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NC0031879_Final Fact Sheet_20210330
Fact Sheet NPDES Permit No. NCO031879 Permit Writer / Email Contact Diana Yitbarek / diana.yitbarek@ncdenr.gov Date: 3/30/2021 Division/Unit: NC DEQ Division of Water Resources / NPDES Municipal Permitting Unit Fact Sheet Template: Version 1/9/2017 Permitting Action: ❑X Renewal ❑ Renewal with Expansion ❑ New Discharge ❑ Modification (Fact Sheet should be tailored to mod request) Note: A complete application should include the following: • For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee • For Existing Dischargers (POTW), EPA Form 2A, three effluent pollutant scans, four 2nd species WET tests. • For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based on industry category. Complete applicable sections below. If not applicable, enter N.A. 1. Basic Facility Information Table 1. Facility Information Facility Information Applicant/Facility Name: City of Marion/Corpening Creek Wastewater Treatment Plant (WWTP) Applicant Address: P.O. Box 700, Marion, NC 28752-0700 Facility Address: 3982 Highway 226 South, Marion, NC 28752 Permitted Discharge Flow: 2.5/3.0 million gallons per day (MGD) Facility Type/Waste: Major Municipal/ Domestic Facility Class: Class 111(2.5 MGD)/ Class IV (3.0 MGD) Biological - 15A NCAC 08G .0302 Treatment Units: Influent pump station, bar screening and grit removal structures, two primary clarifiers, two aeration basins, two secondary clarifiers, tertiary filters, chlorine contact chamber, dechlorination/sulfar dioxide, gravity sludge thickeners, and aerobic digester Pretreatment Program (Y/N) N — Industrial Waste Survey (IWS) requested by 7/l/2021 County: McDowell Region: Asheville Regional Office (ARO) Permitting Action: The City of Marion (City) applied for NPDES permit renewal for Corpening Creek WWTP in August 2019. The WWTP has a design capacity of 3.0 MGD and is currently authorized to discharge 2.5 MGD (up to 3.0 MGD upon request) into Corpening Creek (also identified as Youngs Fork), a class C waters. The class denotes use as a fishable/swimmable water. The Corpening Creek WWTP (Facility) serves about Page 1 of 14 4,300 customers within the City and in areas outside the City. The pretreatment program is inactive since 2008. An industrial waste survey (IWS) was requested by July 1, 2021. August 5, 2020, City's cover letter for renewal application explains that their average flow has remained less than 1.2 MGD and requests that the two tiers remain in effect (2.5 and 3.0 MGD), as with the last permit cycle. Facility Background: In the past the facility has been dealing with inflow and infiltration (I/I) issues that surged the treatment system and caused washouts. In 2011, the City completed Improvement Projects that involved upgrades to the Facility to make it a true 3.0 MGD wastewater plant. Currently, the primary clarifiers are being used as EQ basins to control the stormwater surges into the treatment system. In 2015, the Division added an effluent limitation and monitoring page with a lower design flow tier of 2.5 MGD based on the City's request due to the sustained lower average flows. At the present time this fact sheet assessment is based on a wastewater plant flow of 2.5 MGD. 2. Receiving Waterbody Information: Table 2. Receiving Waterbodv Information Outfalls/Receiving Stream(s): Outfall 001 [35039105.311N 81057'28.2"W]/Corpening Creek (Youngs Fork) Stream Segment/Assessment Unit (AU): 11-32-1-4a Stream Classification: C Drainage Area (mi2): 8.21 Summer 7Q10 (cfs) 2.3 Winter 7Q10 (cfs): 3.6 30Q2 (cfs): 6 Average Flow (cfs): 12 Instream Waste Concentration (IWC) (% effluent): 63 % at 2.5 MGD (7Q10S) 67 % at 3.0 MGD (7Q10S) 303(d) listed/parameter: Yes - For benthos and fish community Subject to TMDL/parameter: Yes- Mercury Statewide TMDL implemented in 2012 Basin/Sub-basin/ Hydrologic unit code (HUC): Catawba River Basin/03-08-30/03050101 USGS Topo Quad/State Grid: Marion East/E11NW Youngs Fork was listed in the NC 2014, 2018, and draft 2020 303(d) list for benthos and fish community and was categorized as degraded aquatic life with an impaired condition, which means that the biological community normally expected in a lake, stream or other waterway is unhealthy, much reduced, or absent, and the exact pollutant cause is not known. Further information can be found at the 2010 Catawba River Basinwide Water Quality Plan. Page 2of14 3. Effluent Data Summary Effluent data for Outfall 001 is summarized below from September 2016 through September 2020. Table 3. Effluent Data Summary with permit limits Outfall 001. Parameters listed as in the last permit. Parameter Units Average Max. Min. Permit Limit Flow MGD 0.99 4.13 0.05 MA* 2.5 MGD BODs mg/1 4.4 212 2.0 MA 30.0 mg/I WA* 45.0 mg/I Total Suspended n'gn 9.7 2140.0 2.2 MA 30.0 mg/I Solids (TSS) WA 45.0 mg/I 0.89 13.6 0.50 MA 1.5 mg/I NH3N (Summer) mg/1 WA 4.4 mg/I NH3N (Winter) mg/1 0.96 15.0 0.50 MA 3.3 mg/I WA 9.8 mg/I Dissolved Oxygen mg/1 8.36 11.30 4.90 DA*>_ 5.0 mg/I (DO) Fecal Coliform #/100 ml 3.7 2420.00 1.00 MA 200/100m1 (Geomean) WA 400/100ml pH SU 6.4 7.1 5.7 6.0<pH<9.0 Total Residual µg/1 20 45 20 DM* 27.00 Ng/I Chlorine (TRC) Temperature °C 17.7 25 8 Total Nitrogen (TN) mg/1 4.9 14.0 0.73 Total Phosphorus m /1 g 1.72 5.20 0.12 (TP) Total Cyanide µg/l 5.39 9.00 5.0 MA 8.0 Ng/I DM 33.0 pg/I Total Copper µg/l 3.72 16.00 1.0 Total Zinc µg/1 46.9 94.00 17.0 *MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average. Table 4. Effluent Data Summary from expanded effluent pollutant scan Outfall 001 Parameter Units Average Max. Mercury* ng/l 1.34 3.03 Chloroform µg/l 17.5 24 *See section 6.6 Mercury Statewide Total Maximum Daily Load (TMDL) Evaluation Sample results for the sampled metals not included above, such as antimony, arsenic, beryllium, cadmium, chromium, lead, nickel, selenium', silver, and thallium, were less than the method detection limit. Chloroform has a water quality standard value for water supply of 60 µg/l. The maximum concentration detected is currently within the accepted water quality standards. 1 See page 7 for discussion about practical quantification limits for selenium and silver Page 3of14 4. Instream Data Summary Instream monitoring may be required in certain situations, for example, 1) to verify model predictions when model results for instream D.O. are within 1 mg/1 of instream standard at full permitted flow; 2) to verify model predictions for outfall diffuser; 3) to provide data for future total maximum daily load (TMDL); 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership is maintained). Instream data summary and instream monitoring proposed for this permit action: The current permit requires instream [upstream (U) and downstream (D)] monitoring for dissolved oxygen and temperature. The U and D locations are about 100 feet and 200 feet from the outfall, respectively. The figure below summarizes instream and effluent (Eff) data from the analyzed period, September 2016 - September 2020. Figure 1. Average, maximum, and minimum instream and effluent data summary Temperature, C DO, mg/1 30.0 20.0 15.0 20.0 10.0 10.0 _ , � 5.0 , 1 0.0 0.0 Upstream Effluent Downstream Upstream Effluent Downstream ■ Average of Value ■ Max of Value Min of Value ■ Average of Value ■ Max of Value ■ Min of Value T-tests were run to analyze relationships between instream sample results. A statistically significant difference is determined when the t-test p-value result is < 0.05. Temperature: The maximum downstream temperature was 24 degrees Celsius, and the maximum temperature differential between the upstream and downstream samples was one degree Celsius. It was concluded that there is statistically significant difference between the upstream and downstream temperatures. DO: The minimum downstream DO detected was 4.6 mg/1 on 9/4/2018, and the maximum DO differential between the upstream and downstream samples was 3.0 mg/l. It was concluded that there is not a statistically significant difference between upstream and downstream DO. Conductivity: Effluent conductivity and instream conductivity sampling have been added to the permit. An industrial waste survey (IWS) was requested by July 1, 2021. If the IWS confirms industrial sources, instream monitoring for conductivity will need to commence. Hardness: Effluent hardness and instream hardness sampling, upstream of the discharge, have been added to the permit at a monitoring frequency of quarterly. The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Committee (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016 with some exceptions. The NC Division of Water Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after April 6, 2016. The new standards for most metals include acute standards. Further, the freshwater standards for several metals are expressed as the dissolved form of the Page 4 of 14 metals, and seven metals have hardness -dependent equations. As a result, the NPDES Permitting Unit will need site -specific effluent hardness data and instream hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit limitations. Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): NO Name of Monitoring Coalition: NA 5. Compliance Summary From November 2015 to November 2020 the Facility received a total of 20 notices of violation (NOVs) for exceeding monthly average (MA) limits for ammonia and TSS, and weekly average (WA) limits for BOD5, ammonia, and TSS; not reaching daily minimum (Dmin) for DO and pH, and for failing to comply with sampling frequencies. The Facility also received 12 Enforcement Cases for exceeding MA and WA limits for TSS and total ammonia. The ARO representative, Lauren Armeni, is working with the Facility to monitor the Facility's compliance performance. The report on limit violations that proceeded to NOV or Enforcement Case were as follows: • Ammonia - 4 MA limit exceedances and 6 WA limit exceedances. The maximum MA limit exceedance was 6.2 µg/1 in 2016 and the maximum WA limit exceedance was 13.67 µg/l in 2018. • BOD5 - 1 WA limit exceedance in 2020 at 83.15 mg/1. • TSS - 3 MA limit exceedances and 6 WA limit exceedances. The maximum MA limit exceedance was 183.84 mg/l and the maximum WA limit exceedance was 726.47 mg/l. • pH - 2 Daily Minimum not reached in 2020. • DO - 1 Daily Minimum not reached in 2020. Summary of the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The Facility passed eighteen of eighteen quarterly chronic toxicity tests from February 2016 to May 2020 and complied with all four 2nd species WET tests. Summary of the results from the most recent compliance inspection: The last facility inspection conducted in February 2021 reported that the facility has not had limit violations since May 2020 and is in non-compliance with requirements outlined in Permit Conditions Part II Section C (2) Proper Operation and Maintenance. Both primary clarifiers are being used as equalization basins; one of the secondary clarifiers needs repair due to a broken arm. A new RAS pump is needed, and there is currently no backup RAS pump. The facility staff is aware that some system components are degrading and have plans to improve the system. They plan to buy a new RAS pump in FY 22, and also plan to rehabilitate the offline aeration basin and eventually the tertiary filters. They have also ordered parts to replace the sweep arm and drive unit in one of the secondary clarifiers. 6. Water Quality -Based Effluent Limitations (WQBELs) 6.1 Dilution and Mixin Zones ones In accordance with 15A NCAC 2B.0206, the following stream flows are used for dilution considerations for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic Life; non -carcinogen H.H.); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, H.H.). If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA Page 5of14 If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA Stream flow values were extracted from the previous fact sheet from 2015. 6.2 Oxygen -Consuming Waste Limitations Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to ensure protection of the instream dissolved oxygen (D.O.) water quality standard. Secondary TBEL limits (e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and model results. If permit limits are more stringent than TBELs, describe how limits were developed: The current permit limits for BOD are secondary TBELs and are based on 40 CFR 133.102. No changes are proposed for this permit cycle. 6.3 Ammonia and Total Residual Chlorine Limitations Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals. Limitations for Total Residual Chlorine (TRC) are based on the N.C. water quality standard for protection of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values reported below 50 ug/l are considered compliant with their permit limit. Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: There are no proposed changes for ammonia. The current permit sets summer and winter MA and WA limits for ammonia for both flow tiers. The limits are needed to protect aquatic life. The MA was exceeded twice in summer, to a maximum of 4.82 mg/1(MA limit: 1.5 mg/1) and the WA was exceeded fourteen times in summer and four times in winter (WA limit: 4.4 mg/1); however, none of the ammonia results from the evaluated period exceeded 35 mg/l. The maximum value of ammonia reported for summer was 13.6 mg/1 and for winter 15 mg/l; The ammonia limits will be the same as the previous permit cycle. With this permit renewal, the City requested ammonia limits to be established at a level that is compatible to the surrounding WWTP facilities in the area (The permits for the surrounding facilities reflect a WA of 11 to 35 mg/l and a MA of 4 to 16mg/1). As mentioned above, the ammonia limits will be the same as the previous permit cycle. The WQBELs for ammonia for each WWTP are based on WLA calculations for the facility's specific flow tiers. The facility uses chlorination as its primary disinfection. The current permit limits TRC at 27 and 25 ug/L as a daily maximum for 2.5 and 3.0 MGD, respectively. Though several reported TRC values exceeded the 27 ug/L daily maximum limit, the facility is considered compliant with its permit since all reported values were less than 50 ug/L. The maximum TRC value reported was 45 ug/L. The TRC limit has been reviewed in the attached WLA and has been found to be protective. No changes are proposed for TRC. 6.4 Reasonable Potential Analysis (RPA) for Toxicants The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of detection limit for "less than" values; and 4) stream flows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, N.C. began implementation of Page 6 of 14 dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. The RPAs were conducted for permitted flows of 2.5 MGD and 3.0 MGD with a 7Q 10 (Summer) of 2.3 cubic feet per second (cfs) and default hardness values. The City of Marion reported total selenium and total silver at less than detection, with detection levels < 10.0 µg/L, and < 5.0 µg/L respectively, in the Effluent Pollutant Scans. Based on the Reasonable Potential Analysis (RPA), the City's allowable discharge concentrations are 8.00 µg/L and 0.096 µg/L for total selenium and total silver, respectively. DWR's laboratory identifies the target Practical Quantification Limits (PQLs) for total selenium and total silver as 1.0 µg/L. 15A NCAC 2B .0505 (e) (4) requires that all test procedures must produce detection and reporting levels that are below the permit discharge requirements and all data generated must be reported to the approved detection level or lower reporting level of the procedure. If no approved methods are capable of achieving a detection level below the permit discharge requirement (or allowable discharge concentration) the method with the lowest detection level must be used. The City should use sufficiently sensitive test methods for all pollutants, including when performing Effluent Pollutant Scans. The results of the RPA showed that the facility does not require any additional toxicant limitations. The answers below are based on the RPA. RPAs were conducted on effluent toxicant data collected in the Permittee's 2016 to 2018 effluent pollutant scans and DMRs. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. The data set was limited for arsenic, beryllium, cadmium, total phenolic compounds, chromium, lead, nickel, selenium, and silver. Based on this analysis, the following permitting actions are proposed for this permit: Effluent Limit with Monitoring. The following parameters will receive a water quality -based effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water quality standards/criteria: Cyanide (this is carried over from the previous permit) Monitoring. Only. nly. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was >50% of the allowable concentration: Copper (this is carried over from the previous permit) No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and the maximum predicted concentration was <50% of the allowable concentration: Antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, molybdenum, nickel, selenium, silver, tin, titanium, vanadium, zinc, total phenolic compounds, and chloroform. These compounds will be monitored in the pretreatment program during this permit cycle: None. Pretreatment program is currently inactive. POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for additional pollutants of concern. o The following parameter(s) will receive a water quality -based effluent limit (WQBEL) with monitoring, since as part of a limited data set, two samples exceeded the allowable discharge concentration: NA o The following parameter(s) will receive a monitor -only requirement, since as part of a limited data set, one sample exceeded the allowable discharge concentration: NA RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater are included as attachments of this Fact Sheet. Page 7of14 6.5 Toxicity Testing Limitations Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test failure. Describe proposed toxicity test requirement: This is a Major Publicly Owned Treatment Work (POTW), and a chronic WET limit will continue on a quarterly frequency at Outfall 001 at 63% at 2.5 MGD using Ceriodaphnia dubia. For the 3.0 MGD flow tier, a quarterly chronic WET limit would apply at 67% effluent concentration, using Ceriodaphnia dubia, as well. 6.6 Mercury Statewide Total Maximum Daily Load (TMDL) Evaluation There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a wasteload allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and industrial facilities with known mercury discharges. Given the small contribution of mercury from point sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source control. Municipal facilities > 2 MGD and discharging multiple quantifiable levels of mercury (>1 ng/1) received an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/l A mercury evaluation was conducted in accordance with the Permitting Guidance developed for the implementation of the statewide Mercury TMDL to determine the need for a limit. The facility started collecting data in 2012. Table 5. Mercury Evaluation 2012 2013 2014 2015 2016 2017 2018 # of Samples 4 4 4 3 Mercury Annual Average (ng/1) 5.2 5.0 2.3 4.1 0.5 0.5 3.03 Mercury Annual Max (ng/1) 9.2 7.6 3.4 5.6 0.5 0.5 3.03 Below find summaries of compliance mercury data from 2016 to 2018. Based on the dataset, the water quality based effluent limitation (WQBEL) for mercury is 19.1 and 17.9 ng/1 for 2.5 and 3.0 MGD. The technology based effluent limit (TBEL) is 47 ng/1. Table 6. Mercury Effluent Data Summary - 2.5 MGD 2C'=6 2C"7 2018 #ofSam ples _ _ 1 Annual Average, ng/L U 5 U 5 K0 Maximum Value, ng/L U 51, 0.50 3.03 TBEL, ng/L 47 WQBEL, ng/L 19.1 Page 8 of 14 Table 7. Mercury Effluent Data Summary — 3.0 MGD 2016 2017 2019 # of Sam pl es 1 1 1 Annual Average,ng/L 0.5 0.5 3.0 Maximum Value, ng/L 0.50 0.W 3D3 TBEL, ng/L 47 WCLBEL, ng/L 17.9 Describe proposed permit actions based on mercury evaluation: Mercury evaluation results used 1631E. No annual average mercury concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL. The maximum value reported in this period was 3.03 ng/l. No mercury limit is required and the mercury minimization plan (MMP) will be removed in this permit cycle. 6.7 Other TMDL/Nutrient Management Strategy Considerations If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: During the 2010 permit renewal, effluent and instream monitoring for total nitrogen (TN) and total phosphorous (TP) were included in the permit due to the impairment of Lake Rhodhiss (2010 NC 303(d) List). Corpening Creek is within the Lake Rhodhiss' drainage basin. In 2015, the instream monitoring for TN and TP was eliminated due to the Lake Rhodhiss being taken off the 303(d) list. In 2014, the Division decided to change nutrient monitoring frequencies from weekly to monthly and eliminate instream monitoring requirements for four facilities (Marion, Morganton, Lenoir, and Valdese) discharging to Lake Rhodhiss. The permit reflects the monthly nutrient (T.P. and T.N.; TKN + NO3-N + NO2-N) monitoring for 2.5 MGD and 3.0 MGD flows. Annual nutrient T.N. and T.P. loads: The maximum T.N. and T.P. annual loads during the evaluated period were 18,344 lb/yr (2019) and 5,246 lb/yr (2019). The Facility is currently operating at a flow limit of 2.5 MGD and there is no proposal to increase to 3.0 MGD. There are not annual load T.N. and T.P. limits for the 3.0 MGD flow tier. Annual loads for TN and TP will be revisited when a final nutrient TMDL for the Catawba River Basin is concluded. Table 8. Nutrients Effluent Data Summary Parameter 2017 2018 2019 Annual TN load, Ib/yr 12,118 14,675 18,344 Annual TP load, Ib/yr 4,751 4,722 5,246 6.8 Other WQBEL Considerations If applicable, describe any other parameters of concern evaluated for WQBELs: N.A. If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall comply with in order to protect the designated waterbody: N.A. If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 1 SA NCAC 2H 0107(c)(2) (B), 40CFR 122.47, and EPA May 2007 Memo: N.A. If applicable, describe any water quality standards variances proposed in accordance with NCGS 143- 215.3(e) and 1 SA NCAC 2B.0226 for this permit renewal: NA Page 9of14 7. Technology -Based Effluent Limitations (TBELs) Municipals (if not applicable, delete and skip to Industrials) Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/l BODS/TSS for Monthly Average, and 45 mg/l for BODS/TSS for Weekly Average). YES If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA Are 85% removal requirements for BOD51TSS included in the permit? YES If NO, provide a justification (e.g., waste stabilization pond). NA 8. Antidegradation Review (New/Expanding Discharge) The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges require an antidegradation review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all cases, existing instream water uses and the level of water quality necessary to protect the existing use is maintained and protected. If applicable, describe the results of the antidegradation review, including the Engineering Alternatives Analysis (EAA) and any water quality modeling results: NA 9. Antibacksliding Review Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL limits, or WQBELs may be less stringent based on updated RPA or dilution). Are any effluent limitations less stringent than previous permit (YES/NO): YES. Monitoring and reporting for Zinc was removed. Mercury Minimization Plan requirement was removed. If YES, confirm that antibacksliding provisions are not violated: Confirmed. Zinc was removed based on updated RPA and the MMP removal is consistent with EPA approved 2012 Statewide Mercury TMDL Implementation. 10. Monitoring Frequency Requirements Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding prohibitions would not be triggered by reductions in monitoring frequencies. For instream monitoring, refer to Section 4. Page 10 of 14 11. Electronic Reporting Requirements The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs) electronically. While NPDES regulated facilities would initially be required to submit additional NPDES reports electronically effective December 21, 2020, EPA is proposing to extend this deadline from December 21, 2020, to December 21, 2025. This permit contains the requirements for electronic reporting, consistent with Federal requirements. 12.Summary of Proposed Permitting Actions Table 9. Current Permit Conditions and Proposed Changes for 2.5 MGD and 3.0 MGD Parameter Current Permit Limits and Proposed Change Basis for Condition/Change Monitoring Frequency Flow MA 2.5 MGD No changes 15A NCAC 2B .0505 and 3.0 MGD The average flow for the past five years is less than 1.15 MGD Continuous BODS For 2.5 MGD and 3.0 MGD No changes TBEL. Secondary treatment MA 30.0 mg/I standards/40 CFR 133 / 15A NCAC 213 WA 45.0 mg/I .0406. 3/week for 2.5 MGD Daily for 3.0 MGD TSS For 2.5 MGD and 3.0 MGD No changes TBEL. Secondary treatment MA 30 mg/I standards/40 CFR 133 / 15A NCAC 213 WA 45 mg/I .0406. 3/week for 2.5 MGD Daily for 3.0 MGD NH3-N (Summer) For 2.5 MGD No changes WQBEL based on WLA calculations for MA 1.5 mg/I 2.5 and 3.0 MGD using 1990 DWR WA 4.4 mg/I ammonia toxicity policy For 3.0 MGD MA 1.4 mg/I WA 4.2 mg/I 3/week for 2.5 MGD Daily for 3.0 MGD NH3-N (Winter) For 2.5 MGD No changes WQBEL based on WLA calculations for MA 3.3 mg/I 2.5 and 3.0 MGD using 1990 DWR WA 9.8 mg/I ammonia toxicity policy For 3.0 MGD MA 3.0 mg/I WA 9.0 mg/I 3/week for 2.5 MGD Daily for 3.0 MGD Page 11 of 14 Conductivity None If needed, effluent The facility has potential industrial conductivity dischargers 15A NCAC 2B.0500 monitoring Monitoring and reporting for for 2.5 and 3.0 MGD conductivity will begin only if the 2021 industrial waste survey (IWS) confirms 3/week for 2.5 MGD industrial sources discharging Daily for 3.0 MGD pretreated wastewater into the Facility. If needed, instream conductivity monitoring for 2.5 and 3.0 MGD Monitor and report instream at a variable" frequency DO Not less than 5 mg/I. No changes WQBEL. State WQ standard, 15A NCAC 2B .0200, 15A NCAC 2B.0500 Monitor and report instream at a variable" frequency Monitor and report effluent 3/week for 2.5 MGD Daily for 3.0 MGD Fecal coliform MA 200 /100ml No changes WQBEL. State W.Q. standard, 15A (Geometric Mean) WA 400 /100ml NCAC 26 .0200. for 2.5 MGD and 3.0 MGD 3/week for 2.5 MGD Daily for 3.0 MGD pH 6-9 S.U. No changes WQBEL. State W.Q. standard, 15A for 2.5 and 3.0 MGD NCAC 26 .0200 3/week for 2.5 MGD Daily for 3.0 MGD TRC DM 27.0 µg/I No changes WQBEL. State W.Q. standard, 15A for 2.5 MGD and 25 µg/I NCAC 2B .0200. The Division considers for 3.0 MGD all effluent TRC values reported below 50 ug/I to be in compliance with the 3/week for 2.5 MGD permit. Daily for 3.0 MGD Temperature Monitor and report No changes 15A NCAC 26.0200 and 15A NCAC effluent 3/week for 213.0500 for 2.5 MGD Daily for 3.0 MGD Monitor and report instream at a variable" frequency Page 12 of 14 Total Hardness None Added quarterly Hardness -dependent dissolved metals monitoring upstream water quality standards approved in and in effluent 2016. for 2.5 MGD and 3.0 MGD Total Nitrogen (TN) Monitor and report No changes 15A NCAC 2B .0500 - Surface Water monthly Monitoring and Reporting. for 2.5 MGD and 3.0 MGD Total Phosphorus (TP) Monitor and report No changes 15A NCAC 2B .0500 - Surface Water monthly Monitoring and Reporting. for 2.5 MGD and 3.0 MGD Total Cyanide For 2.5 MGD No changes RP, State WQ standards, 15A 2B .0200 MA 8.0 µg/I WA 33.0 µg/I For 3.0 MGD MA 7.5 µg/I WA 31.1 µg/I Monitor and report monthly for 2.5 MGD and 3.0 MGD Total Copper Quarterly monitoring for No changes Predicted Max >_ 50% of Allowable Cw - 2.5 MGD and 3.0 MGD Continue Quarterly Monitoring Total Zinc Quarterly monitoring for Removed No RP. Predicted Max < 50% of 2.5 MGD and 3.0 MGD Allowable Cw. No Monitoring required Toxicity Test Chronic limit, 63% at 2.5 No changes WQBEL. No toxics in toxic amounts. MGD or 67% at 3.0 MGD 15A NCAC 26.0200 and 15A NCAC 213.0500 Effluent Pollutant Three times per permit Next scans must be 40 CFR parts 423 and 122 Scan cycle for 2.5 MGD and 3.0 performed in each of MGD the following years: 2023, 2024, and 2025. Mercury Minimization MMP Removed Consistent with EPA approved 2012 Plan (MMP) for 2.5 MGD and 3.0 MGD Statewide Mercury TMDL Implementation. Electronic Reporting Electronic reporting Added language for In accordance with EPA Electronic special condition new electronic Reporting Rule 2015 and Rule -Phase 2 for 2.5 MGD and 3.0 MGD reporting deadline Extension December 21, 2025 * M.A. - Monthly Average, WA - Weekly Average, D.M. - Daily Max. ** Variable monitoring frequency is defined as follows: samples collected three times per week during June 1 through September 30 and once per week October 1 through May 31. 13. Public Notice Schedule Permit to Public Notice: February 23, 2021 Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall be submitted to the Director Page 13 of 14 within the 30 days comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted. 14. Fact Sheet Addendum (if applicable) Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes If Yes, list changes and their basis below: The Special Condition A. (5.) Electronic Reporting of Discharge Monitoring Reports was corrected to clarify that duplicate signed copies shall be submitted only if a permittee is unable to use the eDMR system due to a demonstrated hardship. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. 15. Fact Sheet Attachments (upon request): 1. RPA Sheets Summary for 2.5 and 3.0 MGD. Each sheet contains: input information tab, data analyzed tab, results summary tab, and dissolve to total metals calculation tab. 2. BOD and TSS Removal Rate calculations 3. NH3/TRC/Fecal Waste Load Allocation (WLA) Spreadsheet for 2.5 and 3.0 MGD 4. Mercury TMDL Calculations for 2.5 and 3.0 MGD 5. Toxicity Summary/WET testing 6. Instream data summary and ttest 7. Pretreatment Summary 8. Limit violations summary, MA and WA limit exceedances, and compliance facility report from ECHO 9. Renewal Application Addendums o Signed Effluent Pollutant Scans o Addendum Form 2A 10. NPDES Implementation of Instream Dissolved Metals Standards Freshwater Standards 11. 2018 NC 303(d) List (one page) 12. 2021 Inspection Report 13. Affidavit 14. Questions and Responses from the Public Notice Period Page 14 of 14 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY CHECK WQS Table 1. Project Information Facility Name WWTP/WTP Class NPDES Permit Outfall Flow, Ow (MGD) Receiving Stream HUC Number Stream Class ❑ Apply WS Hardness WQC 7Q10s (cfs) 7Q10w (cfs) 30Q2 (cfs) QA (cfs) 1 Q10S (cfs) Effluent Hardness -------------- Upstream Hardness Combined Hardness Chronic -------------- Combined Hardness Acute Data Source(s) ❑ CHECK TO APPLY MODEL ❑ CHECK IF HQW OR DPW WQS Corpening Creek III NCO031879 001 2.500 Corpening Creek (Youngs Fork) 03050101 C 2.300 3.60 6.00 12.00 1.93 49.33 mg/L (Avg) 25 mg/L (Avg) ---------------------- 40.27 mg/L ---------------------- 41.24 mg/L - - - - - - - - - - - - - - - - - - - - - - Note: 7Q10S, 7Q10W, 30Q2, and QA values were taken from previous fact sheet. Limited dataset for arsenic, beryllium, cadmium, total phenolic compounds, chromium, lead, nickel, selenium, and silver. Par01 Par02 Par03 Par04 Par05 Par06E Par07 Par08 Par09 Par10 Par91 Par12 Par13 Par14 Parts Par16 Par17 Par18 Par19 Par20 Par21 Par22 Par23 Par24 Table 2. Parameters of Concern Name WQS Type Chronic Modifier Acute PQL Units Arsenic Aquactic Life C 150 FW 340 ug/L Arsenic Human Health Water Supply C 10 HH/WS N/A ug/L Beryllium Aquatic Life NC 6.5 FW 65 ug/L Cadmium Aquatic Life NC 0.8459 FW 5.0150 ug/L Chlorides Aquatic Life NC 230 FW mg/L Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L Total Phenolic Compounds Aquatic Life NC 300 A ug/L Chromium III Aquatic Life NC 173.9654 FW 1363.7927 1 ug/L Chromium VI Aquatic Life NC 11 FW 16 pg/L Chromium, Total Aquatic Life NC N/A FW N/A pg/L Copper Aquatic Life NC 11.8434 FW 16.7832 ug/L Cyanide Aquatic Life NC 5 FW 22 10 ug/L Fluoride Aquatic Life NC 1,800 FW ug/L Lead Aquatic Life NC 5.0194 FW 132.2827 ug/L Mercury Aquatic Life NC 12 FW 0.5 ng/L Molybdenum Human Health NC 2000 HH ug/L Nickel Aquatic Life NC 55.7269 FW 511.9717 pg/L Nickel Water Supply NC 25.0000 WS N/A pg/L Selenium Aquatic Life NC 5 FW 56 ug/L Silver Aquatic Life NC 0.06 FW 0.7012 ug/L Zinc Aquatic Life NC 189.8090 FW 192.1174 ug/L Chloroform Water Supply C 60 WS pg/L 31879 RPA 2.5.xlsm, input 3/30/2021 Corpening Creek NCO031879 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 Qw (MGD) = 2.5000 WWTP/WTP Class: III 1Q10S(cfs)= 1.93 IWC% @ 1Q10S = 66.75279931 7Q10S (cfs) = 2.30 IWC% @ 7Q10S = 62.75303644 7Q10W (cfs) = 3.60 IWC% @ 7Q10W = 51.83946488 30Q2 (cfs) = 6.00 IWC% @ 30Q2 = 39.24050633 Avg. Stream Flow, QA (cfs) = 12.00 TW%C @ QA = 24.40944882 Receiving Stream: Corpening Creek (Youngs Fork) HUC 03050101 Stream Class: C Outfall 001 Qw = 2.5 MGD COMBINED HARDNESS (mg/L) Acute = 41.24 mg/L Chronic = 40.27 mg/L YOU HAVE DESIGNATED THIS RECEIVING STREAM AS WATER SUPPLY Effluent Hard: 0 value > 100 mg/L Effluent Hard Avg = 49.33 mg/L PARAMETER NC STANDARDS OR EPA CRITERIA REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE � CY oApplied � Chronic Acute n # Det. Max Pred Cw Allowable Cw Standard Acute (FW): 509.3 Arsenic C 150 FW(7010s) 340 u;,,/L _ _ _ ____ ________ ______ 3 0 15.0 _____ Chronic (FW) 239.0 C.V. (default) M_ax_MD_L= 10 Arsenic C 10 HH/WS(Qavg) ug/L Note: n 5 9 NO DETECTS Chronic (HH) 41.0 Limited dataset. No RP, Predicted Max < 50% of Allowable Cw - No Monitoring required, other than Limited data set Max MDL = 10 pollutant scan (PS) Acute: 97.37 Beryllium NC 6.5 FW(7Q10s) 65 ug/L 3 0 1.50__ Note: n 5 9 C.V. (default) Chronic: 10.36 All values in limited dataset reported non -detect < 1 Limited data set NO DETECTS Max MDL = 1 ug/L - No Monitoring required, other than PS. Acute: 7.513 Cadmium NC 0.8459 FW(7Q10s) 5.0150 ug/L 3 0 1.500 Note: n < 9 C.V. (default) ------------------------------------------------ Chronic: 1.348 No RP, Predicted Max < 50% of Allowable Cw - No Limited data set NO DETECTS Max MDL = 1 Monitoring required, other than PS. Acute: NO WQS Total Phenolic Compounds NC 300 A(30Q2) ug/L 1 1 15.5 Note: n < 9 C.V. (default) Chronic: 764.5 No RP, Predicted Max < 50% of Allowable Cw - No Limited data set No value > Allowable Cw Monitoring required, other than PS. Acute: 2,043.0 Chromium III NC 173.9654 FW(7Q10s) 1363.7927 µg/L 0 0 N/A -_ _ _ _ ---------- -Chronic: -------------------------- 277.2 See Chromium, Total Acute: 24.0 Chromium VI NC 11 FW(7Q10s) 16 µg/L 0 0 N/A _ _ _ _ -- ----- - -- --------------- Chronic: >_ 5 but < Cr VI Allowable See Chromium, Total Tot Cr value(s) Cw Chromium, Total NC µg/L 3 0 7.5 Max reported value = 2.5 a: No monitoring required if all Total Chromium samples are < 5 pg/L or Pred. max for Total Cr is < Note: n < 9 C.V. (default) default allowable Cw for Cr VI. Limited data set NO DETECTS Max MDL = 5 Acute: 25.14 Copper NC 11.8434 FW(7Q10s) 16.7832 ug/L 22 19 23.52 _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ Chronic: 18.87 _ No RP , Predicted Max z 50%f Allowable Cw No value > Allowable Cw Continue Quarterly Monitoring Acute: 33.0 Cyanide NC 5 FW(7Q10s) 22 10 ug/L 51 14 5.0 ___ ______ _____________ Chronic: 8.0 Predicted Max z 50% of Allowable Cw - Maintain 31879 RPA 2.5.xlsm, rpa Page 1 of 2 3/30/2021 Corpening Creek Outfall 001 NCO031879 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 2.5 MGD No value > Allowable Cw limits and monitoring Acute: 198.168 Lead NC 5.0194 FW(7Q10s) 132.2827 ug/L 3 0 7.500 Note: n < 9 C.V. (default) ------------------------------------------------ Chronic: 7.999 No RP. All values reported non -detect < 5 ug/L - No Limited data set NO DETECTS Max MDL = 5 monitoring required. Acute (FW): 767.0 Nickel NC 55.7269 FW(7Q10s) 511.9717 µg/L 3 0 15.0 _ _ _ _ _ ---- -- Chronic (FW) 88.8 -------------------------- Note: n 5 9 C.V. (default) M—ax_MD_L = 10 _ _ _ _ ---------------------------- Nickel NC 25.0000 WS(7Q10s) µg/L Limited data set NO DETECTS Chronic (WS) 39.8 No RP. All values reported non -detect < 10 ug/L Predicted Max < 50% of Allowable Cw - No Max MDL = 10 Monitoring required Acute: 83.9 Selenium NC 5 FW(7Q10s) 56 ug/L 3 0 15.0 Note: n 5 9 C.V. (default) Chronic: 8.0 No RP. All values reported non -detect < 10 ug/L Predicted Max < 50% of Allowable Cw - No Limited data set NO DETECTS Max MDL = 10 Monitoring required Acute: 1.050 Silver NC 0.06 FW(7Q10s) 0.7012 ug/L 3 0 7.500 ------------------------------------------------ Note: n < 9 C.V. (default) Chronic: 0.096 All values reported non -detect < 5 ug/L - No monitoring required. Limited data set NO DETECTS Max MDL = 5 Acute: 287.8 No RP, Predicted Max < 50% of Allowable Cw - No Zinc NC 189.8090 FW(7Q10s) 192.1174 ug/L 22 22 114.7 Monitoring required -- ---------- Chronic: 302.5 -------------------------- No value > Allowable Cw Acute: NO WQS Chloroform C 60 WS(Qavg) µg/L 3 3 72.00000 Note: n < 9 C.V. (default) ................. _ Chronic: 245.806 No RP, Predicted Max < 50% of Allowable Cw - No Limited data set No value > Allowable Cw Monitoring required 31879 RPA 2.5.xlsm, rpa Page 2 of 2 3/30/2021 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY CHECK WQS Table 1. Project Information Facility Name WWTP/WTP Class NPDES Permit Outfall Flow, Ow (MGD) Receiving Stream HUC Number Stream Class ❑ Apply WS Hardness WQC 7Q10s (cfs) 7Q10w (cfs) 30Q2 (cfs) QA (cfs) 1 Q10S (cfs) Effluent Hardness -------------- Upstream Hardness Combined Hardness Chronic -------------- Combined Hardness Acute Data Source(s) ❑ CHECK TO APPLY MODEL ❑ CHECK IF HQW OR DPW WQS Corpening Creek IV NCO031879 001 3.000 Corpening Creek (Youngs Fork) 03050101 C 2.300 3.60 6.00 12.00 1.93 49.33 mg/L (Avg) 25 mg/L (Avg) ---------------------- 41.28 mg/L ---------------------- 42.2 mg/L - - - - - - - - - - - - - - - - - - - - - - Note: 7Q10S, 7Q10W, 30Q2, and QA values were taken from previous fact sheet. Limited dataset for arsenic, beryllium, cadmium, total phenolic compounds, chromium, lead, nickel, selenium, and silver. Par01 Par02 Par03 Par04 Par05 Par06E Par07 Par08 Par09 Par10 Par91 Par12 Par13 Par14 Parts Par16 Par17 Par18 Par19 Par20 Par21 Par22 Par23 Par24 Table 2. Parameters of Concern Name WQS Type Chronic Modifier Acute PQL Units Arsenic Aquactic Life C 150 FW 340 ug/L Arsenic Human Health Water Supply C 10 HH/WS N/A ug/L Beryllium Aquatic Life NC 6.5 FW 65 ug/L Cadmium Aquatic Life NC 0.8619 FW 5.1160 ug/L Chlorides Aquatic Life NC 230 FW mg/L Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L Total Phenolic Compounds Aquatic Life NC 300 A ug/L Chromium III Aquatic Life NC 177.5331 FW 1389.5448 1 ug/L Chromium VI Aquatic Life NC 11 FW 16 pg/L Chromium, Total Aquatic Life NC N/A FW N/A pg/L Copper Aquatic Life NC 12.0970 FW 17.1483 ug/L Cyanide Aquatic Life NC 5 FW 22 10 ug/L Fluoride Aquatic Life NC 1,800 FW ug/L Lead Aquatic Life NC 5.1601 FW 135.6928 ug/L Mercury Aquatic Life NC 12 FW 0.5 ng/L Molybdenum Human Health NC 2000 HH ug/L Nickel Aquatic Life NC 56.9079 FW 521.9609 pg/L Nickel Water Supply NC 25.0000 WS N/A pg/L Selenium Aquatic Life NC 5 FW 56 ug/L Silver Aquatic Life NC 0.06 FW 0.7293 ug/L Zinc Aquatic Life NC 193.8377 FW 195.8716 ug/L Chloroform Water Supply C 60 WS ug/L 31879 RPA 3.0.xlsm, input 3/30/2021 Corpening Creek Outfall 001 NCO031879 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 3 MGD MAXIMUM DATA POINTS = 58 Qw (MGD) = 3.0000 WWTP/WTP Class: IV 1Q10S(cfs)= 1.93 IWC% @ 1Q10S = 70.66869301 7Q10S (cfs) = 2.30 IWC% @ 7Q10S = 66.90647482 7Q10W (cfs) = 3.60 IWC% @ 7Q10W = 56.36363636 30Q2 (cfs) = 6.00 IWC% @ 30Q2 = 43.66197183 Avg. Stream Flow, QA (cfs) = 12.00 TW%C @ QA = 27.92792793 Receiving Stream: Corpening Creek (Youngs Fork) HUC 03050101 Stream Class: C COMBINED HARDNESS (mg/L) Acute = 42.2 mg/L Chronic = 41.28 mg/L YOU HAVE DESIGNATED THIS RECEIVING STREAM AS WATER SUPPLY Effluent Hard: 0 value > 100 mg/L Effluent Hard Avg = 49.33 mg/L PARAMETER NC STANDARDS OR EPA CRITERIA REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE o Applied Chronic Acute n # Det. Max Pred Cw Allowable Cw Standard Acute (FW): 481.1 Arsenic C 150 FW(7010s) 340 uWL _ _ _ ---_ -_ -- -------------------------- 3 0 15.0 Chronic (FW)- C.V. (default) M_ax_MD_L= 10 Arsenic C 10 HH/WS(Qavg) ug/L Note: n 5 9 NO DETECTS Chronic (HH) 35.8 Limited dataset. No RP, Predicted Max < 50% of Allowable Cw - No Monitoring required, other than Limited data set Max MDL = 10 pollutant scan (PS) Acute: 91.98 Beryllium NC 6.5 FW(7Q10s) 65 ug/L 3 0 1.50 Note: n 5 9 C.V. (default) Chronic: 9.72 All values in limited dataset reported non -detect < 1 Limited data set NO DETECTS Max MDL = 1 ug/L - No Monitoring required, other than PS. Acute: 7.239 Cadmium NC 0.8619 FW(7Q10s) 5.1160 ug/L 3 0 1.500 Note: n 5 9 C.V. (default) ------------------------------------------------ Chronic: 1.288 No detects Limited data set NO DETECTS Max MDL = 1 Acute: NO WQS Total Phenolic Compounds NC 300 A(30Q2) ug/L 1 1 15.5 Note: n 5 9 C.V. (default) Chronic: 687.1 No RP, Predicted Max < 50 % of Allowable Cw - No Limited data set No value > Allowable Cw Monitoring required, other than PS. Acute: 1,966.3 Chromium III NC 177.5331 FW(7Q10s) 1389.5448 µg/L 0 0 N/A -_ _ _ _ ---------- -Chronic:265.3 --------------- See Chromium, Total Acute: 22.6 Chromium VI NC 11 FW(7Q10s) 16 µg/L 0 0 N/A -_ _ _ _ ----- - -- -Chronic: -------------------------- >_ 5 but < Cr VI Allowable See Chromium, Total Tot Cr value(s) Cw Chromium, Total NC µg/L 3 0 7.5 Max reported value = 2.5 a: No monitoring required if all Total Chromium samples are < 5 pg/L or Pred. max for Total Cr is < Note: n 5 9 C.V. (default) allowable Cw for Cr VI. Limited data set NO DETECTS Max MDL = 5 Acute: 24.27 Copper NC 12.0970 FW(7Q10s) 17.1483 ug/L 22 19 23.52 _ _ _ _ _ __ _ Chronic: 18.08 _ _ _ _ _ _ _ _ _ _ _ _ No RP , Predicted Max z 50%f Allowable Cw No value > Allowable Cw Continue Quarterly Monitoring Acute: 31.1 Cyanide NC 5 FW(7Q10s) 22 10 ug/L 51 14 5.0 ___ _____ Chronic: 7.5 ___ _________ Predicted Max >_ 50% of Allowable Cw - Maintain 31879 RPA 3.0.xlsm, rpa Page 1 of 2 3/30/2021 Corpening Creek Outfall 001 NCO031879 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 3 MGD No value > Allowable Cw limits and monitoring Acute: 192.013 Lead NC 5.1601 FW(7Q10s) 135.6928 ug/L 3 0 7.500 Note: n < 9 C.V. (default) ------------------------------------------------ Chronic: 7.712 No RP. All values reported non -detect < 5 ug/L - No Limited data set NO DETECTS Max MDL = 5 monitoring required. Acute (FW): 738.6 Nickel NC 56.9079 FW(7Q10s) 521.9609 µg/L 3 0 15.0 _ _ _ _ _ ---- - -- Chronic (FW)Note: -------------------------- n 5 9 C.V. (default) M—ax_MD_L = 10 _ _ _ _ ---------------------------- Nickel NC 25.0000 WS(7Q10s) µg/L Limited data set NO DETECTS Chronic (WS) 37.4 No RP. All values reported non -detect < 10 ug/L Max MDL = 10 Predicted Max < 50% of Allowable Cw - No Monitoring required Acute: 79.2 Selenium NC 5 FW(7Q10s) 56 ug/L 3 0 15.0__ Note: n 5 9 C.V. (default) Chronic: 7.5 No RP. All values reported non -detect < 10 ug/L - No Limited data set NO DETECTS Max MDL = 10 Monitoring required Acute: 1.032 Silver NC 0.06 FW(7Q10s) 0.7293 ug/L 3 0 7.500 ------------------------------------------------ Note: n < 9 C.V. (default) Chronic: 0.090 All values reported non -detect < 5 ug/L - No monitoring required. Limited data set NO DETECTS Max MDL = 5 Acute: 277.2 No RP, Predicted Max < 50% of Allowable Cw - No Zinc NC 193.8377 FW(7Q10s) 195.8716 ug/L 22 22 114.7 Monitoring required -- ---------- Chronic: 289.7 -------------------------- No value > Allowable Cw Acute: NO WQS Chloroform C 60 WS(Qavg) ug/L 3 3 72.00000 Note: n < 9 C.V. (default) ................. _ Chronic: 214.839 No RP, Predicted Max < 50% of Allowable Cw - No Limited data set No value > Allowable Cw Monitoring required -------------------------- Acute: 0 0 N/A _ _ _ ----------------------------------------- Chronic: No RP, Predicted Max < 50% of Allowable Cw - Monitoring to continue as total nitrogen 31879 RPA 3.0.xlsm, rpa Page 2 of 2 3/30/2021 REASONABLE POTENTIAL ANALYSIS H1 H2 Use"PASTE SPECIAL Use"PASTE SPECIAL Effluent Hardness Values" then "COPY.' Upstream Hardness Values" then "COPY" . Maximum data . Maximum data points = 58 points = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 6/4/2016 54.00 54 Std Dev. 5.0332 1 9/30/2020 25.00 25 Std Dev. N/A 2 8/12/2017 50.00 50 Mean 49.3333 2 Mean 25.0000 3 11/10/2018 44.00 44 C.V. (default) 0.6000 3 C.V. 0.0000 4 n 3 4 n 1 5 10th Per value 45.20 mg/L 5 10th Per value 25.00 mg/L 6 Average Value 49.33 mg/L 6 Average Value 25.00 mg/L 7 Max. Value 54.00 mg/L 7 Max. Value 25.00 mg/L 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 31879 RPA 2.5.xlsm, data 1 - 3/30/2021 REASONABLE POTENTIAL ANALYSIS Par01 & Par02 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Arsenic Date Data BDL=1/2DL 5/26/2016 < 10 5 8/8/2017 < 10 5 11/27/2018 < 10 5 Use"PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 Results Std Dev. 0.0000 Mean 5.0000 C.V. (default) 0.6000 n 3 Mult Factor = 3.00 Max. Value 5.0 ug/L Max. Pred Cw 15.0 ug/L -2- 31879 RPA 2.5.xlsm, data 3/30/2021 REASONABLE POTENTIAL ANALYSIS Par03 Par04 Use "PASTE SPECIAL Use "PASTE SPECIAL Beryllium Values" then "COPY" Cadmium Values" then "COPY" . Maximum data . Maximum data points = 58 points = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 5/26/2016 < 1 0.5 Std Dev. 0.0000 1 5/26/2016 < 1 0.5 Std Dev. 0.0000 2 8/17/2017 < 1 0.5 Mean 0.5000 2 8/8/2017 < 1 0.5 Mean 0.5000 3 12/4/2018 < 1 0.5 C.V. (default) 0.6000 3 11/27/2018 < 1 0.5 C.V. (default) 0.6000 4 n 3 4 n 3 5 5 6 Mult Factor = 3.00 6 Mult Factor = 3.00 7 Max. Value 0.50 ug/L 7 Max. Value 0.500 ug/L 8 Max. Pred Cw 1.50 ug/L 8 Max. Pred Cw 1.500 ug/L 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 31879 RPA 2.5.xlsm, data -3- 3/30/2021 REASONABLE POTENTIAL ANALYSIS Par05 Chlorides Use "PASTE SPECIAL- Values" then "COPY". Par06 Use "PASTE SF Chlorinated Phenolic Compounds Values" then "I . Maximum c Maximum data points = points = 5 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 5/15/2016 220 220 Std Dev. 78.9892 1 Std Dev. NO DATA 2 8/4/2016 262 262 Mean 253.6 2 Mean NO DATA 3 11/14/2016 378 378 C.V. (default) 0.6000 3 C.V. NO DATA 4 2/14/2017 163 163 n 5 4 n 0 5 5/5/2017 245 245 5 601 Mult Factor = 2.3 6 Mu It Factor = N/A 7 Max. Value 378.0 mg/L 7 Max. Value N/A 8 Max. Pred Cvv 877.0 mg/L 8 Max. Pred Cvv N/A 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 31879 RPA 2.5.xlsm, data -4- 3/30/2021 REASONABLE POTENTIAL ANALYSIS COPY" Total Phenolic Compounds late ;8 Date Data BDL=1/2DL Results 1 5/26/2016 < 5 2.5 Std Dev. 2 8/17/2017 < 5 2.5 Mean 3 11/27/2018 < 5 2.5 C.V. (default) 4 n 5 6 Mult Factor = ug/L 7 Max. Value ug/L 8 Max. Fred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Par08 Use "PASTE SPECIAL Values" then "COPY" Chromium III . Maximum data points = 58 Date Data BDL=1/2DL Results 0.0000 1 Std Dev. 2.5000 2 Mean 0.6000 3 C.V. 3 4 n 5 6.20 6 Mult Factor = 2.5 ug/L 7 Max. Value 15.5 ug/L 8 Max. Fred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Use "PASTE SF Values" then Maximum c points = 5 NO DATA NO DATA NO DATA 0 N/A N/A N/A 31879 RPA 2.5.xlsm, data -5- 3/30/2021 REASONABLE POTENTIAL ANALYSIS COPY" Chromium VI late ;8 Date Data BDL=1/2DL Results 1 Std Dev. 2 Mean 3 C.V. 4 n 5 6 Mult Factor = Ng/L 7 Max. Value pg/L 8 Max. Fred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Par10 Use "PASTE SPECIAL Values" then "COPY" Total . Maximum dChromium,ChrO1Um, points = 58 Date Data BDL=1/2DL Results NO DATA 1 5/26/2016 < 5.00 2.5 Std Dev. NO DATA 2 8/17/2017 < 5.00 2.5 Mean NO DATA 3 11/27/2018 < 5.00 2.5 C.V. (default) 0 4 n 5 N/A 6 Mult Factor = N/A Ng/L 7 Max. Value N/A pg/L 8 Max. Fred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Use "PASTE SF Values" then Maximum c points = 5 0.0000 2.5000 0.6000 3 3.00 2.5 7.5 31879 RPA 2.5.xlsm, data -6- 3/30/2021 REASONABLE POTENTIAL ANALYSIS COPY" late ;8 Ng/L pg/L 1 Copper Date Data BDL=1/2DL Results 1 9/19/2016 6 6 Std Dev. 2 11/1/2016 2 2 Mean 3 1/6/2017 3 3 C.V. 4 2/7/2017 4 4 n 5 5/9/2017 2 2 6 8/1/2017 5 5 Mult Factor = 7 11/7/2017 4 4 Max. Value 8 1/8/2018 2 2 Max. Fred Cw 9 2/6/2018 1 1 10 5/8/2018 2 2 11 8/7/2018 2 2 12 11 /6/2018 3 3 13 2/5/2019 5 5 14 5/7/2019 2 2 15 8/6/2019 < 5 2.5 16 9/9/2019 3 3 17 10/7/2019 5 5 18 11 /5/2019 3 3 19 1 /7/2020 < 2 1 20 2/4/2020 < 2 1 21 5/5/2020 3 3 22 8/4/2020 16 16 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Use"PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 3.5227 0.8853 22 1.47 16.00 ug/L 23.52 ug/L 2 Cyanide Date Data BDL=1/2DL Results 1 9/12/2016 < 5 5 Std Dev. 2 9/16/2016 6 5 Mean 3 10/3/2016 < 5 5 C.V. 4 11/1/2016 8 5 n 5 12/6/2016 < 5 5 6 1/6/2017 9 5 Mult Factor = 7 1/30/2017 6 5 Max. Value 8 2/6/2017 < 5 5 Max. Fred Cw 9 3/6/2017 6 5 10 4/10/2017 7 5 11 5/9/2017 < 5 5 12 6/5/2017 7 5 13 7/10/2017 6 5 14 8/1/2017 < 5 5 15 9/5/2017 < 5 5 16 10/6/2017 < 5 5 17 11 /7/2017 < 5 5 18 12/4/2017 6 5 19 1 /8/2018 < 5 5 20 2/5/2018 < 5 5 21 3/6/2018 < 5 5 22 4/2/2018 < 5 5 23 5/7/2018 < 5 5 24 6/5/2018 < 5 5 25 7/9/2018 < 5 5 26 8/7/2018 < 5 5 27 9/10/2018 < 5 5 28 10/2/2018 < 5 5 29 11 /6/2018 < 5 5 30 12/4/2018 < 5 5 31 1/8/2019 < 5 5 32 2/5/2019 < 5 5 33 3/5/2019 < 5 5 34 4/2/2019 < 5 5 35 5/7/2019 5 5 36 6/4/2019 7 5 37 7/9/2019 < 5 5 38 8/6/2019 < 5 5 39 9/9/2019 < 5 5 40 10/7/2019 < 5 5 41 11 /5/2019 5 5 42 12/10/2019 < 5 5 43 1 /7/2020 < 5 5 44 2/4/2020 < 5 5 45 3/3/2020 < 5 5 46 4/7/2020 < 5 5 47 5/5/2020 < 5 5 48 6/2/2020 6 5 49 7/7/2020 < 5 5 50 8/4/2020 6 5 51 9/1/2020 < 5 5 52 53 54 55 56 57 58 Use "PASTE SF Values" then Maximum c points = 5 5.00 0.0000 51 1.00 5.0 5.0 Mr! 31879 RPA 2.5.xlsm, data 3/30/2021 REASONABLE POTENTIAL ANALYSIS PaF'14 PaF'15 �ECIAL Use "PASTE SPECIAL Mercury COPY" Lead Values" then "COPY" . Maximum data ;8 points = 58 1 Date 5/26/2016 < BDL=1/2DL 5.00 2.5 Results Std Dev. 0.0000 1 Date Data 5/26/2016 < BDL=1/2DL 0.50 0.25 Results Std Dev. 2 8/8/2017 < 5.00 2.5 Mean 2.5000 2 8/4/2017 < 0.50 0.25 Mean 3 11/27/2018 < 5.00 2.5 C.V. (default) 0.6000 3 11/15/2018 3.03 3.03 C.V. (default) 4 n 3 4 n 5 5 6 Mult Factor = 3.00 6 Mult Factor = ug/L 7 Max. Value 2.500 ug/L 7 Max. Value ug/L 8 Max. Fred Cw 7.500 ug/L 8 Max. Fred Cw 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 Use "PASTE SF Values" then Maximum c points = 5 1.1767 0.6000 3 3.00 3.0 9.1 31879 RPA 2.5.xlsm, data -8- 3/30/2021 REASONABLE POTENTIAL ANALYSIS Par16 Par17 8� Par18 >ECIAL Use "PASTE SPECIAL Nickel COPY" late Molybdenum Values" then "COPY" . Maximum data ;8 points = 58 Date 1 Data BDL=1/2DL Results Std Dev. NO DATA 1 Date Data 5/26/2016 < 10.00 BDL=1/2DL 5 Results Std Dev. 2 Mean NO DATA 2 8/8/2017 < 10.00 5 Mean 3 C.V. NO DATA 3 11/29/2018 < 10.00 5 C.V. (default) 4 n 0 4 n 5 5 6 Mult Factor = N/A 6 Mult Factor = ng/L 7 Max. Value N/A ug/L 7 Max. Value ng/L 8 Max. Fred Cw N/A ug/L 8 Max. Fred Cw 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 Use "PAS SPECIAL-Vz then "COP Maximum points = 0.0000 5.0000 0.6000 3 3.00 5.0 15.0 31879 RPA 2.5.xlsm, data -9- 3/30/2021 REASONABLE POTENTIAL ANALYSIS ;TE Par19 dues" ,Y• data 58 Selenium Date Data BDL=1/2DL Results 1 5/26/2016 < 10.00 5 Std Dev. 2 8/8/2017 < 10.00 5 Mean 3 11/27/2018 < 10.00 5 C.V. (default) 4 n 5 6 Mult Factor = Ng/L 7 Max. Value pg/L 8 Max. Pred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Use"PASTE 7 SPECIAL -Values" then "COPY". Maximum data points = 58 5.0000 0.6000 3 3.00 5.0 ug/L 15.0 ug/L Use"PASTE: Silver V alues" then Maximum data 58 Date Data BDL=1/2DL Results 1 5/26/2016 < 5.00 2.5 Std Dev. 2 8/11/2017 < 5.00 2.5 Mean 3 11/21/2018 < 5.00 2.5 C.V. (default) 4 n 5 6 Mult Factor = 7 Max. Value 8 Max. Pred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 2.5000 0.6000 3 3.00 2.500 7.500 31879 RPA 2.5.xlsm, data _10- 3/30/2021 REASONABLE POTENTIAL ANALYSIS 3PECIAL- ..COPY". a points = Par21 ug/L ug/L 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Zinc Date Data BDL=1/2DL Results 9/19/2016 69 69 Std Dev. 11/1/2016 67 67 Mean 1/6/2017 49 49 C.V. 2/7/2017 58 58 n 5/9/2017 30 30 8/1/2017 38 38 Mult Factor = 11/7/2017 17 17 Max. Value 1/8/2018 36 36 Max. Pred Cw 2/6/2018 27 27 5/8/2018 46 46 8/7/2018 35 35 11 /6/2018 37 37 2/5/2019 35 35 5/7/2019 19 19 8/6/2019 65 65 9/9/2019 76 76 10/7/2019 66 66 11 /5/2019 47 47 1 /7/2020 35 35 2/4/2020 45 45 5/5/2020 41 41 8/4/2020 94 94 Par22 Use "PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 46.9091 0.4133 22 1.22 94.0 ug/L 114.7 ug/L Chloroform Date Data BDL=1/2DL Results 1 6/3/2016 13.8 13.8 Std Dev. 2 8/31/2017 14.7 14.7 Mean 3 12/6/2018 24 24 C.V.(default) 4 n 5 6 Mult Factor = 7 Max. Value 8 Max. Pred Cw 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 l�fii ! 31879 RPA 2.5.xlsm, data 3/30/2021 REASONABLE POTENTIAL ANALYSIS Use "PASTE SPECIAL - Values" then "COPY". Maximum data points = 58 17.5000 0.6000 3.00 24.000000 Ng/L 72.000000 Ng/L -12- 31879 RPA 2.5.xlsm, data 3/30/2021 NCO031879 Corpening Creek WWTP CBOD monthly removal rate Month September-16 October-16 November-16 December-16 January-17 February-17 March-17 April-17 May-17 June-17 July-17 August-17 September-17 October-17 November-17 December-17 January-18 February-18 March-18 April-18 May-18 June-18 July-18 August-18 September-18 October-18 November-18 December-18 January-19 February-19 RR (%) 98.60 99.16 98.74 99.18 97.82 98.30 98.59 98.90 96.72 98.75 98.08 97.56 96.04 97.86 99.06 98.52 98.90 98.43 97.71 97.88 98.89 98.10 99.15 98.29 99.32 97.76 99.32 99.29 98.76 97.56 Month March-19 April-19 May-19 June-19 July-19 August-19 September-19 October-19 November-19 December-19 January-20 February-20 March-20 April-20 May-20 June-20 July-20 August-20 September-20 October-20 November-20 December-20 January-21 February-21 March-21 April-21 May-21 June-21 July-21 August-21 Overall CBOD removal rate RR (%) 99.77 98.53 97.85 97.98 98.69 98.95 98.67 98.43 99.31 99.08 99.39 93.88 98.62 99.37 91.07 98.99 98.82 97.93 98.96 98.28 Month September-16 October-16 November-16 December-16 January-17 February-17 March-17 April-17 May-17 June-17 July-17 August-17 September-17 October-17 November-17 December-17 January-18 February-18 March-18 April-18 May-18 June-18 July-18 August-18 September-18 October-18 November-18 December-18 January-19 February-19 11/30/2020 TSS monthly removal rate RR (%) 97.83 99.38 98.94 99.38 97.67 96.76 97.98 98.98 97.62 99.59 99.28 98.34 97.46 97.98 98.64 99.19 99.29 98.95 98.37 98.53 99.30 99.22 99.53 92.88 99.38 94.82 98.92 98.84 96.82 97.82 Month March-19 April-19 May-19 June-19 July-19 August-19 September-19 October-19 November-19 December-19 January-20 February-20 March-20 April-20 May-20 June-20 July-20 August-20 September-20 October-20 November-20 December-20 January-21 February-21 March-21 April-21 May-21 June-21 July-21 August-21 Overall TSS removal rate RR (%) 99.82 98.79 98.30 98.56 98.70 98.99 98.64 97.57 99.14 98.19 98.86 84.50 98.25 99.45 29.32 99.29 98.79 97.77 98.77 96.72 NH3/TRC WLA Calculations Facility: City of Marion/Corpening Creek Wastewater Treatment Plant (WWTP) PermitNo. NCO031879 Prepared By: Diana Yitbarek Enter Design Flow (MGD): 2.5 Enter s7Q10 (cfs): 2.3 Enter w7Q10 (cfs): 3.6 Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 2.3 s7Q10 (CFS) 2.3 DESIGN FLOW (MGD) 2.5 DESIGN FLOW (MGD) 2.5 DESIGN FLOW (CFS) 3.875 DESIGN FLOW (CFS) 3.875 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 62.75 IWC (%) 62.75 Allowable Conc. (ug/1) 27 Allowable Conc. (mg/1) 1.5 Maintain limit at 27 ug/I Maximum MA ammonia (summer): 3.65 mg/I. Daily Max 13.6 mg/I Current MA limit: 1.5 mg/I Maintain limit Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 3.6 Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 2.5 (If DF >331; Monitor) DESIGN FLOW (CFS) 3.875 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 1.59 Upstream Bkgd (mg/1) 0.22 IWC (%) 51.84 Allowable Conc. (mg/1) 3.3 Maintain 200/100 ml MA limit Maximum MA ammonia (summer): 4.82 mg/1. Daily Max 15 mg/I Current MA limit: 3.3 mg/I Maintain limit Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N 1. If Allowable Conc > 35 mg/I, Monitor Only Summer Winter 2. Monthly Avg limit x 3 = Weekly Avg limit (Municil WA ammonia, mg/1 4.39 9.80 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NH3/TRC WLA Calculations Facility: City of Marion/Corpening Creek Wastewater Treatment Plant (WWTP) PermitNo. NCO031879 Prepared By: Diana Yitbarek Enter Design Flow (MGD): 3 Enter s7Q10 (cfs): 2.3 Enter w7Q10 (cfs): 3.6 Total Residual Chlorine (TRC) Ammonia (Summer) Daily Maximum Limit (ug/1) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 2.3 s7Q10 (CFS) 2.3 DESIGN FLOW (MGD) 3 DESIGN FLOW (MGD) 3 DESIGN FLOW (CFS) 4.65 DESIGN FLOW (CFS) 4.65 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 66.91 IWC (%) 66.91 Allowable Conc. (ug/1) 25 Allowable Conc. (mg/1) 1.4 Maintain limit at 27 ug/I Maximum MA ammonia (summer): 3.65 mg/I Daily Max 13.6 mg/I Current MA limit: 1.4 mg/I Maintain limit Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 3.6 Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 3 (If DF >331; Monitor) DESIGN FLOW (CFS) 4.65 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 1.49 Upstream Bkgd (mg/1) 0.22 IWC (%) 56.36 Allowable Conc. (mg/1) 3.0 Maintain 200/100 ml MA limit Maximum MA ammonia (summer): 4.82 mg/I Daily Max 15 mg/I Current MA limit: 3.0 mg/I Maintain limit Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) Corpening Creek WWTP/NC0031879 Mercury Data Statistics (Method 1631E) 2016 2017 2018 # of Samples 1 1 1 Annual Average, ng/L 0.5 0.5 3.0 Maximum Value, ng/L 0.50 0.50 3.03 TBEL, ng/L 47 WQBEL, ng/L 19.1 Corpening Creek WWTP/NC0031879 Mercury Data Statistics (Method 1631E) 2016 2017 2018 # of Samples 1 1 1 Annual Average, ng/L 0.5 0.5 3.0 Maximum Value, ng/L 0.50 0.50 3.03 TBEL, ng/L 47 WQBEL, ng/L 17.9 PART E. TOXICITY TESTING DATA, EPA FORM 35-10-2A CORPENING CREEK WWTP, NC0031879 SUBMITTED: 7/29/2019 RECEIVED BY WATER QUALITY PERMITTING SECTION: 8/5/2019 In accordance with EPA-35-10-2A Part EA, if applicant previously submitted biomonitoring test data, dates and summary of the results was to be added to the application. To the best of my knowledge, that information was inadvertently omitted. Below is the required information. Ceriodaphnia, tested Feb, May, Aug, and Nov Dates entered Aquatic Toxicology Branch System: 25 Feb 19 30 May 19 21 Aug 19 26 Nov 19 Flathead Minnow, tested Aug, Sep, Oct, and Nov Submittal Dates: 8/4/19 10/6/19 11/3/19 *Sep data submitted 1/12/2021 *Data may have been previously submitted, but was not in the Chronic Toxicity database Summary: All testing events passed without any issues noted. Whole Effluent Toxicity Testing and Self Monitoring Summary Marion-Corpening Cr. WWTP NCO031879/001 County: McDowell Ceri7dPF Begin: 5/1/2016 chr lim: 63% @ 2.5M NonComp: Single J F M A M 2016 - Pass - - Pass 2017 - Pass - - Pass 2018 - Pass - - Pass 2019 - Pass - - Pass 2020 - Pass - - Pass Mars Hill WTP NCO083712/001 County: Madison Ceri7dPF Begin: 7/1/2011 Chr Monit: 5.78% NonComp: J F M A M 2016 Pass - - Pass - 2017 Pass - - Pass - 2018 Pass - - Pass - 2019 Pass - - Pass - 2020 Pass - - Pass - Region: ARO Basin: CTB30 Feb May Aug Nov 7Q10: 2.3 PF: 3.0 IWC: 67 Freq: Q J J A S O Pass Pass Pass - - >100(P)Pass - >100( Region: ARO Basin: FRB04 Jan Apr Jul Oct 7Q10: PF: IWC: Freq: Q J J A S O - Pass - - Pass - Pass - - Pass - Pass - - Pass - Pass - - Pass Marshall WWTP NCO021733/001 County: Madison Region: ARO Basin: FRB04 Feb May Aug Nov Fthd24PF Begin: 4/1/2012 24hr p/f ac lim: 90% + NonComp: Single 7Q10: 535 PF: 0.40 IWC: 0.12 Freq: Q J F M A M J J A S O 2016 - Pass - - Pass - - Pass - - 2017 - Pass - - Pass - - Pass - - 2018 - Pass - - Pass - - Pass - - 2019 - Pass - - Pass - - Pass - - 2020 - Pass - - Pass - - - - - Martin County WTP NCO089435/001 County: Martin Region: WARO Ceri7dPF Begin: 4/1/2014 Chr Monit: 90% NonComp: 7Q10: J F M A M J 2016 - - Pass - - H 2017 - - Pass - - Pass 2018 - - Pass - - Pass 2019 - - Pass - - Pass 2020 - - Pass - - Pass Maxton WTP NCO048577/001 County: Robeson Ceri7dPF Begin: 9/1/2014 Chr Monit: 90% NonComp: J F M A M 2016 Fail - - Pass - 2017 Fail - - Pass - 2018 Pass - - Fail - 2019 Fail - - Fail - 2020 Fail - - Pass - SOC JOC: N Pass Pass Pass >100 Pass SOC JOC: N SOC JOC: N Pass Pass Pass Pass Basin: ROA09 Mar Jun Sep Dec SOC JOC: PF: IWC: Freq: Q J A S O N Pass - Pass Pass Pass Region: FRO Basin: LUM51 Jan Apr Jul Oct SOC JOC: 7Q10: PF: IWC: Freq: Q J J A S O N - Fail - - Pass - - Fail - - Fail - Fail - - Fail - NR Pass D D D D Pass Pass Pass Pass D Legend: P= Fathead minnow (Pimphales promelas), H=No Flow (facilitv is active), s = Split test between Certified Labs Page 73 of 122 Data Parameter Location Average of Value Max of Value Min of Value 00010 - Temperature, Water Deg. Centigrade Downstream 16.9 24.0 2.0 Effluent 17.8 25.0 8.0 U stream 1 16.4 23.0 1.0 00010 - Temperature, Water Deg. Centigrade Total 17.2 25.0 1.0 00300 - Oxygen, Dissolved (DO) Downstream 9.0 14.2 4.6 Effluent 8.4 11.3 4.9 Upstream 9.2 15.3 4.6 00300 - Oxygen, Dissolved DO Total 8.8 15.3 4.6 Grand Total 13.0 25.0 1.0 Temperature, C 30.0 25.0 20.0 15.0 10.0 5.0 0.0 18.0 16.0 14.0 12.0 10.0 8.0 6.0 4.0 2.0 0.0 IN. III IN= Upstream Effluent Downstream 00010 - Temperature, Water Deg. Centigrade ■ Average of Value ■ Max of Value ■ Min of Value DO, mg/1 III III III Upstream Effluent Downstream 00300 - Oxygen, Dissolved (DO) ■ Average of Value ■ Max of Value ■ Min of Value Sum of Value Parameter Location 00300 - Oxygen, Dissolved DO Years Date Downstream Upstream 2016 Sep 101.9 105.1 Oct 45.3 44.4 Nov 42.7 39.8 Dec 42.7 41.8 2017 Jan 53.9 55.5 Feb 41.3 45.2 Mar 40.1 36.6 Apr 38.6 38.3 May 43.5 44.4 Jun 104.9 110 Jul 103.8 108.7 Aug 115.4 119.6 Sep 108.6 110.4 Oct 42 43.6 Nov 52.8 54.7 Dec 45.7 47.9 2018 Jan 63.9 68 Feb 43.8 44.2 Mar 46.7 48.2 Apr 51.5 52.8 May 36.92 37.52 Jun 104 107.8 Jul 116 117.8 Aug 105.2 106.8 Sep 95.1 97.3 Oct 42.3 45.7 Nov 40.6 41.4 Dec 52.1 52 45.3 44.8 2019 Jan Feb 44.6 45.2 Mar 45.3 45.9 Apr 52.9 54 May 38.2 39.2 Jun 106.6 110.6 Jul 122.4 120.8 Aug 94 97.7 Sep 94.6 98.3 Oct 58.3 59.1 Nov 41.5 41.6 Dec 49.2 51.2 2020 Jan 43.5 44.2 Feb 41.6 44.4 Mar 51.7 53.5 Apr 39 39.3 May 36.6 36.8 Jun 119.3 120 F-Test Two -Sample for Variances Variable 1 Variable 2 Mean 68.263673 66.8922449 Variance 989.33216 943.181197 Observations 49 49 df 48 48 F 1.0489312 P(F<=f) one -tail 0.4346221 F Critical one -tail 1.6153703 Comment: The variance of Variable 1 is higher than the va We accept the null hypothesis. The variances of the two sE t-Test: Two -Sample Assuming Equal Variances Variable 1 Variable 2 Mean 68.263673 66.8922449 Variance 989.33216 943.181197 Observations 49 49 Pooled Variance 966.25668 Hypothesized Mean Differenc( 0 df 96 t Stat 0.2183786 P(T<=t) one -tail 0.4137989 t Critical one -tail 1.6608814 P(T<=t) two -tail 0.8275977 t Critical two -tail 1.9849843 We look at the p-value, two tail. Since we set alpha value < 2020 Jul 105.3 104.3 Aug 98.6 99.3 Sep 127.9 129.2 Grand Total 3277.72 3344.92 1 /24/2021 Mail - Yitbarek, Diana - Outlook Re: [External] Request - NC0031879, Corpening Creek WWTP, City of Marion, McDowell County, ARC) Yitbarek, Diana <diana.yitbarek@ncdenr.gov> Thu 1/7/2021 14:40 To: Tim Horton <thorton@marionnc.org> Cc: Montebello, Michael J <Michael.Montebello@ncdenr.gov> Dear Tim Horton - I checked with the pretreatment staff. We will need the City to perform an industrial waste survey (IWS) to ensure that the POTW's list of Industrial Users (IUs) and the pollutants in their waste streams are current. The IWS will help determine if any of the IUs should become Significant Industrial Users (SIU) or if the IU might need regulation as a non-SIU (NSCIU). The SIU criteria are found in 15A NCAC 02H .0903(b)(30). Guidance on how to conduct an IWS can be found here and you can find further information about IWS on our website. If you can complete the IWS within 180 days, that would be appreciated. Please let me know if you have any questions. -Diana Diana Yitbarek Engineer T: +1-919-707-9130 diana.yitbarek@ncdenr.gov NPDES Municipal Permitting Unit NC Department of Environmental Quality Division of Water Resources Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical: 512 N. Salisbury Street,_Ern. 925T, Raleigh, NC 27604-1170 w t EkQa GgwiwrOILniaixaw�isi p,iavty *Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience and stay safe. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Yitbarek, Diana <diana.yitbarek@ncdenr.gov> Sent: Thursday, January 7, 2021 12:00 To: Tim Horton <thorton@marionnc.org> Subject: Re: [External] Request - NC0031879, Corpening Creek WWTP, City of Marion, McDowell County, ARO Good morning, Dear Tim Horton Thanks for your message and congratulations on your new position as WWTP Superintendent. Addressing your questions: Item#1 - According to our records, the City of Marion's pretreatment (PT) program is on the inactive list since 2008. I will check in with the PT staff to get more information about this and get back to you. https://outlook.office365.com/mail/search/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQAPL9AOBgXltliG6Kn1osTH... 1/3 1/24/2021 Mail - Yitbarek, Diana - Outlook Item#3 - The City submitted the permit application (attached to this email) on August 5, 2019. I only have that scanned version. Hopefully, you find the editable version in your files. If not, let me know, and I can point you to the updated fillable 2A form for permit applications. Item#5 - The mercury minimization plan (MMP) was one of the special conditions included in the permit. I will attach the permit here. See section A. (6), page 10/11, and please let me know if you have any questions. Best, -Diana Diana Yitbarek Engineer T: +1-919-707-9130 diana.yitbarek@ncdenr.gov NPDES Municipal Permitting Unit NC Department of Environmental Quality Division of Water Resources Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical: 512 N. Salisbury Street, Rm. 925T, Raleigh, NC 27604-1170 xt � ovPM PIFn++�rn�i+l gq�llMy *Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience and stay safe. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Tim Horton <thorton@marionnc.org> Sent: Thursday, January 7, 2021 07:27 To: Yitbarek, Diana <diana.yitbarek@ncdenr.gov> Subject: [External] Request - NC0031879, Corpening Creek WWTP, City of Marion, McDowell County, ARO CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Good Morning, Larry Carver retired 28 Feb 20. 1 am the new WWTP Superintendent. I have questions regarding Items #1, #3, and #5. Item#1 Item 1.7of Table 2 "Indicate the number of SIUs and NSCIUs that discharge to the POTW". I'm researching pretreatment status Item#3 I can't open the file to complete the required section. Item#5 I'm unfamiliar with the Mercury Minimization Plan. I'll research it. https://outlook.office365.com/mail/search/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQAPL9AOBgXltliG6Kn1osTH... 2/3 1 /24/2021 Thanks, Mail - Yitbarek, Diana - Outlook Tim Horton Wastewater Superintendent City of Marion (828) 652-8843 (office) (828) 803-5736 (mobile) thorton@marionnc.org On Tue, Jan 5, 2021 at 1:52 PM Yitbarek, Diana <diana.yitbarek@ncdenr.gov> wrote: Dear Larry Carver, I hope this message finds you well. I am the assigned permit writer for the subject WWTP. I recently started reviewing the NPDES permit application for renewal submitted by the City on August 5, 2019, and have a couple of requests: 1. Since the EPA form 2A has been updated, I will need you to complete this form. Please send it to me, and I'll attach it as an addendum to your application. 2. Please submit the signed Annual Monitoring and Pollutant Scan for 2016, 2017, and 2018. Scanned copies with your signature would suffice. 3. Please fill out Part E. Toxicity Testing Data of the permit application, attach testing results, and resubmit. 4. Please provide coordinates for upstream and downstream location points. 5. Please submit the WWTP's mercury minimization plan and summarized results since the last permit renewal. If you provide this information within the next three weeks, that would be appreciated. Thanks for your continued cooperation with the NPDES program and your work protecting public health and the environment. Please confirm the reception of this email and let me know if you have any questions. -Diana Diana Yitbarek Engineer T: +1-919-707-9130 diana.yitbarek@ncdenr.gov NPDES Municipal Permitting Unit NC Department of Environmental Quality Division of Water Resources Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical: 512 N. Salisbury Street, Rm. 925T, Raleigh, NC 27604-1170 �� ID�_EA. Dgp+�jn�r��i of Fny�ronniraiial {k,sliYy *Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience and stay safe. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. https://outlook.office365.com/mail/search/id/AAQkADNmOTIxZjdhLTEyMWYtNDEzMS1 iOGNiLTkxNmZhYWJmZThIMAAQAPL9AOBgXltliG6Kn1osTH... 3/3 ECH(s Enforcement and Compliance History Online Detailed Facility Report Facility Summary_ CORPENING CREEK WWTP 3982 NC HWY 226 S, MARION, NC 28752 FRS (Facility Registry Service) ID: 110028271313 EPA Region: 04 Latitude: 35.652445 Longitude:-81.95739 Locational Data Source: FRS Industry: Sewerage Systems Indian Country: N Enforcement and Compliance Summary statute CwA Insp (5 Years) 3 Date of Last Inspection 03/21/2019 Current Compliance Status Violation Identified Qtra with NC (of 12) 12 Qtrs with Significant Violation I Informal Enforcement Actions (5 years) 10 Formal Enforcement Actions (5 years) 6 Penalties from Formal Enforcement Actions (5 years) $8,193 EPA Cases (5 years) -- Penalties from EPA Cases (5 years) — Regulatory Information Clean Air Act (CAA): No Information Clean Water Act (CWA): Minor, Permit Admin Continued (NCL031879), Major, Permit Expired (NC0031879), Minor, Permit Effective (NCG110102) Resource Conservation and Recovery Act (RCRA): No Information Safe Drinking Water Act (SDWA): No Information Other Regulatory Reports Air Emissions Inventory (EIS): No Information Greenhouse Gas Emissions (eGGRT): No Information Toxic Releases (TRI): No Information Compliance and Emissions Data Reporting Interface (CEDRI): No Information Known Data Problems Facility/System Characteristics Facility/System Characteristics S stem FRS Statute Identifier Universe Status Areas Permit Expiration Date Indian Court, N Latitude 35.652445 Longitude .81.95739 110028271313 ICIS-NPDES CWA NCL031879 Minor: Associated Permit Record Admin Continued Biosolids 12/31/2020 N 35.652445 -81.95739 ICIS-NPDES CWA NC0031879 Major: NPDES Individual Permit Expired Biosolids, POTW O1/31/2020 N 35.652298 -81.956771 ICIS-NPDES I CWA I NCGlIO102 I Minor: General Permit Covered Facility Effective 05/31/2023 N 35.652298 -81.956771 Facility Address System Statute Identifier 110028271313 Facility Name Facility Address 3982 NC HWY 226 S, MARION, NC 28752 FRS CORPENING CREEK WWI? ICIS-NPDES CWA NCL031879 CITY OF MARION PO DRAWER 700, MARION, NC 28752 ICIS-NPDES CWA NC0031879 CORPENING CREEK W WTP 3982 NC HWY 226 S, MARION, NC 28752 ICIS-NPDES CWA NCGI10102 CORPENING CREEK W WTP 3982 NC HWY 226 S, MARION, NC 28752 Facility SIC (Standard Industrial Classification) Codes Facility NAICS (North American Industry System I Identifier — SIC Code SIC Description Classification System) Codes ICIS-NPDES NC0031879 4952 Sewerage Systems NPDES NC0031879 4952 Sewerage Systems ICIS-NPDES NCGI10102 4952 Sewerage Systems NPDES NCGI10102 4952 Sewerage Systems Facility Industrial Effluent Guidelines IdentifierI Effluent Guideline 40 CFR PartEffluent Guideline Descri lion NCGI10102 401 General provisions Enforcement and Compliance Compliance Monitoring History (5 years) Sy>icm Identifier NAICS Code NAICS Description No data records returned Facility Tribe Information ff!5L' ervation Name Tribe Name EPA Tribal ID Distance to Tribe miles No data records returned Statute Source ID System Activity Type Com liance Monitoring Type Lead Agency State Date 03/21/2019 Finding if aERlicable) CWA NC0031879 ICIS-NPDES Inspection/Evaluation Base Program - Evaluation CWA NCGI10102 ICIS-NPDES Inspcction/Evalua0on Base Program - Evaluation State O1/16/2019 CWA NCGI10102 ICIS-NPDES Inspection/Evaluation Base Program - Evaluation State 11/15/2018 Entries in italics are not counted in EPA compliance monitoring strategies or annual results. Compliance Summary Data Statute CWA I Source ID I CL03 Vl Current SNC (Significant Noncom liance /HPV (Hieh Prioritv Violation Current As Of Qtra with NC (Noncompliance) of 12 Data Last Refreshed 01/15/2021 No 09/30/2020 0 CWA NC0031879 No 09/30/2020 12 01/15/2021 CWA NCGI10102 No 09/30/2020 0 01/15/2021 Three -Year Compliance History by Quarter CWA (Source Ill: NCL031879) 10/01-12/31/17 01/01-03/31/18 04/O1-06/30/18 07/01-09/30/18 10/O1-12/31/18 01/01-03/31/19 04/O1-06/30/19 07/01-09/30/19 10/01-12/31/19 01/01-03/3 U20 04/O1-06/30/20 07/01-09/30/20 10/01-01/15/21 Facility -Level Status o Violation No Violation No Viola on No Mo a on No Violation No Violation o o a on o Molation No Molation No o a on Ne o a on No Violation Undetermined Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Quarterly Noncompliance Report History Violation Violation Violation Violation Violation Violation Violation Violation Violation Volation ' rg°r re Violation Vol-ted Facility -Level Statue Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Catego Undetermined Noncomplian Quarterly Noncompliance Report Reportable Reportable Reportable Reportable Reportable Reportable Reportable Reportable Reportable Reportable Ettlucnt - Non- Reportable History Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance Noncompliance monthly Average Noncompliance Limit Pollutant Disch Mon Freq Point Loc ROD, 5-day, CWA 20 deg. C © 001 - M Eftuent� Goss 89 CWA I total [as N)© 1001 M - I Effluent I Mthly I I 43% M Goss CWA I total [as Nj 1001 - Effluent I Nf I I 39 © M Gros CWA [Dp) © 0`1 - I!ftluent Neither M Gross Solids, total CWA suspendedff3l 0W - Effluent Mthly M Goss 141% 108% [ [ 1 1 19% 2% 35% 1 508% Solids, total CWA suspended MGros 0- Eftluent �_d 53% Ih% 34% 151% 1514% M CWA pit Efluent Neither LIMIT LIMIT M Gross VIOLATION VIOLATION Late or Missing Discharge Monitoring Report (DMR) Measurements Counts of Missing DMR Measurements I9 1-1 lCn .T•N!`rll nl ail I 9.1I I,I III 'a/111 n6 1I nl 0111 1 K 10.n 1..1 it n n1 1 10 fis Ill n6.L n Jill.1n 10 11.n 111 Ln I n.. ndin 1n.9( ne.1n, INnI-n1/1 [/01 Facility -Level Status Violation No Violation No Violation No Violation No Violation No Violation No Molation No Molation No Molation No Molation No Molation No Violation U°determined tified Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Identified Quarterly Noncompliance Report History Informal Enforcement Actions (5 Years) Statute S stem Source ID T e of Action Lead Agency State Date CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation 06/09/2020 CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation State 04/22/2020 CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation State 03/29/2019 CWA ICIS-NPDES NC0031979 Base Program- Notice of Violation State 02/07/2019 CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation State 10/03/2018 CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation State 06Y07/2018 CWA ICIS-NPDES NC0031879 Base Program- Notice of Violation State 06/02/2017 CWA ]CIS-NPDES NC0031879 Base Program- Notice of Violation State 09/08/2016 State 06/28/2016 State 06/28/2016 tools. State/Local Penalty Assessed $1,122 SEP Cost Comp Action Cost $0 $0 $614 $0 $0 $1,364 So $0 $1,617 So $0 $1,363 Sa S0 $2,113 ao So Environmental Conditions Watershed(s) 12-Digit WBD (Watershed Boundary Dataset) HUC WBD (Watershed Boundary Dataset) Subwatershed State Water Body Name (ICI (Integrated Beach Closures Beach Closures Within Pollutants Potentially Watershed with ESA (Endangered Species (RAD (Reach Address Database)) Name RAD Reach Address Database Compliance Information System)) Within Last Yeaz Last iwo Years Related to Ira a rment Act -listed Aquatic Species? 030501010601 No. Muddy Creek YOUNGS FORK (COPERNING CREED No No Y Assessed Waters From Latest State Submission (ATTAINS) State Report Cycle Assessment Unit ID Assessment Unit Name Water Condition Cause Groups Impaired Drinkin Water Use A uatic Life Fish Consum lion Use Recreation Use Other Use NCI 2016 I NCIl-32-1-46 Youngs Fork(Copeming Creek) Impaired-303(d)Listed -With Restoration Plan CAUSE UNKNOWN -IMPAIRED BIOTA Not Supporting Air Quality Nonattainment Areas Pollutant i Within Nonattainment Status Area? Nonattainment Status Applicable Standard(s) Within Maintenance Status Area? Maintenance Status Applicable Standards) No data records returned Pollutants Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at Site TRI Facili IDlYcarl Total Air Emissions I Surface Water Discharges Off -Site Transf to POTWa(Publicly Owned Treatment Works Underground Iniections I Releases to Land Total On -site Relesaea Total Off -site Transfers No data records returned Toxics Release Inventory Total Releases and Transfers in Pounds by Chemical and Year Chemical Name No data records returned Demographic Profile EJSCREEN EJ Indexes Eleven primary environmental justice (EJ) indexes of EJSCREEN, EPA's screening tool for EJ concerns. EPA uses these indexes to identify geographic areas that may warrant further consideration or analysis for potential EJ concerns. The index values below are for the Census block group in which the facility is located. Note that use of these indexes does not designate an area as an "EJ community" or "EJ facility." EJSCREEN provides screening level indicators, not a determination of the existence or absence of EJ concerns. For more information, see the EJSCREEN home page. Census Block Group EJ Indexes (percentile) Particulate Matter (PM 2.5) 52.9 Ozone NATA Diesel PM 53.3 �ATA Air -xi- Cancer Risk 53 ATA Respiratory Hazard Index (HI) 52.9 Traffic Proximity 47.4 Lead Paint Indicator 45.3 Superfund Proximity 54.4 Risk Management Plan (RMP) Proximity 54.7 Hazardous Waste Proximity 54.6 Wastewater Discharge Proximity 18.4 Demographic Profile of Surrounding Area (3 Miles) Number of EJ Indexes Above 80th Percentile View EJSCREEN Report This section provides demographic information regarding the community surrounding the facility. ECHO compliance data alone are not sufficient to determine whether violations at a particular facility had negative impacts on public health or the environment. Statistics are based upon the 2010 U.S. Census and 2006-2010 American Community Survey 5-Year Summary and are accurate to the extent that the facility latitude and longitude listed below are correct. EPXs spatial processing methodology considers the overlap between the selected radii and the census blocks (for U.S. Census demographics) and census block groups (for ACS demographics) in determining the demographics surrounding the facility. For more detail about this methodology, see the DFR Data Dictionary. General Statistics otal Persons 5,706 opnlatuat Density 203/sq.mi. rcent Minority 16% Households in Area 1,945 Housing Units in Area 2,254 Households on Public Assistance 36 rsons Below Poverty Level 1,832 Geography Radius of Selected Area Center Latitude LCenter Longitude �µ�.and Area (Water Area Age Breakdown - Persons (%) Children 5 years and younger 298 (5%) Minors 17 years and younger 1, 126 (20%) Adults 18 years and older 4,580 (80%) Seniors 65 years and older 803 (14%) Race Breakdown - Persons (%) White 4,873 (85%) African -American 415 (7°/a) Hispanic -Origin 382 (7%) Asion/Pacific Islander 36 (1%) American Indian 28 (0%) 10ther/Multimcial 355 (61/4) Education Level (Persons 25 & older -Persons ,Less than 9th Grade 303 (8.72%) Breakdown -Households (% ) 9th through 12th Grade 617 (17.75%) LLIncome µ,ess than $15,000 416 (23.94%) High School Diploma 1,288 (37.05%) $15,000 - $25,000 357 (20.54%) Some College/2-year 929 (26.73%) $25,000 - $50,000 423 (24.34%) B.S./B.A. (Bachelor of Science/Bachelor of Arts) or More 339 (9.75%) $50,000 - $75,000 311 (17.89%) 1 1 Greater than $75,000 231 (13.29%) MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/04/21 Page 1 of 5 Permit: NCO031879 MRS Betweei 11 - 2015 and11 - 2020 Region: % Violation Category:% Program Category: Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO031879 FACILITY: City of Marion - Corpening Creek WWTP COUNTY: McDowell REGION: Asheville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 05 - 2020 001 Effluent BOD, 5-Day (20 Deg. C) - 05/23/20 3 X week mg/I 45 85.13 89.2 Weekly Average Proceed to NOV Concentration Exceeded 12-2015 001 Effluent Chlorine, Total Residual 12/31/15 5 X week ug/I 25 27 8 Daily Maximum No Action, BPJ Exceeded 01 -2016 001 Effluent Chlorine, Total Residual 01/07/16 5 X week ug/I 25 31 24 Daily Maximum No Action, BPJ Exceeded 02 - 2016 001 Effluent Chlorine, Total Residual 02/03/16 5 X week ug/I 25 47 88 Daily Maximum No Action, BPJ Exceeded 02 - 2016 001 Effluent Chlorine, Total Residual 02/17/16 5 X week ug/I 25 40 60 Daily Maximum No Action, BPJ Exceeded 02 - 2016 001 Effluent Chlorine, Total Residual 02/26/16 5 X week ug/I 25 35 40 Daily Maximum No Action, BPJ Exceeded 03 - 2016 001 Effluent Chlorine, Total Residual 03/03/16 5 X week ug/I 25 27 8 Daily Maximum No Action, BPJ Exceeded 03 - 2016 001 Effluent Chlorine, Total Residual 03/16/16 5 X week ug/I 25 26 4 Daily Maximum No Action, BPJ Exceeded 03 - 2016 001 Effluent Chlorine, Total Residual 03/24/16 5 X week ug/I 25 27 8 Daily Maximum No Action, BPJ Exceeded 04 - 2016 001 Effluent Chlorine, Total Residual 04/08/16 5 X week ug/I 25 48 92 Daily Maximum No Action, BPJ Exceeded 05-2016 001 Effluent Chlorine, Total Residual 05/12/16 3 X week ug/I 27 48 77.8 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/06/16 3 X week ug/I 27 32 18.5 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/07/16 3 X week ug/I 27 35 29.6 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/13/16 3 X week ug/I 27 29 7.4 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/14/16 3 X week ug/I 27 45 66.7 Daily Maximum No Action, BPJ Exceeded 12-2016 001 Effluent Chlorine, Total Residual 12/20/16 3 X week ug/I 27 34 25.9 Daily Maximum No Action, BPJ Exceeded MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/04/21 Page 2 of 5 Permit: NCO031879 MRS Betweei 11 - 2015 and11 - 2020 Region: % Violation Category:% Program Category: % Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO031879 FACILITY: City of Marion - Corpening Creek WWTP COUNTY: McDowell REGION: Asheville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 01 -2017 001 Effluent Chlorine, Total Residual 01/03/17 3 X week ug/I 27 34 25.9 Daily Maximum No Action, BPJ Exceeded 01 -2017 001 Effluent Chlorine, Total Residual 01/05/17 3 X week ug/I 27 40 48.1 Daily Maximum No Action, BPJ Exceeded 01 -2017 001 Effluent Chlorine, Total Residual 01/11/17 3 X week ug/I 27 40 48.1 Daily Maximum No Action, BPJ Exceeded 01 -2017 001 Effluent Chlorine, Total Residual 01/18/17 3 X week ug/I 27 41 51.9 Daily Maximum No Action, BPJ Exceeded 03-2017 001 Effluent Chlorine, Total Residual 03/13/17 3 X week ug/I 27 31 14.8 Daily Maximum No Action, BPJ Exceeded 08-2017 001 Effluent Chlorine, Total Residual 08/14/17 3 X week ug/I 27 44 63.0 Daily Maximum No Action, BPJ Exceeded 01 -2018 001 Effluent Chlorine, Total Residual 01/04/18 3 X week ug/I 27 43 59.3 Daily Maximum No Action, BPJ Exceeded 02-2018 001 Effluent Chlorine, Total Residual 02/07/18 3 X week ug/I 27 29 7.4 Daily Maximum No Action, BPJ Exceeded 04-2018 001 Effluent Chlorine, Total Residual 04/04/18 3 X week ug/I 27 37 37.0 Daily Maximum No Action, BPJ Exceeded 12-2018 001 Effluent Chlorine, Total Residual 12/28/18 3 X week ug/I 27 29 7.4 Daily Maximum No Action, BPJ Exceeded 06-2020 001 Effluent Chlorine, Total Residual 06/09/20 3 X week ug/I 27 29 7.4 Daily Maximum No Action, BPJ Exceeded 08-2020 001 Effluent Chlorine, Total Residual 08/25/20 3 X week ug/I 27 28 3.7 Daily Maximum No Action, BPJ Exceeded 04-2016 001 Effluent Cyanide, Total (as Cn) 04/09/16 Monthly ug/I 7.5 9 20 Weekly Average No Action, BPJ Exceeded 03 - 2016 001 Effluent Nitrogen, Ammonia Total (as 03/26/16 5 X week mg/I 9 11.08 23.1 Weekly Average Proceed to N) - Concentration Exceeded Enforcement Case 03 - 2016 001 Effluent Nitrogen, Ammonia Total (as 03/31 /16 5 X week mg/I 3 6.2 106.8 Monthly Average Proceed to N) - Concentration Exceeded Enforcement Case 04 - 2016 001 Effluent Nitrogen, Ammonia Total (as 04/02/16 5 X week mg/I 4.2 14.6 247.6 Weekly Average Proceed to N) - Concentration Exceeded Enforcement Case MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/04/21 Page 3 of 5 Permit: NCO031879 MRS Betweei 11 - 2015 and11 - 2020 Region: % Violation Category:% Program Category: % Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO031879 FACILITY: City of Marion - Corpening Creek WWTP COUNTY: McDowell REGION: Asheville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 04 - 2016 001 Effluent Nitrogen, Ammonia Total (as 04/09/16 5 X week mg/I 4.2 12.54 198.6 Weekly Average Proceed to N) - Concentration Exceeded Enforcement Case 04 - 2016 001 Effluent Nitrogen, Ammonia Total (as 04/30/16 5 X week mg/I 1.4 3.93 180.6 Monthly Average Proceed to N) - Concentration Exceeded Enforcement Case 03 - 2018 001 Effluent Nitrogen, Ammonia Total (as 03/24/18 3 X week mg/I 9.8 13.67 39.5 Weekly Average Proceed to N) - Concentration Exceeded Enforcement Case 03 -2018 001 Effluent Nitrogen, Ammonia Total (as 03/31/18 3 X week mg/I 3.3 4.71 42.7 Monthly Average Proceed to N) - Concentration Exceeded Enforcement Case 05 - 2019 001 Effluent Nitrogen, Ammonia Total (as 05/25/19 3 X week mg/I 4.4 9.17 108.3 Weekly Average Proceed to NOV N) - Concentration Exceeded 05 -2019 001 Effluent Nitrogen, Ammonia Total (as 05/31/19 3 X week mg/I 1.5 3.62 141.0 Monthly Average Proceed to NOV N) - Concentration Exceeded 05 - 2020 001 Effluent Nitrogen, Ammonia Total (as 05/23/20 3 X week mg/I 4.4 5.23 18.9 Weekly Average Proceed to NOV N) - Concentration Exceeded 12-2015 001 Effluent Oxygen, Dissolved (DO) 12/07/15 5 X week mg/I 5 4.3 14 Daily Minimum Not No Action, BPJ Reached 05-2020 001 Effluent Oxygen, Dissolved (DO) 05/26/20 3 X week mg/I 5 4.9 2.0 Daily Minimum Not Proceed to NOV Reached 01 -2016 001 Effluent pH 01/05/16 5 X week su 6 5.8 3.3 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/06/16 5 X week su 6 5.9 1.7 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/07/16 5 X week su 6 5.8 3.3 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/08/16 5 X week su 6 5.9 1.7 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/14/16 5 X week su 6 5.8 3.3 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/15/16 5 X week su 6 5.8 3.3 Daily Minimum Not No Action, BPJ Reached 01 -2016 001 Effluent pH 01/25/16 5 X week su 6 5.9 1.7 Daily Minimum Not No Action, BPJ Reached MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/04/21 Page 4 of 5 Permit: NCO031879 MRS Betweei 11 - 2015 and11 - 2020 Region: % Violation Category:% Program Category: % Facility Name: % Param Nam(% County: % Subbasin: % Violation Action: % Major Minor: % PERMIT: NCO031879 FACILITY: City of Marion - Corpening Creek WWTP COUNTY: McDowell REGION: Asheville Limit Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 01 -2016 001 Effluent pH 01/26/16 5 X week su 6 5.7 5 Daily Minimum Not No Action, BPJ Reached 12-2017 001 Effluent pH 12/27/17 3 X week su 6 5.7 5 Daily Minimum Not Proceed to NOD Reached 05-2020 001 Effluent pH 05/21/20 3 X week su 6 5.8 3.3 Daily Minimum Not Proceed to NOV Reached 05-2020 001 Effluent pH 05/26/20 3 X week su 6 5.8 3.3 Daily Minimum Not Proceed to NOV Reached 02 - 2016 001 Effluent Solids, Total Suspended - 02/27/16 5 X week mg/I 45 393.12 773.6 Weekly Average Proceed to Concentration Exceeded Enforcement Case 02 - 2016 001 Effluent Solids, Total Suspended - 02/29/16 5 X week mg/I 30 96.83 222.8 Monthly Average Proceed to Concentration Exceeded Enforcement Case 08 - 2018 001 Effluent Solids, Total Suspended - 08/25/18 3 X week mg/I 45 68.67 52.6 Weekly Average Proceed to Concentration Exceeded Enforcement Case 10 - 2018 001 Effluent Solids, Total Suspended - 10/13/18 3 X week mg/I 45 49.5 10 Weekly Average Proceed to NOV Concentration Exceeded 01 -2019 001 Effluent Solids, Total Suspended - 01/26/19 3 X week mg/I 45 60.13 33.6 Weekly Average Proceed to NOV Concentration Exceeded 02 - 2020 001 Effluent Solids, Total Suspended - 02/15/20 3 X week mg/I 45 112.82 150.7 Weekly Average Proceed to Concentration Exceeded Enforcement Case 02 - 2020 001 Effluent Solids, Total Suspended - 02/29/20 3 X week mg/I 30 40.48 34.9 Monthly Average Proceed to Concentration Exceeded Enforcement Case 05 -2020 001 Effluent Solids, Total Suspended - 05/23/20 3 X week mg/I 45 726.47 1,514.4 Weekly Average Proceed to NOV Concentration Exceeded 05 -2020 001 Effluent Solids, Total Suspended - 05/31/20 3 X week mg/I 30 182.38 507.9 Monthly Average Proceed to NOV Concentration Exceeded Monitoring Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 12 - 2018 001 Effluent BOD, 5-Day (20 Deg. C) - 12/29/18 3 X week mg/I Frequency Violation Proceed to NOV Concentration 12-2018 001 Effluent Chlorine, Total Residual 12/29/18 3 X week ug/I Frequency Violation Proceed to NOV MONITORING REPORT(MR) VIOLATIONS for: Permit: NCO031879 MRS Betweei 11 - 2015 and11 - 2020 Region: % Facility Name: % Param Nam(% County: % Major Minor: % Report Date: 02/04/21 Page 5 of 5 Violation Category:% Program Category: % Subbasin: % Violation Action: % PERMIT: NCO031879 FACILITY: City of Marion - Corpening Creek WWTP COUNTY: McDowell REGION: Asheville Monitoring Violation MONITORING VIOLATION UNIT OF CALCULATED % REPORT OUTFALL LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 12-2018 001 Effluent Coliform, Fecal MF, MFC 12/29/18 3 Xweek #/100ml Broth, 44.5 C 03-2017 001 Effluent Nitrogen, Ammonia Total (as 03/04/17 3 X week mg/I N) - Concentration 12-2018 001 Effluent Nitrogen, Ammonia Total (as 12/29/18 3 X week mg/I N) - Concentration 12 - 2018 001 Effluent Oxygen, Dissolved (DO) 12/29/18 3 X week mg/I 12 - 2018 001 Effluent pH 12/29/18 3 X week su 12-2018 001 Effluent Solids, Total Suspended - 12/29/18 3 X week mg/I Concentration 12-2018 001 Effluent Temperature, Water Deg. 12/29/18 3 X week deg c Centigrade Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Frequency Violation Proceed to NOV Permit No. NC0031879 NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as approved. Table 1. NC Dissolved Metals Water Q ality Standards/A uatic Life Protection Parameter Acute FW, µg/1 (Dissolved) Chronic FW, µg/l (Dissolved) Acute SW, µg/l (Dissolved) Chronic SW, µg/1 (Dissolved) Arsenic 340 150 69 36 Beryllium 65 6.5 --- --- Cadmium Calculation Calculation 40 8.8 Chromium III Calculation Calculation --- --- Chromium VI 16 11 1100 50 Copper Calculation Calculation 4.8 3.1 Lead Calculation Calculation 210 8.1 Nickel Calculation Calculation 74 8.2 Silver Calculation 0.06 1.9 0.1 Zinc Calculation Calculation 90 81 Table 1 Notes: 1. FW= Freshwater, SW= Saltwater 2. Calculation = Hardness dependent standard 3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative concerns (as are all human health standards for all metals). It is still necessary to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life protection). Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC 02B .0211 Subparagraph (11)(d) Metal NC Dissolved Standard, µg/I Cadmium, Acute WER* { 1. 136672-[ln hardness] (0.041838)} e^{0.9151 [In hardness]-3.1485} Cadmium, Acute Trout waters WER*{1.136672-[ln hardness] (0.041838)} e^{0.9151[ln hardness]-3.6236} Cadmium, Chronic WER*{1.101672-[ln hardness] (0.041838)} e^{0.7998[ln hardness]-4.44511 Chromium III, Acute WER*0.316 e^{0.8190[ln hardness]+3.7256} Chromium III, Chronic WER*0.860 e^{0.8190[ln hardness]+0.6848} Copper, Acute WER*0.960 e^{0.9422[ln hardness]-1.7001 Copper, Chronic WER*0.960 e^{0.8545[ln hardness]-1.702} Lead, Acute WER*{1.46203-[ln hardness](0.145712)} • e^{l.273[ln hardness]-1.460} Lead, Chronic WER*{1.46203-[ln hardness](0.145712)} • e^{l.273[ln hardness]-4.705} Nickel, Acute WER*0.998 eA10.8460[ln hardness]+2.255} Nickel, Chronic WER*0.997 eA10.8460[ln hardness]+0.0584} Page 1 of 4 Permit No. NCO041696 Silver, Acute WER*0.85 - e^{1.72[ln hardness]-6.59} Silver, Chronic Not applicable Zinc, Acute WER*0.978 e^{0.8473[ln hardness]+0.884} Zinc, Chronic WER*0.986 e^{0.8473[ln hardness]+0.884} General Information on the Reasonable Potential Analysis (RPA) The RPA process itself did not change as the result of the new metals standards. However, application of the dissolved and hardness -dependent standards requires additional consideration in order to establish the numeric standard for each metal of concern of each individual discharge. The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness and so must be calculated case -by -case for each discharge. Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The discharge -specific standards must be converted to the equivalent total values for use in the RPA calculations. We will generally rely on default translator values developed for each metal (more on that below), but it is also possible to consider case -specific translators developed in accordance with established methodology. RPA Permitting Guidance/WOBELs for Hardness -Dependent Metals - Freshwater The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern, based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable standards and the critical low -flow values for the receiving stream. If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below detection level), then the Division may remove the monitoring requirement in the reissued permit. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the following information: • Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates the 1 Q 10 using the formula 1 Q 10 = 0.843 (s7Q 10, cfs) 0.993 • Effluent hardness and upstream hardness, site -specific data is preferred • Permitted flow • Receiving stream classification 2. In order to establish the numeric standard for each hardness -dependent metal of concern and for each individual discharge, the Permit Writer must first determine what effluent and instream (upstream) hardness values to use in the equations. The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any hardness data and contacts the Permittee to see if any additional data is available for instream hardness values, upstream of the discharge. If no hardness data is available, the permit writer may choose to do an initial evaluation using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively. If the use of a default hardness value results in a hardness -dependent metal showing reasonable potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and upstream hardness samples over a period of one week. The RPA is rerun using the new data. Page 2 of 4 Permit No. NCO041696 The overall hardness value used in the water quality calculations is calculated as follows: Combined Hardness (chronic) _ (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L) (Permitted Flow, cfs + s7Q10, cfs) The Combined Hardness for acute is the same but the calculation uses the 1 Q 10 flow. 3. The permit writer converts the numeric standard for each metal of concern to a total recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any have been developed using federally approved methodology. EPA default partition coefficients or the "Fraction Dissolved" converts the value for dissolved metal at laboratory conditions to total recoverable metal at in -stream ambient conditions. This factor is calculated using the linear partition coefficients found in The Metals Translator: Guidance for Calculating a Total Recoverable Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation: Cdiss = 1 Ctotal 1 + { [Kpo] [ss('+a)] [10-6] } Where: ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used, and Kpo and a = constants that express the equilibrium relationship between dissolved and adsorbed forms of metals. A list of constants used for each hardness -dependent metal can also be found in the RPA program under a sheet labeled DPCs. 4. The numeric standard for each metal of concern is divided by the default partition coefficient (or site -specific translator) to obtain a Total Recoverable Metal at ambient conditions. In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is dissolved to the same extent as it was during EPA's criteria development for metals. For more information on conversion factors see the June, 1996 EPA Translator Guidance Document. 5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration (permit limits) for each pollutant using the following equation: Ca = (s7Q 10 + Qw) (Cwgs)- s7Q 10) (Cb) Qw Where: Ca = allowable effluent concentration (µg/L or mg/L) Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L) Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L) Qw = permitted effluent flow (cfs, match s7Q 10) s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human health through the consumption of water, fish, and shellfish from noncarcinogens (cfs) * Discussions are on -going with EPA on how best to address background concentrations Flows other than s7Q 10 may be incorporated as applicable: IQ 10 = used in the equation to protect aquatic life from acute toxicity Page 3 of 4 Permit No. NC0041696 QA = used in the equation to protect human health through the consumption of water, fish, and shellfish from carcinogens 30Q2 = used in the equation to protect aesthetic quality 6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern. Data entered must have been taken within four and one-half years prior to the date of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper concentration of each pollutant. The Predicted Max concentrations are compared to the Total allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds the acute or chronic Total allowable concentrations, the discharge is considered to show reasonable potential to violate the water quality standard, and a permit limit (Total allowable concentration) is included in the permit in accordance with the U.S. EPA Technical Support Document for Water Quality -Based Toxics Control published in 1991. 7. When appropriate, permit writers develop facility specific compliance schedules in accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements. The Total Chromium NC WQS was removed and replaced with trivalent chromium and hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data results may be used as a conservative surrogate in cases where there are no analytical results based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for total chromium will be compared against water quality standards for chromium III and chromium VI. 9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the accuracy of the permit limits and to build a more robust hardness dataset. 10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included: Parameter Value Comments (Data Source) Average Effluent Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] 49.33 Data provided in DMRs Average Upstream Hardness (mg/L) [Total as, CaCO3 or (Ca+Mg)] 25 Default value used 7Q 10 summer (cfs) 2.3 NPDES Files 1Q10 (cfs) 1.93 Calculated in RPA Permitted Flow (MGD) 2.5 NPDESpermit application Date: 1/11/2021 Permit Writer: Diana Yitbarek Page 4 of 4 2018 NC Category 5 Assessments "303(d) List" Final 11-38-34 11-32-1-4a Catawba River Basin Wilson Creek From source to Johns River Classification B;Tr,ORW Length or Area kssessment Criteria Status Reason for Rating Exceeding Criteria Youngs Fork (Coperning Creek) From source to Marion WWTP Upper Catawba Subbasin 03050101 23 Units IFW Miles (Previous AU Number) L Parameter of Interest Category pH (6 su, AL, FW) 5 Classification �___ (Length or Area I I 4 (Units fW Miles --] (Previous AU Number) \ssessment Crit R Exceeding Criteria Poor 11-32-1-4b Youngs Fork (Coperning Creek) From Marion WWTP to North Muddy Creek Classification C (Length or Area Benthos (Nar, AL, FW) 2 (Units FW Miles (Previous AU Number kssessment Criteria Status Reason for Rating Parameter of Interest Category Exceeding Criteria Fair iBenthos (Nar, AL, FW) 5 Exceeding Criteria Fair Fish Community (Nar, AL, FW) 0 11-39-1 Zacks Fork Creek From source to Lower Creek Classification C Length or Area kssessment Criteria Status Reason for Rating Is Exceeding Criteria FCB 5in30 GM >200 or >20% 8 Units IFW Miles J Previous AU Number Parameter of Interest Category j, Fecal Coliform (GM 200/400, REC, FW) South Fork Catawba Subbasin 03050102 6/3/2019 2018 NC Category 5 Assessments "303(d) List" Approved by EPA May 22,2019 Page 47 of 262 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 u 3 I NCO031879 I11 121 21/02/05 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 11:00AM 21/02/05 16/05/01 Corpening Creek WWTP 3982 NC Hwy 226 S Exit Time/Date Permit Expiration Date Marion NC 28752 12:30PM 21/02/05 20/01/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Larry Carver,PO Box 700 Marion NC 287520700//828-652-8843/8286591943 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date D—Signed by: Lauren E Armeni �y�,�, Amu' DWR/ARO WQ/828-296-4500/ 2/18/2021 Mikal Willmer D13869d&fty: DWR/Division of Water Qua lity/828-296-4686/ 2/18/2021 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 2/18/2021 1&. kEE rm ��4�3F (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D NPDES yr/mo/day Inspection Type (Cont.) NCO031879 I11 12I 21/02/05 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni and Mikal Willmer, with the Asheville Regional Office, conducted a compliance evaluation inspection of the Corpening Creek WWTP on February 5, 2021. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0031879. Tim Horton (ORC), Jeff Sanders (Lead Operator), and Doug Mackey (Interim Lead Operator) were present and assisted in the inspection. Facility consists of a mechanical step bar screen backed up by a manual bar screen, grit chamber, two circular primary clarifiers (both of these clarifiers are currently being used as EQ basins), two aeration basins (one is operational), two circular secondary clarifiers, baffled chlorine contact chamber, gas chlorination and sulfur dioxide dechlorination, step aeration, two gravity sludge thickeners, and one aerobic digester. The following items were noted during the inspection: Primary Clarifiers: Both primary clarifiers are currently being used as EQ basins. Both sweep arms on the clarifiers are broken and in need of repair. Additionally, the weirs still need to be leveled. The ORC stated the plan is to level the weirs themselves this year. The first clarifier arm stopped working around one year ago, and the second clarifier arm stopped working a couple months ago. The water within the clarifiers was black with scum on the surface. The sludge blanket in both clarifiers is 9 feet with a depth of 16 feet. Sludge was pumped out of one of the primary clarifiers around 10 years ago using a vacuum truck. The pipes from the primary clarifiers to the thickeners have been clogged for more than 10 years. Aeration Basins: One of the two aeration basins is currently operational. The #1 aeration basin is currently being used as a backup EQ basin as needed and some aerators need replaced. The ORC stated they would like to get it cleaned out and back in operation since all the valves work and it would add to their treatment capacity; however, rainfall has made this difficult. This facility utilizes brush aerators. The ORC stated that the DO levels were maintained around 1 mg/L in the aeration basin during operation. The measured DO on the day of inspection was around 3.0 mg/L. The MLSS is still being maintained at 7,000 mg/L; however, the effluent numbers appear to be in compliance and are meeting ammonia limits. Secondary Clarifiers: The weirs on primary clarifier #2 still needs to be leveled and is on the docket to be leveled this year; however, this issue is not currently impacting treatment. The sludge blankets have been significantly reduced due to better solids management within the plant (blankets were previously run 8-9 feet). The sludge blanket in both clarifiers was around two feet and the depth of the clarifiers is ten feet. The sweep arm on secondary clarifier #1 starts and stops, and it appears that the suction arm is clogged and the drive unit is not operational. The staff plans on draining the clarifier and they are having someone out to figure out the exact issue and make necessary repairs. The plant currently has two RAS pumps. One is around 40 years old and the other is around 20 years old. The older RAS pump is not being used, so currently there is no backup. In the new fiscal year (FY22), the plant is planning on buying a new RAS pump and using the 20-year old pump as the backup. Both WAS pumps are operational and in good condition. Tertiary Filters: The tertiary filters are not in use at this time. The ORC indicated they would like to have them operational at some point, but they will first need to be rehabilitated It is recommended that the tertiary filters be added back to the permit since they are still a system component, just not Page# DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Corpening Creek WWTP Inspection Date: 02/05/2021 Inspection Type: Compliance Evaluation currently in operation. Overall, the facility is in non-compliance with the requirements outlined in the permit for the following reasons: 1. Both primary clarifiers are being used as equalization basins. Both primary clarifiers need to be repaired and utilized as they were intended to, otherwise an engineering analysis and permit modification may need to be performed. The sludge blankets are 9 feet in both primary clarifiers, whicf is a concern for high flows into the plant. 2. The #1 secondary clarifier is in need of repair due to a broken arm. 3. A new RAS pump is needed. There is currently not a backup RAS pump due to the age of the previous backup RAS pump (-40 years old). Page# DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Inspection Date: 02/05/2021 Inspection Type: Corpening Creek WWTP Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ 0 ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The permittee has submitted a new application and the permit is currently in draft and under review. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operatc ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification' ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? M ❑ ❑ ❑ MOT, 171,"M Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Page# 4 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Corpening Creek WWTP Inspection Date: 02/05/2021 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The facility checks sludge depth daily using a sludge fudge. Dissolved oxygen and MLSS are checked weekly. Bar Screens Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The mechanical bar screen was previously down for approximately 6 months to a year, but is now repaired and fully operational. Grit Removal Yes No NA NE Type of grit removal a.Manual ❑ b.Mechanical Is the grit free of excessive organic matter? 0 ❑ ❑ ❑ Is the grit free of excessive odor? 0 ❑ ❑ ❑ # Is disposal of grit in compliance? 0 ❑ ❑ ❑ Comment: Grit removal was previously not working for approximately 6 months to a year, but is now repaired and fully operational. Since the bar screen and grit removal were down for this amount of time, solids management became an issue, but the ORC appears to have this under control now. Primary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Yes No NA NE ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Corpening Creek WWTP Inspection Date: 02/05/2021 Inspection Type: Compliance Evaluation Primary Clarifier Yes No NA NE Is the drive unit operational? ❑ 0 ❑ ❑ Is the sludge blanket level acceptable? ❑ 0 ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) ❑ 0 ❑ ❑ Comment: Both Drimary clarifiers are currently being used as EQ basins, and the weirs need leveled on both. The wastewater within the primary clarifiers appeared black with scum on the surface. The ORC stated the drive units malfunctioning may be the reason the sweep arms stopped working. The sludge blanklet levels in both clarifiers are at 9 feet out of 16 feet. See summary for further details. Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Yes No NA NE Ext. Air Surface ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Aeration basin #2 is currently in operation and Aeration basin #1 currently needs to be cleaned out in order to be put back online. See summary for futher details. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Inspection Date: 02/05/2021 Secondary Clarifier Owner -Facility: Corpening Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The weirs on secondary clarifier #2 need to be leveled. The drive unit and sweep arm are not operational on secondary clarifier #1. See summary for further details. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ 0 ❑ ❑ Comment: The current RAS pump is -20 years old and is operational, but no backup RAS pump is available. The WAS pumps are working and in good condition. Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Comment: The tertiary filters are not in use at this time. See summary for further details. Disinfection -Gas Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000- - ) If yes, then when was the RMP last updated? Comment: All cylinders are adequately secured and out of direct sunlight. Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ Page# 7 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Inspection Date: 02/05/2021 Inspection Type: Corpening Creek WWTP Compliance Evaluation De -chlorination Yes No NA NE Type of system ? Gas Is the feed ratio proportional to chlorine amount (1 to 1)? 0 ❑ ❑ ❑ Is storage appropriate for cylinders? 0 ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Comment: Are the tablets the proper size and type? ❑ ❑ 0 ❑ Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? M ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? 0 ❑ ❑ ❑ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Page# 8 DocuSign Envelope ID: EFC010C6-F66F-4429-960B-126FC3D6F34D Permit: NCO031879 Owner -Facility: Inspection Date: 02/05/2021 Inspection Type: Corpening Creek WWTP Compliance Evaluation Laboratory Yes No NA NE Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ Comment: Environmental Testing is used for toxicity, metals, total cyanide, total nitrogen, and total phosphorus. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: A new generator was installed in February 2020. The generator was assessed during the inspection, and it was found that the digital fuel level was inaccurate (said zero gallons but tank was full). It is recommended to repair this function so it is always known what the precise fuel level is. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Comment: The ORC stated that some blowers were that need repaired. Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ aired in early 2020. but there are still blowers Page# 9 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-F06156F28DAB State of North Carolina ®r- Division of Water Resources Water Quality Regional Operations Section Environmental Staff Report Quality To: ® NPDES Unit ❑ Non -Discharge Unit Application No.: NCO031879 Attn: Diana Yitbarek Facility name: Corpening Creek WWTP From: Lauren Armeni Asheville Regional Office Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non - discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ® Yes or ❑ No a. Date of site visit: 02/05/2021 b. Site visit conducted by: Lauren Armeni & Mikal Willmer c. Inspection report attached? ® Yes or ❑ No (See Laserfiche for Inspection) d. Person contacted: Tim Horton and their contact information: (82�8 652-8843 ext. e. Driving directions: Take exit 86 off of I-40 E for NC-226 S toward Marion/Shelby. Turn left onto NC- 226 S and the WWTP (3982 NC-226 S) is on the right approximately 0.5 miles down. 2. Discharge Point(s): Latitude: 35.651658 Latitude: Longitude:-81.957656 Longitude: 3. Receiving stream or affected surface waters: Youngs Fork (Corpening Creek) Classification: C River Basin and Subbasin No. CTB, 03050101 Describe receiving stream features and pertinent downstream uses: River is protected for class C uses. 11. PROPOSED FACILITIES: NEW APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit) Proposed flow: Current permitted flow: 2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No If no, explain: 3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A If no, please explain: 4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A If no, please explain: 5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A If no, please explain: FORM: WQROSSR 04-14 Page 1 of 6 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-F06156F28DAB 6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable`? ❑ Yes ❑ No ❑ N/A If no, please explain: 7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No If yes, attach a map showing conflict areas. 8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A If no, explain and recommend any changes to the groundwater monitoring program: 9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites with restrictions (Certification B) Describe the residuals handling and utilization scheme: 10. Possible toxic impacts to surface waters: 11. Pretreatment Program (POTWs only): III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A ORC: Tim Horton Certificate #:1008211 Backup ORC: Jeffery Sanders Certificate #:992546 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ® No If no, please explain: Both primary clarifiers are currently being used as EQ basins because the primary clarifier sweep arms and drive units are not operational. Description of existing facilities: • Influent pump station, • Mechanical step bar screen backed up by a manual bar screen, • Grit chamber, • Two circular primary clarifiers (both of these clarifiers are currently being used as EO basins), • Two aeration basins (one is in operation), • Two circular secondary clarifiers, • Tertiary filters, • Baffled chlorine contact chamber, • Gas chlorination and sulfur dioxide dechlorination, • Step aeration, • Two gravity sludge thickeners, • One aerobic digester Proposed flow: No Change. Current permitted flow: 3.0 MGD Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc.) Facility equipment is aging, and some equipment needs to be brought off line in the future for repairs. Both primary clarifiers are currently being used as EO basins. The sweep arms and drive units are broken on both of the primary clarifiers and the middle wells are rusting out. Additionally, the pipes from the primary clarifiers to the thickeners are clogged, so wasting cannot be done. One of the two aeration basins FORM: WQROSSR 04-14 Page 2 of 6 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-F06156F28DAB is currently in operation, although the second aeration could be put back online if cleaned. The tertiary filters are not in use at this time. The ORC indicated they would like to have them operational at some point, but they will first need to be rehabilitated. It is recommended that the tertiary filters be added back to the permit since they are still a system component, lust not currently in operation. See inspection report for further details on system components. 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? ❑ Yes or ❑ No ®N/A If no, please explain: 4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? ❑ Yes or ® No If yes, please explain: 5. Is the residuals management plan adequate? ® Yes or ❑ No If no, please explain: 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable`? ❑ Yes or ❑ No ® N/A If no, please explain: 7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A If no, explain and recommend any changes to the groundwater monitoring program: 8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No If yes, attach a map showing conflict areas. 9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No If no, please explain: See inspection report for details of system components. 10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no, please explain: FORM: WQROSSR 04-14 Page 3 of 6 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-F06156F28DAB 11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A If no, please complete the following (expand table if necessary): Monitoring Well Latitude Longitude O l 11 O I // O / // O I II O / // O I it 12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No Please summarize any findings resulting from this review: Ammonia limits were exceeded in March and April 2016, March 2018, May 2019, and May 2020; however ammonia has not been an issue in the past 6+ months. Additionally, TSS limits were exceeded in February 2016, August and October 2018, January 2019, and February and May 2020; however, TSS limits have not been an issue in the past 6+ months. No violations have been issued to the facility since May 2020. Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. 13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No If yes, please explain: 14. Check all that apply: ❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC ® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been working with the Permittee? Is a solution underway or in place? The facility has had compliance issues during the hermit cvcle as noted above. but have not had a limit violation since Mav 2020. Both Drimary clarifiers are being used as EO basins, and we believe this should be reevaluated by the facility. The facility staff are aware that some system components are degrading and they are very interested in improving them. Their plan is to buy a new RAS pump in FY 22, and they also hope to rehabilitate the offline aeration basin and eventually tertiary filters. Solids management has greatly improved (sludge blankets are maintained at a much lower level) and thev are still fine tuning it. Thev have also ordered Darts to replace the sweet arm and drive unit in one of the secondary clarifiers. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A If no, please explain: 15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ®No❑N/A If yes, please explain: 16. Possible toxic impacts to surface waters: Chlorine can impact surface waters if not properly removed. No issues reported with the dechlorination feed at the facility and no permit issues related to chlorine residual. 17. Pretreatment Program (POTWs only): N/A — IWS requested by 7/1/2021. FORM: WQROSSR 04-14 Page 4 of 6 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-F06156F28DAB IV. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No If yes, please explain: 2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an additional information request: Item Reason 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason 5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office ® Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ❑ Issue ❑ Deny (Please state reasons: ) 6. Signature of report preparer: Docu Signed by: �,a VY l7l Qv*uu- CB17648770724F6... DocuSigned by: 0 All Signature of assistant regional supervisor: E397192DABFB4FF... 2/18/2021 Date: FORM: WQROSSR 04-14 Page 5 of 6 DocuSign Envelope ID: 99D100F8-7020-490D-8F54-FO6156F28DAB V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS See inspection report from February 2021 for facility recommendations. FORM: WQROSSR 04-14 Page 6 of 6 DocuSign Envelope ID: A045B785-2D59-476B-9979-2F7BA0164F82 ROY COOPER Governor MICHAEL S. REGAN 5ecrutary S. DANIEL SMITH arecror NORTH CAROLINA Envifionmental Quality SENT VIA ELECTRONIC MAIL ONLY. NO HARD COPY WILL BE MAILED February 17, 2021 J. R. Boyette, City Manager City of Marion Email: bboyette@marionnc.org SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2021-PC-0144 Permit No. NCO031879 Corpening Creek WWTP McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Corpening Creek WWTP on February 5, 2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0031879. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Primary Clarifier Both primary clarifiers are being used as equalization basins, and both sweep arms are not operational. Additionally, the sludge blankets are 9 feet out of 16 feet in both primary clarifiers. Permit Standard Conditions Section C. 2 requires the permittee to properly operate and maintain all facilities and systems of treatment which are installed to achieve compliance. Secondary Clarifier The #1 secondary clarifier is currently out of operation because it is in need of repair due to a broken drive unit and sweep arm. Permit Standard Conditions Section C. 2 requires the permittee to properly operate and maintain all facilities and systems of treatment which are installed to achieve compliance. North Carolina Department of Environrnenta; Q¢airty I Diusion of Water Resm r-�--s Ashev,;e RegionalOff:ce I Z090 U.S. 7-DHghway I SwanRSROs, North Csro:irs 2S77S DocuSign Envelope ID: A045B785-2D59-476B-9979-2F7BA0164F82 Pumps-RAS-WAS A new RAS pump is needed since there is currently no backup RAS pump. Permit Standard Conditions Section C. 2 requires the permittee to properly operate and maintain all facilities and systems of treatment which are installed to achieve compliance. In addition, the issue below must also be addressed: *The tertiary filters are currently not listed in the permit, but should be added back to the permit because they are existing structures at the WWTP. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, ocuSigned bbJyy: E�D >(Jo?�1-397192DABFB4FF... Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Brant Sikes, Public Works Director Tim Horton, ORC LF NorthCaroiinaDepartnientofEnvironrnenta;Qua:rty I DiusionofWater Resources Ashev.;e Regnnai4ffice 1 2090 U.S. 7-DHghw'ay I SwanRSROs, North Csro:ins 23773 `•• "'� 3237%-45D0 The McDowell News Advertising Affidavit PO Box 968 Hickory, NC 28603 NC DENR/DWQ ATTN: WREN THEDFORD 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 Account Number 3142720 Date February 26, 2021 Date Category Description Ad Number Ad Size 02/26/2021 Legal Notices Public Notice North Carolina Environmental Management Coon 0000704704 2 x 29 L Publisher of The McDowell News McDowell County Before the undersigned, a Notary Public duly commissioned, qualified, and authorized by law to administer oaths, personally appeared the Publisher's Representative who by being duly swom 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 McDowell News on the following dates: 02/26/2021 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 ] •597 of the General Statutes of Nortiny/��. _ Billing Representative Newspaper reference: 0000704704 Sworn to and subscribed before me, this 26th day of February, 2021. Notary Public Sharon R Carsten State of Virginia NOTARY PUBLIC County of Hanover Commonwealth of Virginia Notary Registration Number 329549 My commission expiresCemmisssinn r=rni.es ,July 31 2021 THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU North Carolina Environmental Management Commission/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES wastewater Permit NCO031879 Corpening Creek W WTP The North Carolina Environmental Management Commission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below. Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Division of Water Resources (DWR) may hold a pub- lic hearing should there be a significant degree of public interest. Please mail comments and/or information requests to DWR at the above ad- dress. Interested persons may visit the DWR at 512 N. Salisbury Street, Ra- leigh, NC 27604 to review information on file. Additional information on NPDES permits and this notice may be found on our website: hhttp;//deq.n ing (919) 707-3601. The City of Marion (3982 Hwy 226 South, has requested renewal of permit NCO031879 for its Corp wastewater treatment plant in McDowell County. This perm discharges treated domestic wastewater to Youngs Fork Creek) in the Catawba River Basin. Currently, flow, biochen demand, dissolved oxygen, total suspended solids, fecal colifr monia, total cyanide, and total residual chlorine are water qu parameters in the permit. This discharge may affect future a this segment of Youngs Fork (Corpening Creek). The Division received comments/questions from the Corpening WWTP through the public comment period, February 26, 2021— March 26, 2021, and provided the following responses: 1. Question: On page 7, the fourth paragraph uses terms "TGP3B" and "THP3B." What do those mean? Response: TGP313 and THP313 are whole effluent toxicity (WET) parameter codes for the pass/fail chronic toxicity tests. Please find here the test description for each code. "All toxicity testing results required as part of this permit condition will be entered electronically using the Division's eDMR system for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP313 for the Chronic Value." - Permit, page 7. 2. Question: On page two under changes second one from the bottom, the change discusses the Electronic Reporting Rule. As I read the change and the Special Condition Section A (5), it looks like I'm to submit an electronic DMR and a paper copy too. We received other guidance in Nov 2019. Response: Duplicate signed copies shall be submitted only if a permittee is unable to use the eDMR system due to a demonstrated hardship. The section on the permit was recently updated. I will make sure to update it on the final permit as follows: "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. The eDMR system may be accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr 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 following mailing address:" Question: In your letter which accompanied our new proposed permit, page one, bullet point six, Total Selenium and Silver limits are discussed. It is noted that the detection limits for both per DWR's Lab is 1.0 ug/L. Can we get a copy of all of the Annual Pollutant Parameters we are required to analyze? Also, the letter states, "Based on the RPA, the City's allowable discharge concentrations are 8.00ug/L and 0.096ug/L for Total Selenium and Total Silver respectively. " As I understand the discussion of RPA, Fact Sheet, pages 6-7, the City's values change from permit to permit based on the documentation we provide. Is this correct? Is the discrepancy the detection limit used by our contracted lab not at the appropriate level? Response: The list of all the Pollutant Parameters the City is required to analyze once a year (in 2023, 2024, and 2025) is in the permit Section A. (4.) Effluent Pollutant Scan, page 8 of 12. You are correct. The City's limit values change from permit to permit. The limits are calculated using the recent discharge monitoring reports (eDMRs) and the effluent pollutant scans provided. Correct. The current detection level used does not produce detection and reporting levels below the City's allowable discharge concentrations of 8.00 µg/L and 0.096µg/L for Total Selenium and Total Silver. 4. Question: On the effluent limits pages, Sections A. (1.) and A.(2.), hardness is discussed. In footnote 5, it states hardness should be performed in conjunction with hardness -dependent metals --cadmium, copper, lead, nickel, silver, and zinc. The following question was recently raised: Is this stating we are to analyze all of those metals? Since copper is the only metal listed on our permit, I was understanding copper is the only one that applies to us. Am I correct? Response: Copper is the only hardness dependent metal that Corpening Creek WWTP is required to test in a quarterly basis. Effluent hardness sampling shall be performed in conjunction with testing for copper and whenever you sample for the effluent pollutant scan. Three effluent pollutant scans shall be sampled. The list of pollutants to sample include all the hardness -dependent metals (cadmium, copper, lead, nickel, silver, and zinc).