
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
WQ0005555 Version 4.1 Shell Version 181105 Page 2 of 10

11. The facilities herein were permitted per the following setbacks:
a. The 10.4 acre spray irrigation area originally permitted prior to October 1, 1987 under Permit No.
14378, and subsequently never modified after October 1, 1987, have no setbacks. The original
permit (Permit No. 14378) pre-dates administrative code 15A NCAC 02H .02190), which was
effective October 1, 1987. Original facilities with no modifications or expansions are is still
covered under the 15A NCAC 02H .0200 rules effective February 1, 1976, which contain no
setback requirements. [15A NCAC 02H .0200]
b. An additional 10 acres of irrigation sites were originally permitted April 29, 1993. The setbacks
for spray irrigation sites originally permitted or modified from February 1, 1993 to August 31,2006
are as follows(all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 4001
ii. Each private or public water supply source: 100
iii. Surface waters: 100
iv. Groundwater lowering ditches: 100
v. Surface water diversions(upslope): 100
vi. Surface water diversions(downslope): 100
vii. Each well with exception of monitoring wells: 100
viii.Each property line: 150 z
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Each water line: 10
xi. Each swimming pool: 100
xii. Public right of way: 50
xiii.Nitrification field: 20
xiv.Each building foundation or basement: 15
1 Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H .02190)(5)]
WQ0005555 Version 4.1 Shell Version 181105 Page 3 of 10

c. An additional 8.53 acres of irrigation sites were originally permitted July 29, 2013. The setbacks
for spray irrigation sites originally permitted or modified from September 1, 2006 to August 31,
2018 are as follows(all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 4001
ii. Each habitable residence or place of assembly owned by the Permittee: 200
iii. Each private or public water supply source: 100
iv. Surface waters: 100
v. Groundwater lowering ditches: 100
vi. Surface water diversions: 25
vii. Each well with exception of monitoring wells: 100
viii.Each property line: 150 2
ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15
x. Each water line: 10
xi. Subsurface groundwater lowering drainage systems: 100
xii. Each swimming pool: 100
xiii.Public right of way: 50
xiv.Nitrification field: 20
xv. Each building foundation or basement: 15
1 Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing,owns both parcels separated by the property line.
[15A NCAC 02T.0506(a),02T.0506(e),02T .0506(f)]
d. The storage and treatment units were originally permitted April 29, 1993. The setbacks for storage
and treatment units originally permitted or modified from February 1, 1993 to August 31,2006 are
as follows(all distances in feet):
i. Each habitable residence or place of assembly under separate ownership(for 100 ,
activated sludge plants):
ii. Each private or public water supply source: 100
iii. Surface waters: 50
iv. Each well with exception of monitoring wells: 100
v. Each property line: 502
vi. Nitrification field: 20
' Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H.02190)(5)]
WQ0005555 Version 4.1 Shell Version 181105 Page 4 of 10

e. The Dissolved Air Floatation unit (DAF) was originally permitted September 11, 2019. The
setbacks for storage and treatment units originally permitted or modified on or after September 1,
2018 are as follows (all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 1001
ii. Each private or public water supply source: 100
iii. Surface waters: 50
iv. Each well with exception of monitoring wells: 100
v. Each property line: 50 2
1 Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02T .0506(b), 02T.0506(e), 02T .0506(f)]
III. OPERATION AND MAINTENANCE RE(UIREMENTS
1. The Permittee shall operate and maintain the subject facilities as a non-discharge system. [15A NCAC
02T .0500]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational
functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02T
.0507(a)]
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non-discharge facilities,the Permittee shall designate and employ a certified
operator in responsible charge(ORC),and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T
.0117]
4. The Permittee shall maintain vegetative cover on the irrigation sites, such that crop health is optimal,
allows even effluent distribution, and allows inspection of the irrigation system. [15A NCAC 02T
.0507(b)]
5. The Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites
listed in Attachment B. [15A NCAC 02T .0507(c)]
6. The Permittee shall not irrigate treated effluent during inclement weather, or when the soil is in a
condition that will cause ponding or runoff. [15A NCAC 02T .0505(x)]
7. Irrigation equipment shall be tested and calibrated once per permit cycle. [15A NCAC 02T .0507(d)]
8. Only treated effluent from the Weyerhaeuser—Elkin OSB Mill WWTF shall be irrigated on the sites
listed in Attachment B. [15A NCAC 02T .0501]
9. The Permittee shall not allow vehicles or heavy machinery on the irrigation area, except during
equipment installation or maintenance activities. [15A NCAC 02T .0507(e)]
10. The Permittee shall prohibit public access to the wastewater treatment,storage,and irrigation facilities.
[15A NCAC 02T .0505(q)]
11. The Permittee shall dispose or utilize generated residuals in a Division-approved manner. [15A NCAC
02T .0508,02T.11001.
WQ0005555 Version 4.1 Shell Version 181105 Page 5 of 10

12. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject
facilities. [15A NCAC 02T.05050)]
13. Freeboard in the interconnected 420,000 gallon settling pond, 840,000 gallon settling pond, 230,000
gallon irrigation pond, and 190,000 gallon irrigation pond shall not be less than two feet at any time.
[15A NCAC 02T .0505(d)]
14. Gauges to monitor waste levels in the interconnected 420,000 gallon settling pond, 840,000 gallon
settling pond, 230,000 gallon irrigation pond, and 190,000 gallon irrigation pond shall be provided.
These gauges shall have readily visible permanent markings, at inch or tenth of a foot increments,
indicating the following elevations: maximum liquid level at the top of the temporary liquid storage
volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest
point on top of the dam. [15A NCAC 02T.0507(f)]
15. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees,shrubs,and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T.0507(g)]
16. Metering equipment shall be tested and calibrated annually. [15A NCAC 02T.0507(d)]
17. Collected wastewater from washing down of the regenerative thermal oxidizer shall be introduced into
the wastewater treatment and spray irrigation facilities such that the permitted flow limit of the facilities
is not violated at any time. [15A NCAC 02T .0108(b)(1)(A)]
IN. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
facility's impact on groundwater and surface water. [15A NCAC 02T .0108(c)]
2. A Division-certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR. Facilities with a permitted flow less than 10,000 GPD may estimate their
flow from water usage records provided the water source is metered. [15A NCAC 02T .0105(k), 02T
.0108(c)]
4. The Permittee shall monitor the treated effluent at the frequencies and locations for the parameters
specified in Attachment A. [15A NCAC 02T.0108(c)]
5. The Permittee shall maintain records tracking the amount of effluent irrigated. These records shall
include the following information for each irrigation site listed in Attachment B:
a. Date of irrigation;
b. Volume of effluent irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly,monthly,and year-to-date hydraulic(inches/acre)loadings;
f. Continuous monthly and year-to-date loadings for any non-hydraulic parameter specifically
limited in Attachment B;
g. Weather conditions; and
h. Maintenance of cover crops.
[15A NCAC 02T .0108(c)]
WQ0005555 Version 4.1 Shell Version 181105 Page 6 of 10

6. Freeboard(i.e.,waste level to the lowest embankment elevation)in the interconnected 420,000 gallon
settling pond, 840,000 gallon settling pond, 230,000 gallon irrigation pond, and 190,000 gallon
irrigation pond shall be measured to the nearest inch or tenth of a foot,and recorded weekly. Weekly
freeboard records shall be maintained for five years, and shall be made available to the Division upon
request. [15A NCAC 02T.0108(c)]
7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for
each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and
IV.6.)on Form NDAR-1 for every site in Attachment B shall be submitted on or before the last day of
the following month. If no activities occurred during the monitoring month,monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(1)]
8. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. This record shall
include:
a. Name of the residuals hauler;
b. Non-Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T .0508(b)]
9. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Date of flow measurement device calibration;
b. Date of irrigation equipment calibration;
c. Visual observations of the plant and plant site; and
d. Record of preventative maintenance(e.g.,changing of equipment,adjustments,testing,inspections
and cleanings, etc.).
[15A NCAC 02T.0507(h)]
10. Monitoring wells MW-4, MW-5, MW-6, MW-7, MW-8, MW-9, MW-10, MW-11, and MW-12 shall
be sampled at the frequencies and for the parameters specified in Attachment C. All mapping, well
construction forms,well abandonment forms and monitoring data shall refer to the permit number and
the well nomenclature as provided in Attachment C and Figure 1. [15A NCAC 02T .0105(m)]
WQ0005555 Version 4.1 Shell Version 181105 Page 7 of 10

11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form(GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
[15A NCAC 02T.0105(m)]
12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each irrigation site listed in Attachment B. These results shall be maintained at the facility for five
years,and shall be made available to the Division upon request. Each Standard Soil Fertility Analysis
shall include the following parameters:
Acidity Exchangeable Sodium Percentage Phosphorus
Base Saturation(by calculation) Magnesium Potassium
Calcium Manganese Sodium
Cation Exchange Capacity Percent Humic Matter Zinc
Copper pH
[15A NCAC 02T .0108(c)]
13. Noncompliance Notification:
The Permittee shall report to the Winston-Salem Regional Office, telephone number(336) 776-9800,
within 24 hours of first knowledge of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate wastewater treatment.
c. Any facility failure resulting in a discharge to surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the irrigation sites.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Winston-Salem Regional Office within
five days of first knowledge of the occurrence, and this report shall outline the actions proposed or
taken to ensure the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)]
WQ0005555 Version 4.1 Shell Version 181105 Page 8 of 10

V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater
treatment and irrigation facilities. [15A NCAC 02T .0507(i)]
2. The Permittee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions,
facility deterioration, and operator errors that may result in discharges of wastes to the environment,
threats to human health, or public nuisances. The Permittee shall maintain an inspection log that
includes the date and time of inspection, observations made, and maintenance, repairs, or corrective
actions taken. The Permittee shall maintain this inspection log for a period of five years from the date
of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T
.0507(h), 02T .0507(i)]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property,premises,or place related to the wastewater treatment and irrigation facilities permitted herein
at any reasonable time for determining compliance with this permit. Division authorized
representatives may inspect or copy records maintained under the terms and conditions of this permit,
and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application,and Division-approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit,there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T .0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies(e.g., local, state, and federal)
may require. [15A NCAC 02T .0105(c)(6)]
5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall
submit a permit modification request on Division-approved forms. The Permittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor-owner. [G.S. 143-
215.1(d3)]
6. The Permittee shall retain a set of Division-approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T.0105(o)]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .01050)]
WQ0005555 Version 4.1 Shell Version 181105 Page 9 of 10

8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this per are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T .0110]
9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.613, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent,subsidiary,or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent,subsidiary,or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T .0120(b),02T.0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T .0120(c)]
Permit issued this the 31'day of December 2019
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
rivia Culpepper,Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0005555
WQ0005555 Version 4.1 Shell Version 181105 Page 10 of 10

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ATTACHMENT C—GROUNDWATER MONITORING AND LIMITATIONS Permit Number:WQ0005555 Version: 4.1
Monitoring Wells:MW-4,MW-5,MW-6,MW-7,MW-8,MW-9,MW-10,MW-11,and MW-12
GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS
PCS Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes
00680 Carbon,Tot Organic(TOC) mg/L 3 x Year Grab 1,6
00940 Chloride(as Cl) 250 mg/L 3 x Year Grab 1
01034 Chromium,Total(as Cr) 10 µg/L 3 x Year Grab 1
31616 Coliform,Fecal MF,M-FC Broth,44.5°C #/100 mL 3 x Year Grab 1
71900 Mercury,Total(as Hg) 1 µg/L 3 x Year Grab 1
76995 Methanol(Formaldehyde)Whole Water 600 µg/L 3 x Year Grab 1
00610 Nitrogen,Ammonia Total(as N) 1.5 mg/L 3 x Year Grab 1
00620 Nitrogen,Nitrate Total(as N) 10 mg/L 3 x Year Grab 1
00335 Oxygen Demand,Chemical(Low Level) mg/L 3 x Year Grab 1
00400 pH 6.5-8.5 Su 3 x Year Grab 1,2
00665 Phosphorus,Total(as P) mg/L 3 x Year Grab 1
70300 Solids,Total Dissolved- 180°C 500 mg/L 3 x Year Grab 1
GWVOC Volatile Compounds(GW) Present:Yes/No Annually Grab 1,4,5
82546 Water Level,Distance from measuring point feet 3 x Year Calculated 1,2,3
1. 3 x Year monitoring shall be conducted in March,July,and November;Annual monitoring shall be conducted in November.
2. The measurement of water levels shall be made prior to purging the wells.The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points(top of well casing)of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points(top of
casing)of all monitoring wells shall be surveyed relative to a common datum.
4. Volatile Organic Compounds(VOC)-In November only,analyze by one of the following methods:
a. Standard Method 6230D,PQL at 0.5 µg/L or less
b. Standard Method 621 OD,PQI,at 0.5 µg/L or less
c. EPA Method 8021,Low Concentration,PQL at 0.5 µg/L or less
d. EPA Method 8260,Low Concentration,PQL at 0.5 µg/L or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used shall meet the following qualifications:
a. A laboratory shall be DWR certified to run any method used.
b. The method used shall include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used shall provide a PQL of 0.5 µg/L or less that shall be supported by laboratory proficiency studies as required by the DWR Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 µg/L shall be qualified(estimated)and reported.
WQ0005555 Version 4.1 Attachment C Page 1 of 2

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FINDING OF NO SIGNIFICANT IMPACT
AND ENVIRONMENTAL ASSESSMENT
TOWN OF WILKESBORO
WILKESBORO CUB CREEK WASTEWATER TREATMENT PLANT EXPANSION
RESPONSIBLE AGENCY: NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
CONTACT: KAVITHA AMBIKADEVI, SECTION CHIEF
WATER INFRASTRUCTURE FUND SECTION
DIVISION OF WATER INFRASTRUCTURE
1633 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1633
[phone]
January 29, 2024

(This page intentionally left blank.)

FINDING OF NO SIGNIFICANT IMPACT
Article I, Chapter 113A of the North Carolina General Statutes requires an action to be subject to
the requirements of the North Carolina Environmental Policy Act(NCEPA) if it involves the
expenditure of public funds and if a potential impact is anticipated to the environment. The
project has been evaluated for compliance with the NCEPA and is determined to be a major
agency action, which will affect the environment.
Project Applicant: Town of Wilkesboro,North Carolina
Project Description: The proposed project will upgrade major components and
increase the capacity of the existing Wilkesboro Cub Creek
Wastewater Treatment Plant from 4.9 million gallons per day
(MGD) maximum month flow to 8 MGD maximum month flow.
Improvements will include upgraded influent pump station,
upgraded headworks, conversion of aeration basin to equalization
basin, influent buffering, addition of secondary treatment, tertiary
disk filtration, new UV disinfection system, new effluent flow
metering, improved aerobic digestion and thickening, replacement
of sludge dewatering unit, and a new operations building.
Project Number: CS370829-02 & SRP-W-0208
Project Cost: $72,000,000
Clean Water State $42,000,000
Revolving Loan Fund:
Wastewater State Reserve $18,000,000
Program:
Local Funds: $12,000,000
The review process indicated that significant adverse environmental impacts should not occur if
mitigative measures are implemented, and an environmental impact statement will not be
required. The decision was based on information in the Engineering Report/Environmental
Information Document (ER/EID) submitted by the applicant and reviews by governmental
agencies. The attached Environmental Assessment(EA),prepared by the Division based on the
ER/EID, supports this action and outlines mitigative measures that must be followed. This
Finding of No Significant Impact(FONSI) completes the environmental review record,which is
available for inspection at the State Clearinghouse.
No administrative action will be taken on the proposed project for at least 30 days after
notification that the FONSI has been published in the North Carolina Environmental Bulletin.
Sincerely,
16X1444U�
Kavitha Ambikadevi, Section Chief
Water Infrastructure Fund Section
Division of Water Infrastructure

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ENVIRONMENTAL ASSESSMENT
A. Proposed Facilities and Actions
The proposed project will upgrade major components and increase the capacity of the existing
Wilkesboro Cub Creek Wastewater Treatment Plant (WWTP) from 4.9 million gallons per day
(MGD)maximum month flow to 8 MGD maximum month flow. Improvements will include the
following components:
• Upgrade the influent pump station to increase the total pumping capacity of the municipal
flow.
• Retrofitted and upgrade the existing headworks including new screens and new grit
classifier.
• Convert the existing aeration basin to a wet weather flow equalization basin.
• Convert secondary clarifier 4 to an influent buffer tank to converge the municipal and
industrial flows upstream of secondary treatment and install pumps to convey the flow to
the biological treatment system.
• Upgrade secondary treatment by constructing three AquaNereda aerobic granular sludge
(AGS)tanks and converting secondary clarifier 3 to a dual sludge buffer(SB) and water
level correction(WLC) tank, which will serve to thicken the WAS before pumping to the
aerobic digesters; existing secondary clarifier 1 and 2,which are located in the
floodplain,will be decommissioned.
• A set of two tertiary disc filter may be installed as needed based on future nutrient
removal limits in the High Rock Lake basin.
• The existing UV system in the floodplain will be decommissioned, and a new UV
disinfection system will be installed outside of the floodplain.
• The existing effluent Parshall flume in the floodplain will be decommissioned, and a new
Parshall Flume will be constructed just downstream of the new UV disinfection system.
• The existing aerobic digesters will remain operational, and new disc thickening units will
be installed in 10 years or approximately by 2032. The timing of the disc thickening unit
is dependent on expected growth in the area and on the expenses of landfill tipping fees.
• The existing Huber Q-Press 800 sludge dewatering unit is nearing the end of its service
life and will be replaced with another unit of the same model. A second unit will be
installed to increase capacity.
• A new operations building will be constructed outside of the floodplain and near the
secondary treatment process for the plant operations staff.
Funding Status: The estimated total cost for the project is $72,000,000. The Town is applying for
a Clean Water State Revolving Fund(CWSRF) loan of$42,000,000 including $1,000,000 of
principal forgiveness and has been awarded a State Reserve Program (SRP) grant of
$18,000,000. The Town will fund the remainder of the project, including closing
costs/administrative fees of$1,110,0000,through local funds. The City may apply for additional
CWSRF funding.
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B. Existiniz Environment
Topography and Soils. Wilkesboro is located in the Piedmont physiographic province. The
elevation of the project area ranges from 946 feet mean sea level (msl) to 1,038 feet msl.
Portions of the project site are located within the 100-year flood plain.
The project site includes the following soil units: Banister fine sandy loam, 1 to 6 percent slopes,
rarely flooded(BaB), moderately well drained or somewhat poorly drained soils; characterized
as strongly acidic; Codorus loam, 0 to 2 percent slopes, frequently flooded (CoA), consist of very
deep, moderately well drained and somewhat poorly drained soils; Dan River loam, 0 to 4
percent slopes, occasionally flooded(DaA)very deep, well drained soils, characterized as very
strongly acidic in the upper parts through slightly acidic in the lower parts; Danripple sandy clay
loam, 8 to 15 percent slopes, moderately eroded(DpC2), very deep, well drained soils,
characterized as very strongly acidic to moderately acidic; Fairview sandy loam, 15 to 25 percent
slopes (FaD), very deep,well drained soils, characterized as extremely acidic to moderately
acidic throughout; Fairview sandy clay loam, 8 to 15 percent slopes, moderately eroded(FcC2)
soils, similar to Fairview sandy loam located in less steep terrain; Fairview-Urban land complex,
2 to 15 percent slopes (FrC) soils, also similar to Fairview sandy loam typically including built
upon urban lands; and Rhodhiss fine sandy loam, 25 to 60 percent slope (RdE), very deep, well-
drained soil characterized by very strongly acidic to slight acidic throughout.
Surface Water. The project area is located in the Yadkin Headwaters Subbasin of the Yadkin-
Pee-Dee River Basin(HUC 0304010103). Surface waters in the area include Cub Creek, Little
Cub Creek, and the Yadkin River. All are rated Class C. Cub Creek is impaired for poor fish
community.
Water Soply. The Town's public water supply draws water from the Yadkin River.
C. Existing Wastewater Treatment Facilities
The Town owns and operates the Club Creek WWTP, which is an activated sludge plant with a
permitted capacity of 4.9 MGD under NPDES Permit Number NC0021717 discharging to the
Yadkin River. The WWTP was constructed in 1965 with various improvements made since
construction. The plant has been maintained in good condition overall but is nearing capacity.
Some service components are nearing the end of their useful life. The liquids train consists of an
influent pumping station, screening and grit removal, an aeration basin with surface mixers,
secondary clarification, and UV disinfection. The solids train consists of aerobic digestion,
dewatering by a Huber screw press, and landfilling of dewatered solids. The average daily
effluent flows in 2019 and 2020 were 4.44 MGD and 4.77 MGD, respectively. The WWTP
receives 70 to 80 percent of its flow from Tyson Foods, Inc., and the WWTP site contains
Tyson's influent pump station and two of Tyson's pretreatment basins. The 2021 current average
daily flow is 4.21 MGD, which is approximately 86% of the plant's permitted capacity. The
Town has received 22 Notices of Violations (NOVs) for effluent permit exceedances between
December 2016 and December 2021. Several components are located within the 100-year
floodplain.
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In addition to the WWTP, the Town owns and operates a wastewater collection system
consisting of 67 miles of gravity sewer, 1,383 manholes, 10 miles of force main, and 13 pump
stations. An asset inventory and assessment study was recently completed including a 10-year
rehabilitation and replacement plan for the collection system.
D. Need for Proposed Facilities and Actions
The Town's existing WWTP is aging and under capacity. Upgrades are needed to replace aging
equipment, improve treatment, and provide additional capacity for anticipated demand. The
Town's NPDES Permit previously included requirements to monitor nutrients but did not specify
numerical nutrient limits. The speculative permit includes numerical limits for both TN and TP
which will require improved treatment, and the Town is experiencing industrial and commercial
growth.Nutrient limits to the Yadkin River may change depending on the final nutrient strategy
developed for High Rock Lake. The Town has received 22 Notices of Violations (NOVs) for
effluent permit exceedances between December 2016 and December 2021. In July 2021, the
Town received a Sewer Line Moratorium from NCDEQ. The moratorium was issued because in
the previous calendar year when the Town's effluent from the WWTP flow averaged 4.8 MGD
representing 97.2 percent of the plant's current treatment capacity.
The purpose of this proposed project there is to provide an upgraded and expanded facility that
will enable Wilkesboro to meet future permit limits while accommodating future growth.
E. Alternatives Analysis
No-Action: The No-action alternative would continue operation of the WWTP with aging
equipment, components located in the floodplain, exceeding flow limits, and unable to meet
future effluent water quality standards for total nitrogen and phosphorus. This alternative is
infeasible and was rejected.
Alternative 1 —AquaNereda Aerobic Granular Sludge (AGS) (Preferred): This alternative
consists of upgrading the secondary treatment process using an AquaNereda aerobic granular
sludge (AGS) system operating in three new sequencing batch reactors and increasing the
capacity of the WWTP from 4.9 MGD to 8 MGD. Associated improvements to the plant include
influent pump station upgrades, the existing headworks will be retrofitted and upgraded,
conversion of existing Clarifier No. 4 to an AGS influent buffer tank, construction of new tanks
required for the Nereda process, construction of a new UV disinfection system and effluent
measurement/monitoring facilities, and the addition of a new solids dewatering screw press. A
new operations building is also included in this alternative. The existing aerobic digesters will
remain in-use. This alternative is preferred because it meets the desired treatment flows for the
plant with the lowest treatment cost per gallon, greatest energy savings, and smallest spatial
footprint compared to other alternatives.
Alternative 2—Oxidation Ditch with Mobile Organic Biofilm Process: This alternative would
also upgrade treatment and increase the plant capacity using an oxidation ditch with Mobile
Organic Biofilm(MOB)process by Nuvoda. The oxidation ditch would be filled with Kenaf
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media to enhance treatment and settling, and a media retention screen would be included to filter
out any wasted media and return it to the biological process. Associated plant upgrades would
include updates to the influent pump station,rehabilitation of existing headworks system,
construction of a new ultraviolet(UV) disinfection system, construction of a high river effluent
pump station, addition of a new effluent flow meter,upgrades to the existing RAS pump station,
and addition of a new solids dewatering unit. This alternative was rejected due to higher
treatment cost per gallon, higher energy demand, and larger spatial footprint compared to the
preferred alternative. Additionally,this alternative would include constructing new treatment
components within the floodplain.
Alternative 3 —Conventional Sequencing Batch Reactor(SBR): This alternative consists of a
conventional SBR system with four tanks located adjacent to the existing maintenance building.
Associated plant improvements would include upgrades to the influent pump station,
construction of new headworks north of Tyson's pretreatment basins, construction of a new UV
disinfection system, addition of a new effluent flow meter, and addition of new solids thickening
and dewatering units. A new plant operations/control building would also be included in this
alternative. This alternative was rejected due to higher treatment cost per gallon, higher energy
demand, and larger spatial footprint compared to the preferred alternative.
F. Environmental Consequences and Mitigative Measures
Topography and Soils: Significant impacts to topography and soils are not anticipated. The
WWPT site has already been disturbed. Minimal grading will be required. Total impervious area
will change from 14 percent to 17 percent. Disturbed areas that are not within building footprints
will be re-seeded after construction. Impacts to the floodplain will include removing and
demolishing the existing aeration basin and Tyson influent pump station, adding rock to existing
access roads, and temporary erosion control devices. There will be no permanent changes to
existing elevations within the 100-yea floodplain. The project will comply with local FEMA
regulations including appropriate permits. The project will expand the WWTP, and secondary
and cumulative impacts (SCI) are possible due to future wastewater lines and development in the
service area. These impacts will be minimized through adherence to Town of Wilkesboro and
Wilkes County ordinances addressing floodplain development, flood damage prevention, sewer
use, and watershed development.
Land Use: Significant impacts to land use are not anticipated. The project is located within sites
owned by the Town of Wilkesboro and Tyson Foods and used for wastewater treatment. SCI will
be managed through the Town's Comprehensive Land Use Plan, which includes provisions for
preserving open spaces.
Wetlands: Significant impacts to wetlands are not anticipated. There are no wetlands on the
project site and therefore no direct impacts anticipated. SCI related to future growth will be
minimized through the Wilkes County Watershed Ordinance, which limits certain development
and places impervious surface limits on certain developments to project wetlands and streams.
Important Farmlands: Significant impacts to important farmlands are not anticipated. The project
area does include soils designated as prime and unique farmland, but the site is already disturbed
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and not in agricultural use. Potential SCI will be minimized through the NC Agricultural
Development and Farmland Preservation Fund, which promotes farmland preservation.
Public Lands and Scenic, Recreational, and State Natural Areas: Significant impacts to public
lands, scenic, recreational, or state natural areas are not expected. Parks and public lands in the
surrounding area may experience increase in noise during construction activities,but these
impacts will be minor and temporary.
Cultural Resources: Direct impacts to cultural and historic resources are not anticipated. The
Downtown Wilkesboro Historic District is located within a mile of the project area,but impacts
are not anticipated. Five previously recorded archaeological sites are located within one mile of
the project site and are not expected to be impacted due to construction activities occurring at
previously disturbed locations. The North Carolina State Historic Preservation Office (SHPO)
conducted a review of the project and is aware of no historic resources which will be impacted
by the project(July 29, 2022, ER 21-2531). Potential SCI will be minimized through
Wilkesboro's Historic Preservation Committee's guidelines.
Air Quality: No significant impacts to air quality are anticipated. Construction activities may
cause a temporary increase in emissions and will cease when construction is complete. Dust
control measures will be implemented, and open burning of materials will not be allowed.
Testing of emergency generators may cause temporary, short-term emissions. Otherwise, the
project will not result in new sources of air pollution. SCI to air quality are not anticipated.
Noise Levels: No significant noise impacts are anticipated. Noise from construction activities
will be temporary with construction hours restricted under the Town's Noise Ordinance.
Operational noise impacts may increase slightly as a result of additional components and new
technologies at the WWTP. Forested areas surrounding the project site create natural noise
buffers to minimize any noise for surrounding residences. SCI may include construction noise
for wastewater line installation and residential and industrial development. These impacts will be
minimized through compliance with Wilkes County's High Impact Land Use Ordinance.
Water Resources: No significant negative impacts to water resources are anticipated. A
sedimentation and erosion control plan will be implemented to minimize impacts to surface
water from construction activities. The project will provide a benefit to nearby surface waters by
removing several components from the floodplain and improving the treatment process and
qualify of effluent from the WWTP. SCI related to future develop will be minimized through the
Wilkes County Watershed Ordinance and stormwater provisions in the Town's Subdivision
Ordinance.
Forest Resources: Significant impacts to forest resources are not expected. The project site
includes scattered wooded areas. A small area of approximately 0.18 acre of upland forest will
be cleared. SCI from future development will be minimized through the Town's Tree,
Subdivision, and Zoning ordinance and Wilkes County Watershed Ordinance.
Shellfish or Fish and Their Habitats: Impacts to shellfish, fish, and their habitats are not expected
to be significant. There are no known occurrences of threatened or endangered aquatic species in
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the project site or immediate surrounding area. Impacts to aquatic species from construction
activities will be minimized through adherence to a sediment and erosion control plan. Aquatic
species will benefit from improved wastewater effluent quality. SCI related to future develop
will be minimized through the Wilkes County Watershed Ordinance and stormwater provisions
in the Town's Subdivision Ordinance.
Wildlife and Natural Vegetation: No significant impacts to wildlife and natural vegetation are
expected. No threatened or endangered species have been identified within one mile of the
project site. Suitable habitat exists for the Northern long-eared bat and tricolored bat. To protect
these species, the recommendation from the U.S. Fish& Wildlife Service (USFWS)to avoid tree
removal between March 15th and November 15t1i will be followed. Impacts to other terrestrial
species are not anticipated. Most of the project is located in previously disturbed and maintained
areas. SCI related to future development will be minimized through County and Town
development ordinances.
Introduction of Toxic Substances: The project is not expected to introduce toxic substances into
the environment. Construction specifications will include provisions for fuel, oil, and lubricants
to be contained and equipment to be properly maintained to prevent leakage and spills.
Chemicals used on-site will be controlled and maintained as currently required at the WWTP.
The U.S. Fish and Wildlife Service was consulted and provided guidance (June 2, 2023). The
North Carolina Wildlife Resources Commission,Natural Heritage Program, and DWR Winston-
Salem Regional Office do not object to the proposed project. The U.S. Army Corps of Engineers
was consulted and did not object to the project. The North Carolina Department of Natural and
Cultural Resources is aware of no historic resources which will be impacted by the proposed
project(July 29, 2022, ER 21-2531).
G. Public Participation, Sources Consulted
The Town of Wilkesboro held a public meeting on November 6, 2023. The meeting included a
presentation about the proposed project and opportunity for public comments. The Town also
provided a 30-day period for submission of written comments. Comments at the meeting
included support for the project from a councilman and a question about publishing time. No
written comments were received.
The current user charge for a typical residential customer is $30.77 per month for sewer and
water combined,based on consumption of 5,000 gallons per month. The proposed project will
increase the bill by $9.62, for a future sewer bill of$40.39. The Town intends to raise rates
through a series of smaller annual increases.
Sources consulted about this project for information or concurrence included:
1) City of Wilkesboro
2) Wilkes County
3) North Carolina Department of Environmental Quality
-Wildlife Resources Commission
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-Natural Heritage Program
-DEQ Winston-Salem Regional Office
-Division of Air Quality
-Division of Water Resources
-Division of Forest Resources
-Division of Environmental Assistance and Customer Service
-Division of Waste Management
4) North Carolina Department of Natural and Cultural Resources
5) North Carolina State Clearinghouse
6) North Carolina Department of Public Safety
7) U.S. Fish and Wildlife Service
8) U.S. Army Corps of Engineers
7

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Town of Wilkesboro I Cub Creek CCWWTP Expansion Project ER-EID 1 ��
Executive Summary r
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upgraded Secondary Clarifier 4 conversion to Building Future Disc Filter System
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conversion to Sludge Buffer
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L ""G ""' PROJECT LOCATION D6 i N MAP
0 Figure 2
CUB CREEK WASTEWATER TREATMENT PLANT EXPANSION
Figure 1.2. Project Location Map
7