NC0080853_Comments_20240610

ICLM AECOM
5438 Wade Park Boulevard,Suite 200
Raleigh,NC 27607,USA
T:919.854.6200
F:919.854.6259
aecom.com
June 5, 2024
RECEIVED
Mr. Joe Corporon JUN 1 0 2024
Division of Water Resources
North Carolina Environmental Management NCDE
Commission/NPDES Unit Q/DWR/NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on the NPDES Permit Renewal - Draft for 2nd Public Notice
Permit NC0080853
Salem Business Park Remediation Site
Nokia of America Corporation
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Corporon,
On behalf of Nokia of America Corporation (Nokia),AECOM prepared and submits this comment letter in
response to version 3 of draft National Pollutant Discharge Elimination System (NPDES) permit
NC0080853 (dated May 15, 2024)for the groundwater treatment system operating at the above-
referenced Site. Please include this letter and its attachments in the Site's administrative record.
Comment#1— Site Location - County is Incorrect in Draft Binder Cover Letter
Please update the project location to Forsyth County, rather than Surry County as referenced in page 1 of
the Draft Binder Cover Letter.
Comment#2— Treated Discharge Flowrate May Necessitate Reduced Pumping and Could Result in
Loss of Groundwater Containment
Version 3 of the draft renewal permit establishes an effluent flow limit of 0.07 MGD with the justification
that this limit is "[a]t Nokia's request, siting new remediation requirements and an intent to redesign of the
treatment system." (#3, Fact Sheet for Expidited (sic) Renewal and May 2024 Draft Permit Cover Letter.)
This justification is factually incorrect and should be modified or deleted on an issued renewal permit's
Fact Sheet.
As shown by our March 25, 2024 response to the Division of Water Resources' (Division) initial issuance
of a renewal permit on February 26, 2024 (withdrawn before becoming effective); our January 23, 2024
comment letter regarding version 2 of the draft permit renewal; and multiple email communications
between October and December of 2023 in response to version 1 of the draft permit renewal, Nokia never
requested a discharge limit of 0.07 MGD, nor did it propose a redesign of the groundwater treatment
system. We cannot respond to the "siting new remediation requirements" component of the justification
because we do not understand that reference and have no information about any "new remediation
requirements."
Regarding the other components of the justification, the now-withdrawn February 26, 2024 renewal permit
imposed an effluent discharge limit of 0.062 MGD, instead of the 0.120 MGD limit that Nokia had, in fact,
offered in exchange for other relief in the new permit. Nokia has repeatedly informed the Division that a
permit limit of 0.062 MGD would result in unnecessary restrictions to operations under the groundwater
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A=COM
treatment system's current design and pumping protocols.A permit limit of 0.070 MGD is only marginally
higher and will produce the same problems.
More specifically, and as further explained in those earlier communications and in a conference call with
the Division held April 22, 2024, a limit that low is:
1) inconsistent with Nokia's 2023 offer to lower the current effluent flow rate of 0.302 MGD to a
significantly reduced rate of 0.120 MGD;
2) likely cannot be met without adverse impacts to well pumping volumes, given that current
flow rates average between 0.06 and 0.08 MGD; and
3) may result in a reduction or loss of hydraulic containment for groundwater.
The above-referenced submittals are attached for your convenience.
Under the current 0.06 to 0.08 MGD daily flow average discharge rate, a renewal permit limit as low as
0.07 MGD will produce multiple, recurrent violations of the permit limit unless operational changes were
implemented. Achieving permit compliance, then, likely will require discontinued use of some recovery
wells or reduced pumping volumes for multiple wells. The Division may regard this as "redesign of the
treatment system," but that is not something intended by Nokia, nor is it a desirable result. A reduced level
of groundwater recovery may negatively impact the effectiveness of the remediation system in maintaining
hydraulic control over the groundwater plume.
Accordingly, Nokia again requests that the effluent flowrate be established at 0.120 MGD, consistent with
the requests sent via email on November 16, 2023, via letter on January 23, 2024, and as discussed in
the conference call of April 22, 2024.
Comment#3—Receiving Stream—Need Copy of Permitting Guidance Document
The Site's permitted discharge has always used the unnamed tributary of Salem Creek as the receiving
stream via an existing stormwater system, with the current permit recognizing the diluting effects of that
receiving stream. Version 3 of the revised draft permit specifically noted that nothing has physically
changed regarding the receiving stream or the stormwater collection system. Nonetheless, the revised
draft permit states that"effluent receives no credit for dilution per current Permitting Guidance."We are
unfamiliar with the Permitting Guidance document cited. Please share a copy of, or website address for,
this Guidance document, as well as the timing and publication information underlying its issuance so that
we can understand the history underlying such a consequential change in policy.
Comment#4—PCE Compliance Schedule—New Date of August 2025
The Renewal Permit issued February 26, 2024 (never in-effect and now withdrawn)established a monthly
average PCE effluent limit of 3.3 pg/L(as compared with the current permit limit of 6.12 pg/L). Presumably
because of this drastic reduction to almost 50% of the prior limit,the February 26 permit set a compliance
date of May 31, 2028 to allow implementation of the technology changes required to address the stricter
limit. Version 3 of the draft renewal permit retains that 3.3 pg/L proposed limit for PCE, yet sets a
compliance date almost three years sooner: i.e., one year after the renewal permit's expected effective
date of early August 2025, instead of the end of May 2028.
Nokia did not propose this lower PCE limit.As with the lower effluent discharge limit, such a lower PCE
limit will require either modifying the existing treatment system or changing the entire groundwater remedy
to add an in-situ treatment element. Designing and implementing either option will require significant time
and resources, possibly including pilot studies to evaluate feasibility, as well as coordination with other
regulators within the Department(i.e., Division of Waste Management). Nokia therefore requests that the
PCE compliance schedule be returned to the 2028 date adopted by the withdrawn February renewal
permit.

AECOM
Comment#5—AT-3 Submission Directions—Request Restoration of Electronic Submittals
In Permit Section A. (2), the email reference for electronic submission of AT-3 forms is no longer present.
Electronic submittal of AT-3 forms has been the standard at this Site for several years and was allowed by
the now-withdrawn February 26, 2024 renewal permit. Please include updated directions for the electronic
submittal of AT-3 forms in the final renewal permit to allow continuation of this successful process step.
Comment#6— Outfall Coordinates— Correct Coordinates Given
Coordinates for the Outfall differ between the Draft Permit Binder(36° 03' 18" N, 80° 13' 51"W), the permit
Facility Location map figure (same), and the Draft Permit Fact Sheet (36° 03' 17" N, 80° 13' 51"W). The
coordinates in the Draft Permit Fact Sheet are a more accurate representation of Outfall location. Please
change all Outfall references and figure depictions to coordinates 36° 03' 17" N, 80° 13' 51"W.
Thank you in advance for your consideration of these points. Please contact either of the undersigned for
any questions or clarifications.
Yours sincerely,
.G ,. •.l `�`,iJt/V 11, daoL,C.Z,{�--
Conan Fitz9 e of (d PE Cristin Dolan
Project Manager,AECOM Engineer,AECOM
AECOM AECOM
T: [phone] T: [phone]
E: [e-mail] E: [e-mail]
cc: John Galasso, Nokia of America Corporation
Attachments:
1) Email Correspondence dated November 16, 2023; C. Dolan AECOM to J. Corporon NCDEQ
2) Comments on the Draft V2 NPDES Permit Renewal; Permit NC0080853; January 23, 2024 Letter from
AECOM to NCDEQ
3) Response to the NPDEQ Permit Renewal; Permit NC0080853; March 25, 2024 Letter from AECOM to
NCDEQ

ATTACHMENTS

ATTACHMENT 1
Email Correspondence dated November 16, 2023
C. Dolan AECOM to J. Corporon NCDEQ

Dolan, Cristin
From: Dolan, Cristin
Sent: Thursday, November 16, 2023 1:00 PM
To: [e-mail]
Cc: Fitzgerald, Conan
Subject: Draft NPDES Review
Good Afternoon Joe-
I'm Cristin Dolan, an engineer with AECOM working on the Salem Business Park Remediation Site in Winston-Salem, NC.
Our team received the Draft Permit Review for NPDES NC0080853,and are hoping you can help us work through a
handful of related questions below.
1. Please clarify the timeline for:
a. Public Notice Issuance
b. Response period for AECOM (30 days from Nov 15 or due by Nov 30)?
c. The expected timeline for the changes proposed in the new permit to take effect.
2. Are you able to provide the RPA calculation file for PCE and other contaminants?
3. The permitted flow of 0.302 MGD predates the current system configuration established in the 2012
modifications, and can be reduced. Currently system operations lend to a top end daily flow of 0.06 to 0.08
MGD. Nokia would be willing to reduce the permitted flow rate in the range of 50-65%if that would provide
some relief on the effluent limits.
4. Regarding effluent limits could the NCDEQ clarify
a. Why monthly averages were added for Total Suspended Solids(TSS)and Oil&Grease(O&G)?
b. Why daily maximums were added for O&G and tetrachloroethylene?
5. Nokia and AECOM are disappointed to see pH monitoring added to this permit, since the local groundwater that
is treated by the remediation system is often naturally less than 6 standard units. Could the NCDEQ please
clarify:
a. What are the expectations and regulatory requirements for the method of pH monitoring? AECOM
understands that off-site laboratory analyses is not permitted.
b. Will there be any consideration to the background conditions of the groundwater treated,or the pH of
the receiving stream, in establishing the final limits for this permit?
c. Currently the permitted system operates without adding treatment chemicals to the NPDES
discharge. Does the NCDEQ prefer that Nokia begin to add treatment chemicals to the effluent to
modify the discharge pH to be above natural conditions?
d. Per question 1, please clarify the timeline for this change to take effect,and whether there will be a
grace period to accommodate a change that may require new treatment equipment or other system
modifications.
6. Does change in O&G analytical parameter code reflect a change in analytical method we need to request?
Please let me know if you would like to set up a call to discuss.Thank you,
Cristin Dolan
Engineer, Environment
she, her, hers
M +1.304.830.9425
cristin.dolanc aecom.com
Click here to connect with me on LinkedIn
AECOM I Raleigh. NC
1

5438 Wade Park Boulevard, Suite 200
Raleigh, NC 27607, USA
T+1.919.461.1100
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2

ATTACHMENT 2
Comments on the Draft V2 NPDES Permit Renewal
Permit NC0080853
January 23, 2024 Letter from AECOM to NCDEQ

AECOM AECOM
5438 Wade Park Boulevard,Suite 200
Raleigh,NC 27607,USA
T 919.854.6200
F:919.854.6259
aecom.com
January 23, 2024
Mr. Joe Corporon
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on the Draft V2 NPDES Permit Renewal
Permit NC0080853
Salem Business Park Remediation Site
Nokia of America Corporation
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Joe Corporon,
On behalf of Nokia of America Corporation (Nokia),AECOM prepared this comments letter in response to
the draft National Pollutant Discharge Elimination System (NPDES)permit issued on December 29, 2023
for the groundwater treatment system (GWTS)operating at the site, as well as respond to a Division of
Water Resources (DWR) request regarding the receiving stream dated January 18, 2024.
Comment#1 —Facility Location
The GWTS is located within Salem Business Park at 3370 Old Lexington Road, Winston-Salem, in
Forsyth County, North Carolina. Throughout the permitting documents, please remove references to
Starlight Drive, which is west of the railroad tracks from the Salem Business Park and does not border the
Salem Business Park at any point.
Comment#2— Treated Discharge Flowrate
Thank you for reviewing our request to review the treated discharge flowrate. The previously permitted
discharge flowrate of 0.302 MGD predates the current system configuration, which was established in the
2012 modifications. Current system operations lend to a top end daily flow of 0.06 to 0.08 MGD. To
preserve tolerances for operational variability, Nokia requests that the maximum effluent flowrate be
established at 0.120 MGD, consistent with the request sent via email on November 16, 2023.
Comment#3—Receiving Stream
In response to an email request dated January 18, 2024 received from Mr. Joe Corporon of the Division of
Water Resources (DWR), AECOM has contacted the Stormwater department for the City of Winston-
Salem. The city was willing to share screenshots of their internal GIS stormwater piping network, which
should clarify answers to the questions from the DWR. The screenshots with notes from the call are
included as Attachment A to this letter.
A. In the Attachment A figure, blue segments have known dimensions and orientation within the
Winston-Salem internal GIS. Segments in yellow are undefined flow connectors.
B. The effluent discharge for FE-151 (Outfall 001)joins the stormwater discharge just east of the
railroad line. From there the discharge is to the west underneath the railroad tracks.
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C. After the stormwater drainage flows under the railroad tracks, it enters a series of underground
culverts which collect stormwater from the region between Lexington Road and Interstate 285.
D. Subsequently, the culverted discharge crosses underneath Interstate 285, collecting additional
stormwater from the region west of the interstate. This culvert crosses underneath Cassell Street
towards an unnamed tributary of Salem Creek. According to city records, the stormwater
drainage enters another 82-inch culvert which runs parallel to the unnamed tributary towards the
northwest for approximately 150 feet past another tributary, before the culverted flow finally
discharges into the unnamed tributary.
In summary, the permitted effluent drains west from its discharge point via underground culverts that
eventually run parallel to and finally drain into an unnamed tributary of Salem Creek.At the point of this
discharge, the unnamed tributary receives drainage from substantial areas both east and west of
Interstate 285 that are well beyond the ARC GIS image provided by the City of Winston-Salem.
In accordance with emails received from Mr. Joe Corporon on January 4, 2024, and January 18,AECOM
understands that the DWR is internally deliberating on details surrounding the receiving stream and will
therefore need to issue a revised draft once this is completed. AECOM and Nokia recommend that the
permit maintain the receiving stream criteria from the current permit, as we are unaware of any
downstream changes that would necessitate reducing the criteria of the receiving stream flow. If changes
from the current permit are a part of the next draft permit,AECOM and Nokia reserve the right to further
comment.
Comment#4— 1,4-Dioxane Offsite Source(Introductory Letter page 2 of 2)
Within the Introductory Letter, summary item#8, DWR states 1,4-Dioxane "reportedly originates from
offsite." Historically 1-4 Dioxane was commonly used as a stabilizer for chlorinated solvents; as such, its
detection at this remediation site is not unexpected. Nokia respectfully requests that DWR share any data
that indicates 1,4-Dioxane may have other sources that originate from offsite.
Comment#5— 1,4-Dioxane Sampling Frequency(Introductory Letter page 2 of 2 and Table A. (1.)]
Within the Introductory Letter, summary item#8, DWR states "1,4-Dioxane effluent data do not show
reasonable potential".As analyzed in the GWTS effluent during quarterly sampling from 2021 to 2023,
effluent concentrations of 1,4-Dioxane range from non-detect to below 10 pg/L. Given that 1,4 Dioxane is
approximately an order of magnitude or more below the 15A North Carolina Administrative Code subpart
2B (NCAC 2B)Surface Water standard of 80 pg/L prior to mixing with the unnamed tributary of Salem
Creek, an increase in monitoring frequency does not seem warranted. A decrease, or possibly elimination
of monitoring for this constituent appears more consistent with historic results.
Comment#6— Oil& Grease Daily Maximum[Introductory Letter page 2 of 2 and Table A. (1.)]
Table A. (1.)documents the Daily Maximum (DM) Effluent Limit for Oil and Grease as 20.0 mg/L.
However, the Introductory Letter summary item#6 documents the Oil and Grease DM Limit as 30.0 mg/L.
Please clarify which value stands as the DM Limit for Oil and Grease.
Comment#7—Bag Filtration (Supplement to Permit Cover Sheet)
On March 22, 2021,AECOM received approval from NCDEQ's Water Quality Permitting Section of
Nokia's to discontinue the use of bag filters, as the filters were primarily utilized to prevent sediment
buildup within the GAC filters. On the Permit Cover Sheet, please add a note to indicate the bag filters are
back-up equipment, with primary function to preventing sediment buildup within the back-up GAC filters.

AECOM
Comment#8—Map Features(Site Map)
On the facility map, please revise location callouts to represent conditions of the following pertinent
features:
1. The callout identifying Salem Business Park is shown to the west of the railroad tracks. Salem
Business Park is located east of the railroad tracks.
2. The callout identifying Outfall 001 is shown to the west of the railroad tracks. Outfall 001 is
located east of the railroad tracks.
3. The Salem Creek callout identifies a surface water segment which is an unnamed tributary to
Salem Creek, rather than Salem Creek itself.
If you have any questions or need additional information, please contact Conan Fitzgerald at(919)461-
1260.
Yours sincerely,
•
;; Cuot ,� da
Conan Fitzgerald Cristin Dolan
Project Manager,AECOM Engineer,AECOM
AECOM AECOM
T: [phone] T: [phone]
E: [e-mail] E: [e-mail]
cc: John Galasso,Nokia of America Corporation
Attachment A
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Attachment A
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TO CITY OF W-S.
2. INFORMATION SUMMARIZED IN FIGURE WAS CAPTURED ON A PHONE CALL BETWEEN THE CITY OF W-S AND AECOM.ARCGIS DATABASE INTERNAL TO CITY OF W-S CONTAINS ADDITIONAL
INFORMATION FOR EACH BLUE SEGMENT,POTENTIALLY INCLUDING:SEGMENT LENGTH,UPSTREAM AND DOWNSTREAM INVERTS,UPSTREAM AND DOWNSTREAM STRUCTURES,AND SLOPE.
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O "
3

ATTACHMENT 3
Response to NPDES Permit Renewal
Permit NC0080853
March 25, 2024 Letter from AECOM to NCDEQ

AECOM AECOM
5438 Wade Park Boulevard,Suite 200
Raleigh.NC 27607,USA
T:919.854.6200
F:919.854.6259
aecom.corn
March 25, 2024
Mr. Joe Corporon
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Response to NPDES Permit Renewal
Permit NC0080853
Salem Business Park Remediation Site
Nokia of America Corporation
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Corporon,
On behalf of Nokia of America Corporation (Nokia),AECOM prepared this letter in response to the
National Pollutant Discharge Elimination System (NPDES) permit renewal issuance for the groundwater
treatment system (GWTS) operating at the site.
AECOM received the attached Permit and fact sheet from the North Carolina Division of Water Resources
(DWR)via email on March 11, 2024.As a preliminary matter, please note that the Permit's cover letter
was addressed to the undersigned, but at an address which corresponds to Nokia of America
Corporation's (Nokia) New Jersey corporate address.The undersigned is employed by Nokia's
environmental consulting company AECOM. The only other addressee was AECOM's Cristin Dolan in
AECOM's Raleigh office. Correspondence intended for Nokia should be addressed to Nokia's remediation
manager for this site: G. John Galasso, P.E., at Mr. Galasso's Nokia address of 600-700 Mountain
Avenue, Murray Hill, NJ 07974. We believe you already have Mr. Galasso's email address.
As for the Permit itself,AECOM and Nokia have identified terms in the new Permit which require change
and/or clarification.AECOM attempted to provide feedback regarding these points prior to the Permit's
release for public comment(see attached comment letter of January 23, 2024), but that comment letter
was sent on the same date that DWR initiated its second public comment review period and DWR does
not appear to have considered that correspondence before issuing the Permit(based on the statement in
the Permit that no public comments were received).
Regardless of how this situation developed, however,the items identified below represent disputes that
will require Nokia to initiate a contested case under Chapter 150B of the North Carolina General Statutes.
We would strongly prefer to avoid that route and resolve these issues informally, as encouraged by
N.C.G.S. Chap. 150E-22.
Accordingly, we request an in person meeting, an electronic meeting, or a telephone conference with you
at your earliest opportunity so that we can seek such a resolution. We also note that according to the
Permit, its terms become effective on April 1, which does not allow a full "30 days from receipt" appeal
period. Given this and the urgency of the change required to the Permit's effluent flow limit, Nokia will
have no choice but to file for administrative relief on or before March 29, 2024.
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Effluent Flow Limit
In a November 16, 2023 email to DWR discussing the draft revised permit,AECOM noted that the current
"top end daily flow"discharge from the groundwater treatment system was 0.06 to 0.08 million gallons per
day(MGD), and that the then-permitted flow limit of 0.302 MGD could be reduced by 50-65%"if that
would provide some relief on the effluent limits."Applying such a 50-65% reduction in flow would have
produced a new discharge rate limit of between 0.106-0.151 MGD.
It appears that DWR may have misinterpreted this suggestion, and instead characterized it as a request
from AECOM/Nokia to lower the flow limit by almost 80%to 0.062 MGD.This was not only mistaken, but
also may produce an adverse impact on the environment.The current 0.06 to 0.08 MGD daily flow
average discharge rate would produce multiple, recurrent violations using a 0.062 MGD limit.Achieving
compliance with that low limit likely will require AECOM to either discontinue use of some recovery wells
or reducing the pumping volume of all or most of the wells.Any reduction in the rate of groundwater
recovery could reduce the effectiveness of the groundwater remediation system and potentially cause a
loss of hydraulic control over a groundwater plume that otherwise has been reducing-to-stable for
decades.
Receiving Stream Flow Statistics
We would like to understand the rationale for the significant changes to receiving stream flow statistics. In
previous communications to DWR,AECOM provided information on the receiving stream as requested by
DWR, including additional information on the infrastructure downstream of the remediation system effluent
outfall. Please refer to the attached comment letter of January 23, 2024 for further information.We do not
understand the basis on which DWQ is changing the receiving stream criteria from the previously
established permits, as we are unaware of any downstream changes that would necessitate reducing the
criteria of the receiving stream flow.
Tetrachloroethylene(PCE)Discharge Limit.
The prior permit limit for PCE for this facility was a monthly average of 6.12 pg/L.The new Permit's
monthly average limit is 3.3 pg/L. It appears that DWR imposed this permit limit because of its conclusion
that the receiving stream is zero flow and therefore the PCE limit was set as the same as the applicable
surface water standards.
Additionally, prior draft versions of the permit contained proposed PCE limits of either 5.0 pg/L monthly
average(MA)and 4.67 pg/L daily maximum (DM), or alternatively, no PCE limit.The current Permit's PCE
limit of 3.3 pg/L MA does not appear consistent with the draft permit correspondence.
1,4 Dioxane Sampling Frequency.
We do not understand the rationale behind increasing 1,4-dioxane sampling frequency from quarterly to
monthly. DWR notes that the source of the 1,4-dioxane is unknown, but that is not consistent with the
facility's historical use of chlorinated solvents (which can contain 1,4-dioxane).
Additionally,AECOM previously provided DWR with facility sampling results indicating the presence of 1,4
dioxane, but with effluent flow detections that never exceeded 8 to 9 pg/L(approximately 10.5%of the 80
pg/L surface water standard).
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AECOM
Altogether, Nokia would strongly prefer to avoid initiatinga contested case and administrative hearing
9Y
procedures, but is concerned that the new Permit flow rate limits will hinder effective operation of the
groundwater remediation system required under a corrective action permit issued by the Division of Waste
Management.
We therefore request your prompt attention to the items identified above prior to March 29, 2024.
Yours sincerely,
Conan Fitzgerald
Associate Vice President, Engineering
AECOM Technical Services, North Carolina
T: [phone]
E: [e-mail]
cc: John Galasso, Nokia of America Corporation
Attachment A Permit and Fact Sheet
Attachment B AECOM Response Letter January 23 2024
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Attachment A
Permit and Fact Sheet

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
40 STAh
.ROY COOPER
Governor
ELIZABETH BISER
1r . �
Secretary `.
RICHARD E. ROGERS, JR �Ow"
Director NORTH CAROLINA
Environmental Quality
2/26/2024
Nokia of America Corporation(Nokia)
Attn:Conan Fitzgerald,PE,AVP Engineering
600 Mountain Avenue
Murray Hill,New Jersey 07974
do Cristin Dolan,Engineer Environmental
AECOM/Raleigh
5438 Wade Park Boulevard,Suite 200
Raleigh,North Carolina 27607
Subject: Renewal Issuance NPDES Permit NC0080853
Nokia Groundwater Treatment System,WPCS Grade PC-1
Salem Business Park Remediation Site
3370 Old Lexington Road,Winston-Salem
Forsyth County
Ms.Dolan:
The Division of Water Quality(DWR or the Division)understands that your client,Nokia of America
Corporation(Nokia),proposes to reduce the treated discharge flowrate for renewal.Based on your email of
16Nov2023,you propose an effluent flow range of 0.060 to 0.080 MGD.We agree that this is reasonable
considering our calculated discharge average of 0.062 MGD over the previously permitted discharge cycle.
There is an additional change.DWR considers that receiving-stream flows recorded in the Basinwide
Information System(BIMS)are likely in error.BIMS lists stream-flow average of 0.40 cfs;30Q2=0.14 cfs,
7Q1Ow=0.13 cfs,and 7Q lOs=0.05 cfs.We feel these flows reflect the mainstem of Salem Creek and do
not reflect streamflow at the outfall.
Considering that this effluent discharges at the very top of the hydrological unit,DWR has assumed zero-
flow conditions[7Q10/30Q2=0.0 cfs]at Outfall 001.It follows that the Division has recalculated flow-
limit reasonable potential analyses(RPAs)and the instream waste concentration(IWC)as these dictate
permit limits and monitoring requirements[see RPA attached to the Fact Sheet].
Summary of Revisions for Renewal
1. Discharge flow—previously 0.302 MGD,herein recalculated for renewal as 0.062 MGD.
2. Updates-Supplement to Permit Cover Sheet,other permit texts,Electronic Reporting[A.(5.)]
and the Site Map.
3. Receiving-Stream—discharge at the top of the drainage reflects zero flow receiving-stream
conditions [7Q10/30Q2=0.0 cfs], per USGS.Renewal assumes instream waste
concentration(IWC)= 100%.
4. Public Notice-Because of revised effluent flow and streamflow,the permit draft was offered for
additional Public Notice on 23Jan2024—no comments received.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center Raleigh,North Carolina 27699-1617-919.707.3616

DocuSign Envelope ID:EE4E51 B2-171E-4A4E-AF39-EF6D30132FAB
Nokia of America Corporation
do Christin Dolan,AECOM/Raleigh
Renewal—Draft v3 Review
Jan2024
5. Tetrachloroethylene(PCE)—Notwithstanding the modified IWC to 100%,PCE continues to
show reasonable potential to exceed its surface water-quality standard. Monitoring therefore
continues Monthly with permit limits in accord with the RPA.Limits=3.3 µg/L Monthly
Average(MA),and Daily Max(DM)=6.6 µg/L(MA x 2).A Schedule of Compliance is
addressed as Special Condition A.(3.).
6. O&G—renewal revises the BIMS analytical parameter code from 00556 to 00552(as appropriate
for industrial discharges).Renewal O&G limits are 15 mg/L(MA)and 30 mg/L(DM).
7. TSS—renewal retains 30 mg/L as DM[anti-backsliding]but adds 15 mg/L MA[EPA requires
both limits].
8. 1,4-Dioxane effluent data do not show reasonable potential[see RPA MAX Predicted= 10 µg/L,
Allowable=80 µg/L].However,influent 1,4-Dioxane is NOT remediated by current treatment
technology(air striping)and reportedly originates from offsite.Therefore,renewal considers 1,4-
Dioxane a new parameter of concern[see RPA].Monitoring is hereby revised from Quarterly to
Monthlywithoutpermit limits,in an effort to establish a viable effluent database[Table A. 1. .
( )]
Monitoring and reporting are subject to Special Condition A.(4.).
9. pH-added monitoring to the permit[required by EPA for all industrial discharges]
If any parts,measurement frequencies,or sampling requirements contained in this permit are unacceptable,
you have the right to an adjudicatory hearing,upon written request submitted within thirty(30)days after
receiving this letter.Your request must take the form of a written petition conforming to Chapter 150B of the
North Carolina General Statutes,and you must file it with the office of Administrative Hearings,6714 Mail
Service Center,Raleigh,North Carolina 27699-6714.Unless such a demand is made,this permit becomes
fmal and binding.
This permit is not transferable except after notifying the Division of Water Resources.The Division may
require permit modification,or revocation and re-issuance.Please note that this permit does not affect your
legal obligation to obtain other permits required by the Division of Water Resources,the Division of Land
Resources,the Coastal Area Management Act,or other federal or local governments.
If you have questions,or if we can further assist you,please email my staff member,Joe R.Corporon,P.G.
at[[e-mail]].
Respectfully,
DocuSigned by:
c
8328844CE9E84A1...
John E.Hennessy,Section Chief
Water Quality Regional Operations
NCDEQ/DWR/NPDES Permitting
ec: NPDES Permit Files[Laserfiche]
DWR/WSRO,Gary Hudson[[e-mail]];Jenny Graznak
DWR/Aquatic Toxicology Branch,Attn.Molly Nicholson[[e-mail]]
DWR/OCU,Jeffrey Talbot[[e-mail]]
Nokia/John Galasso,Remediation Manager[[e-mail]]
AECOM/Raleigh,Cristin Dolan,[[e-mail]]

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General Statute 143-215.1,other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission,and the Federal Water Pollution Control Act,as amended,
Nokia of America Corporation
is hereby authorized to discharge wastewater from a facility located at
Salem Business Park Remediation Site
3370 Old Lexington Road, Winston-Salem
Forsyth County
to receiving waters designated as unnamed tributary to Salem Creek in the Yadkin-Pee-Dee River
Basin in accordance with the discharge limitations,monitoring requirements,and other conditions
set forth in Parts I,II,III,and IV hereof.
This permit shall become effective April 1, 2024
This permit and the authorization to discharge shall expire at midnight on June 30, 2028.
Signed this day February 26/2024
by:
".—8328B44CE9EB4A1...
John E.Hennessy, Section Chief
Water Quality Regional Operations
By Authority of the Environmental Management Commission
Page 1 of 7

DocuSign Envelope ID:EE4E51 B2-171 E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility,whether for operation or discharge are hereby
revoked.As of this permit issuance, any previously issued permit bearing this number is no longer
effective.Therefore,the exclusive authority to operate and discharge from this facility arises under
the permit conditions,requirements,terms,and provisions included herein.
Nokia of America Corporation
is hereby authorized to:
1. continue to operate and maintain an existing 0.062 MGD groundwater remediation treatment
system consisting of,but not limited to:
• extraction wells
• feed-water equalization
• bag filtration(pre-filters for the GAC
• granular activated carbon(GAC)filter,as back-up for air stripper
• low-profile air stripper
these facilities located at the Salem Business Park Remediation Site, 3370 Old Lexington
Road, Winston-Salem,Forsyth County,and
2. discharge from said treatment works via Outfall 001,at the location specified on the attached
map, into an unnamed tributary(UT)to Salem Creek [Stream Segment_12-94-12-(4)],a
waterbody currently classified C within hydrological unite 03-07-04 [HUC: 0304010113] of
the Yadkin-Pee Dee River Basin.
Page 2 of 7

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B.0400 et seq., 15A NCAC 02B .0500 et seq.]WPCS Grade PC-1 [15A NCAC 08G.0306]
During the period beginning on the effective date of the permit and lasting until expiration,the
Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored,
and reported by the Permittee as specified below:
PARAMETER EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly Daily Measurement Sample Sample
Parameter Code Average Maximum Frequency Type Location
Flow, MGD 50050 0.062 Continuous Recorder Influent or
Effluent
pH(Standard Units) 00400 Not<6.0 or>9.0 s.u. Monthly Grab Effluent
Total Suspended Solids(TSS) C0530 15.0 mg/L 30.0 mg/L Monthly Grab Effluent
Oil and Grease(mg/L) 00552 15.0 mg/L 30.0 mg/L Monthly Grab Effluent
Tetrachloroethene(PCE) 78389 3.3 !AWL 2 6.6 µg/L 2 Monthly 3 Grab Effluent
1,4-Dioxane(µg/L) 82388 Monitor and Report 3 Monthly Grab Effluent
Whole Effluent Toxicity 4
TGP3B Monitor and Report Quarterly Grab Effluent
Chronic
Footnotes:
1. The Permittee shall submit Discharge Monitoring Reports electronically using NCDWR's
eDMR application system [see A.(5.)I.
2. Compliance to effluent limits shall commence on May 31,2028,one(1)month before permit
expiration [see Condition A. (3)].
3. Monitoring and reporting of 1,4-Dioxane are subject to additional reporting requirements[see
Special Condition A.(4.)].
4. Monitoring shall coincide with the Chronic WET testing as appropriate to frequency.
5. Whole Effluent Toxicity(WET)testing,Chronic,(Ceriodaphnia)P/F at 90%effluent
concentration during March,June,September,and December[see A.(2.)].
Condition: The Permittee shall discharge no floating solids or foam visible in other than trace amounts.
Page 3 of 7

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B.0200]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality
to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perfonn at a minimum,quarterly monitoring using test procedures outlined in the
North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure, Revised December 2010, or subsequent
versions or North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure(Revised-December
2010)or subsequent versions.The tests will be performed during the months of March,June,September,
and December. These months signify the first month of each three-month toxicity testing quarter assigned
to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge
and shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple-concentration testing shall be performed at a minimum, in each of the
two following months as described in"North Carolina Phase H Chronic Whole Effluent Toxicity Test
Procedure"(Revised-December 2010)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally,DWR Form AT-3(original)is to be sent
to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh,NC 27699-1623
Or,results can be sent to the email, [e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating
the facility name,permit number,pipe number,county,and the month/year of the report with the notation of
"No Flow"in the comment area of the form. The report shall be submitted to the Water Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,monitoring will
be required during the following month. Assessment of toxicity compliance is based on the toxicity testing
quarter,which is the three-month time interval that begins on the first day of the month in which toxicity testing
is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream,this permit may be re-opened and modified
to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last
day of the month following the month of the initial monitoring.
Page 4 of 7

DocuSign Envelope ID EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
A. (3.) SCHEDULE OF COMPLAINCE
[G.S. 143-215.1(b)]
To afford the Permittee a schedule to consider additional treatment,if needed,permit limits for
Tetrachloroethene(PCE)become subject to Compliance beginning on May 31,2028,one(1)month
prior to permit expiration.
A. (4.) SPECIAL CONDITION - PERMIT REOPENER
[G.S. 143-215.1(b)]
Upon receiving effluent analytical results for 1,4-Dioxane equal to or greater than 80 µg/L,the Permittee
shall report this result,within 48 hrs,to the Division's Winston-Salem Regional Office(WSRO).if
deemed necessary,the Division may reopen this permit to modify requirements to address 1,4-Dioxane
monitoring and limitations.
A. (5.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports(DMRs)and
program reports.The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21,2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit(Standard Conditions for NPDES Permits):
• Section B.(11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D.(6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D.(2.)and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report(eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month
and submitted electronically using eDMR. The eDMR system allows permitted facilities to
enter monitoring data and submit DMRs electronically using the internet. Until such time that
the state's eDMR application is compliant with EPA's Cross-Media Electronic Reporting
Regulation(CROMERR),permittees will be required to submit all discharge monitoring data to
the state electronically using eDMR and will be required to complete the eDMR submission by
printing, signing,and submitting one signed original and a copy of the computer printed eDMR
to the following address:
NC DEQ/Division of Water Resources/Water Quality Permitting Section
A 1-1'ENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Page 5 of 7

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access,then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms(MR 1,
1.1,2, 3)or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above. See"How to Request a Waiver from Electronic
Reporting"section below.
Regardless of the submission method,the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility,on the last day of the month
following the commencement of discharge.
Starting on December 21,2025,the permittee must electronically report the following
compliance monitoring data and reports,when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports;and
• Clean Water Act(CWA) Section 316(b)Annual Reports.
The permittee may seek an electronic reporting waiver from the Division(see"How to Request
a Waiver from Electronic Reporting"section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(l)(9),the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity(EPA or the state authorized by EPA to implement the NPDES program)that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and use
the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the"Reporting Requirements"section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be submitted
in writing to the Division for written approval at least sixty(60)days prior to the date the
facility would be required under this permit to begin submitting monitoring data and reports.
Page 6 of 7

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
Permit NC0080853
The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At
such time, monitoring data and reports shall be submitted electronically to the Division unless
the permittee re-applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the
Division for the period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found
on the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements[Supplements Section B.(11.)(b)and Supersedes Section B.(11.)(d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a)or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position,must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions,the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system,registering for eDMR and obtaining an eDMR user account,please
visit the following web page: http://deq.nc.gov/aboutldivisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the.system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D.(6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
Page 7 of 7

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
LI !J
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Nokia of America Corporation
3370 Old Lexington Road Facility
Salem Business Park,Winston-Salem Location
Outfall Latitude: 36°03'18"N Outfall Longitude: 80°13'51"W not to scale
Stream Class: C Receiving Stream: UT to Salem Creek
011
Stream Segment: 12-94-12-(4) Flow: 0.062 MGD Subbasin: 03-07-04 USGS 4
*
Quad: Winston-Salem East
ff : 0304010113 NPDES Permit NC0080853
Drainage Basin: Upper Yadkin,Yadkin Pee-Dee / N o It h
Forsyth County

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
V.d I s .. •.• i,• 1 yss ...No,. w-, f \v1 NI 0 i 0 I I 6;4 1 v,: 411\ v. 7 . ....... i r),,, 1 , ....L.... I N 1
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'ti,..• .4,........,77/7( /APIs '
Nokia of America Corporation
3370 Old Lexington Road ii Facility
Salem Business Park, Winston-Salem Location
Outfall Latitude: 36°03'18"N Outfall Longitude: 80°13'51"W not to scale
Stream Class: C Receis ing Stream: UT to Salem Creek
Stream Segment: I2-94-12-(4) Flow: 0.062 MGD 011
�,
Subbasin: 03-07-04 USGS Quad: Winston-Salem East T
HUC: 0113 NPDES Permit NC0080853
Upper ,
Drainage Basin: Upper Yadkin,Yadkin Pee-Dee North
Forsyth County

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
NPDES Permit Standard Conditions
Page 1 of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days.These samples shall be representative of
the wastewater discharged during the sample period.
Act or"the Act"
The Federal Water Pollution Control Act,also known as the Clean Water Act(CWA),as amended,33 USC 1251,et.
seq.
Annual Average
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar year.In the case of fecal
conform,the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system,which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day.However,for purposes of this permit,any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods:January through March,April through June,July through September,and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period.The
Director may designate the most appropriate method(specific number and size of aliquots necessary,the time interval
between grab samples,etc.)on a case-by-case basis.Samples may be collected manually or automatically.Composite
samples may be obtained by the following methods:
(1) Continuous:a single,continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume:a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection,or
(3) Variable time/constant volume:a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point.Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer,and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system,or
Version 11/09/2011

DocuSign Envelope ID EE4E51 B2-171E-4A4E-AF39-EF6D30132FAB
NPDES Permit Standard Conditions
Page 2 of 18
(4) Constant time/constant volume:a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval.Use of this method requires prior approval by the Director.This method may only be
used in situations where effluent flow rates vary less than 15 percent.The following restrictions also apply:
> Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
> Influent samples shall not be collected more than once per hour.
> Permittees with wastewater treatment systems whose detention time<24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
> Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours;there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility.Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling.For pollutants measured in units of mass,the"daily discharge"is calculated as
the total mass of the pollutant discharged over the day.For pollutants expressed in other units of measurement,the
"daily discharge"is calculated as the average measurement of the pollutant over the day.(40 CFR 122.2;see also
"Composite Sample,"above.)
Daily Maximum
The highest"daily discharge"during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit.Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling.If sampling is required for all seven days of the week for any permit parameter(s),that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or"the Division"
The Division of Water Quality,Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit.Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N=the number of individual values.For purposes of
calculating the geometric mean,values of"0"(or"<[detection level]")shall be considered= 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes.Grab samples can be
collected manually.Grab samples must be representative of the discharge(or the receiving stream,for instream
samples).
Version 11/09/2011

DocuSign Envelope ID:EE4E51B2-171E-4A4E-AF39-EF6D30132FAB
NPDES Permit Standard Conditions
Page 3 of 18
Hazardous S ubstance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance.To the extent practical,instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average(concentration limit)
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar month.In the case of fecal
coliform or other bacterial parameters or indicators,the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average(concentration limit).
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property,damage to the treatment facilities which causes them to become inoperable,or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1)of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements.An upset does not include noncompliance caused by
operational error,improperly designed treatment facilities,inadequate treatment facilities,lack of preventive
maintenance,or careless or improper operation.
Weekly Average(concentration limit)
The arithmetic mean of all"daily discharges"of a pollutant measured during the calendar week.In the case of fecal
coliform or other bacterial parameters or indicators,the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit.Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action;for permit termination,revocation and reissuance,or
modification;or denial of a permit renewal application[40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a)of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d)of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal,even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s]301,302,306,307,308,318 or 405 of the Act,or
any permit condition or limitation implementing any such sections in a permit issued under section 402,or any
requirement imposed in a pretreatment program approved under sections 402(a)(3)or 402(bX8)of the Act,is
subject to a civil penalty not to exceed$37,500 per day for each violation. [33 USC 1319(d)and 40 CFR
127.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301,302,306,307,308,318,or 405 of
the Act,or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act,or any requirement imposed in a pretreatment program approved under section 402(a)(3)or
402(b)(8)of the Act,is subject to criminal penalties of$2,500 to$25,000 per day of violation,or
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imprisonment of not more than 1 year,or both.In the case of a second or subsequent conviction for a negligent
violation,a person shall be subject to criminal penalties of not more than$50,000 per day of violation,or by
imprisonment of not more than 2 years,or both. [33 USC 1319(c)(1)and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections,or such conditions or limitations is subject to criminal
penalties of$5,000 to$50,000 per day of violation,or imprisonment for not more than 3 years,or both.In the
case of a second or subsequent conviction for a knowing violation,a person shall be subject to criminal
penalties of not more than$100,000 per day of violation,or imprisonment of not more than 6 years,or both.
[33 USC 1319(c)(2)and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301,302,303,306,307,308,318 or 405 of the Act,or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury,shall,upon conviction,be subject to a fine of not more than$250,000 or imprisonment of not more than
15 years,or both.In the case of a second or subsequent conviction for a knowing endangerment violation,a
person shall be subject to a fine of not more than$500,000 or by imprisonment of not more than 30 years,or
both.An organization,as defined in section 309(c)(3)(B)(iii)of the CWA,shall,upon conviction of violating
the imminent danger provision,be subject to a fine of not more than$1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law,a civil penalty of not more than$25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms,conditions,or requirements of a permit. [North
Carolina General Statutes§ 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301,302,
306,307,308,318 or 405 of this Act,or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act.Administrative penalties for Class I violations are not to
exceed$16,000 per violation,with the maximum amount of any Class I penalty assessed not to exceed
$37,500.Penalties for Class II violations are not to exceed$16,000 per day for each day during which the
violation continues,with the maximum amount of any Class II penalty not to exceed$177,500. [33 USC
1319(g)(2)and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment[40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on"Bypassing"(Part II.C.4),"Upsets"(Part II.C.5)and"Power Failures"
(Part II.C.7),nothing in this permit shall be construed to relieve the Permittee from any responsibilities,liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act,33 USC
1319.Furthermore,the Permittee is responsible for consequential damages,such as fish kills,even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities,liabilities,or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq.or Section 311 of the Federal Act,33 USG 1321.Furthermore,the Permittee is responsible for
consequential damages,such as fish kills,even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property,or any exclusive
privileges,nor does it authorize any injury to private property or any invasion of personal rights,nor any
infringement of Federal,State or local laws or regulations[40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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7. Severability
The provisions of this permit are severable.If any provision of this permit,or the application of any provision of
this permit to any circumstances,is held invalid,the application of such provision to other circumstances,and the
remainder of this permit,shall not be affected thereby[NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority,within a reasonable time,any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying,revoking and reissuing,or
terminating this permit or to determine compliance with this permit.The Permittee shall also furnish to the Permit
Issuing Authority upon request,copies of records required by this permit[40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit,the
Permittee must apply for and obtain a new permit[40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date.In order to receive automatic authorization to
discharge beyond the expiration date,the Permittee shall submit such information,forms,and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director.(The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.)[40 CFR 122.21(d)]Any Permittee that has not
requested renewal at least 180 days prior to expiration,or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration,will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et.seq.
11. Signatory Requirements
All applications,reports,or information submitted to the Permit Issuing Authority shall be signed and certified[40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer.For the purpose of this Section,a responsible
corporate officer means: (a)a president,secretary,treasurer or vice president of the corporation in charge
of a principal business function,or any other person who performs similar policy or decision making
functions for the corporation,or(b)the manager of one or more manufacturing,production,or operating
facilities,provided,the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations,and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations;the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements;and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,respectively;or
(3) For a municipality,State,Federal,or other public agency: by either a principal executive officer or
ranking elected official[40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a.above or by a duly authorized representative of that person.A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity,such as the position of plant manager,operator of a well or well field,
superintendent,a position of equivalent responsibility,or an individual or position having overall
responsibility for environmental matters for the company.(A duly authorized representative may thus be
either a named individual or any individual occupying a named position.);and
(3) The written authorization is submitted to the Permit Issuing Authority[40 CFR 122.22]
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c. Changes to authorization:If an authorization under paragraph(b)of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility,a new authorization
satisfying the requirements of paragraph(b)of this section must be submitted to the Director prior to or
together with any reports,information,or applications to be signed by an authorized representative[40 CFR
122.22]
d. Certification.Any person signing a document under paragraphs a.or b.of this section shall make the following
certification[40 CFR 122.22].NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"I certiA under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted.Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate,and complete.I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified,revoked and reissued,or terminated for cause.The filing of a request by the
Pernuttee for a permit modification,revocation and reissuance,or termination,or a notification of planned changes
or anticipated noncompliance does not stay any permit condition[40 CFR 122.41(f)].
13. Permit Modification,Revocation and Reissuance,or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit,or terminating the permit as allowed by the laws,rules,and regulations
contained in Title 40,Code of Federal Regulations,Parts 122 and 123;Title 15A of the North Carolina
Administrative Code,Subchapter 02H.0100;and North Carolina General Statute 143.215.1 et.al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division.Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H.0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators,certified by the Water Pollution
Control System Operators Certification Commission(WPCSOCC),of the appropriate type and grade for the
system,and,for each classification must[T15A NCAC 08G.0201]:
a. designate one Operator In Responsible Charge(ORC)who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s)in Responsible Charge(Back-up ORCs)who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system,with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year,and
c. submit a signed completed"Water Pollution Control System Operator Designation Form"to the Commission
(or to the local health department for owners of subsurface systems)countersigned by the designated certified
operators,designating the Operator in Responsible Charge(ORC)and the Back-up Operator in Responsible
Charge(Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system;or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge(ORC)and Back-up Operator in Responsible Charge(Back-up ORC)
of the proper type and grade;or
➢ a vacancy in the position of Operator in Responsible Charge(ORC)or Back-up Operator in
Responsible Charge(Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility(or the Back-up ORC,when acting as surrogate for the ORC)must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system;the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G.0204.
The ORC of each Class II,III and IV facility(or the Back-up ORC,when acting as surrogate for the ORC)must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system;the treatment
facility must be visited at least five days per week,excluding holidays
> Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G.0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances)which are installed or used by the Permittee to achieve compliance with the conditions
of this permit.Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures.This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit[40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility,and all documentation required thereof,whether acting as a contract operator[subcontractor]or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit[40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations[40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded,but
only if it also is for essential maintenance to assure efficient operation.These bypasses are not subject to the
provisions of Paragraphs b.and c.of this section.
b. Notice[40 CFR 122.41(m)(3)]
(1) Anticipated bypass.If the Permittee knows in advance of the need for a bypass,it shall submit prior notice,
if possible at least ten days before the date of the bypass;including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass.The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6.(24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass,unless:
(A) Bypass was unavoidable to prevent loss of life,personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass,such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime.This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance;and
(C) The Permittee submitted notices as required under Paragraph b.of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system-wide collection system
permit associated with the treatment facility.
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(3) The Permit Issuing Authority may approve an anticipated bypass,after considering its adverse effects,if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1)of this section.
5. Upsets
a. Effect of an upset[40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b.of
this condition are met.No determination made during administrative review of claims that noncompliance was
caused by upset,and before an action for noncompliance,is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset:Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate,through properly signed,contemporaneous operating logs,or other relevant
evidence that:
(1)An upset occurred and that the Permittee can identify the cause(s)of the upset;
(2)The Permittee facility was at the time being properly operated;and
(3)The Permittee submitted notice of the upset as required in Part II.E.6.(b)of this permit.
(4)The Permittee complied with any remedial measures required under Part II.B.2.of this permit.
c. Burden of proof[40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids,sludges,filter backwash,or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission.The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge,including 40 CFR 503,Standards for the Use and Disposal of Sewage Sludge;40 CFR
Part 258,Criteria For Municipal Solid Waste Landfills;and 15A NCAC Subchapter 2T,Waste Not Discharged To
Surface Waters.The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards(as required by 15A NCAC 02H.0124)to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources,standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken,as required herein,shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents.All samples shall be taken at the monitoring points specified in this
permit and,unless otherwise specified,before the effluent joins or is diluted by any other wastestream,body of
water,or substance.Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority[40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s)shall be summarized for each month and reported on a
monthly Discharge Monitoring Report(DMR)Form(MR 1, 1.1,2,3)or alternative forms approved by the
Director,postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility,on the last day of the month following the commencement of discharge.Duplicate signed copies of these,
and all other reports required herein,shall be submitted to the following address:
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NC DENR/Division of Water Quality/Surface Water Protection Section
ATTENTION:Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges.The
devices shall be installed,calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device.Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10%from the true discharge rates throughout the range of expected discharge
volumes.Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once-through condenser cooling water flow monitored by pump logs,or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division.Permittees should contact the Division's
Laboratory Certification Section(919 733-3908 or http://portal.ncdenr.org/web/wq/lab/cert)for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field-certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations(published pursuant to NCGS
143-215.63 et.seq.),the Water and Air Quality Reporting Acts,and to regulations published pursuant to Section
304(g),33 USC 1314,of the CWA(as amended),and 40 CFR 136;or in the case of sludge use or disposal,
approved under 40 CFR 136,unless otherwise specified in 40 CFR 503,unless other test procedures have been
specified in this permit[40 CFR 122.41].
To meet the intent of the monitoring required by this permit,all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure.If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements,then the most
sensitive(method with the lowest possible detection and reporting level)approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies,tampers with,or knowingly renders inaccurate,any monitoring
device or method required to be maintained under this permit shall,upon conviction,be punished by a fme of not
more than$10,000 per violation,or by imprisonment for not more than two years per violation,or by both.If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fme of not more than$20,000 per day of violation,or by imprisonment of not more than 4 years,
or both[40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities,which shall be retained for a period of at least five years(or longer as required by 40 CFR
503),the Permittee shall retain records of all monitoring information,including:
➢ all calibration and maintenance records
> all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
> copies of all data used to complete the application for this pert
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement,report or application.This period may be extended by request of the Director at any time[40 CFR
122.41].
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7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit,the Permittee shall record the
following information[40 CFR 122.41]:
a. The date,exact place,and time of sampling or measurements;
b. The individuals)who performed the sampling or measurements;
c. The date(s)analyses were performed;
d. The individual(s)who performed the analyses;
e. The analytical techniques or methods used;and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director,or an authorized representative(including an authorized contractor acting as
a representative of the Director),upon the presentation of credentials and other documents as may be required by
law,to;
a. Enter,at reasonable times,upon the Permittee's premises where a regulated facility or activity is located or
conducted,or where records must be kept under the conditions of this permit;
b. Have access to and copy,at reasonable times,any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities,equipment(including monitoring and control equipment),practices,
or operations regulated or required under this permit;and
d. Sample or monitor at reasonable times,for the purposes of assuring permit compliance or as otherwise
authorized by the CWA,any substances or parameters at any location[40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit.The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility[40 CFR 122.41(1)].Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b);or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged.This notification applies to pollutants subject neither to effluent limitations in the permit,nor to
notification requirements under 40 CFR 122.42(a)(1);or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,and
such alteration,addition or change may justify the application of permit conditions that are different from or
absent in the existing permit,including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit[40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61.The Director may condition approval in accordance with NCGS 143-215.1,in
particular NCGS 143-215.1(b)(4)b.2.,and may require modification or revocation and reissuance of the permit,or
a minor modification,to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA[40 CFR 122.41(1)(3), 122.61]or state statute.
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5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit[40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report(DMR)(See Part II.D.2)or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge,the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment.Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances.A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances.The written submission
shall contain a description of the noncompliance,and its cause;the period of noncompliance,including exact
dates and times,and if the noncompliance has not been corrected,the anticipated time it is expected to
continue;and steps taken or planned to reduce,eliminate,and prevent reoccurrence of the noncompliance[40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case-by-case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at(800)662-7956,[phone] or(919)733-3300.
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6.of this permit at the
time monitoring reports are submitted.The reports shall contain the information listed in Part II.E.6.of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application,or submitted
incorrect information in a permit application or in any report to the Director,it shall promptly submit such facts or
information[40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
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. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic,such as the dumping of the contents of a sludge
digester,the known passage of a slug of hazardous substance through the facility-,or any other unusual
circumstances.
b. Any process unit failure,due to known or unknown reasons,that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps,aerators,compressors,etc.
c. Any failure of a pumping station,sewer line,or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.Also see reporting requirements for municipalities in Part IV.C.2.c.of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2)or Section 308 of the Federal Act,33
USC 1318,all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division.As required by the Act,effluent data shall not be considered confidential.Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2)or in Section 309 of the Federal Act.
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11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement,representation,or certification in
any record or other document submitted or required to be maintained under this permit,including monitoring
reports or reports of compliance or noncompliance shall,upon conviction,be punished by a fine of not more than
$25,000 per violation,or by imprisonment for not more than two years per violation,or by both[40 CFR 122.411
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee(NCGS 143-215.1C).The
report shall summarize the performance of the collection or treatment system,as well as the extent to which the
facility was compliant with applicable Federal or State laws,regulations and rules pertaining to water quality.The
report shall be provided no later than sixty days after the end of the calendar or fiscal year,depending upon which
annual period is used for evaluation.
The report shall be sent to:
NC DENR/Division of Water Quality/Surface Water Protection Section
ATTENTION:Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
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PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities,nor add to the plant's treatment
capacity,nor change the treatment process(es)utilized at the treatment plant unless(1)the Division has issued an
Authorization to Construct(AC)permit or(2)the Permittee is exempted from such AC permit requirements
under Item b.of this Section.
b. In accordance with NCGS 143-215.1(a5)[SL 2011-394],no permit shall be required to enter into a contract for the
construction,installation,or alteration of any treatment work or disposal system or to construct,install,or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat,equalize,neutralize,stabilize,recycle,or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above,the permit issued for the
discharge may be modified if required by federal regulation.
c. Issuance of an MC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall,upon written notice from the Director,conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe(40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge,on a routine or frequent basis,of
any toxic pollutant which is not limited in the permit,if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter(100 µg/L);
(2) Two hundred micrograms per liter(200 µg/L)for acrolein and acrylonitrile;five hundred micrograms per liter
(500 µg/L)for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol;and one milligram per liter(1 mg/L)for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge,on a non-routine or infrequent
basis,of a toxic pollutant which is not limited in the permit,if that discharge will exceed the highest of the
following"notification levels";
(1) Five hundred micrograms per liter(500 µg/L);
(2) One milligram per liter(1 mg/L)for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Pennittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit.The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State.This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit,the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non-domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b),(c)or(d)of the CWA. [40 CFR 403.3 (i)and(j)and 15A NCAC 02H.0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes;operations;or its sludge process,use,or disposal which
causes or contributes to a violation of any requirement of the Penmittee's(or any satellite POTW's if different from the
Permittee)NPDES,collection system,or non-discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes,regulations,or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which,alone or with
discharges from other sources,causes a violation,including an increase in the magnitude or duration of a violation,of
the Penmittee's(or any satellite POTW's,if different from the Permittee)NPDES,collection system,or non-discharge
permit. [15A NCAC 02H.0903(b)(23)]
Publicly Owned Treatment Works(POTW)
A treatment works as defined by Section 212 of the CWA,which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage,treatment,recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature.It also includes the collection system,as defined in 15A NCAC 2T
.0402,only if it conveys wastewater to a POTW treatment plant.The term also means the local government
organization,or municipality,as defined in section 502(4)of the CWA,which has jurisdiction over indirect discharges
to and the discharges from such a treatment works.In this context,the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges.This second type of
POTW may be referred to as a"satellite POTW organization."[15A NCAC 02H.0903(b)(26)]
"Significant Industrial User"or"SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that[15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW(excluding sanitary,
noncontact cooling and boiler blowdown wastewaters);or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non-discharge permitted
flow limit or organic capacity of the POTW treatment plant.In this context,organic capacity refers to BOD,TSS
and ammonia;or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471;or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement,or the POTW's effluent
limitations and conditions in its NPDES or non-discharge permit,or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H.0907(b),the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement,the POTW's effluent limitations and
conditions in its NPDES or non-discharge permit,or to limit the POTW's sludge disposal options,and thus is not a
Significant Industrial User(SIU);or
6. Subject to approval under 15A NCAC 02H.0907(b),the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(vX2)and thus is a
non-significant categorical Industrial User.
Section B. Publicly Owned Treatment Works(POTWs)
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All POTWs must provide adequate notice to the Director of the following[40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger,regardless of the means of
transport,which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph,adequate notice shall include information on(1)the quality and quantity of effluent
introduced into the POTW,and(2)any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part 1 of this permit.Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge.At such time as sufficient information
becomes available to establish limitations for such pollutants,this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H.0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system[40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW,including,but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW,but in no case discharges with pH lower
than 5.0,unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant,including oxygen demanding pollutants(BOD,etc.)released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference,but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C(104°F)
unless the Division,upon request of the POTW,approves alternate temperature limits;
(6) Petroleum oil,non-biodegradable cutting oil,or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases,vapors,or fumes within the POTW in a quantity that
may cause acute worker health and safety problems;or
(8) Any trucked or hauled pollutants,except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW,including slug loads and other
unusual discharges,which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances.A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances.The written submission shall contain a description of the discharge;the
investigation into possible sources;the period of the discharge,including exact dates and times;if the
discharge has not ceased,the anticipated time it is expected to continue;and steps taken or planned to reduce,
eliminate,and prevent reoccurrence of the noncompliance,
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3. With regard to the effluent requirements listed in Part I of this permit,it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards(40 CFR,Part 403)to ensure compliance by
the Permittee with all applicable effluent limitations.Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User(IU)discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b)of the Act as amended(which includes categorical standards and
specific local limits,best management practices and narrative requirements).Prior to accepting wastewater from
any Significant Industrial User(SIU),the Permittee shall either develop and submit to the Division a new
Pretreatment Program or,as necessary,a modification of an existing Pretreatment Program,for approval as
required under section D below as well as 15A NCAC 02H.0907(a)and(b).[40 CFR 122.440)(2)]
5. This permit shall be modified,or alternatively,revoked and reissued,to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402(b)(8)of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program,as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307(b)and(c)and 402(bX8)of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14)and implementing regulations 15A NCAC 02H.0900,and in accordance
with the approved pretreatment program,all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit.[40 CFR 122.44(j)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8)of the CWA,40
CFR 403, 15A NCAC 02H.0900,and the legal authorities,policies,procedures,and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof.Such operation shall include but is
not limited to the implementation of the following conditions and requirements.Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H.0903 and 40 CFR 403.3.
1. Sewer Use Ordinance(SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H.0903(bX32),.0905 and.0906(bx1);40 CFR 403.8(f)(1)and 403.9(b)(1)and(2)]
2. Industrial Waste Survey(IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant,as required by 40 CFR 403.8(f)(2)(i-iii)and 15A NCAC 02H.0905 [also 40 CFR 122.44(j)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU.Where the Permittee accepts wastewater from one or more satellite POTWs,the
IWS for the Permittee shall address all satellite POTW services areas,unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program.The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years,and as
required by the Division.The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c.of this Part.[15A NCAC 02H.0903(b)(13),.0905 and.0906(b)(2);40 CFR 403.8(f)(2)and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division-approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis(HWA)for the development of specific pretreatment
local limits.Effluent data from the Plan shall be reported on the DMRs(as required by Parts 11.D and II.E.5.). [15A
NCAC 02H.0903(b)(16),.0906(b)(3)and.0905]
4. Headworks Analysis(HWA)and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years,and as required by the
Division.Within 180 days of the effective date of this permit(or any subsequent permit modification)the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits(i.e.,an
updated HWA or documentation of why one is not needed)[40 CFR 122.44].The Permittee shall develop,in
accordance with 40 CFR 403.5(c)and 15A NCAC 02H.0909,specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a)and(b)and 15A NCAC 02H.0909.Pursuant to 40 CFR 403.5,local limits are
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enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H.0903(b)(10),.0905,and
.0906(b)(4)]
5. Industrial User Pretreatment Permits(IUP)&Allocation Tables
In accordance with NCGS 143-215.1,the Permittee shall issue to all Significant Industrial Users,permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works.These
permits shall contain limitations,sampling protocols,reporting requirements,appropriate standard and special
conditions,and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements.The
Permittee shall maintain a current Allocation Table(AT)which summarizes the results of the HWA and the limits
from all IUPs.Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.[15A NCAC 02H.0906(bX6),.0909,.0916,and.0917;40 CFR 403.5,403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct(AtC)
The Permittee shall ensure that an Authorization to Constructpermit(AtC)is issued to all applicable Industrial
h pp
Users for the construction or modification of any pretreatment facility.Prior to the issuance of an AtC,the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit(IUP)limitations.[15A NCAC 02H.0906(b)(7)and.0905;NCGS 143-
215.1(a)(8)]
7. POTW Inspection&Monitoring of their His
The Permittee shall conduct inspection,surveillance,and monitoring activities as described in its Division
approved pretreatment program in order to determine,independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards.[15A NCAC 02H.0908(e);40 CFR 403.8(f)(2Xv)] The
Permittee must:
a. Inspect all Significant Industrial Users(SIUs)at least once per calendar year;
b. Sample all Significant Industrial Users(SIUs)at least once per calendar year for all SIU permit-limited
parameters including flow except as allowed under 15A NCAC.0908(e);and
c. At least once per year,document an evaluation of any non-significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2),and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division-approved pretreatment program,the industry's pretreatment permit,or in 15A
NCAC 02H.0908. [15A NCAC 02H.0906(b)(5)and.0905;40 CFR 403.8(f)(1)(v)and(2)(iii);40 CFR
122.44(j)(2)and 40 CFR 403.12]
9. Enforcement Response Plan(ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b)and(c)of the CWA(40 CFR 405 et.seq.),prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H.0909,specific local limitations,and other pretreatment
requirements.All remedies,enforcement actions and other,shall be consistent with the Enforcement Response
Plan(ERP)approved by the Division. [15A NCAC 02H.0903(bX7),.0906(b)(8)and.0905;40 CFR 403.8(0(5)]
10. Pretreatment Annual Reports(PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H.0908.In lieu of submitting annual
reports,Modified Pretreatment Programs developed under 15A NCAC 02H.0904(b)may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs,the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR)describingitspretreatment activities over theprevious calendar year to the Division at the following
address:
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NC DENR/Division of Water Quality/Surface Water Protection Section
Pretreatment,Emergency Response,and Collection Systems(PERCS)Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken,or proposed,by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summary(PPS)
A pretreatment program summary(PPS)on forms or in a format provided by the Division;
c. Significant Non-Compliance Report(SNCR)
A list of Industrial Users(Ills)in significant noncompliance(SNC)with pretreatment requirements,and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms(IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users(SIUs).These
analytical results must be reported on Industrial Data Summary Forms(1DSF)or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table,new or modified enforcement compliance schedules,public notice of
Ws in SNC,a summary of data or other information related to significant noncompliance determinations for
lUs that are not considered S1Us,and any other information,upon request,which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users(Ws)that were in significant noncompliance(SNC)
as defined in the Pernittee's Division-approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period.This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H.0903(bX34),.0908(b)(5)and.0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results,along with
support information including general records,water quality records,and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H.0908(f). [15A
NCAC 02H.0908(f);40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program.and retain a written description of those current levels of inspection.[15A NCAC 02H
.0906(b)(9)and(10)and.0905;40 CFR 403.8(f)(3),403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications,POTW
monitoring of their Significant Industrial Users(SIUs),and Monitoring Plan modifications,shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H.0114 and 15A NCAC 02H.0907.
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NCDEQ/DWR/NPDES
FACT SHEET -FOR EXPIDITED RENEWAL
NPDES PERMIT NC0080853 —Revised DRAFT v3
Table 1 --Facility Information
Applicant/Facility Name: Nokia of America Corporation WWTP
Applicant Address: 3370 Old Lexington Road,Winston-Salem
Facility Address: Salem Business Park(same as above)
Facility Contacts: John Galasso,Remediation Manager[[e-mail]]
Conan Fitzgerald,PE 919-461-1291 [[e-mail]]
Permitted Flow/Actual Revised by the Permittee to 0.062 MGD[as calculation error, 16Nov2023]
Flow: 0.070(5-year ave.);0.050(ave. last 9 months)
Type of Waste: GW-REM for chlorinated hydrocarbons and 1-4,Dioxane
WWTP Class/Permit WPCS Class PC-1 /
Status: Active;Renewal
County: Forsyth County
Miscellaneous
Receiving Stream: UT to Salem Creek Regional Office: Winston-Salem(WSRO)
Stream Class/Segment: Class C/ 12-94-12-(4) State Grid/ Winston Salem East,NC
USGS Quad:
No?Downstream,Yes
303(d)Listed?/NO Middle Fork Salem Creek
INFO Impaired for Fecal/ Permit Writer: Joe R.Corporon,P.G.
recreation
Hydrological Unit: 03-07-04 Date: Updated 22Feb2024
HUC: 0304010113
s7Q10(cfs) 0.0
w7Q10(cfs) 0.0
Average Flow(cfs): 0.0
IWC(%): 100%
Outfall:
• Permittee requests to Lat. 36°03' 18"N
Comments on DRAFT: revise permitted flow. Long. 80° 13'51"W
• BIMS receiving-
stream flow corrected.
For Renewal: Nokia of America Corporation(Nokia or the Permittee)proposes no operational changes
to the currently permitted groundwater treatment system featuring a low-profile air stripper.
BACKGROUND/SITE HISTORY--There is no folder/no records for Nokia[NC0080853]on the
server's NPDES Permit Files.Nokia submitted updates to the previous permit on January 2,2019,
approved by DWR,as summarized as:
• Granulated Activated Carbon(GAC)was noted as back-up in the prior permit,available in the
event of an increase in influent contaminant concentrations,however a GAC filter was not used.
• On March 22,2021,AECOM notified NCDEQ's Water Quality Permitting Section of Nokia's
intention to discontinue filtration.AECOM noted that the filters were part of the permitted
treatment system,primarily to prevent clogging within the GAC filters.
• Removed GAC units from normal operation eliminating the need to maintain the filtration units.
They remain in the treatment building but have been bypassed,as approved by the Water Quality
Permitting Section by email the same day that the request was made.
Page 1 of 8

• Chemical additives,formerly added to control fouling,were eliminated prior to the January 2019
permit.As was confirmed by email correspondence with the Water Quality Permitting Section on
February 13,2023,no additional analyses beyond what is required under the permit is necessary
for this submittal.
RECEIVING STREAM INFORMATION-Nokia's WWTP discharges to an unnamed tributary(UT)to
upper Salem Creek,classified C within the Upper Yadkin,Yadkin Pee-Dee River Basin.The facility
treats local groundwater for chlorinated hydrocarbons lost to the environment-no domestic discharge.
Although the water quality of the UT is unknown(no data),the downstream segment of Salem Creek is
impaired for fecal coliform/recreation likely due to the dense industrial and urban population.
It is significant to note for this renewal that the Basinwide Information System(BIMS)reflects
receiving-stream flows consistent with the mainstem of Salem Creek—not the UT at the outfall.
Therefore,until new stream data are provided,this renewal assumes zero-flow conditions[7Q10/30Q2
=0.0 cfs],i.e.,an instream waste concentration(IWC)= 100%.This Renewal will update BIMS.
INSTREAM MONITORING-monitoring not previously required/no changes recommended.
SUMMARY OF REPORTED DATA(JAN2021-SEP2023)
Table 2
Effluent Characteristics Minimum Average Maximum Sample Count
Flow(MGD) 0.005 0.070 0.10 949
Total Suspended Solids(mg/L) 0.2 2.35 2.6 35
Oil and Grease(per 100 ml) 4.8 6.55 39.5 34
1,4 Dioxane(µg/L) 3.4 5.89 8.4 10
Tetrachloroethylene(µg/L) 1.0 1.9 3.9 33
INSPECTION/CORRESPONDENCE-WSRO last inspected the facility and generated a Staff Report
dated 140ct2021.Inspector Hudson thus described the facility:"The ground water remediation site
Pest Gary h'
appeared to be very well maintained."
PERMIT COMPLIANCE-During Nokia's previous two(2)years,WET testing resulted in four(4)
notices of violation[NOV/NODs];one(1)resulted in afrequency violation and two(2)violations.
resulted in enforcement cases(Table 3).
Table 3
�CILH MONTH YEAR VTOL DATE UNITS TYPE ACTION COMMENT UPDATE
Nokia 4 2023 04/20/2023 WET violation Proceed to Enforce NC NOV molly.nicholson
t lokia 3 2023 03/22/2023 WET violation Proceed to NOV NC NOV molly_nicholson
Nokia 2 2023 02/09/2023 WET violation Proceed to Enforce NC NOV 001 molly.nicholson
Nokia 12 2022 Effluent 1 4 dioxane 12/31/2022 ug/l Frequency Proceed to NOD gary.hudson
IJokia 12 2022 12/06/2022 WET violation Proceed to NOV NC NOV 001 molly.nicholson
Jokia 9 2022 09/06/2022 WET violation Proceed to NOV NC NOV madisonmyers
lokia 3 2022 03/15/2022 WET violation Proceed to NOV NC NOV zach.thomas
SUMMARY/JUSTIFICATION for RENEWAL-REVISED
1. Effluent Flow-Based on input from the Permittee,and on effluent flow data averages from the
previous permit cycle,permitted effluent flow is revised from the previous 0.302 MGD to 0.062
MGD for this renewal.
2. Receiving-Stream Flows in BIMS are suspected to reflect the mainstem of Salem Creek
[Ave flow=0.40 cfs;30Q2=0.14 cfs;7Q10w=0.13 cfs;and 7Q10s=0.05 cfs].It is
unlikely that these flows represent the unnamed tributary(UT)upstream at the outfall.
Page 2 of 8

It follows therefore that DWR has applied zero flow[7Q10/30Q2=0.0 cfs]to recalculate
reasonable potential analyses(RPAs)and wasteload allocations(WLAs)for this revised
draft v2.Renewal assumes IWC= 100%. BIMS will reflect these data until new UT stream
flows may be provided.
3. Public Notice-Because of recent changes in discharge and receiving-stream flow,additional
Public Notice is required[per EPA].
4. Tetrachloroethylene(PCE)—based on revised IWC at 100%,PCE continues to show
reasonable potential to exceed its surface water-quality standard.Therefore,monitoring
continues Monthly with limits in accord with the RPA.New Limits=3.3 µg/L Monthly
Average(MA),and Daily Max(DM)=6.6 µg/L(MA x 2).
5. O&G—renewal revises the previous analytical parameter code from 00556 to 00552 (as
appropriate for industrial discharges);added limits of 15 mg/L MA and 30 mg/L DM.
6. TSS—renewal retains 30 mg/L as DM[anti-backsliding]and adds 15 mg/L MA[EPA
requires both limits].
7. 1,4-Dioxane effluent data do not show reasonable potential[see attached RPA MAX
Predicted= 10 µg/L,Allowable=80 µg/L].However,influent 1,4-Dioxane is NOT
remediated by current treatment technology(air striping)and reportedly originates from
offsite.Therefore,renewal considers 1,4-Dioxane a new parameter of concern[see RPA].
Monitoring is hereby revised from Quarterly to Monthly without limits,in order to establish
a viable effluent database[Table A.(1.)].Monitoring and reporting are subject to Special
Condition A.(4.).
8. pH-added monitoring to the permit[as required by EPA for all industrial discharges]
9. Updates-Supplement to Permit Cover Sheet,other permit texts,Electronic Reporting[A.
(5.)]and the Site Map.
REVISED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: November 15,2023
Re-draft to Public Notice January 23, 2024
Permit submitted for final signature February 23,2024
Permit scheduled to issue(Tentative) March 14,2024
Effective Date(Tentative) April 1,2024
NPDES DIVISION CONTACT
If you have questions on any of the above information or on the attached permit,please email Joe R.
Corporon,P.G. [[e-mail]].
/9
,
NAME: DATE: UPDATED 22FEB2024
t
I
i ( Page3of8

NPDES Implementation of lnstream 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 5.NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter Acute FW, µg/1 Chronic FW, Acute SW, µg/1 Chronic SW,
(Dissolved) µg/1 (Dissolved) µg/1
(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/1
Cadmium,Acute WER*{1.136672-[In hardness](0.041838)} • e^{0.9151 [In
hardness]-3.1485)
Cadmium, Acute Trout WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151[In
waters hardnessj-3.6236}
Page 4 of 8

Cadmium, Chronic WER*{1.101672-[In hardness](0.041838)} • e^{0.7998[In
hardness]-4.4451}
Chromium III,Acute WER*0.316 •e^{0.8190[ln hardness]+3.7256}
Chromium III,Chronic WER*0.860 • e1'{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[In hardness]-1.702}
Lead,Acute WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[In 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[In hardness]+0.0584}
Silver,Acute WER*0.85 • e^{1.72[In 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[In 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.
Page 5 of 8

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 1Q10 using the formula 1Q10=0.843 (s7Q10,cfs)0.993
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness-dependent metal of concern
and for each individual discharge,the Permit Writer must first determine what effluent
and instream(upstream)hardness values to use in the equations.
The permit writer reviews DMR's,Effluent Pollutant Scans,and Toxicity Test results for
any hardness data and contacts the Permittee to see if any additional data is available for
instream hardness values,upstream of the discharge.
If no hardness data is available,the permit writer may choose to do an initial evaluation
using a default hardness of 25 mg/L(CaCO3 or(Ca+Mg)). Minimum and maximum
limits on the hardness value used for water quality calculations are 25 mg/L and 400
mg/L,respectively.
If the use of a default hardness value results in a hardness-dependent metal showing
reasonable potential,the permit writer contacts the Permittee and requests 5 site-specific
effluent and upstream hardness samples over a period of one week. The RPA is rerun
using the new data.
The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness(chronic)
=(Permitted Flow, cfs*Avg.Effluent Hardness,mg/L)x(s7Q10,cfs *Avg. Upstream Hardness,
mg/L)
(Permitted Flow,cfs+s7Q 10,cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total
recoverable metal,using the EPA Default Partition Coefficients(DPCs)or site-specific
translators, if any have been developed using federally approved methodology.
Page 6 of 8

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:
Cass = 1
Ctotat 1 ± { [Kpo} [SP-v. } [le} }
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 nroaram under a
4. The numeric standard for each metal of concern is divided by the default partition
coefficient(or site-specific translator)to obtain a Total Recoverable Metal at ambient
conditions.
In some cases,where an EPA default partition coefficient translator does not exist(ie.
silver),the dissolved numeric standard for each metal of concern is divided by the EPA
conversion factor to obtain a Total Recoverable Metal at ambient conditions. This
method presumes that the metal is dissolved to the same extent as it was during EPA's
criteria development for metals.For more information on conversion factors see the June,
1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable
concentration(permit limits)for each pollutant using the following equation:
Ca=(s7Q10+Qw)(Cwqs)—(s7Q10)(Cb)
Qw
Where: Ca=allowable effluent concentration(µg/L or mg/L)
Cwqs=NC Water Quality Standard or federal criteria(µg/L or mg/L)
Cb=background concentration: assume zero for all toxicants except NH3* (µg/L or
mg/L)
Qw=permitted effluent flow(cfs,match s7Q10)
s7Q10=summer low flow used to protect aquatic life from chronic toxicity and
human health through the consumption of water, fish,and shellfish from
noncarcinogens(cfs)
* Discussions are on-going with EPA on how best to address background
concentrations
Flows other than s7Q10 may be incorporated as applicable:
1 Q 10=used in the equation to protect aquatic life from acute toxicity
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
Page 7 of 8

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 facilityspecific 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,u stream of the discharge,
P g P g ,
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 (RPA) for this
permit included:
Parameter Value Comments(Data Source)
Average Effluent Hardness(mg/L) Metals/Hardness not
[Total as, CaCO3 or(Ca+Mg)] N/A monitored.
Average Upstream Hardness (mg/L) Metals/Hardness not
[Total as,CaCO3 or(Ca+Mg)] N/A monitored.
7Q10 summer(cfs) 0•0
1Q10(cfs) 0.0
Permitted Flow(MGD) Revised from 0.30 to 0.062
Page 8 of 8

2014 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information Table 2. Parameters of Concern
❑CHECK IF HQW OR ORW Name Type Chronic Modifier Acute PQL Units
Facility Name Nokia of America Corporation Par01
WWTP/WTP Class PC-1 Par02
NPDES Permit NC0080853 Par03
Outfall 001 Par04
Flow,Qw(MGD) 0.062 Par05 Tetrachloroethene C 3.3 FW 3.3 pg/L
Receiving Stream UT to Salem Creek Par06
Stream Class C Par07
7Q10s(cfs) 0.00 Par08
7Q10w(cfs) 0.00 Par09
30Q2(cfs) 0.00 1 Par10
QA(cfs) Par11
1Q10s(cfs) 0.00 Par12
Data Source(s) FLOW(not weather-dependednt):calculated using Par13 1,4 Dioxane C 80 FW 80 pg/L
❑CHECK TO APPLY MODEL 0.062 MGD average over the past two(2)years Par14 Oil&Grease NC 15 FW 20 mg/L
Par15
Par16
Par17
Par18
Follow directions for data entry. In some cases a Par19
•
Comment menu list the available choices or a Par20
dropdown menu will provide a list you may select
from. Error message occur if data entry does not Par21
•
meet input criteria. Par22
80853 Nokia RPA v7 zero flow 21Dec2023,input
2/23/2024

REASONABLE POTENTIAL ANALYSIS
80853 Nokia RPA v7 zero flow 21Dec2023,data
-1- 2/23/2024

wix,sro -4Ai.F_�t
JOURNA L
See Proof on Next Page
AFFIDAVIT OF PUBLICATION
Winston-Salem Journal
418 N Marshall St
[phone]
State of Florida, County of Orange,ss.
Before the undersigned,a Notary Public duty commissioned,
qualified,and authorized by law to administer oaths,personally •
appeared the Publisher's Representative,Laquansay Nickson
Watkins,who by being duly sworn deposes and says:,that he/she is
authorized to make this affidavit and sworn statement;that the
notice or other legal advertisement,a copy of which is attached
hereto,was published in the Winston-Salem Journal and that the
said newspaper in which such notice,paper document,or legal
advertisement was published,was at the time of each and every
such publication,a newspaper meeting all the requirements and
qualifications of Section 1-597 of the General Statutes of North
Carolina.
PUBLICATION DATES:
Jan. 27,2024
NOTICE ID:eNSAB7iUJ0gNaLEbfC5E
PUBLISHER ID:COL-NC-600054
NOTICE NAME: NC0080853
Publication Fee:
$�320.00
tbIgnetl) �ll._ ua __-'T Q�J�t
'iA- —..--
*we►y PAMELA BAE7
ill A, f.o} Notary Public-State at Florida
VERIFICATION :1 Commission o""'.�°6
Expires on Octiam u mfs
State of Floridaol
County of Orange
Subscribed in my presence and sworn to before me on this:02/01/2024
i(tf +r
Notary Public
Notarized online using audio-video communication
NC0080853 - Page 1 of 2

Public Notice
North Carolina Environmental Management Commission/NPDES Unit
1617 Mail Service Center
Raleigh.NC 27699-1617
The North Carolina Environmental Management Commission proposes
to issue a NPDES wastewater discharge permit to the person(s)listed
below. Written comments regarding the proposed permit will be accept-
ed until 30 days after the publish date of this notice.The Director of the
NC Division of Water Resources(DWR)may hold a public hearing should
there be a significant degree of public interest.Please mail comments
and/or information requests to DWR at the above address. Interested
persons may visit the DWR at 512 N.Salisbury Street Raleigh,NC 27604
to review the information on file. Additional information on NPDES per-
mits and this notice may be found on our website:https.//deq.ncgov/
public-notices-hearings,or try calling(919)707-3601. Nokia of America,
3370 Old Lexington Road,requests to renew permit NC0080853 for its
groundwater remediation treatment plant,Winston-Sale,Forsyth Court-
ty This facility discharges to a UT to Salem Creek,Yadkin River Basin.,
The parameter Tetrachioroethytene(BCE)is water-quality limited.This
discharge may affect future wasteload allocations in this portion of the
Yadkin River Basin.
WSJ:January 27,2024.COL-NC-600054
•
NC0080853 - Page 2 of 2

REASONABLE POTENTIAL ANALYSIS
80853 Nokia RPA v7 zero flow 21 Dec2023,data
-1- 2/23/2024

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Attachment B
AECOM Response Letter January 23, 3034

1
Nokia of America Corporation REASONABLE POTENTIAL ANALYSIS Outfall 001
NC0080853 2014 Generic RPA-95% Probability/95% Confidence Qw = 0.062 MGD
MAXIMUM DATA POINTS=58
Qw(MGD)= 0.06 W W TP/WTP Class: PC-1
1Q1OS(cfs)= 0.00 IWC @ 1Q1OS = 100.00
7Q1OS(cfs)= 0.00 IWC ®7Q1OS= 100.00%
7Q10W(cfs)= 0.00 IWC @ 7Q10W= 100.00%
30Q2(cfs)= 0.00 IWC®30Q2= 100.00%
Avg.Stream Flow,QA(cfs)= NO QA DATA IWC @ QA= N/A
Receiving Stream; UT to Salem Creek Stream Class: C
PARAMETER TYPE STANDARDS&CRITERIA(2) cn REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION
(1) NC WQS/ Applied 1/2FAV/ g z Max Pred
Chronic Standard Acute n "Det. CwAllowable Cw
Acute: 3.3 RPA for non-AL-apply Monthly Monitoring with Limit
Tetrachloroethene C 3.3 FW 3 3 ttgI. 33 25 4.5 _ _ _ _
Chronic: 3.3 RPA for non-AL-apply Monthly Monitoring with Limit
3 value(s)>Allowable Cw
Acute: 80 No RP, Predicted Max<50%of Allowbale Cw-
However,current treatment system does not
1,4 Dioxane C 30 1U Si) tiz1. 10 1() 10 rememdiate.Therefore,Monitor Monthly with
Iimits.Add Compliance Period.
Chronic: 80 No RP, Predicted Max<50%of Allowbale Cw-
However,current treatment system does not
NO DETECTS No value>Allowable Cw rememdiate.Therefore,Monitor Monthly with
limits.Add Compliance Period.
Acute: 20 RP=Yes:parameter of concern.add limits;retain
Oil&Grease NC 15 FW 20 nig I. 34 3 54 Monthly monioring
Chro111C 15 - RP=Yes;parameter of concern;add limits:retain
2 value(s)>Allowable Cw Monthly monioring
80853 Nokia RPA v7 zero flow 21 Dec2023,rpa
Page 1 of 1 2/23/2024

AECOM
AECOM
5438 Wade Park Boulevard,Suite 200
Raleigh,NC 27607,USA
T 919.854.6200
F.919.854.6259
aecom.corn
January 23, 2024
Mr. Joe Corporon
Division of Water Resources
Water Quality Permitting Section -NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Comments on the Draft V2 NPDES Permit Renewal
Permit NC0080853
Salem Business Park Remediation Site
Nokia of America Corporation
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Joe Corporon,
On behalf of Nokia of America Corporation (Nokia),AECOM prepared this comments letter in response to
the draft National Pollutant Discharge Elimination System (NPDES)permit issued on December 29, 2023
for the groundwater treatment system (GWTS)operating at the site, as well as respond to a Division of
Water Resources (DWR) request regarding the receiving stream dated January 18, 2024.
Comment#1—Facility Location
The GWTS is located within Salem Business Park at 3370 Old Lexington Road, Winston-Salem, in
Forsyth County, North Carolina. Throughout the permitting documents, please remove references to
Starlight Drive, which is west of the railroad tracks from the Salem Business Park and does not border the
Salem Business Park at any point.
Comment#2— Treated Discharge Flowrate
Thank you for reviewing our request to review the treated discharge flowrate. The previously permitted
discharge flowrate of 0.302 MGD predates the current system configuration, which was established in the
2012 modifications. Current system operations lend to a top end daily flow of 0.06 to 0.08 MGD. To
preserve tolerances for operational variability, Nokia requests that the maximum effluent flowrate be
2023.
established at 0.120 MGD, consistent with the request sent via email on November 16,
Comment#3—Receiving Stream
In response to an email request dated January 18, 2024 received from Mr. Joe Corporon of the Division of
Water Resources (DWR),AECOM has contacted the Stormwater department for the City of Winston-
Salem. The city was willing to share screenshots of their internal GIS stormwater piping network, which
should clarify answers to the questions from the DWR. The screenshots with notes from the call are
included as Attachment A to this letter.
A. In the Attachment A figure, blue segments have known dimensions and orientation within the
Winston-Salem internal GIS. Segments in yellow are undefined flow connectors.
B. The effluent discharge for FE-151 (Outfall 001)joins the stormwater discharge just east of the
railroad line. From there the discharge is to the west underneath the railroad tracks.
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C. After the stormwater drainage flows under the railroad tracks, it enters a series of underground
culverts which collect stormwater from the region between Lexington Road and Interstate 285.
D. Subsequently,the culverted discharge crosses underneath Interstate 285, collecting additional
stormwater from the region west of the interstate. This culvert crosses underneath Cassell Street
towards an unnamed tributary of Salem Creek. According to city records,the stormwater
drainage enters another 82-inch culvert which runs parallel to the unnamed tributary towards the
northwest for approximately 150 feet past another tributary, before the culverted flow finally
discharges into the unnamed tributary.
In summary,the permitted effluent drains west from its discharge point via underground culverts that
eventually run parallel to and finally drain into an unnamed tributary of Salem Creek.At the point of this
discharge, the unnamed tributary receives drainage from substantial areas both east and west of
Interstate 285 that are well beyond the ARC GIS image provided by the City of Winston-Salem.
In accordance with emails received from Mr.Joe Corporon on January 4, 2024, and January 18,AECOM
understands that the DWR is internally deliberating on details surrounding the receiving stream and will
therefore need to issue a revised draft once this is completed. AECOM and Nokia recommend that the
permit maintain the receiving stream criteria from the current permit, as we are unaware of any
downstream changes that would necessitate reducing the criteria of the receiving stream flow. If changes
from the current permit are a part of the next draft permit,AECOM and Nokia reserve the right to further
comment.
Comment#4— 1,4-Dioxane Offsite Source(Introductory Letter page 2 of 2)
Within the Introductory Letter, summary item#8, DWR states 1,4-Dioxane"reportedly originates from
offsite."Historically 1-4 Dioxane was commonly used as a stabilizer for chlorinated solvents; as such, its
detection at this remediation site is not unexpected. Nokia respectfully requests that DWR share any data
that indicates 1,4-Dioxane may have other sources that originate from offsite.
Comment#5— 1,4-Dioxane Sampling Frequency[Introductory Letter page 2 of 2 and Table A. (1.)]
Within the Introductory Letter, summary item#8, DWR states"1,4-Dioxane effluent data do not show
reasonable potential'.As analyzed in the GWTS effluent during quarterly sampling from 2021 to 2023,
effluent concentrations of 1,4-Dioxane range from non-detect to below 10 pg/L. Given that 1,4 Dioxane is
approximately an order of magnitude or more below the 15A North Carolina Administrative Code subpart
2B (NCAC 2B)Surface Water standard of 80 pg/L prior to mixing with the unnamed tributary of Salem
Creek, an increase in monitoring frequency does not seem warranted. A decrease, or possibly elimination
of monitoring for this constituent appears more consistent with historic results.
Comment#6—Oil& Grease Daily Maximum(Introductory Letter page 2 of 2 and Table A. (1.)]
Table A. (1.)documents the Daily Maximum (DM) Effluent Limit for Oil and Grease as 20.0 mg/L.
However, the Introductory Letter summary item#6 documents the Oil and Grease DM Limit as 30.0 mg/L.
Please clarify which value stands as the DM Limit for Oil and Grease.
Comment#7—Bag Filtration(Supplement to Permit Cover Sheet)
On March 22, 2021,AECOM received approval from NCDEQ's Water Quality Permitting Section of
Nokia's to discontinue the use of bag filters, as the filters were primarily utilized to prevent sediment
buildup within the GAC filters. On the Permit Cover Sheet, please add a note to indicate the bag filters are
back-up equipment, with primary function to preventing sediment buildup within the back-up GAC filters.
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AECOM
Comment#8—Map Features(Site Map)
On the facility map, please revise location callouts to represent conditions of the following pertinent
features:
1. The callout identifying Salem Business Park is shown to the west of the railroad tracks. Salem
Business Park is located east of the railroad tracks.
2. The callout identifying Outfall 001 is shown to the west of the railroad tracks.Outfall 001 is
located east of the railroad tracks.
3. The Salem Creek callout identifies a surface water segment which is an unnamed tributary to
Salem Creek, rather than Salem Creek itself.
If you have any questions or need additional information, please contact Conan Fitzgerald at(919)461-
1260.
Yours sincerely,
f *4,., Ctiatkn.
Conan Fitzgerald Cristin Dolan
Project Manager,AECOM Engineer,AECOM
AECOM AECOM
T: [phone] T: [phone]
E: [e-mail] E: [e-mail]
cc: John Galasso,Nokia of America Corporation
Attachment A
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Attachment A
Figure

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Up p3j O > O �, k ." ^V; """\r LEGEND
•l ! �f E : ,~ we. ,t 4 STORMWATER INFRASTRUCTURE IN W-S GIS
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•••F NOTES:
N1. BACKGROUND IMAGE WAS PROVIDED UNSCALED FROM CITY OF WINSTON-SALEM(W-S)STORMWATER DEPARTMENT.IMAGE IS A SNAPSHOT SOURCED FROM ARCGIS PROGRAM INTERNAL
TO CITY OF W-S.
2. INFORMATION SUMMARIZED IN FIGURE WAS CAPTURED ON A PHONE CALL BETWEEN THE CITY OF W-S AND AECOM.ARCGIS DATABASE INTERNAL TO CITY OF W-S CONTAINS ADDITIONAL
v
INFORMATION FOR EACH BLUE SEGMENT,POTENTIALLY INCLUDING:SEGMENT LENGTH,UPSTREAM AND DOWNSTREAM INVERTS,UPSTREAM AND DOWNSTREAM STRUCTURES,AND SLOPE.
�' '] 3. 82"RCP NOTED ON BLUE SEGMENT EXTENDING TO THE NORTHWEST.
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