NC0020354_Fact Sheet_20210505

Fact Sheet
NPDES Permit No. NCOO2O354
Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: February 16, 2021
Division/Branch: NC Division of Water Resources/NPDES Municipal Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
N Renewal (Note: including joint permittee)
❑ Renewal with Expansion
❑ New Discharge
N Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2"d species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Co-Applicant/Facility
Name:
Town of Pittsboro/Pittsboro Wastewater Treatment Plant (WWTP)
Chatham Park Investors LLC/Chatham Park Water Recovery Center
(CPWRC)
Co -Applicant Address:
Town of Pittsboro - P.O. Box 759, Pittsboro, NC 27312
Chatham Park Investors LLC — 105 Weston Estates Way, Cary, NC
27513
Facility Address:
Pittsboro WWTP - 485 Small Street, Pittsboro, NC 27312
CPWRC— 2261 US highway 64 Business East, Pittsboro, NC 27312
Permitted Flow:
Outfall 001A: 0.75 MGD with existing expanded flow tier 1.249 MGD
(to be moved to combined Outfall C01)
Outfall 001B: 0.499 MGD (to be added)
Outfall 002: 1.971 MGD upon expansion of Pittsboro WWTP
Combined: 3.22 MGD at full expansion
Facility Type/Waste:
Pittsboro WWTP: MINOR Municipal; 100% domestic (Upon
Expansion - 1.971 MGD - MAJOR Municipal)
CPWRC: MINOR Privately -Owned Domestic; 100% domestic
Facility Class:
Pittsboro WWTP: Class IV
CPWRC: Class III
Page 1 of 22

Treatment Units:
Pittsboro WWTP: Manual and mechanical bar screen, diffused aeration
basins, clarifiers, phosphorous removal, high -rate sand filters, sludge
thickening, aerobic sludge digestion, ultraviolet disinfection, effluent
flow measurement, cascade post aeration
CPWRC: mechanical bar screens, splitter box, odor control system,
chemical feed system, four -stage biological membrane bio reactor
system, intermediate screening, membrane filtration, sludge holding
tank, ultraviolet disinfection, chlorine disinfection for reclaimed water,
reclaimed water holding tank, effluent flow measurement
Pretreatment Program (Y/N)
N; inactive, to be reactivated as a satellite system upon connection to
Sanford Big Buffalo WWTP
County:
Chatham
Region
Raleigh
Briefly describe the proposed permitting action and facility background: The Town of Pittsboro's
WWTP serves a population of approximately 4,300 residents. The facility has a primary Outfall 001 and
the ability to expand and discharge to a secondary Outfall 002. A complete renewal application with a
modification request was submitted in August 2020.
During the 2014 renewal, the Pittsboro WWTP (discharging to Outfall 001A) was classified as Grade III.
However, per 15A NCAC 08G .0302(c) and (f), the facility has been reclassified as a Grade IV facility
for this permit renewal. To ensure concurrent sampling, the monitoring frequency of a Grade IV facility
has also been applied to the Chatham Park Water Recovery Center (CPWRC). This does not impact the
grade of the CPWRC. Upon decommissioning of the Pittsboro WWTP, and upon Division approval of a
submitted data review and monitoring frequency reduction justification for each parameter, CPWRC shall
begin sampling for BOD5, TSS, ammonia, total residual chlorine, pH, dissolved oxygen, fecal coliform
and conductivity at a monitoring frequency of 3/week. The frequency reduction could be for one or more
or all parameters.
In 2011, during the permit modification for addition of the Haw River discharge and in response to
concerns from the community, the Town of Pittsboro agreed to be limited for fecal coliform at reclaimed
water effluent standards of 14/100 mL as a monthly average and 25/100mL as a weekly average in their
Haw River effluent (Outfall 002).
Current Status
Currently, the Town of Pittsboro owns and operates a Pittsboro WWTP under NPDES permit
NC0020354. The permit contains two outfalls: Outfall 001 to Robeson Creek and Outfall 002 to the Haw
River. The Town's existing facility has a permitted flow of 0.75 MGD (average annual daily flow is 0.42
MGD, max daily is 1.44 MGD for 2019) and discharges via Outfall 001 to Robeson Creek. The permit
allows for a plant expansion up to 1.249 MGD at Outfall 001 and an additional discharge of 1.971 MGD
to Outfall 002, providing 3.22 MGD of combined flow across two streams. Outfall 002 was added to the
permit issued in June 2011 (existing permit issued Aug. 2014); however, to date Pittsboro has not built a
POTW on the Haw River and there is currently no discharge to Outfall 002.
Additionally, the Town's nutrient discharge is governed by both the Robeson Creek Total Phosphorous
TMDL and the Jordan Lake Nutrient Management Strategy. As such, the Town is currently allocated
36,202 lb/yr of nitrogen and 4,551 lb/yr of phosphorous to be discharged. Due to the Robeson Creek
TMDL, the Town is only allowed to discharge 3221b of total phosphorous from April 1 through October
31 via Outfall 001. The Town has a reuse permit (#WQ0024838) which allows Pittsboro to provide up to
0.3 MGD of treated wastewater to an industrial facility.
Page 2 of 22

The Town also has an agreement with the City of Sanford's Big Buffalo WWTP (NC0024147) allowing
up to 2.0 MGD of untreated wastewater to be diverted to the Big Buffalo WWTP from the Pittsboro
WWTP. The force main to carry the 2.0 MGD to Sanford has not been constructed and is being reviewed
by DWI for funding. A Finding of No Significant Impact (FONSI) was issued for this project on February
9, 2021.
Non -discharge permit # WQ0039375 was issued to Old North State Water Company, LLC on February
15, 2018 for the construction of the Chatham Park Decentralized WRRF. On November 19, 2020, a
name/ownership change was issued to WQ0039375 to change the owner of the facility to Chatham Park
Investors LLC and to change the name of the facility to Chatham Park Water Recovery Center. The force
main that transports this treated effluent to the Pittsboro WWTP is currently under construction with a
zero -flow permit #40514.
The Town of Pittsboro maintains a water reuse non -discharge permit # WQ0024838. On January 8, 2021,
a modification was issued for the Pittsboro WWTP reclaimed water system to allow for reclaimed water
from the Chatham Park Recovery Center (from WQ0039375) to be conveyed to the Pittsboro WWTP and
distributed under this permit.
The Proposal
The Town of Pittsboro ("The Town") and Chatham Park Investors LLC ("CPI") have applied as co-
permittees for the modification and renewal of NC0020354. The Town entered into a "Master Services
Agreement" with CPI in August 2020 to acquire wastewater treatment services from the new wastewater
CPWRC for treatment of up to 0.499 MGD of wastewater per day to serve the Town's future residential
and non-residential customers in a service area described in the Master Services Agreement. The co -
application is requested to be between the Town and CP RWC. The division requested that the permit be
submitted as a joint application so all the conditions in the permit would apply to both parties. The
renewal would add Chatham Park Investors LLC's CPWRC as a discharger to Robeson Creek through the
existing Outfall 001. The proposal includes two phases:
Phase I: The CPWRC would be allowed to discharge up to 0.499 MGD to Outfall 001, while the existing
Pittsboro WWTP would continue to operate at 0.75 MGD, totaling 1.249 MGD at Outfall 001. This
matches the expanded flow tier at Outfall 001 in the current permit. The Town of Pittsboro will have sole
ownership over the 1.971 MGD of flow capacity to the Haw River via Outfall 002 for future use. The
Phase I flow schematic is shown below as Attachment 1. Note: The conversion of the existing CPWRC
from a non -discharge facility to a direct discharge facility, along with the connection of force main from
the CPWRC to the Pittsboro WWTP should be accompanied by an ATC.
Phase II: Upon receipt of an Authorization to Construct and funding, the Town of Pittsboro proposes to
decommission its treatment units, with the exception of its UV disinfection and reaeration. This process
would also include the conversion of the existing 0.5 MG treatment tanks to equalization basins to be
added to the existing 0.6 MG equalization tanks to make a total of 1.1 MG of equalization. In addition, a
new 2 MGD force main and headworks facility for basic screening and grit removal is to be constructed
and the Town's existing sewer line will be connected to this force main that will discharge to Sanford's
Big Buffalo WWTP. A separate chlorination system will be maintained for treatment of some of the
wastewaters from the CPWRC to be used to meet reclaimed wastewater requirements. The Phase II flow
schematic is shown below as Attachment 2. The Town of Pittsboro does not currently have an active
pretreatment program, as it has no industrial users. However, per the March 13, 2017 Wastewater
Treatment and Capacity Reservation Contract between The City of Sanford, North Carolina and The
Town of Pittsboro, North Carolina, the Town of Pittsboro agrees to reactivate and maintain an industrial
pretreatment program in accordance with Sanford's rules and regulations upon connection and discharge
to the Big Buffalo WWTP.
Page 3 of 22

Chatham Park
A new biological membrane wastewater treatment plant is being constructed in Chatham Park to handle
wastewaters from the Chatham Park Service area. This facility will be owned and operated by Chatham
Park Investors LLC. Pittsboro will not operate or own this new facility but has entered into an Agreement
with Chatham Park Investors LLC to either:
A) receive the treated wastewaters at the decommissioned plant for discharge to Outfall 001 after UV
disinfection and reaeration with up to 0.3 MG to be treated in Pittsboro's reclaimed system for
chlorination and use at 3M, an industry in Chatham County. While both plants are operating, the
effluent streams will be joined downstream of the existing UV system but upstream of the
cascade aerator. After decommissioning of the Town WWTP, the CPWRC effluent stream can be
directed to the existing UV system. Nonetheless, the CPWRC does and will continue to disinfect
by UV at the CPWRC facility.
B) in the event the treated wastewaters from the CPWRC do not meet permit limitations, they will be
sent to Sanford's WWTP, and
C) in the event the flow received at CPWRC is greater than 0.499 MGD (treatment capacity) the
additional untreated wastewaters will either be directed to the EQ basin and sent to Sanford via
the force main or directly sent to Sanford via the force main. The decision is up to Pittsboro.
D) Also, at Pittsboro's discretion (ORC), any or all wastewaters from the CPWRC can directly be
sent to Sanford's WWTP up to the agreement capacity.
Collection and distribution lines will be constructed by the Town, CPI, and/or other developer(s), but all
are to be dedicated to the Town for ownership and operation/maintenance. CPI is constructing the raw
wastewater diversion/transfer line from the CPWRC to the Town's repurposed WWTP for eventual
transfer to Sanford — and again will be dedicated to the Town. The Town of Pittsboro will be responsible
for constructing all necessary collection and distribution lines for diversion of wastewater to Sanford's
WWTP and distribution of reclaimed wastewater. However, as part of the Agreement and only as allowed
by their Non -discharge permit, CPWRC can chlorinate and distribute reclaimed wastewater directly from
their WWTP.
The CPWRC is intended to have an initial design capacity of 0.499 MGD. The plant has been designed to
meet the following limitations:
Table 1 - WRC Design Effluent Discharge Limits
Parameter
Monthly Average
Daily Maximum
BOD5
<5 mg/L
< 10 mg/L
TSS
< 5 mg/L
< 10 mg/L
Ammonia
< 1 mg/L-N
< 2 mg/L-N
TN
< 3.69 mg/L-N
NA
TP (Apr -Oct)
< 0.145 mg/L-P
NA
TP
< 0.464 mg/L-P
NA
Fecal Coliform
< 3/100 mL (geo. Mean)
< 25/100 mL
pH
6-9 units
6-9 units
Dissolved Oxygen
> 6 mg/L
> 6 mg/L
Turbidity
< 5 NTU
NA
This basis of design is consistent or more stringent than existing limits for Pittsboro's existing NPDES
permit (NC0020354). Although, Pittsboro's existing permit has not been renewed since the state adopted
the 2007-2014 Triennial Review WQS's which included dissolved metals. Therefore, the renewed permit
has been developed using the new Surface Water Quality Standards containing acute and chronic
dissolved metal standards.
Page 4 of 22

ATTACHMENT 1
PITTSBORO WASTEWATER MANAGEMENT SYSTEM AFTER PROPOSED PHASE 1 IMPROVEMENTS ARE COMPLETE
Orange lines = untreated wastewater (Pittsboro cal lection system) T
Blue lines = treated wastewater (not chlorinated)
Green lines = treated wastewater (chlorinated for reuse as reclaimed water)
Pittsboro sewer area
tributary to CPI Facility
Pittsboro sewer area
currently tributary to Pittsboro WWTP
4t24-3953-1421 v3
New Pittsboro reclaimed
water distribution system
CPI Facility 3M plant in Pittsboro
Pittsboro WWTP Robeson Creek
Page 5 of 22

ATTACHMENT 2
PITTSBORO WASTEWATER MANAGEMENT SYSTEM AFTER PROPOSED PHASE 2 IMPROVEMENTS ARE COMPLETE
Orange ales = untreated %va stews to r yF i tnburo culiec ti o n system!
Blue Tines = treated wastewater (not chlorinated)
soiogooloir
Green lines =treated wastewater (chlorinated for reuse as reclaimed water)
Pittsboro sewer area
tributary to CPI Facility
Pittsboro sewer area
currently tributary to Pittsboro WWTP
2. Receiving Waterbodv Information:
Pittsboro pump station
with flow equalization
Sanford WWTP
NC0024147
New Pittsboro reclaimed
water distribution system
Reclaimed water to 3M plant
Robeson Creek
Big Buffalo Creek
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001A and 001B —
Robeson Creek
Outfall 002 - Haw River
Stream Segment:
16-38-(3)
16-(36.7)
Stream Classification:
WS-IV, NSW
Drainage Area (mi2):
10.5
1275
Summer 7Q10 (cfs)
0.03
71.8
Winter 7Q10 (cfs):
0.41
125.6
30Q2 (cfs):
0.4
159
Average Flow (cfs):
10
1240
IWC (% effluent):
100%
4%
303(d) listed/parameter:
Yes, the segment is listed in
the 2018 303(d) as exceeding
criteria for Benthos
No
Subject to TMDL/parameter:
Yes- State wide Mercury TMDL implementation.
Basin/Sub-basin/HUC:
Cape Fear River Basin/03-06-04/03030002
USGS Topo Quad:
E22NW
Page 6 of 22

3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of May 2016 through April 2020.
Table 1. Effluent Data Summary Outfall 001 (existing Pittsboro WWTP discharge)
Parameter
Units
Monthly
Average
Weekly
Average
Max
Min
Pittsboro
Permit
Limit
Flow
MGD
0.41
-
1.751
0.094
MA 0.75
Total Monthly Flow
MG/Month
12.54
-
25.79
7.88
BOD summer
mg/1
2.3
2.3
54
< 2
WA 7.5
MA 5.0
BOD winter
mg/1
2.3
2.4
18
< 2
WA 15.0
MA 10.0
NH3N
mg/1
0.24
0.24
12
< 0.0073
WA 6.0
MA 2.0
TSS
mg/1
3.5
3.5
97
2.5
WA 45.0
MA 30.0
pH
SU
6.9
-
7.4
6.02
6.0>pH<
9.0
Fecal coliform
#/100 ml
1.3
6.7
2420
< 1
(geometric)
WA 400
MA 200
DO
mg/1
8.6
-
10.71
5.74
DO > 6
TRC
1,1g/1
NA (UV)
NA (UV)
(UV)
NA (UV)
DM 17.0
(< 50
compliance)
Temperature
° C
19.9
19.95
28.9
10.9
Conductivity
umhos/cm
626.3
661.4
3400
8.2
TKN
mg/1
1.2
-
23
0.26
NO3-N + NO2-N
mg/1
15.1
36
0.97
TN
mg/1
16.4
36.7
2.89
TN Load
lb/month
1581
2788
467
TN Load
lb/year
19,430
29,402
9,220
36,202
TP
mg/1
QA 0.35
2.4
0.025
QA 2.0
TP Load
lb/month
37
159
10
TP Load
lb/yr
460
546
301
4,551
TP Load summer
lb
123
225
26
322
Total Nickel
41
3.3
8.47
< 2
WA 25
DM 261
Total Copper
µg/1
QA 4.4
-
22.8
1.6
Total Zinc
41
QA 54.8
-
79.7
30.3
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average, QA = Quarterly Average
With the addition of the CPWRC, an additional Effluent Limitations and Requirements sheet has been
added to the permit. While both the Pittsboro WWTP and the CPWRC will be discharging to Robeson
Creek Outfall 001 until the decommissioning of the Pittsboro WWTP, each facility will be limited and be
required to sample separately. For the sake of reporting, the Pittsboro WWTP will discharge to Outfall
Page 7 of 22

OO1A and the CPWRC will discharge to Outfall 001B. As the CPWRC is a privately owned treatment
works, discharge to 001B will be limited as Monthly Averages and Daily Maximums.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen, temperature, fecal
coliform and conductivity. Instream monitoring for dissolved oxygen, temperature, fecal coliform and
conductivity is provisionally waived in light of the Permittee's participation in the Upper Cape Fear River
Basin Association. Upstream hardness sampling is only waived in the event the Upper Cape Fear River
Basin Association conducts the sampling. Instream monitoring shall be conducted as stated in this permit
should the Permittee end its participation in the Association.
No basin association monitoring stations exist upstream of the facility or downstream of the facility in
Robeson Creek. However, Ambient Monitoring Station B2450000 is located downstream of the treatment
facility's discharge at Boat Access off SR 1943 NR Hanks. Data from this downstream location was
observed from May 2016 to April 2020 and has been summarized in Table 2, shown below.
Table 2. Instream AMS Data Summary
Parameter
Units
B2450000 Downstream
Average
Max
Min
Conductivity
µmhos/cm
189.5
407.8
83.7
Fecal Coliform
#/100 ml
(geomean)
19.7
1500
1
DO
mg/1
7.4
12.03
1.27
Temperature
° C
19.4
32.7
5.1
The downstream temperature exceeded 32 degrees Celsius [per 15A NCAC 02B .0211 (18)] on one
occasion during the period reviewed.
Downstream DO dropped below 5 mg/L on 6 occasions [per 15A NCAC 02B .0211 (6)] during the period
reviewed. Downstream DO dropped below 4 mg/L on 3 occasions during the period reviewed.
The geometric mean for fecal coliform did not exceed 200/100mL downstream of the facility [per 15A
NCAC 02B .0211 (7).4)] during the period reviewed. Fecal coliform was reported at levels greater than
400/100m1 in fewer than 20% of samples taken downstream of the facility during the period reviewed.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): YES; The
Town of Pittsboro is currently a coalition member. Chatham Park Investors, LLC is in the process of
joining the coalition.
Name of Monitoring Coalition: Upper Cape Fear River Basin Association
Page 8 of 22

5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The Pittsboro WWTP
reported 2 BOD limit violations in 2017. The facility also reported 2 fecal coliform limit violations, 1
flow limit violation, 1 nickel limit violation and 1 dissolved oxygen limit violation in 2018. In 2019, the
facility reported 2 BOD limit violations, and 2 ammonia limit violations.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The Pittsboro WWTP passed 15 of 15 outfall 001 quarterly chronic toxicity tests between
January 2016 and November 2019.40 CFR 122 (j)(5)(iv-v) requires that at least 4 WET tests be
conducted on a species other than the primary species. At the time the Division received the Permittee's
NPDES permit renewal application, the Permittee had not completed all 4 chronic WET testing on a
second species. The facility has passed 4 of 4 second species tests conducted from April 2020 to July
2020.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in July 2020 reported that the Pittsboro WWTP was compliant.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 1SA NCAC 2B.0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed:
Limitations for BOD are based on a Streeter Phelps model (Level B) conducted in 1988 for instream DO
protection when the Permittee had informed the Division of intent to expand to 0.75 MGD to Robeson
Creek. These limits have been applied in the existing permit to both the 0.75 MGD and 1.249 MGD flow
tiers discharging to Robeson Creek, as well as the 1.971 MGD flow tier Outfall 002 Haw River discharge.
No changes are proposed from the previous permit limits and the limits will also be applied to the
Chatham Park CPWRC. With the addition of the Chatham Park WRC, the 1.249 MGD flow tier is
achieved as a combined flow.
Page 9 of 22

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/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal:
Currently, ammonia is limited to a monthly average of 2.0 mg/L and weekly average of 6.0 mg/L at the
0.75 MGD tier to Robeson Creek. The 2.0 mg/L monthly average limit was concluded from a 1988 Level
B model. Ammonia is limited to a monthly average of 1.0 mg/L and weekly average of 3.0 mg/L at the
1.249 MGD flow tier to Robeson Creek. This is consistent with the results of the attached 2020 WLA
ammonia review at 1.249 MGD. These limits have also been applied to the Outfall 002 Haw River
discharge. Weekly average limitations are based on agreement between DWR and EPA to have a weekly
average to monthly average ratio of 3:1 for both flow tiers. Per 2020 WLA review, ammonia limitations
at the Robeson Creek Outfall 001A discharge location are proposed to be 1.0 mg/L and 3.0 mg/L as a
monthly average and weekly average, respectively. To allow for the Town to implement technology to
come into compliance with these limits at the current flow tier, or decommission their plant and eliminate
the discharge, a 3-year compliance schedule has been added to the permit for ammonia for Outfall 001A.
As the CPWRC is a privately owned treatment works, limits will be applied as monthly averages and
daily maximums. Based on the IWC-based calculations in the 2020 WLA review, the CPWRC will be
limited to a monthly average of 1.0 mg/L and a daily maximum of 5.0 mg/L of ammonia.
TRC is currently limited to a daily maximum of 17 ug/L at both flow tiers, and the Outfall 002 Haw River
discharge, which is consistent with the conclusions of the attached 2020 WLA and is the most restrictive
limit concluded. These limits are maintained and will also be applied to the Chatham Park CPWRC.
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between May 2016 and
April 2020. Pollutants of concern included toxicants with positive detections and associated water quality
standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Copper, Nitrate
Page 10 of 22

• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was >50% of the allowable concentration: NA
• 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: Zinc, Nickel
• POTW Effluent Pollutant Scan Review: The Permittee submitted the results of an effluent
pollutant scan from 7/10/2019 which reported "non -detect" results for all toxicants except
copper, nickel and zinc. As such, the RPA was only conducted on these three parameters. The
cover letter shall include language requesting the Permittee report to the lowest PQL for silver
(PQL = 1 ug/L) and lead (PQL = 2 ug/L)
As the facility discharges to WS waters, chlorinated phenolic compounds, total dissolved solids (TDS)
and nitrate were assessed. All chlorinated phenols were reported as non -detected in the 2019 effluent
pollutant scan. Nitrite + Nitrate values were used in conducting a reasonable potential analysis for nitrate.
TDS was reported as 350 mg/L in the 2019 PPA. The allowable discharge concentration for TDS is 512.9
mg/L. Per Division guidance regarding parameters with maximum predicted concentrations greater than
50% of the allowable discharge concentration, quarterly monitoring for TDS has been added to the permit
to track levels and ensure no excursions above the allowable discharge concentration occur.
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: The Permittee conducts aquatic toxicity testing with a
chronic WET limit of 90% effluent at Outfall 001 (Robeson Creek 100% IWC). Upon expansion to the
plant and discharge to the Haw River via Outfall 002, the Permittee shall also conduct aquatic toxicity
testing with a chronic WET limit of 4% effluent at Outfall 002 (Haw River 4% IWC). No changes are
proposed to the Pittsboro WWTP's requirements. Aquatic toxicity testing with a chronic WET limit of
90% effluent will be required at Outfall 001B (CPWRC).
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
Page 11 of 22

industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Table 2. Mercury Effluent Data Summary
2019
# of Samples
1
Annual Average Conc. ng/L
0.976
Maximum Conc., ng/L
0.976
TBEL, ng/L
47
WQBEL, ng/L
12.31
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury
limit is required. Since the facility is < 2 MGD and reported no quantifiable levels of mercury (> 1 ng/1),
no mercury minimization plan (MMP) is required in the permit.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: The current permit has two effluent outfalls, outfall 001 to Robeson Creek and outfall
002 to the Haw River. A third outfall, outfall CO2, was created in order to apply the nutrient limits that are
in effect for the combination of both outfalls. Nutrient limits were given both individually for each
outfall, and collectively. The Division developed a Total Phosphorus TMDL for Robeson Creek in 2003.
The TMDL applies during the months of April to October. Because the Town of Pittsboro WWTP is the
only known point source discharger into the creek it is the sole point source contributor of phosphorous
and is liable for the entire point source load reduction established to implement the TMDL. The TP
TMDL caps the discharge at outfall 001 (Robeson Creek) at 322 pounds of TP for the summer season
(April through October). In addition, an existing TMDL and the Jordan Lake Rules limit the combined
TN input from the facility at 27,514 pounds per year, and TP at 3,731 pounds per year. These figures
represent pounds delivered to Jordan Lake, and must be calculated using a transport factor, which account
for stream attenuation prior to discharge. TP and TN limits must be calculated to account for loading to
the lake, rather than loads measured at discharge points. Transport Factors are as follows:
Outfall
TN Transport Factor
TP Transport Factor
001 (Robeson Creek)
76%
99%
002 (Haw River)
82%
99%
Limits at the combined Outfall CO2 (001A + 001B + 002) remain unchanged and are as follows:
Page 12 of 22

IPARAMETER
Parameter Code
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locations
Flow 50050
3.22 MGD
See Conditions A.(1.), A.(2.)
and A (3.)
Combined OO1A,
001B & 002
TP Delivered Load2 QY600
3,731 Ib/yr
Annually
Calculated
Combined OO1A,
001B & 002
TN Delivered Load2 QY665
Monitor and Report
27,514 Ib/yr
Annually
Calculated
Combined 001A,
001B & 002
To ensure the Robeson Creek TP TMDL is maintained with the addition of the CPWRC, a second
combined outfall COI (OO1A + OO1B) has been added to the permit and is limited as follows:
PARAMETER
Parameter Code
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locations
Flow 50050
1.249 MGD
See Conditions A.(1.) and
A.(2.
Combined OO1A &
001B
TP Load
(April 1 — October 31) QS665
322 lb
Seasonally
Calculated
Combined OO1A &
001B
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107( c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: As total copper and nitrate
demonstrated reasonable potential to exceed the facility's allowable discharge concentrations based on
state surface water standards, monthly average and daily maximum limits have been put in the permit for
total copper and a monthly average limit has been put in the permit for nitrate. Additionally, per IWC-
based calculations, monthly average and weekly average ammonia limits for the Pittsboro WWTP have
been revised to be more stringent. A 3-year compliance schedule has also been put in the permit. During
this period, the Pittsboro WWTP shall monitor and report for total copper and nitrate on a monthly basis
and shall achieve compliance with existing ammonia limitations as described in Section A.(1.) of the
permit. Within 1 year of the permit's effective date, the Town of Pittsboro shall submit to DWR an Action
Plan for Division approval, summarizing the strategy or actions to be taken to achieve compliance with
the total copper, nitrate and ammonia limitations specified in Section A.(2.) of the permit. The plan will
include specific dates for completion or implementation of each action. Within 2 years of the permit's
effective date, the Town of Pittsboro shall submit a report to the Division summarizing actions taken in
accordance with the Action Plan. The Town shall achieve compliance with total copper, nitrate and
ammonia limitations within 3 years of the permit's effective date, as specified in Section A.(2.) of the
permit. As the CPWRC is considered a new discharger, the schedule of compliance does not apply to
their discharge. The CPWRC shall achieve compliance with their limits specified in Section A.(3.) of the
permit upon the effective date of the permit.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
Page 13 of 22

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
BOD5/TSS for Monthly Average, and 45 mg/l for BOD5/TSS for Weekly Average). YES;
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BOD5/TSS included in the permit? YES; As a co-permiee,
Pittsboro, is a POTW and is required to meet the 85% removal for BOD/TSS, and due to the two
permittees discharging combined Outfall 001, the inclusion of this requirement at Outfall 001B is
justified. This requirement will remain even after the Pittsboro WWTP is decommissioned.
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 2B.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): NO; Dissolved Oxygen
limitations have been moved from individual Outfalls 001A and 001B to combined Outfall CO1 (Outfall
001A + 001B). The same limits and flow requirements apply.
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
Page 14 of 22

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.
As the Pittsboro WWTP is a Grade IV facility, monitoring frequencies for BOD, ammonia, TSS,
conductivity, TRC, pH and dissolved oxygen have been increased from 3/week to daily, per 15A NCAC
02B .0508. This monitoring frequency increase has been applied to the CPWRC discharge to Outfall
001B as well, but not the class upgrade.
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 extended this deadline from December
21, 2020, to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as
a final regulation change published in the November 2, 2020 Federal Register This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes Outfall 001: Pittsboro
WWTP — OO1A, CPWRC — 001B
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
Pittsboro WWTP: MA
0.75 MGD with
expansion page to 1.249
MGD
Pittsboro WWTP: MA
0.75 MGD, Move 1.249
Flow Tier to combined
outfall C01
CPWRC: MA 0.499
MGD
15A NCAC 2B .0505
Total Monthly
Flow
Pittsboro WWTP: Both
Flow Tiers:
Monitor and report
monthly
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC: Monitor and
report monthly
For calculation of Total Nitrogen
and Total Phosphorous loads
BODS
Pittsboro WWTP: Both
Flow Tiers:
Summer:
MA 5 mg/1
WA 7.5 mg/1
Winter:
MA 10 mg/1
WA 15 mg/1
Monitor and Report
3/week
Pittsboro WWTP: No
change to limits; increase
monitor and report to
daily
CPWRC:
Summer:
MA 5 mg/1
DM 7.5 mg/1
Winter:
MA 10 mg/1
DM 15 mg/1
Monitor and Report Daily
WQBEL. Based on results of
1988 Level B model. 15A
NCAC 2B.0200
Page 15 of 22

NH3-N
Pittsboro WWTP:
0.75 MGD Tier:
MA 2 mg/1
WA 6 mg/1
1.249 MGD Tier:
Summer:
MA 1 mg/1
WA 3 mg/1
Winter:
MA 2 mg/1
WA 6 mg/1
Monitor and Report
3/week
Pittsboro WWTP: 3-year
compliance schedule
Until 3 years past
effective date of permit:
MA 2 mg/1
WA 6 mg/1
Monitor and Report Daily
After 3 years past
effective date of permit:
MA 1 mg/1
WA 3 mg/1
Monitor and Report Daily
CPWRC:
MA 1 mg/1
DM 5 mg/1
Monitor and Report Daily
WQBEL. Based on protection of
State WQ criteria. 15A NCAC
2B.0200; 2020 WLA review.
POTW and non-POTW
TSS
Pittsboro WWTP: Both
Flow Tiers:
MA 30 mg/1
WA 45 mg/1
Monitor and Report
3/week
Pittsboro WWTP: No
change to limits; increase
monitor and report to
daily
CPWRC:
MA 30 mg/1
DM 45 mg/L
Monitor and Report Daily
TBEL. Secondary treatment
standards(for POTW)/40 CFR
133 / 15A NCAC 2B .0406
TRC
Pittsboro WWTP: Both
Flow Tiers:
DM 17 ug/L
Monitor and Report
3/week
Pittsboro WWTP: No
change to limits; increase
monitor and report to
daily
CPWRC:
DM 17 ug/L
Monitor and Report Daily
WQBEL. 15A NCAC 2B.0200;
2020 WLA review. POTW and
non-POTW
Fecal coliform
Pittsboro WWTP: Both
Flow Tiers:
MA 200 /100m1
WA 400 /100m1
Monitor and Report
3/week
Pittsboro WWTP: No
change to limits; increase
monitor and report to
daily
CPWRC:
MA 200 /100m1
DM 400 /100m1
Monitor and Report Daily
WQBEL. State WQ standard,
15A NCAC 2B .0200
DO
Pittsboro WWTP: Both
Flow Tiers:
> 6 mg/1
Monitor and Report
3/week
Pittsboro WWTP:
Monitor and Report Daily;
Move limit to combined
outfall C01
CPWRC:
Monitor and Report Daily;
limited at combined
Outfall CO1
WQBEL. State WQ standard,
15A NCAC 2B .0200
Page 16 of 22

pH
Pittsboro WWTP: Both
Flow Tiers:
6 — 9 SU
Monitor and Report
3/week
Pittsboro WWTP: No
change to limits; increase
monitor and report to
daily
CPWRC:
6 — 9 SU
Monitor and Report Daily
WQBEL. State WQ standard,
15A NCAC 2B .0200
Temperature
Pittsboro WWTP: Both
Flow Tiers:
Monitor Daily
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC:
Monitor and Report Daily
15A NCAC 2B .0500 — Surface
Water Monitoring: Reporting
TKN
Monitor and Report
Weekly
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC:
Monitor and Report
Weekly
For calculation of Total Nitrogen
NO2-N + NO3-N
Monitor and Report
Weekly
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC:
Monitor and Report
Weekly
For calculation of Total Nitrogen
Total Nitrogen
Pittsboro WWTP: Both
Flow Tiers:
Monitor Weekly
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC:
Monitor and Report
Weekly
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management
Strategy T15A NCAC 02B .0270
and 2004 Robeson Creek TMDL.
TN Load
Pittsboro WWTP: Both
Flow Tiers:
Monitor Monthly and
Annually
Pittsboro WWTP:
Monitor Monthly and
Annually
CPWRC:
Monitor Monthly and
Annually
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management
Strategy T15A NCAC 02B .0270
and 2004 Robeson Creek TMDL.
Total Phosphorus
Pittsboro WWTP: Both
Flow Tiers:
QA 2.0 mg/L
Pittsboro WWTP: No
change at 0.75 MGD
CPWRC:
QA 2.0 mg/1
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management
Strategy T15A NCAC 02B
.0270.
TP Load
Pittsboro WWTP: Both
Flow Tiers:
Monitor Monthly and
Annually
3221b (Apr. 1-Oct. 31)
Pittsboro WWTP:
Changed to Monitor
Monthly and Annually
CPWRC:
Changed to Monitor
Monthly and Annually
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management
Strategy T15A NCAC 02B .0270
and 2004 Robeson Creek TMDL.
Conductivity
Pittsboro WWTP: Both
Flow Tiers:
Monitor 3/week
Pittsboro WWTP:
increase monitor and
report to daily
CPWRC:
Monitor daily
15A NCAC 2B .0500 — Surface
Water Monitoring: Reporting
Page 17 of 22

Total Copper
Pittsboro WWTP: Both
Flow Tiers:
Monitor Quarterly
Pittsboro WWTP:
MA 18.5 ug/1
DM 26.7 ug/1
Monthly Monitoring
3-year compliance
schedule
CPWRC:
MA 18.5 ug/1
DM 26.7 ug/1
Monthly Monitoring
WQBEL. Based on results of
RPA; RP shown - apply Monthly
Monitoring with Limit
Total Zinc
Pittsboro WWTP: Both
Flow Tiers:
Monitor Quarterly
Remove requirement
Based on results of RPA; No RP,
Predicted Max < 50% of
Allowable Cw - No Monitoring
required
Total Nickel
Pittsboro WWTP: Both
Flow Tiers:
WA 25 ug/1
DM 261 ug/1
Remove requirement
Based on results of RPA; No RP,
Predicted Max < 50% of
Allowable Cw - No Monitoring
required
TDS
No requirement
Pittsboro WWTP:
Quarterly Monitoring
CPWRC:
Quarterly Monitoring
Based on results of RPA;
reported value from PPA > 50%
of Allowable Cw - apply
Quarterly Monitoring
Nitrate
No requirement
Pittsboro WWTP:
MA 10.2 mg/L
Monthly Monitoring
3-year compliance
schedule
CPWRC:
MA 10.2 mg/L
Monthly Monitoring
WQBEL. Based on results of
RPA; RP shown - apply Monthly
Monitoring with Limit
Total Hardness
No requirement
Pittsboro WWTP and
CPWRC:
Quarterly monitoring
upstream and in effluent;
upstream sampling
Hardness -dependent dissolved
metals water quality standards
approved in 2016 — monitoring
for hardness -dependent metal
Toxicity Test
Pittsboro WWTP: Both
Flow Tiers:
Chronic limit, 90%
effluent
Pittsboro WWTP:
Chronic limit, 90%
effluent
CPWRC:
Chronic limit, 90%
effluent
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200
and 15A NCAC 2B.0500
Effluent Pollutant
Scan
3 per permit cycle upon
expansion to 1.249
MGD flow tier
Add conditional
pretreatment language
40 CFR 122; Pittsboro to employ
pretreatment program upon
discharge to Sanford
Mercury
Minimization Plan
(MMP)
No requirement
No change
Consistent with 2012 Statewide
Mercury TMDL Implementation.
Electronic
Reporting
Electronic Reporting
Special Condition
No change
In accordance with EPA
Electronic Reporting Rule 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 18 of 22

B. Table. Current Permit Conditions and Proposed Changes Outfall 002 Haw River
Parameter
Current Permit
Proposed Change
Basis for Condition/Change -
Flow
MA 1.971 MGD
No change
15A NCAC 2B .0505
Total Monthly
Flow
Monitor and report
monthly
No change
For calculation of Total Nitrogen
and Total Phosphorous loads
BOD5
Summer:
MA 5 mg/1
WA 7.5 mg/1
Winter:
MA 10 mg/1
WA 15 mg/1
Monitor and Report
daily
No change
WQBEL. Based on results of 1988
Level B model. 15A NCAC
2B.0200
NH3-N
Summer:
MA 1 mg/1
WA 3 mg/1
Winter:
MA 2 mg/1
WA 6 mg/1
Monitor and Report
3/week
No change to limits;
increase monitor and
report to daily
WQBEL. Based on protection of
State WQ criteria. 15A NCAC
2B.0200
TSS
MA 30 mg/1
WA 45 mg/1
Monitor and Report
daily
No change
TBEL. Secondary treatment
standards/40 CFR 133 / 15A NCAC
2B .0406
Fecal coliform
MA 14 /100m1
WA 25 /100m1
Monitor and Report
daily
No change
WQBEL. Reclaimed Water Effluent
Standards 15A NCAC 02U .0301;
Town agreed to these during 2011
permit modification
Temperature
Monitor and Report
daily
No change
15A NCAC 2B .0500 — Surface
Water Monitoring: Reporting
DO
> 6 mg/1
Monitor and Report
daily
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
pH
6 — 9 SU
Monitor and Report
daily
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
TRC
DM 28 ug/L
Monitor and Report
3/week
No change to limits;
increase monitor and
report to daily
WQBEL. 15A NCAC 2B.0200;
2020 WLA review.
TKN
Monitor and Report
Weekly
No change
For calculation of Total Nitrogen
NO2-N + NO3-N
Monitor and Report
Weekly
No change
For calculation of Total Nitrogen
Total Nitrogen
Monitor and Report
Weekly
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
TN Load
Monitor Monthly and
Annually
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
Page 19 of 22

Total Phosphorus
Monitor and Report
Weekly
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
TP Load
Monitor Monthly and
Annually
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
Conductivity
Monitor and Report
3/week
No change to limits;
increase monitor and
report to daily
15A NCAC 2B .0500 — Surface
Water Monitoring: Reporting
Total Copper
Monitor and Report
Quarterly
Remove requirement
Based on results of RPA; No RP,
Predicted Max < 50% of Allowable
Cw - No Monitoring required
Total Nickel
Monitor and Report
Quarterly
Remove requirement
Based on results of RPA; No RP,
Predicted Max < 50% of Allowable
Cw - No Monitoring required
Total Zinc
Monitor and Report
Quarterly
Remove requirement
Based on results of RPA; No RP,
Predicted Max < 50% of Allowable
Cw - No Monitoring required
Toxicity Test
Chronic limit, 4%
effluent
No change
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Effluent Pollutant
Scan
3 per permit cycle upon
No change
40 CFR 122; Flow exceeding 1
MGD
Electronic
Reporting
Electronic Reporting
Special Condition
No change
In accordance with EPA Electronic
Reporting Rule 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
C. Table. Current Permit Conditions and Proposed Changes Outfall CO2: Combined
Outfalls 001 (001A + 001B) and 002
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 3.22 MGD
No change
15A NCAC 2B .0505
Total Nitrogen
Delivered
27,514 lb/yr
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
Total Phosphorus
Delivered
3,731 lb/yr
No change
WQBEL. Required individual
TN/TP nutrient limits per Jordan
Lake Nutrient Management Strategy
T15A NCAC 02B .0270
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 20 of 22

D. Table. Current Permit Conditions and Proposed Changes Outfall C01: Combined
Outfalls 001 (001A + 001B)
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
No requirement
MA 1.249 MGD
15A NCAC 2B .0505
DO
No requirement
> 6 mg/1
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Phosphorus
No requirement
3221b April 1 —
October 31
WQBEL. 2004 Robeson Creek
TMDL.
Instream Sampling
Conducted at 001
Moved to combined
outfall CO1
Only one set of samples to be
conducted upstream and downstream
of discharge
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
13. Public Notice Schedule:
Permit to Public Notice: March 9, 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 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):
The draft was submitted to the Town of Pittsboro, Chatham Park Investors, LLC (CPI,LLC), EPA Region
IV, and the Division's Raleigh Regional Office, Aquatic Toxicology Branch, Ecosystems Branch,
Operator Certification Program, and Raleigh Regional Public Water Supply (PWS) for review.
Discussions with the Ecosystems Branch regarding the implications of this permit on the Memorandum of
Agreement with the Upper Cape Fear River Basin Association (UCFRBA) began on 3/24/2021. After
discussions with the Ecosystems Branch, UCFRBA, and CPI, LLC, CPI, LLC agreed to become a
member of UCFRBA and is currently in that process. On 4/19/2021, comments were received from the
Division's Basin Planning Branch regarding instream sampling locations and parameters sampled, as well
as rationale behind the decision to not include specific metals monitoring. The comments and response
has been attached to this fact sheet. The Raleigh Regional PWS submitted a memo concurring with the
issuance of the NPDES permit on 4/26/2021. No comments were received from any other party.
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• As the Monitoring Coalition will not be conducting hardness sampling on behalf of the Permittee,
the footnote language in Sections A.(4.) and A.(5.) has been updated.
15. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
Page 21 of 22

• Dissolved Metals Implementation/Freshwater
• 2020 WLA Review
• Aquatic Toxicity Summary
• 2018 303(d) listing
• Inspection Report
Page 22 of 22

Chatham News Record
NORTH CAROLINA
CHATHAM COUNTY
AFFIDAVIT OF PUBLICATION
Before the undersigned, a Notary Public of said County and State,
duly commissioned, qualified and authorized by law to administer
oaths, personally appeared Florence Turner
, who
being first duly sworn, deposes and says: that he (she) is
Accounts Receivable Clerk
(Owner, partner, publisher, or other officer or employee authorized to make this affidavit)
of the Chatham Media Group, LLC., engaged in the publication of
a newspaper known as, Chatham News+Record, published, issued,
and entered as second class mail in the Town of Siler City, in said
County and State; that he (she) is authorized to make this affidavit
and sworn statement; that the notice or legal advertisement,
a true copy of which is attached hereto, was published in the
Chatham News+Record on the following dates:
1
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 of the requirements and qualifications of Section 1-597 of the
General Statues of North Carolina and was a qualified newspaper
within the meaning of Section 1-597 of the General Statues of
North Carolina.
This /n
day of --711cc,(__ — - rl
(Signature of person making affidavit) /
` / `�
Sworn to and subscribed before me, this
day of
My Commission expires:
rTh
Notary P
CLIPPING OF LEGAL
ADVERTISEMENT
ATTACHED HERETO
PUBLIC NOTICE
North Carolina Environmental
Management Commission/
NPDES Unit,1617 Mail Service
Center, Raleigh, NC 27699-
1617.
Notice of Intent to Issue a
NPDES Wastewater Permit
NC0020354 Town of Pittsboro
WWTP
The North Carolina Environ-
mental Management Com-
mission proposes to issue a
NPDES wastewater discharge
permit to the person(s) listed
below. Written comments
regarding the proposed permit
will be accepted until 30 days
after the publish date of this
notice. The Director of the NC
Division of Water Resources
(DWR) may hold a public
hearing should there be a
significant degree of public in-
terest. Please mail comments
and/or information requests
to DWR at the above address.
Interested persons may visit
the DWR at 512 N. Salisbury
Street, Raleigh, NC 27604 to
review information on file. Ad-
ditional information on NPDES
permits and this notice may be
found on our website: http://
deq.nc.gov/about/divisions/
water-resources/water-re-
sources-permits/wastewa-
ter-branch/npdes-wastewater/
public-notices,or by calling
[phone]. The Town of
Pittsboro [485 Small Street,
Pittsboro, NC 27312] and
Chatham Park investors LLC
[2261 US Highway 64 Business
East, Pittsboro, NC 27312]
have requested modification
and renewal of NPDES permit
NC0020354 for the Pittsboro
Wastewater Treatment Plant,
located in Chatham Coun-
\\,,►111 11. ty. This permitted facility
, EN W discharges treated municipal
wastewater to Robeson Creek,
a class WS-IV, NSW water in
the Cape Fear River Basin. The
N 0 TA permit modificationincor-
porates the inclusiarrjof the
Chatham Park Waterfiecov-
:0 PUB!'
ery Center as a discharger
to the existing Outfall 001
to Robeson Creek. Currently
�y9�l BOD, ammonia, total resid-
//'77IIo11' dissolved oxygen, pH,iformtotal
loading,coppernitrogen nitrate, total
total phosphorus, and
total phosphorous loading are
water quality limited param-
eters. This discharge may
affect future allocations in this
segment of Robeson Creek.
M18,1tc

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
4/19/2021
Nick Coco
DWR, NPDES
512 N. Salisbury St.
Raleigh, NC 27604
NORTH CAROLINA
Environmental Quality
Nora Deamer
DWR, Basin Planning Branch
512 N. Salisbury St.
Raleigh, NC 27604
Re: Comments regarding the proposed co -permit modification and renewal (NC0020354) the Town of Pittsboro
and Chatham Park Water Recovery Center.
Dear Mr. Coco,
I am submitting comments from the Division of Water Resources, Basin Planning Branch in regard to the permit
modification and renewal of permit NC0020354 for the Town of Pittsboro and Chatham Park Water Recovery
Center (Chatham Park LLC). I am the basinwide planner for the Cape Fear River Basin and I utilized the water
quality data that is collected by the division and the ambient monitoring coalitions to understand the impacts from
both point and nonpoint sources of pollution on the surface waters of the state.
Much of the Robeson Creek watershed is currently impaired due to fair benthic macroinvertebrate bioclassification
ratings. There is also a TMDL for total phosphorus in Robeson Creek as well as the Jordan Lake nutrient strategy
due to excess nitrogen and phosphorus. My concern as a basin planner, is that there are no ambient monitoring
stations within the upper portion of the watershed for those of us that need to understand the impacts from the
wastewater treatment discharge and/or due to the existing and the new development that is coming to this
watershed. I feel that it is imperative that we have some additional instream monitoring to help us understand the
current and future conditions and changes that are occurring as result of the large scale Chatham Park
development.
As part of the permit, there are a few instream monitoring requirement which do not include monitoring for
nitrogen or phosphorous. These are critical parameters to have in a watershed that has a nutrient strategy and a
TMDL associated with nutrients. The current downstream ambient station (B2450000) is located in the Robeson
Creek arm of Jordan Lake [AU# 16-(37.5)b]. This station is representative of what is happening in a cove of the lake
and not in Robeson Creek proper. This station indicates that there is excess nitrogen and phosphorus resulting in
elevated chlorophyll a as well as elevated total suspended solids and turbidity.
I would like to request additional parameters to be included as part of the permit upstream and downstream
monitoring in order to make sure that those of us working in this watershed have the data needed to better
understand what is occurring and how we can better protect this critical resource.
Currently the table in section A.(5.) Combined Limitations — Outfall CO1 (Combined outfalls 001A and 0018)
includes:
Temperature,
Dissolved Oxygen,
Fecal Coliform,
Conductivity, and
£ D_E
NORTH CAROLINA
Department of Environmental Uuaii�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

Total Hardness (upstream only).
I appreciate that these parameters are currently included and would like to see additional parameters added as a
requirement of the permit. These include:
Total Nitrogen (reporting both NO2 + NO3 and TKN),
Ammonia,
Total Phosphorus,
Total Suspended Solids,
Turbidity and
Chlorophyll a.
I know that the upstream and downstream monitoring are waived due to the Town of Pittsboro's participation in
the monitoring coalition. The data collected from the coalition is incredibly valuable and important for our use in
DWR. I support this program completely and appreciate the quality of the date they produce. I would however like
to see additional stations in the Robeson Creek watershed as result of a new discharger and major development in
the watershed.
I feel that additional monitoring upstream and downstream of the actual discharge location on Robeson Creek
would provide those living in and managing this watershed a better overall understand of what pollutants are
coming from development verses the wastewater treatment plant. It could also show how well the measures put
in place to protect the stream are working. This stream is already impacted by the existing development and point
source discharge as seen by the fair benthic macroinvertebrate ratings. We must protect it from further
degradation.
According to what I understand from the NPDES permit fact sheet, Robeson Creek is listed as 100 % IWC but the
permit only requires testing at 90% effluent concentration. Given that this stream is impaired for benthos, it
seems to me that there could be an impact from the effluent at very low flows.
The Reasonable Potential Analysis (RPA) indicated that it is safe for the Town of Pittsboro to no longer have limits
or monitoring requirements for Zinc and Nickel. I do not know that I understand that same assumption should be
given to CPWRC since they have not started treating wastewater. It would seem wise to error on the side of being
overprotective, especially given the current benthos impairment.
Please let me know if you have any questions or concerns regarding my comments. I know I have a lot to learn
about permitting and how new permits are developed. This is an interesting one with the co-permittee aspect. I do
not recall ever looking at anything like this before. Thank you for the opportunity to review this co -permit.
Sincerely,
-/6.-140� �ca�rvwL
Nora Deamer
DEQ-DWR
Basinwide Planning Branch
919-707-9116
[e-mail]
£ D_E
NORTH CAROLINA
Department of Environmental Umfi�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611
919.707.9000

Fact Sheet Addendum
On April 19, 2021, comments were received from the Division's Basin Planning Branch regarding instream
sampling locations and parameters sampled, as well as rationale behind the decision to not include specific
metals monitoring (see full comments attached). The Municipal Permitting Unit has provided the following
response:
Dear Nora,
Thank you for reviewing draft NPDES permit NC0020354 and for providing your comments.
We understand your concern regarding the lack of instream monitoring stations upstream and downstream near
the point of discharge and your request for additional parameters to be sampled. As you are aware, the Town of
Pittsboro is already a member of the Upper Cape Fear River Basin Association (UCFRBA) and Chatham Park
Investors, LLC is in the process of joining. As you noted in your comment letter, the data collected from the
coalition is valuable and important for use in DWR. It is not our intention to drive members away from the
coalition by requiring additional monitoring requirements that may diminish the perceived value of coalition
membership unless absolutely necessary. We do feel that instream monitoring is an important requirement for
assessing impacts of dischargers on the receiving stream and agree that it would be beneficial to have better
located stations, especially considering the addition and mixing of a new wastestream. This has been discussed
with the Ecosystems Branch and it has been agreed that the Division will encourage the UCFRBA to reactivate
their monitoring station located downstream of the discharge, add a monitoring station upstream of the
discharge, and incorporate the suite of parameters you had requested in their regular sampling suite.
With regard to the total zinc and total nickel inquiry, it is not expected that total zinc and total nickel would be
present in 100% domestic waste streams at levels of concern. The additional sampling conducted by the Town
of Pittsboro demonstrated that there was no reasonable potential for excursions above the allowable discharge
concentration for total nickel or total zinc. The domestic wastewater received and treated by the CPWRC is not
expected to differ significantly from the domestic wastewater received and treated by the Town of Pittsboro. As
such, no monitoring has been added for total nickel or total zinc.
We appreciate your time and comments. The permit is being issued without substantial changes from the draft.
Best,
Nicholas Coco, EI
Engineer
NPDES Municipal Permitting Unit
NCDEQ/Division of Water Resources/Water Quality Permitting

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretory
S. DANIEL SMITH
Director
MEMORANDUM
To:
From:
Subject:
NORTH CAROLINA
Environmental Quality
March 19, 2021
Shawn Guyer
NC DEQ / DWR / Regional Engineer
Raleigh Regional Office
Nick Coco
919-707-3609
NPDES Unit
Review of Draft NPDES Permit NC0020354
Pittsboro WWTP/Chatham Park WRC
Chatham County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by April 19,
2021. If you have any questions on the draft permit, please feel free to contact me at the telephone number
shown above.
RESPONSE: (Check one)
Signe
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
.11E
ut,H=..nrM:E ovaPir
Rapartivnt of a:rimnme .' ika;;; 40104"
North Carolina Department of Environmental Quality 1 Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center 1 Raleigh, North Carolina 27699-16(7
919.707.9000

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
CPI Facility
C
III
NC0020354
001
0.499
Robeson Creek
WS-IV,NSW
Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
0.03
0.41
0.40
10.00
0.03
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
67 mg/L (Avg)
25 mg/L (Avg)
65.43 mg/L
65.43 mg/L
Note: All chlorinated phenols reported as non -detect
in 2019 PPA. Nitrite + Nitrate values used in RPA for
Nitrate.
Data Source(s)
❑ CHECK TO APPLY MODEL
CHECK WQS
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
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
1.2204
FW
7.5000
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
yTotal Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
258.8896
FW
1990.2418
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
17.9314
FW
25.9255
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
8.5982
FW
220.6455
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
84.0250
FW
756.5109
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
1.5509
ug/L
Zinc
Aquatic Life
NC
286.3746
FW
284.0511
ug/L
Nitrate
Water Supply
NC
10
WS
mg/L
TDS
Water Supply
NC
500
WS
mg/L
RPA Chatham Park, input
9/10/2020

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Pittsboro WWTP
IV
NC0020354
001
1.971 E
Haw River
WS-IV,NSW
Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
71.80
125.60
159.00
1240.00
58.74
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
67 mg/L (Avg)
25 mg/L (Avg)
26.71 mg/L
27.08 mg/L
Note: All chlorinated phenols reported as non -detect
in 2019 PPA. Nitrite + Nitrate values used in RPA for
Nitrate.
Data Source(s)
❑ CHECK TO APPLY MODEL
CHECK WQS
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
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
0.6202
FW
3.4734
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
yTotal Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
124.3039
FW
966.2002
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
8.3401
FW
11.2896
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
3.1696
FW
82.5789
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
39.3799
FW
358.6164
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
0.3400
ug/L
Zinc
Aquatic Life
NC
134.0586
FW
134.4972
ug/L
Nitrate
Water Supply
NC
10
WS
mg/L
TDS
Water Supply
NC
500
WS
mg/L
RPA Pittsboro Haw River, input
9/10/2020

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Pittsboro WWTP
IV
NC0020354
001
0.750 E
Robeson Creek
WS-IV,NSW
Apply WS Hardness WQC
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
0.03
0.41
0.40
10.00
0.03
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
67 mg/L (Avg)
25 mg/L (Avg)
65.94 mg/L
65.94 mg/L
Note: All chlorinated phenols reported as non -detect
in 2019 PPA. Nitrite + Nitrate values used in RPA for
Nitrate.
Data Source(s)
❑ CHECK TO APPLY MODEL
CHECK WQS
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
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
1.2276
FW
7.5511
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
yTotal Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
260.5463
FW
2002.9784
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
18.0511
FW
26.1164
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
8.6724
FW
222.5476
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
84.5805
FW
761.5124
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
1.5718
ug/L
Zinc
Aquatic Life
NC
288.2708
FW
285.9319
ug/L
Nitrate
Water Supply
NC
to
WS
mg/L
TDS
Water Supply
NC
500
WS
mg/L
RPA Pittsboro (Autosaved), input
9/10/2020

REASONABLE POTENTIAL ANALYSIS
Effluent Hardness
Date Data BDL=1/2DL
7/16/2019 67 67
Results
Std Dev.
Mean
C.V.
n
10th Per value
Average Value
Max. Value
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
H2
Upstream Hardness
N/A
67.0000
0.0000
1
67.00 mg/L
67.00 mg/L
67.00 mg/L
Date Data BDL=1/2DL
25 25
Results
Std Dev.
Mean
C.V.
n
10th Per value
Average Value
Max. Value
Use "PASTE SPECIAL•
Values" then "COPY"
. Maximum data
points = 58
N/A
25.0000
0.0000
1
25.00 mg/L
25.00 mg/L
25.00 mg/L
RPA Pittsboro (Autosaved), data
- 1 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=1/2DL Results
1 7/16/2019 < 10 5
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Std Dev. N/A
Mean 5.0000
C.V. (default) 0.6000
n 1
Mult Factor =
Max. Value
Max. Pred Cw
6.20
5.0 ug/L
31.0 ug/L
RPA Pittsboro (Autosaved), data
- 2 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par03
Beryllium
Date Data BDL=1/2DL Results
1 7/16/2019 < 1 0.5 Std Dev.
2 Mean
3 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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par04
Cadmium
N/A
0.5000
0.6000
1
6.20
0.50 ug/L
3.10 ug/L
Date Data BDL=1/2DL Results
1 7/16/2019 < 1 0.5 Std Dev. N/A
2 Mean 0.5000
3 C.V. (default) 0.6000
4 n 1
5
6 Mult Factor = 6.20
7 Max. Value 0.500 ug/L
8 Max. Pred Cw 3.100 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL•
Values" then "COPY"
. Maximum data
points = 58
RPA Pittsboro (Autosaved), data
- 3 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par07
Total Phenolic Compounds
Date Data BDL=1/2DL Results
1 7/17/2019 < 50 25
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
Use "PASTE
SPECIAL -Values
then "COPY" .
Maximum data
points = 58
Par10
Chromium, Total
Std Dev. N/A
Mean 25.0000
C.V. (default) 0.6000
n 1
Mult Factor =
Max. Value
Max. Pred Cw
6.20
25.0 ug/L
155.0 ug/L
Date Data BDL=1/2DL Results
1 7/16/2019 < 10 5 Std Dev.
2 Mean
3 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
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points = 58
N/A
5.0000
0.6000
1
6.20
5.0 pg/L
31.0 pg/L
RPA Pittsboro (Autosaved), data
- 4 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Pall
Copper
Date
6/8/2016
7/5/2016
8/2/2016
9/6/2016
10/25/2016
11/8/2016
12/14/2016
1/24/2017
2/7/2017
3/14/2017
4/25/2017
5/10/2017
6/6/2017
7/11/2017
8/1/2017
9/12/2017
10/12/2017
11/20/2017
12/5/2017
1/3/2018
2/6/2018
3/13/2018
4/19/2018
5/22/2018
6/5/2018
7/3/2018
8/14/2018
9/11/2018
10/4/2018
11/8/2018
12/4/2018
1/8/2019
2/5/2019
3/7/2019
4/9/2019
5/14/2019
6/4/2019
7/2/2019
8/6/2019
9/4/2019
10/15/2019
11/7/2019
12/3/2019
1/28/2020
2/4/2020
3/3/2020
4/7/2020
Data
4.39
3.76
5.29
9.89
9.1
6.51
8.18
6.83
6.51
2.06
22.8
5.01
7.83
5.21
3.29
2.68
9.18
5.68
3.6
6.03
2.97
< 1.6
2.41
< 1.6
1.8
5.1
< 1.6
< 1.6
< 1.6
< 1.6
2.36
2.98
2.18
< 1.6
4.15
< 1.6
3.9
3.19
2.94
2.14
2.74
2.43
3.51
< 1.6
1.65
1.7
3.22
BDL=1/2DL
4.39
3.76
5.29
9.89
9.1
6.51
8.18
6.83
6.51
2.06
22.8
5.01
7.83
5.21
3.29
2.68
9.18
5.68
3.6
6.03
2.97
0.8
2.41
0.8
1.8
5.1
0.8
0.8
0.8
0.8
2.36
2.98
2.18
0.8
4.15
0.8
3.9
3.19
2.94
2.14
2.74
2.43
3.51
0.8
1.65
1.7
3.22
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par12
Cyanide
3.7318
4.0936
0.9116
47
1.08
22.80 ug/L
24.62 ug/L
-5-
Date
1 7/16/2019
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
Data BDL=1/2DL
5 5
Results
Std Dev. N/A
Mean
C.V. (default)
n
Use "PASTE SPECIAL•
Values" then "COPY"
. Maximum data
points = 58
Mult Factor =
Max. Value
Max. Pred Cw
5.00
0.6000
1
6.20
5.0 ug/L
31.0 ug/L
RPA Pittsboro (Autosaved), data
9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par14
Lead
Date BDL=1/2DL Results
1 7/16/2019 < 10 5 Std Dev.
2 Mean
3 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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Par17 & Par18
Nickel
N/A
5.0000
0.6000
1
6.20
5.000 ug/L
31.000 ug/L
Date Data BDL=1/2DL Results
1 3/26/2019 < 2.2 1.1 Std Dev. 1.1815
2 4/2/2019 < 2.2 1.1 Mean 2.2645
3 4/9/2019 < 2.2 1.1 C.V. 0.5218
4 4/18/2019 < 2.2 1.1 n 58
5 4/23/2019 < 2.2 1.1
6 4/30/2019 < 2.2 1.1 Mult Factor = 1.00
7 5/7/2019 2.35 2.35 Max. Value 5.1 pg/L
8 5/14/2019 < 2.2 1.1 Max. Pred Cw 5.1 pg/L
Use "PASTE
SPECIAL -Values"
then "COPY" .
Maximum data
points = 58
9 5/21/2019 2.4 2.42
10 5/28/2019 2.82 2.82
11 6/4/2019 2.38 2.38
12 6/11 /2019 < 2.2 1.1
13 6/18/2019 2.47 2.47
14 6/25/2019 2.53 2.53
15 7/2/2019 < 2.2 1.1
16 7/9/2019 2.56 2.56
17 7/16/2019 3.25 3.25
18 7/23/2019 3.2 3.2
19 7/31/2019 3.56 3.56
20 8/6/2019 2.25 2.25
21 8/13/2019 2.72 2.72
22 8/20/2019 < 2.2 1.1
23 8/27/2019 < 2.2 1.1
24 9/4/2019 < 2.2 1.1
25 9/10/2019 2.79 2.79
26 9/17/2019 3.24 3.24
27 9/24/2019 3.85 3.85
28 10/3/2019 5.04 5.04
29 10/8/2019 4.59 4.59
30 10/15/2019 4.65 4.65
31 10/22/2019 5.12 5.12
32 10/29/2019 3.86 3.86
33 11/7/2019 3.77 3.77
34 11/12/2019 2.84 2.84
35 11/19/2019 2.99 2.99
36 11/25/2019 2.59 2.59
37 12/3/2019 3.17 3.17
38 12/10/2019 < 2.2 1.1
39 12/17/2019 < 2.2 1.1
40 12/23/2019 < 2.2 1.1
41 12/31/2019 < 2.2 1.1
42 1/9/2020 2.79 2.79
43 1/14/2020 2.33 2.33
44 1 /21 /2020 2.38 2.38
45 1 /28/2020 < 2.2 1.1
46 2/4/2020 2.82 2.82
47 2/13/2020 < 2.2 1.1
48 2/18/2020 < 2.2 1.1
49 2/25/2020 < 2.2 1.1
50 3/3/2020 < 2.2 1.1
51 3/10/2020 < 2.2 1.1
52 3/17/2020 3.3 3.3
53 3/24/2020 3.32 3.32
54 3/31/2020 2.51 2.51
55 4/7/2020 3.38 3.38
56 4/14/2020 < 2.2 1.1
57 4/21 /2020 < 2.2 1.1
58 4/28/2020 < 2.2 1.1
RPA Pittsboro (Autosaved), data
- 6 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par19
Selenium
Date
1 7/16/2019
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
Data BDL=1/2DL
3 1.5
Results
Std Dev. N/A
Mean 1.5000
C.V. (default) 0.6000
n 1
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE
SPECIAL -Values
then "COPY" .
Maximum data
points = 58
Par20
Silver
6.20
1.5 ug/L
9.3 ug/L
Date Data BDL=1/2DL
7/16/2019 < 10 5
Results
Std Dev.
Mean
C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points =
58
N/A
5.0000
0.6000
1
6.20
5.000 ug/L
31.000 ug/L
RPA Pittsboro (Autosaved), data
- 7 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par21
Zinc
Date Data
1 6/8/2016
2 7/5/2016
3 8/2/2016
4 9/6/2016
5 10/25/2016
6 11/8/2016
7 12/14/2016
8 1/24/2017
9 2/7/2017
10 3/14/2017
11 4/25/2017
12 5/10/2017
13 6/6/2017
14 7/11/2017
15 8/1/2017
16 9/12/2017
17 10/12/2017
18 11/20/2017
19 12/5/2017
20 1/3/2018
21 2/6/2018
22 3/13/2018
23 4/19/2018
24 5/22/2018
25 6/5/2018
26 7/3/2018
27 8/14/2018
28 9/11/2018
29 10/4/2018
30 11/8/2018
31 12/4/2018
32 1/8/2019
33 2/5/2019
34 3/7/2019
35 4/9/2019
36 5/14/2019
37 6/4/2019
38 7/2/2019
39 8/6/2019
40 9/4/2019
41 10/15/2019
42 11/7/2019
43 12/3/2019
44 1/28/2020
45 2/4/2020
46 3/3/2020
47 4/7/2020
48
49
50
51
52
53
54
55
56
57
58
34.4
37.5
38.9
49.2
56.8
62.5
64.9
55.1
71.6
75.2
74.4
43.2
60.6
61.1
61.8
67.3
63.6
79.7
79
67.2
44
52.8
34.9
41.8
47.2
66.6
33.1
58.6
44.7
30.3
44.9
35.9
56.2
33.2
46.7
50.5
61.8
72
57.9
59.5
60.5
63.6
62.1
47.3
50.4
47.8
49.6
BDL=1/2DL
34.4
37.5
38.9
49.2
56.8
62.5
64.9
55.1
71.6
75.2
74.4
43.2
60.6
61.1
61.8
67.3
63.6
79.7
79
67.2
44
52.8
34.9
41.8
47.2
66.6
33.1
58.6
44.7
30.3
44.9
35.9
56.2
33.2
46.7
50.5
61.8
72
57.9
59.5
60.5
63.6
62.1
47.3
50.4
47.8
49.6
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE
SPECIAL -
Values" then
"COPY" .
Maximum data
points = 58
Par22
Nitrate
13.0720
54.4234
0.2402
47
1.03
79.7 ug/L
82.1 ug/L
Date Data
12/26/2018
1/2/2019
1/8/2019
1/15/2019
1/22/2019
1/29/2019
2/5/2019
2/13/2019
2/19/2019
2/28/2019
3/7/2019
3/12/2019
3/19/2019
3/26/2019
4/2/2019
4/9/2019
4/18/2019
4/23/2019
4/30/2019
5/7/2019
5/14/2019
5/21/2019
5/28/2019
6/4/2019
6/11/2019
6/18/2019
6/25/2019
7/2/2019
7/9/2019
7/16/2019
7/23/2019
7/31/2019
8/6/2019
8/13/2019
8/20/2019
8/27/2019
9/4/2019
9/10/2019
9/17/2019
9/24/2019
10/3/2019
10/8/2019
10/15/2019
10/22/2019
10/29/2019
11/7/2019
11/12/2019
11/19/2019
11/25/2019
12/3/2019
12/10/2019
12/17/2019
12/23/2019
12/31/2019
1/9/2020
1/14/2020
1 /21 /2020
1/28/2020
BDL=1/2DL
9.9
4.3
9.4
7.4
8.7
9.3
7.1
10
4
3.7
3.1
5
8
4.5
6.6
6.4
3.2
7.2
7.1
6
5.5
8.2
6
8.7
7.7
8.9
8.9
4.4
7.8
4.7
4.4
6.1
7.4
3.9
3
3.4
6.1
7.4
10
7.3
8.3
8.9
10
10
10
5.6
6.1
5.1
3.9
8.4
7.7
7.8
11
9.7
15
14
14
14
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points = 58
2.8441
7.4172
0.3835
58
1.00
15.000000 mg/L
15.000000 mg/L
RPA Pittsboro (Autosaved), data
- 8 - 9/10/2020

REASONABLE POTENTIAL ANALYSIS
Par23
TDS
Date Data BDL=1/2DL Results
1 7/10/2019 350 350 Std Dev.
2 Mean
3 C.V. (default)
4 n
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
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
N/A
350.0000
0.6000
1
Mult Factor = 6.20
Max. Value 350.000000 mg/L
Max. Pred Cw ########## mg/L
RPA Pittsboro (Autosaved), data
- 9 - 9/10/2020

CPI Facility
NC0020354
Qw (MGD) = 0.4990
1Q1OS (cfs) = 0.03
7Q1OS (cfs) = 0.03
7Q1OW (cfs) = 0.41
30Q2 (cfs) = 0.40
Avg. Stream Flow, QA (cfs) = 10.00
Receiving Stream: Robeson Creek
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: III
IWC% @ 1Q1OS = 96.26610243
IWC% @ 7Q1OS = 96.26610243
IWC% @ 7Q1OW = 65.35552833
IWC% @ 30Q2 = 65.91248029
IW%C @ QA = 7.179222997
Stream Class: WS-IV,NSW
Outfall 001
Qw = 0.499 M G D
COMBINED HARDNESS (mg/L)
Acute = 65.43 mg/L
Chronic = 65.43 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 67 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
_1
n
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Stapda d AcuteoCi
n # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7Q10s) 340
10 HH/WS(Qavg)
ug/L
ug/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Acute (FW): 353.2
__ _ _ ______________________________________
Chronic (FW) 155.8
Max MDL = 10 _ _ _ _ _ _ _ _
Chronic (HH): 139.3
Max MDL = 10
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
1 0
Note: n < 9
Limited data set
3.10
C.V. (default)
NO DETECTS
Acute: 67.52
____ _ ______ _____
Chronic: 6.75
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Cadmium
NC
1.2204 FW(7Q10s) 7.5000
ug/L
1 0
Note: n < 9
Limited data set
3.100
C.V. (default)
NO DETECTS
Acute: 7.791
____ _ ______ _____
Chronic: 1.268
Max MDL = 1
___ _ _ _ _ _ _ ___ _ _____
Value non -detect at less than PQL 1 ug/L; No
monitoring required.
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
1 0
Note: n < 9
Limited data set
155.0
C.V. (default)
NO DETECTS
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 455.1
Max MDL = 50
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Chromium III
NC
258.8896 FW(7Q10s) 1990.2418
µg/L
0 0
N/A
Acute: 2,067.4
--_ _ ----_ _
--268.9--------------------------------
Chronic:
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
Acute: 16.6
--_ _ ----- _ _
---------------------------------
Chronic: 11.4
Chromium, Total
NC
µg/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Max reported value = 5
Max MDL = 10
Value non -detect at less than PQL 10 ug/L; PQL is
less than Chromium VI allowable discharge
concentration. No monitoring required.
Copper
NC
17.9314 FW(7Q10s) 25.9255
ug/L
47 38
24.62
Acute: 26.93
--_ _ ---- _ _ _
-18 63--------------------------------
Chronic: -RP
1 value(s) > Allowable Cw
shown - apply Monthly Monitoring with Limit
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Acute: 22.9
____ _ _ ___________
Chronic: 5.2
Max MDL = 10
___ _ _ _ _ _ _ _ _ _ _____
Value non -detect at less than PQL 5 ug/L; No
monitoring required.
Page 1 of 2
RPA Chatham Park, rpa
9/10/2020

CPI Facility
NC0020354
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw = 0.499 MGD
Lead
NC
8.5982 FW(7Q10s) 220.6455
ug/L
1 0
Note• n < 9
'
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 229.204
____ _ ______ _____
Chronic: 8.932
Max MDL = 10
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Value non -detect at less than PQL 10 ug/L; No
monitoring required. Permittee shall report to lowest
PQL (2 ug/L) with next PPA.
Nickel
Nickel
NC
NC
84.0250 FW(7Q10s) 756.5109
25.0000 WS(7Q10s)
µg/L
µg/L
58 33
5.1
Acute (FW): 785.9
__ _ _ —_—_ --_—_-------_—_---_—_-------_—_—
Chronic(FW) 87.3
No value > Allowa_bl_e_Cw_ _ _ _
Chronic (WS) 26.0
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
1 0
Note: n < 9
Limited data set
9.3
C.V. (default)
NO DETECTS
Acute: 58.2
Chronic: 5.2
Max MDL = 3
Value non -detect at less than PQL 3 ug/L; No
monitoring required.
Silver
NC
0.06 FW(7Q10s) 1.5509
ug/L
1 0
Note: n < 9
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 1.611
Chronic: 0.062
Max MDL = 10
Value non -detect at less than PQL 10 ug/L; No
monitoring required. Permittee shall report to lowest
PQL (1 ug/L) with next PPA.
Zinc
NC
286.3746 FW(7Q10s) 284.0511
ug/L
47 47
82.1
Acute: 295.1
Chronic: 297.5
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Nitrate
NC
10 WS(7Q10s)
mg/L
58 58
15.00000
Acute: NO WQS
_—_ _ --- _ _ _ _
Chronic: 10.38787 ------------------------------
-RP
5 value(s) > Allowable Cw
shown - apply Monthly Monitoring with Limit
TDS
NC
500 WS(7Q10s)
mg/L
1 1
Note: n < 9
Limited data set
2,170.00000
C.V. (default)
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 519.39363
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
On sample; value reported at 350 mg/L; reported
value > 50% of allowable Cw. BPJ - apply quarterly
monitoring
Page 2 of 2
RPA Chatham Park, rpa
9/10/2020

Pittsboro WWTP
NC0020354
Freshwater RPA -
Qw (MGD) = 1.9710
1Q10S (cfs) = 58.74
7Q1OS (cfs) = 71.80
7Q1OW (cfs) = 125.60
30Q2 (cfs) = 159.00
Avg. Stream Flow, QA (cfs) = 1240.00
Receiving Stream: Haw River
95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: IV
IWC% @ 1Q10S = 4.943842589
IWC% @ 7Q1OS = 4.081287769
IWC% @ 7Q1OW = 2.374605583
IWC% @ 30Q2 = 1.885192717
IW%C @ QA = 0.245769485
Stream Class: WS-IV,NSW
Outfall 001
Qw= 1.971 MGD
COMBINED HARDNESS (mg/L)
Acute = 27.08 mg/L
Chronic = 26.71 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 67 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
_1
n
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Stapda d AcuteoCi
n # Det. Max Pred Cw Allowable Cw
Acute (FW): 6,877.2
Arsenic
C
150 FW(7Q10s) 340
ug/L
__ _ _ ___ _ _ _______________________________
1 0
31.0
Chronic (FW) 3,675.3
C.V. (default)
Max MDL = 10 _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Arsenic
C
10 HH/WS(Qavg)
ug/L
Note: n < 9
NO DETECTS
Chronic (HH): 4,068.9
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
Max MDL = 10
Monitoring required
Acute: 1,314.77
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
1 0
3.10
_ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Note: n < 9
C.V. (default)
Chronic: 159.26
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
NO DETECTS
Max MDL = 1
Monitoring required
Acute: 70.257
Cadmium
NC
0.6202 FW(7Q10s) 3.4734
ug/L
1 0
3.100
_ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Note: n < 9
C.V. (default)
Chronic: 15.197
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
NO DETECTS
Max MDL = 1
Monitoring required
Acute: NO WQS
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
1 0
155.0
_ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Note: n < 9
C.V. (default)
Chronic: 15,913.5
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
NO DETECTS
Max MDL = 50
Monitoring required
Acute: 19,543.5
Chromium III
NC
124.3039 FW(7Q10s) 966.2002
µg/L
0 0
N/A
--_ _ ---_ _
---------------------------------
Chronic: 3,045.7
Acute: 323.6
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
--_ _ ----_ _
--269.5--------------------------------
Chronic:
Chromium, Total
NC
µg/L
1 0
Note: n < 9
31.0
C.V. (default)
Max reported value = 5
Value non -detect at less than PQL 10 ug/L; PQL is
less than Chromium VI allowable discharge
concentration. No monitoring required.
Limited data set
NO DETECTS
Max MDL = 10
Acute: 228.36
Copper
NC
8.3401 FW(7Q10s) 11.2896
ug/L
47 38
24.62
_ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 204.35
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 445.0
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
1 0
31.0
____ _ ______ _____
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Note: n < 9
C.V. (default)
Chronic: 122.5
No RP, Predicted Max < 50% of Allowable Cw - No
Limited data set
NO DETECTS
Max MDL = 10
Monitoring required
Page 1 of 2
RPA Pittsboro Haw River, rpa
9/10/2020

Pittsboro WWTP
NC0020354
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw= 1.971 MGD
Lead
NC
3.1696 FW(7Q10s) 82.5789
ug/L
1 0
Note: n < 9
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 1,670.338
Chronic: 77.662
Max MDL = 10
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Nickel
Nickel
NC
NC
39.3799 FW(7Q10s) 358.6164
25.0000 WS(7Q10s)
µg/L
µg/L
58 33
5.1
Acute (FW): 7,253.8
__ _ _ _____________________________________
Chronic (FW): 964.9
No value > Allowa_bl_e_Cw_ _ _ _
Chronic (WS): 612.6
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ --
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
1 0
Note: n < 9
Limited data set
9.3
C.V. (default)
NO DETECTS
Acute: 1,132.7
Chronic: 122.5
Max MDL = 3
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Silver
NC
0.06 FW(7Q10s) 0.3400
ug/L
1 0
Note: n < 9
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 6.877
Chronic: 1.470
Max MDL = 10
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Zinc
NC
134.0586 FW(7Q10s) 134.4972
ug/L
47 47
82.1
Acute: 2,720.5
Chronic: 3,284.7
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Nitrate
NC
10 WS(7Q10s)
mg/L
58 58
15.00000
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 245.02070
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
TDS
NC
500 WS(7Q10s)
mg/L
1 1
Note: n < 9
Limited data set
2,170.00000
C.V. (default)
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 12251 03517
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Page 2 of 2
RPA Pittsboro Haw River, rpa
9/10/2020

Pittsboro WWTP
NC0020354
Qw (MGD) = 0.7500
1Q1OS (cfs) = 0.03
7Q1OS (cfs) = 0.03
7Q1OW (cfs) = 0.41
30Q2 (cfs) = 0.40
Avg. Stream Flow, QA (cfs) = 10.00
Receiving Stream: Robeson Creek
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
WWTP/WTP Class: IV
IWC% @ 1Q1OS = 97.48427673
IWC% @ 7Q1OS = 97.48427673
IWC% @ 7Q1OW = 73.92686804
IWC% @ 30Q2 = 74.4
IW%C @ QA = 10.41433371
Stream Class: WS-IV,NSW
Outfall 001
Qw = 0.75 MGD
COMBINED HARDNESS (mg/L)
Acute = 65.94 mg/L
Chronic = 65.94 mg/L
YOU HAVE DESIGNATED THIS RECEIVING
STREAM AS WATER SUPPLY
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 67 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
_1
n
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Stapda d AcuteoCi
n # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7Q10s) 340
10 HH/WS(Qavg)
ug/L
ug/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Acute (FW): 348.8
__ _ _ ______________________________________
Chronic (FW) 153.9
Max MDL = 10 _ _ _ _ _ _ _ _
Chronic (HH): 96.0
Max MDL = 10
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
1 0
Note: n < 9
Limited data set
3.10
C.V. (default)
NO DETECTS
Acute: 66.68
____ _ ______ _____
Chronic: 6.67
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Cadmium
NC
1.2276 FW(7Q10s) 7.5511
ug/L
1 0
Note: n < 9
Limited data set
3.100
C.V. (default)
NO DETECTS
Acute: 7.746
____ _ ______ _____
Chronic: 1.259
Max MDL = 1
___ _ _ _ _ _ _ ___ _ _____
Value non -detect at less than PQL 1 ug/L; No
monitoring required.
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
1 0
Note: n < 9
Limited data set
155.0
C.V. (default)
NO DETECTS
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 403.2
Max MDL = 50
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Chromium III
NC
260.5463 FW(7Q10s) 2002.9784
µg/L
0 0
N/A
Acute: 2,054.7
--_ _ ----_ _
--267.3--------------------------------
Chronic:
Chromium VI
NC
11 FW(7Q10s) 16
µg/L
0 0
N/A
Acute: 16.4
--_ _ ----- _ _
---------------------------------
Chronic: 11.3
Chromium, Total
NC
µg/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Max reported value = 5
Max MDL = 10
Value non -detect at less than PQL 10 ug/L; PQL is
less than Chromium VI allowable discharge
concentration. No monitoring required.
Copper
NC
18.0511 FW(7Q10s) 26.1164
ug/L
47 38
24.62
Acute: 26.79
--_ _ ---- _ _ _
-18 52--------------------------------
Chronic: -RP
1 value(s) > Allowable Cw
shown - apply Monthly Monitoring with Limit
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
1 0
Note: n < 9
Limited data set
31.0
C.V. (default)
NO DETECTS
Acute: 22.6
____ _ ____________
Chronic: 5.1
Max MDL = 10
___ _ _ _ _ _ _ _ _ _ _____
Value non -detect at less than PQL 5 ug/L; No
monitoring required.
Page 1 of 2
RPA Pittsboro (Autosaved), rpa
9/10/2020

Pittsboro WWTP
NC0020354
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw = 0.75 MGD
Lead
NC
8.6724 FW(7Q10s) 222.5476
ug/L
1 0
Note: n < 9
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 228.291
____ _ ______ _____
Chronic: 8.896
Max MDL = 10
___ _ _ _ _ _ _ _ _ _ ____
Value non -detect at less than PQL 10 ug/L; No
monitoring required. Permittee shall report to lowest
PQL (2 ug/L) with next PPA.
Nickel
Nickel
NC
NC
84.5805 FW(7Q10s) 761.5124
25.0000 WS(7Q10s)
µg/L
µg/L
58 33
5.1
Acute (FW): 781.2
__ _ _ —_—_ --_
Chronic (FW) 86 8
No value > Allowa_bl_e_Cw_ _ _ _
Chronic (WS) 25.6
No value > Allowable Cw
—_-------_—_---_—_-------_—_
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
1 0
Note: n < 9
Limited data set
9.3
C.V. (default)
NO DETECTS
Acute: 57.4
Chronic: 51
Max MDL = 3
Value non -detect at less than PQL 3 ug/L; No
monitoring required.
Silver
NC
0.06 FW(7Q10s) 1.5718
ug/L
1 0
Note: n < 9
Limited data set
31.000
C.V. (default)
NO DETECTS
Acute: 1.612
Chronic: 0.062
Max MDL = 10
Value non -detect at less than PQL 10 ug/L; No
monitoring required. Permittee shall report to lowest
PQL (1 ug/L) with next PPA.
Zinc
NC
288.2708 FW(7Q10s) 285.9319
ug/L
47 47
82.1
Acute: 293.3
Chronic: 295.7
No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Nitrate
NC
10 WS(7Q10s)
mg/L
58 58
15.00000
Acute: NO WQS
--_ _ --- _ _ _ _
Chronic: 10.25806 -----------------------------
-RP
5 value(s) > Allowable Cw
shown - apply Monthly Monitoring with Limit
TDS
NC
500 WS(7Q10s)
mg/L
1 1
Note: n < 9
Limited data set
2,170.00000
C.V. (default)
Acute: NO WQS
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 512.90323
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
On sample; value reported at 350 mg/L; reported
value > 50% of allowable Cw. BPJ - apply quarterly
monitoring
Page 2 of 2
RPA Pittsboro (Autosaved), rpa
9/10/2020

NH3/TRC WLA Calculations
Facility: CPI Facility
PermitNo. NC0020354
Prepared By: Nick Coco
Robeson Creek
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
0.499
0.03
0.41
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/I)
IWC (%)
Allowable Conc. (ug/I)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
0.03
0.499
0.77345
17.0
0
96.27
18
Limit used
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
0.03
0.499
0.77345
1.0
0.22
96.27
1.0
Limit used
w7Q10 (CFS) 0.41
200/100mI DESIGN FLOW (MGD) 0.499
DESIGN FLOW (CFS) 0.77345
STREAM STD (MG/L) 1.8
1.04 Upstream Bkgd (mg/I) 0.22
IWC (%) 65.36
Allowable Conc. (mg/I) 2.6
Ammonia limits year-round; summer limit used
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)

Permit No. NC0020354
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 April6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, 14/1
(Dissolved)
Acute SW, 14/1
(Dissolved)
Chronic SW, µg/1
(Dissolved)
Arsenic
340
150
69
36
Beryllium
65
6.5
---
---
Cadmium
Calculation
Calculation
40
8.8
Chromium III
Calculation
Calculation
---
---
Chromium VI
16
11
1100
50
Copper
Calculation
Calculation
4.8
3.1
Lead
Calculation
Calculation
210
8.1
Nickel
Calculation
Calculation
74
8.2
Silver
Calculation
0.06
1.9
0.1
Zinc
Calculation
Calculation
90
81
Table 1 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life
standards for Mercury and selenium are still expressed as Total Recoverable Metals due to
bioaccumulative concerns (as are all human health standards for all metals). It is still necessary
to evaluate total recoverable aquatic life and human health standards listed in 15A NCAC
2B.0200 (e.g., arsenic at 10 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.1366724ln hardness](0.041838)} • e^{0.9151 [ln 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]-4.4451 }
Chromium III, Acute
WER*0.316 • e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER*{1.462034ln hardness](0.145712)} • e^{1.273[In hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[In hardness]-4.705}
Nickel, Acute
WER*0.998 • e^{0.8460[ln hardness]+2.255}
Nickel, Chronic
WER*0.997 • e^{0.8460[ln hardness]+0.0584}
Page 1 of 4

Permit No. NC0020354
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^{0.8473[ln hardness]+0.884}
General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness -dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness -based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case -by -case for each discharge.
Metals limits must be expressed as `total recoverable' metals in accordance with 40 CFR 122.45(c). The
discharge -specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case -specific translators developed in accordance with
established methodology.
RPA Permitting Guidance/WQBELs for Hardness -Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low -flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness -dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site -specific data is preferred
• Permitted flow
• Receiving stream classification
2. In order to establish the numeric standard for each hardness -dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.
The permit writer reviews DMR's, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.
If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.
If the use of a default hardness value results in a hardness -dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site -specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.
Page 2 of 4

Permit No. NC0020354
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 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
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(1
+1 [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 = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0020354
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
67
2019 PPA
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25
Default Value used; No upstream
hardness reported
7Q10 summer (cfs)
0.03
NPDES Files
1 Q 10 (cfs)
0.03
Calculated in RPA
Permitted Flow (MGD)
0.75
NPDES Files
Date: 9/10/2020
Permit Writer: Nick Coco
Page 4 of 4

Pittsboro WWTP/NC0020354
Mercury Data Statistics (Method 1631E)
2019
# of Samples
1
Annual Average, ng/L
1.0
Maximum Value, ng/L
0.98
TBEL, ng/L
47
WQBEL, ng/L
12.3

9/10/20 WQS = 12 ng/L
Facility Name Pittsboro WWTP/NC0020354
/Permit No. :
MERCURY WQBEL/TBEL EVALUATION V:2013-6
Total Mercury 1631E PQL = 0.5 ng/L 7Q10s =
Date Modifier Data Entry Value Permitted Flow =
No Limit Required
No MMP Required
0.030
0.750
cfs
WQBEL = 12.31 ng/L
47 ng/L
7/10/19 0.976 0.976 1.0 ng/L - Annual Average for 2019

NC0020354 Pittsboro WWTP 2/24/2021
BOD monthly removal rate
Month RR (%) Month RR (%)
May-16
June-16
July-16
August-16
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
99.30
99.56
99.23
99.20
99.16
99.14
99.42
99.24
98.69
99.20
99.26
97.08
99.30
99.29
99.32
99.36
99.39
99.40
99.26
98.99
99.02
98.80
99.08
98.97
99.17
99.26
99.34
99.17
98.59
99.09
November-18
December-18
January-19
February-19
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
Overall BOD removal rate
97.49
96.89
98.70
98.28
98.48
94.50
98.97
99.12
99.30
99.24
99.26
99.27
99.24
99.09
98.68
97.72
98.92
98.86
TSS monthly removal rate
Month RR (%) Month RR (%)
May-16
June-16
July-16
August-16
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
98.84
98.81
99.12
98.99
99.04
98.62
99.17
99.16
97.69
98.80
98.86
94.37
99.07
98.99
99.17
99.22
99.18
99.14
99.08
99.02
98.28
98.44
98.82
98.44
98.87
99.03
99.07
99.01
96.58
98.86
November-18
December-18
January-19
February-19
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
Overall TSSD removal rate
95.98
95.34
98.19
96.97
97.83
90.77
98.73
98.82
99.01
99.00
99.03
98.92
98.82
98.79
98.47
97.67
98.59
98.31

NH3/TRC WLA Calculations
Facility: Pittsboro WWTP
PermitNo. NC0020354
Prepared By: Nick Coco
Robeson Creek
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
0.75
0.03
0.41
Total Residual Chlorine (TRC) Ammonia (Summer)
Daily Maximum Limit (ug/I) Monthly Average Limit (mg NH3-N/I)
s7Q10 (CFS) 0.03 s7Q10 (CFS) 0.03
DESIGN FLOW (MGD) 0.75 DESIGN FLOW (MGD) 0.75
DESIGN FLOW (CFS) 1.1625 DESIGN FLOW (CFS) 1.1625
STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0
Upstream Bkgd (ug/I) 0 Upstream Bkgd (mg/I) 0.22
IWC (%) 97.48 IWC (%) 97.48
Allowable Conc. (ug/I) 17 Allowable Conc. (mg/I) 1.0
Same as in current permit. Limit used See Fact Sheet Notes
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100mI DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
1.03 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
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
0.41
0.75
1.1625
1.8
0.22
73.93
2.4
Ammonia limits year-round
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Interim CPWRC Sampling Locations and Combined Sampling Location (01/06/2021)
EF
EF
N/F
TOWN OF PITTSBORO
DB 549 PG 259
PB 89 PG 37
PIN 9741-16-9469
AKPAR 65796
EX. 12" PVC EFFLUENT LINE
(BY OTHERS)
Fp
From CPWRC
EF
EF
wv — RC
--RCW(R)------
— RCW(R)— — — — — RCW(R10" RCW
;CJ
Fp \ /..
EX. GRA VEL
(d)SS — — —
t--
J
L_ J
L—
\
J
Existing sample location for
Turbidity for TOP
0
— — From Pittsboro
EOP
EX. ASPHALT
PA VEMEN T
FP
■
■
■
FLOOD PLAIN AND FLOODWAY LINES PER
MAPS 3710975100J AND 3710974100J
EFFECTIVE 02/02/07 (DIGITAL DOWNLOAD
FROM WWW.FRIS.NC. GOV)
FP
Proposed isolation valve (interim open)
X X X
EX. FENCE
ET LINE —
EF _
wv
NORTH EFFLUENT — — �(R)
EF — — — RCW(R)— — — — — RCW(R)— — \
w
fi
■
n
EX. GRA VEL
Proposed isolation valve (interim closed) 1
EX. CHANNEL
EF
— — RCW(R)— — —
Chatham Park Water Recovery Center (CPWRC)
Pittsboro WWTP
\ EF
EF
— RCW(R)
CONC. PAD—\
190 FLOODPLAIN
ZONE AE
RECLAIMED BUILD/NG
'Existing TOP Composite sample
location for effluent.
CHL OR/NA TION
BUILDING
POTABLE WATER
HOSE
'REV.NO.
DESCRIPTION
DATE
In,
C
S
MPOSI TE
MPLER
7\-51>
CONCRETE PAD
EFFLUENT TUBING
CONDU/T
EX. GRA VEL
EOP
EX. ASPHAL T
PA VEMEN T
Pittsboro UV channe
EX. UV DISINFECTANT
CHANNEL
1
N/F
TOWN OF PITTSBORO
DB 284 PG 207
PB 88 PG 46
PIN 9741-95-0000
AKPAR 62411
METAL STAIRS
Existing TOP grab sample location
for Fecal, pH, & Conductivity
CONC. TANK
LUNt X
4MCKIM&CREED
Venture IV Building, Suite 500
1730 Varsity Drive
Raleigh, North Carolina 27606
Phone: [phone], Fax: [phone]
5'
0
5'
SCALE: 1 "=5' (Horiz.)
• t
ms
CHATHAM PARK
Many Choices. One Place.
■
■
■
■
:N
■ \
■
■
■
■
■
■
■
■
Lroposed Manhole: Interim
rab sample location for
PWRC Fecal Coliform/pH
EX.
EFFLUENT
PIPE
EX. CASCADE
AERATOR
N,
N
Existing grab sample location
for CPWRC & TOP combined
effluent - D.O.
:■
■
■
7 1-I T
IIIII
Proposed TOP grab sample for
temperature
10'
CHATHAM PARK WATER RECOVERY
CENTER AND TOWN OF PITTSBORO WWTP
SAMPLING LOCATIONS
To Roberson
Creek
X
MCE PROJ. #
07234-0002
SCALE
HORIZONTAL:
1 "=5'
VERTICAL:
NIA
M1
DRAWING NUMBER
A
REVISION
REVISIONS
J
NC License# F-1222
www.mckimcreed.com
STATUS:
S:\07234\0002\80B-DRAWINGS\MECHANICAL\CP WRC TOP WWTP SAMPLING LOCATIONS.DWG 10/09/2020 11:37:06 KENNETH CRAWFORD

Permanent CPWRC Sampling Locations (01/06/2021)
EF
Fp
N/F
TOWN OF PITTSBORO
DB 549 PG 259
PB 89 PG 37
PIN 9741-16-9469
AKPAR 65796
EF
EX. 12" PVC EFFLUENT LINE
(BY OTHERS)
EF
Fp
wv — RC
--RCW(R)------
RCW(R)--- — — — — RCW(R)— — —
- ;CJ
EX. GRA VEL
(d)SS — — —
Existing sample location for
Turbidity for CPWRC
Abandon flow from Pittsboro
•
L_ J
L
J
EOP
EX. ASPHALT
PA VEMEN T
II
POTABLE WATER
HOSE
'REV.NO.
DESCRIPTION
DATE
FP
wv
■
■
■
■
FLOOD PLAIN AND FLOODWAY LINES PER
MAPS 3710975100J AND 3710974100J
EFFECTIVE 02/02/07 (DIGITAL DOWNLOAD
FROM WWW.FRIS.NC. GOV)
Proposed isolation valve (permanent
Ic1osed)
FP
X
EX. FENCE
EF
EFFLUENT LINE RCW(R)— — —
EF NORTH---(R)-----
EF — — — — RCW(R)— — — — — RCW(R)— — \
RCW(R)—
EX. GRA VEL
Proposed isolation valve (permanent
open)
Pittsboro UV channe
EX. UV DISINFECTANT
CHANNEL
1
EX. CHANNEL
N/F
TOWN OF PITTSBORO
DB 284 PG 207
PB 88 PG 46
PIN 9741-95-0000
AKPAR 62411
METAL STAIRS
CONC. TANK
CHL OR/NA TION
BUILDING
Chatham Park Water Recovery Center (CPWRC)
Pittsboro WWTP
04_,\
EF�
— RCW(R)
CONC. PAD —\
1
\
CONC. PAD
EX.
COMPOSITE
SAMPLER
Existing grab sample location for
' Fecal Coliform for CPWRC
4MCKIM&CREED
Venture IV Building, Suite 500
1730 Varsity Drive
Raleigh, North Carolina 27606
Phone: [phone], Fax: [phone]
EF
190 FLOODPLAIN
ZONE AE
RECLAIMED BUILD/NG
/ /.
/
CONCRETE PAD
EFFLUENT TUBING
CONDUIT
EOP
EX. ASPHAL T
PA VEMEN T
5'
0
5'
SCALE: 1 "=5' (Horiz.)
CHATHAM PARK
Many Choices. One Place.
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
\■
■
■
\
•
■
■
■
■
■
■
10'
EX.
EFFLUENT
PIPE
k
EX. CASCADE
AERATOR
■
■
■
■
■
N
Grab sample location for
CPWRC effluent - D.O.
CHATHAM PARK WATER RECOVERY
CENTER AND TOWN OF PITTSBORO WWTP
SAMPLING LOCATIONS
MCE PROJ. #
07234-0002
SCALE
HORIZONTAL:
1 "=5'
VERTICAL:
NIA
M1
DRAWING NUMBER
A
REVISION
REVISIONS
J
NC License# F-1222
www.mckimcreed.com
STATUS:
S:\07234\0002\80B—DRAWINGS\MECHANICAL\CP WRC TOP WWTP SAMPLING LOCATIONS.DWG 10/09/2020 11:37:06 KENNETH CRAWFORD

Whole Effluent Toxicity Testing and Self Monitoring Summary
Pine Knoll Shores WTP NC0082520/001 County: Carteret Region: WIRO Basin: WOK03 Feb May Aug Nov
Mysd24PF Begin: 8/1/2017 Ac P/F Lim: 90% Mysi NonComp: 7Q10: PF: 1.2 IWC: Freq: Q
SOC JOC:
J F M A M J J A 5 0 N
2016 - H - - H - - H - - H
2017 - H - - H - - H - - H
2018 - H - - H - - H - - H
2019 - H - - H - - H - - H
Pine Street WTP NC0072699/001 County: Carteret Region: WIRO Basin: WOK03 Mar Jun Sep Dec
Mysd24PF Begin: 3/1/2018 Ac P/F Monit: 90% NonComp: 7Q10: PF: na IWC: Freq: Q
SOC_JOC:
J F M A M J J A S 0 N D
2016 - - Pass - - Pass - - Pass - - Pass
2017 - - Pass - - Pass - - Pass - - Pass
2018 - - Pass - - Fail - - Fail - - Fail
2019 - - Fail - - Fail - - Fail - -
Pittsboro WTP NC0080896/001 County: Chatham Region: RRO Basin: CPF04 Jan Apr Jul Oct
Ceri7dPF Begin: 4/1/2017 Chr Monit: 0.27% NonComp: 7Q10: PF: IWC: Freq: Q
SOC JOC:
J F M A M J J A 5 0 N D
2016 Pass - - Pass - - Pass - - Pass -
2017 Pass - - Pass - - Pass - - Pass -
2018 Pass - - Pass - - Pass - - Pass -
2019 Pass - - Pass - - Pass - - Pass -
Pittsboro WWTP
Ceri7dPF
NC0020354/001
Begin: 8/15/2014 chr lim: 90%
County: Chatham Region: RRO
NonComp: Single 7Q10: 0.000
Basin: CPF04 Mar Jun Sep Dec
PF: 0.75 IWC: 100 Freq: Q
SOC_JOC:
J F M A M J J A 5 0 N D
2016 - - Pass - - Pass - - Pass - - Pass
2016 - - H - - - - H - - H
2017 - - Pass - - Pass - - Pass - - Pass
2017 - - H - - - - H - -
2018 - - H - - H - - H - - H
2018 - - Pass - - Pass - - Pass - - Pass
2019 - - H - - H - - H - -
2019 - - Pass - - Pass - - Pass - -
Plantation Pipeline Co. (001) NC0051161/001 County: Guilford Region: WSRO Basin: CPF08
Fthd24PF Begin: 1/1/2017 Acu Fthd 24hr PF Lim NonComp: 7Q10: 0.0 PF: IWC: NA Freq: A
SOC_JOC:
J F M A M J J
2016 H - - - - - -
2017 H - - - - -
2018 H - - - - Pass
2019 Pass - - - - -
A
5 0 N D
Legend: P= Fathead minnow (Pimnhales nromelas). H=No Flow (facility is active). s = Snlit test between Certified Labs
Page 74 of 102

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 01/22/20 Page: 1 of 1
Permit: NC0020354 MRs Between 1 - 2016 and 1 - 2020
Facility Name:
Major Minor: %
Param Name o/o
Region:
County:
Violation Category:Limit Violation
Subbasin:%
Program Category:
Violation Action:
PERMIT: NC0020354
FACILITY: Town of Pittsboro - Pittsboro WWTP
COUNTY: Chatham
REGION: Raleigh
Limit Violation
MONITORING
REPORT OUTFALL
LOCATION
PARAMETER
VIOLATION
UNIT OF
DATE FREQUENCY MEASURE
LIMIT
CALCULATED
VALUE
Over
VIOLATION TYPE
VIOLATION ACTION
04_2017 001
04-2017 001
04_2019 001
04-2019 001
11-2018 001
12_2018 001
12-2018 001
04-2019 001
04_2019 001
09-2018 001
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
BOD, 5-Day (20 Deg. C) -
Concentration
BOD, 5-Day (20 Deg. C) -
Concentration
BOD, 5-Day (20 Deg. C) -
Concentration
BOD, 5-Day (20 Deg. C) -
Concentration
Coliform, Fecal MF, MFC
Broth, 44.5 C
Flow, in conduit or thru
treatment plant
Nickel, Total (as Ni)
Nitrogen, Ammonia Total (as
N) - Concentration
Nitrogen, Ammonia Total (as
N) - Concentration
Oxygen, Dissolved (DO)
04/29/17
04/30/17
04/13/19
04/30/19
11/17/18
12/31/18
12/29/18
04/13/19
04/30/19
09/17/18
3 X week
3 X week
3 X week
3 X week
3 X week
Continuous
Weekly
3 X week
3 X week
3 X week
mg/I
mg/I
mg/I
mg/I
#/100m1
mgd
ug/1
mg/1
mg/1
mg/1
7.5
5
7.5
5
21
5.25
25.57
8.35
180
5
240.9
67.1
Weekly Average
Exceeded
Monthly Average
Exceeded
Weekly Average
Exceeded
Monthly Average
Exceeded
400 678.24 69.6 Weekly Geometric Mean
Exceeded
0.75
25
6
2
6
0.832
63.5
7.7
2.5
11.0
154
28.4
25.1
Monthly Average
Exceeded
Weekly Average
Exceeded
Weekly Average
Exceeded
Monthly Average
Exceeded
5.74 4.3 Daily Minimum Not
Reached
Proceed to NOV
Proceed to NOV
Proceed to
Enforcement Case
Proceed to
Enforcement Case
Proceed to NOV
Proceed to
Enforcement Case
Proceed to
Enforcement Case
Proceed to
Enforcement Case
Proceed to
Enforcement Case
Proceed to NOD

North Carolina Department of Environmental Quality
Water Pollution Control Systems Operator Certification Commission
Roy Cooper W. Corey Basinger Dionne Delli-Gatti
Governor Chairman Secretary
February 22, 2021
SENT VIA E- MAIL TO:
Mr. Bryan Gruesbeck
Town Manager
Town of Pittsboro
P.O. Box 759
Pittsboro, North Carolina 27312-0759
SUBJECT: RE-CLASSIFICATION OF WATER POLLUTION CONTROL COLLECTION SYSTEM TO WW-IV
Town of Pittsboro WWTP
Permit Number: NC0020354
Chatham County
Dear Mr. Gruesbeck:
In accordance with North Carolina General Statute § 90A-37, the Water Pollution Control System Operators
Certification Commission is required to classify all water pollution control systems.
Upon a review of the subject permit, the Water Pollution Control System Operators Certification
Commission has determined that the subject facility is classified:
Grade IV Biological Water Pollution Control System (WW-IV)
Effective: March 1, 2021
[15A NCAC 08G .0302(c)&(f)]
This reclassification does not affect the certified operators currently designated as ORC and backup ORC for
this facility.
Thank you for your attention to this, if you have any questions concerning this reclassification, please
contact me at 919-707-9038, or via email at [e-mail].
Sincerely,
NC Operators Certification Program
ec: Nick Coco, DWR, NPDES Permitting
DWR, Raleigh Regional Operations
Holly Coleman, Town of Pittsboro
John Poteat, Town of Pittsboro
Jamie McLaurin, ORC, Town of Pittsboro
1618 Mail Service Center I Raleigh, North Carolina 27699-1618
919 807 6353 I Fax [phone] I http://deq.nc.gov/about/divisions/water-resources/operator-certification

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 ICI J 2 IS I 3 I NC0020354 111 121 20/07/22 117
Type
18 [
I I I I I
Inspector Fac Type
19 G I 201
211111 I I I I I I II I I I I I I I I I I I I I I I I I
I II
I I I I I 166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671I 70I3 I 711I 72 I N I 73I I 174
L� 1 751
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Pittsboro WWTP
Small St Extension
Pittsboro NC 27312
Entry Time/Date
09:30AM 20/07/22
Permit Effective Date
14/09/01
Exit Time/Date
01:OOPM 20/07/22
Permit Expiration Date
16/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Jamie Lee McLaurin/ORC/919-542-2444/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Holly Coleman,40 E Chatham St Pittsboro NC 27312//919-542-8215/9195458449
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling Dispos 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
Cheng Zhang DWR/RRO WQ/919-791-4200/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/mo/day
31 NC0020354 111 121 20/07/22
117
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
1. The facility is currently permitted to discharge up to 0.75 MGD into Robeson Creek, a Class WS-IV
NSW waters in the Cape Fear River Basin. Current permit expired on April 30, 2016. The Town
submitted permit renewal application on January 26, 2016, which was received by the Division on
February 5, 2016.
2. The plant is classified as a WW-3 wastewater facility. Mr. Jamie McLaurin is designated as the
ORC; Mr. Freddy Peele is designated as the backup ORC. Daily operation log books are detailed and
are kept onsite going back at least three years.
3. Field lab parameter (Certificate No. 5670) calibration and analysis records were reviewed during
the inspection. The inspector reminded Mr. McLaurin of new rules that require field labs to have
Standard Operating Procedures (SOPs) and develop and implement a documented training program.
March 2020 DMR data was compared to bench sheets and lab reports; no data transcription errors
were noted. Lab results, chain -of -custody forms, and DMRs were complete and organized.
4. The permit lists the following units; all were observed during the inspection:
• Influent pump station with two pumps (with a diesel pump serving as bypass pump), both pumps
were operable;
• One mechanical bar screen in operation, the manual bar screen is only used during periods with
high flow;
• Two equalization basin was used to achieve steady flow (0.35 MGD) through the plant under
normal conditions;
• Two secondary clarifiers, sludge is returned to aeration basins via ail lifting;
• Two aeration basins with fine bubble diffusers;
• Three up flow tertiary filters;
• Two banks of UV disinfection units (one in use);
• One waste activated sludge pump station with two pumps;
• Two aerobic digesters hold thickened wasted sludge. At the time of inspection, Synagro was
hauling sludge, one digester was empty, the other was being emptied;
• One rotary drum thickener is used to dewater wasted sludge before it is stored in the two aerobic
digesters (not in use at the time of inspection);
• The on -site generator is tested every week, fuel level is checked and recorded every day.
5. The right of way to the outfall was properly maintained. The effluent appeared clear and free of
solids. There were no visible detrimental impacts to the receiving stream.
This facility was found to be compliant with NPDES permit conditions as a result of this inspection.
Page# 2

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: the facility analyzes the following process control parameters: MLSS, MCRT, SVI, FT, F/M,
alkalinity, settleable solids, pH, DO, sludge judge, Secchi disk depths, ammonia, and total
phosphorous (influent and effluent)
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment: Treatment units not listed: influent pump station and eciaulization basins
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?
Comment: Manual bar screen is only used in high flow situations.
Yes No NA NE
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Yes No NA NE
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•
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Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
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? • ❑ ❑ ❑
Page# 3

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro wwTP
Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Is the DO level acceptable?(1.0 to 3.0 mg/I)
• ❑ ❑ ❑
Comment: DO levels in both basins vary from 1 to 3 mg/L depending on how many blowers (four
blowers) are turned on
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'/4 of the sidewall depth)
Yes No NA NE
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Comment: Sludge blankets at time of inspection, 6 feet (clarifier #1), 3 feet (clarifier #2).
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Up flow
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: Sand media are backwashed constantly
Nutrient Removal Yes No NA NE
# Is total nitrogen removal required? ❑ • ❑ ❑
# Is total phosphorous removal required? • ❑ ❑ ❑
Type Chemical
# Is chemical feed required to sustain process? • ❑ ❑ ❑
Page# 4

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Nutrient Removal
Is nutrient removal process operating properly?
Comment: Sodium aluminate is fed into the front portion of each basin
Disinfection - UV
Are extra UV bulbs available on site?
Are UV bulbs clean?
Is UV intensity adequate?
Is transmittance at or above designed level?
Is there a backup system on site?
Is effluent clear and free of solids?
Yes No NA NE
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Yes No NA NE
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Comment: UV system with two banks of bulbs, one bank was on line at time of inspection, both banks
will be turned on durinq hiqh flow periods. A contractor is responsible for UV system
maintenance. Bulbs are cleaned automatically.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? • ❑ ❑ ❑
# Is the facility using a contract lab? • ❑ ❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ • ❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ • ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ • ❑
Comment: The facility only analyzes field parameters, all other parameters are analyzed by Enco
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Sludqe is returned via air liftinq (eletric pumps available as backup). WAS pump station with
two pumps, one for each clarifier
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Yes No NA NE
• ❑ ❑ ❑
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Page# 5

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Standby Power
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?
Comment: The generator is tested every week (not under load)
Influent Sampling
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is sampling performed according to the permit?
Comment: Time paced composite samples collected at influent (250 ml/20 minutes)
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: Time paced composite samples collected at influent (250 ml/20 minutes)
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Last calibrated on March 2, 2020
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page# 6

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Last calibrated on March 2, 2020
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
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?
Facility has copy of previous year's Annual Report on file for review?
Yes
•
•
•
•
No NA NE
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Yes No NA NE
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Yes No NA NE
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•
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Page# 7

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Comment:
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?
Yes No NA NE
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Comment: Synagro was hauling sludge from the digesters at the time of inspection, one digester was
empty, the other was being emptied.
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Yes No NA NE
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Comment: Wasted sludge is thickened by the Parkson rotary drum thickener and then sent to the two
aerobic digesters.
Comment: Wasted sludge is thickenedThe rotary drum thickener
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Yes No NA NE
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Comment: Polymer feed for sludge thickener; sodium aluminate feed for total phosphorous removal
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Yes No NA NE
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Page# 8

Permit: NC0020354
Inspection Date: 07/22/2020
Owner - Facility: Pittsboro VVVVTP
Inspection Type: Compliance Evaluation
Equalization Basins
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
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Comment: Two EQ basins, 0.3 million -gallon each. One floating aerator in each basin. EQ pump station
with two pumps right downstream influent Parshall flume. Under normal condition, flow to
aeration basins is set to 0.35 MGD, excessive flow is diverted to EQ basins, and returned to
influent when influent flow is lower than 0.35 MGD
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type, anc
sampling location)?
Yes No NA NE
• ❑ • ❑
Comment: Member of Upper Cape Fear River Basin Association. Upstream/downstream sampling
conducted by the Association
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADAtelemetry available and operational?
Is audible and visual alarm available and operational?
Comment: Two influent pumps, with one diesel powered bypass pump
Yes No NA NE
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Page# 9

FINDING OF NO SIGNIFICANT IMPACT
AND ENVIRONMENTAL ASSESSMENT
TOWN OF PITTSBORO
WASTEWATER TREATMENT SYSTEM IMPROVEMENTS
RESPONSIBLE AGENCY: NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
CONTACT: JON RISGAARD, SECTION CHIEF
STATE REVOLVING FUND SECTION
DIVISION OF WATER INFRASTRUCTURE
1633 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1633
[phone]
January 5, 2021

(This page intentionally left blank.)

FINDING OF NO SIGNIFICANT IMPACT
Article I, Chapter 113A of the North Carolina General Statutes requires an action to be subject to
the requirements of the North Carolina Environmental Policy Act (NCEPA) if it involves the
expenditure of public funds and if a potential impact is anticipated to the environment. The
project has been evaluated for compliance with the NCEPA and is determined to be a major
agency action, which will affect the environment.
Project Applicant:
Project Description:
Project Number:
Project Cost:
Clean Water State
Revolving Loan Fund:
Local Funds:
Town of Pittsboro, North Carolina
The proposed project will convert the Town's existing wastewater
treatment plant (WWTP) to provide equalization only and install a
pump station and forcemain to pump the Town's wastewater from
the WWTP site to the City of Sanford's Big Buffalo Creek
WWTP. The converted WWTP will provide approximately 1.1
million gallons of equalization capacity. Screening and grit
removal will be added prior to the pump station. The pump station
will be designed for an average flow of 2 million gallons per day
(MGD) and peak day of 3 MGD. The forcemain will be
approximately 14 miles long. The proposed project covered
under this Finding of No Significant Impact is Phase 1 of a two-
phase plan to address wastewater needs in the 20-year planning
window, including service for the Chatham Park development.
Phase 2 is still under development and is likely to include
construction of a regional WWTP to meet the expected need
beginning in 2026 and is not covered by this environmental
analysis.
CS370413-06
$20,185,800
$19,790,000
$395,800
The review process indicated that significant adverse environmental impacts should not occur if
mitigative measures are implemented, and an environmental impact statement will not be
required. The decision was based on information in the Engineering Report/Environmental
Information Document Revision No. 4 December 29, 2020 (ER/EID), submitted by the
applicant, and reviews by governmental agencies. The attached Environmental Assessment (EA),
prepared by the Division based on the ER/EID, supports this action and, together with the
ER/EID, outlines mitigative measures that must be followed. This Finding of No Significant
Impact (FONSI) completes the environmental review record, which is available for inspection at
the State Clearinghouse.

No administrative action will be taken on the proposed project for at least 30 days after
notification that the FONSI has been published in the North Carolina Environmental Bulletin.
Sincerely,
Jon Risgaard, Section Chief
State Revolving Fund Section
Division of Water Infrastructure

ENVIRONMENTAL ASSESSMENT
A. Proposed Facilities and Actions
The proposed project will convert the Town of Pittsboro's existing wastewater treatment plant
(WWTP) to provide equalization only and install a pump station and forcemain to pump the
Town's wastewater from the WWTP site to the City of Sanford's Big Buffalo Creek WWTP.
The converted WWTP will provide approximately 1.1 million gallons of equalization capacity.
Screening and grit removal will be added prior to the pump station. The pump station will be
designed for an average flow of 2 million gallons per day (MGD) and a peak day of 3 MGD. The
forcemain will be approximately 14 miles long. The proposed project evaluated in this
environmental assessment is Phase 1 of a two-phase plan to address wastewater needs in the 20-
year planning window, including service for the Chatham Park development. Phase 2 is still
under development and is likely to include construction of a regional WWTP to meet the
expected need beginning in 2026.
Funding Status: The estimated total cost for the project is $20,185,800. The Town is applying for
a Clean Water State Revolving Fund (CWSRF) loan of $19,790,000. Local funds will be used
for the closing costs of $395,800.
B. Existing Environment
Topography and Soils. Pittsboro is the Piedmont physiographic province. The topography
includes slopes ranging from gentle to strongly sloping with elevations from 208 to 528 feet
above mean sea level. The majority of the project area is within the Carolina Slate Belt, with the
southern portion of the forcemain in the Triassic Basin. Portions of the proposed forcemain
alignment are in the 100-year floodplain and floodway.
The dominant soil type at the WWTP site is Georgeville silt loam. The dominant soil along the
forcemain route is Cid-Lignum complex with other soils including Cid silt loam, Nanford-Badin
complex, Mayodan fine sandy loam, Pinkston silt loam, and Tarrus silt loam. Some soil types in
the project area may have limitations for development due to wetness, low strength, and
restricted permeability. These soils are upland soils with hydric inclusions.
Surface Water. The project area is located in the Cape Fear River Basin with portions in the Haw
Subbasin (HUC 03030002), Deep Subbasin (HUC 03030003) and Upper Cape Fear Subbasin
(HUC 03030004). Surface waters in project area include Roberson Creek, Turkey Creek, Haw
River, Rocky River, and Deep River. Roberson Creek, Haw River, and Rocky River are
designated as Water -Supply IV, Nutrient Sensitive Waters and are impaired for benthos. Rocky
River and Deep River are designated as Class C with no impairments.
Water Supply. The Town of Pittsboro provides drinking water drawn from the Haw River.
1

C. Existing Wastewater Facilities
The Town currently operates a 0.75 MGD WWTP which discharges to Roberson Creek. The
NPDES permit (No. NC0020354) allows expansion in stages starting with increased discharge at
the Roberson Creek Outfall from 0.75 MGD to 1.249 MGD and then, upon expansion above
1.249, for discharge to the Haw River up to 1.971 MGD. The plant was originally constructed in
1977 with upgrades made in 1988 and 2010. The influent channel, influent wet well, and aeration
basin #1 are original. The 1988 expansion added an additional aeration basin, clarifiers, filters,
mechanical bar screens, and a UV system. The 2010 improvements added equalization basins
and a new UV system. The influent mechanical bar screen was rebuilt in 2011, and a new
emergency generator was added in 2013. The original concrete structures, clarifier sweep arms,
and air lifts are showing signs of deterioration. The equalization basins and UV system are in
good condition.
The liquid treatment train includes screening, influent pumping, two activated sludge package
plants, tertiary filtration UV disinfection, and cascade aeration. The equalization system includes
a dedicated pump station, two tanks, and controlled volume return via a controller pinch valve.
The Town also has a water reuse system, which includes chlorination and a dedicated reuse
pump to provide water to an industrial user. The reuse system is permitted for 300,000 gallons
per day (gpd), but current demand averages approximately 50,000 to 60,000 gpd. Solids
treatment includes waste activated sludge pumps, a sludge thickening unit, two digester/storage
basins. Waste solids are land applied by an outside contractor.
The Town's sewer collection system includes approximately 30.6 miles of gravity sewer 4.4
miles of forcemain, six (6) lift stations, and 729 manholes. Most of the gravity sewer lines are
more than 20 years old. A comprehensive Sanitary Sewer Evaluation Survey is underway for the
collection system to identify and prioritize needed repairs.
D. Need for Proposed Facilities and Actions
Portions of the WWTP are more than 20 years old, and major equipment and structures need to
be repaired or replaced. While annual average wastewater flow from the Town is approximately
0.5 MGD, peak daily flows can be as high as 1.4 MGD with three-day sustained peak flow of 1.2
MGD. These peak flows exceed the capacity ofthe existing equalization and WWTP capacity.
The projected future wastewater flow for the Town, when combined with the planned 7,000-acre
Chatham Park Development, is expected to be 4.41 MGD in 2035. Flow projections indicate that
the existing WWTP's rated capacity will be reached within three to five years.
In addition, the Town's existing NPDES permit includes a requirement to meet future total
nitrogen mass limits by January 1, 2022. Based on an evaluation of effluent data from 2011 to
2014, there is a need to add nitrogen treatment if the Town continues to operate and discharge
treated wastewater from the current WWTP.
The proposed project is needed to accommodate future growth and to address peak flows, aging
equipment, and future nitrogen effluent limits. Phase 1 is expected to be able to handle projected
2

flow from the Town and a portion of the Chatham Park development until 2026. Plans for Phase
2 will continue to be developed and will be constructed to meet the 20-year planning needs
beyond 2026.
E. Alternatives Analysis
Meeting the wastewater needs of the Town of Pittsboro and the Chatham Park development over
the 20-year planning window will require a phased approach and a combination of projects
constructed by the Town and Chatham Park. The proposed project will include only Phase 1 of
the Town's project; however, the alternatives analysis considered the combination of Phase 1,
Phase 2, and Chatham Park wastewater treatment plans to identify a comprehensive approach to
meet the wastewater needs for the full 20-year planning window.
Alternative 1 — No -Action Alternative: The No -Action alternative would continue operating the
WWTP under current conditions with no improvements. This alternative would do nothing to
alleviate peak flow problems, address aging WWTP equipment, or provide for future growth in
the Town and Chatham Park. This alternative would result in repeated by-passes at the existing
plant. This alternative was rejected because it does not address the Town's short-term and long-
term wastewater needs.
Alternative 2 — Refurbish Existing WWTP, Pump to Sanford, Regional WWTP: Phase 1 of this
alternative would include two major components: (1) refurbishing the existing WWTP to address
aging equipment with the treatment capacity remaining at 0.75 MGD; and (2) construction a
1,740 gallon per minute (gpm) pump station at the existing WWTP and approximately 14 miles
of forcemain to pump wastewater to Sanford's Big Buffalo Creek WWTP. Phase 1 under this
alternative would provide approximately 2.75 MGD of capacity (0.75 MGD treated at the
existing WWTP and 2.0 MGD pumped to Sanford). Separately, a decentralized water
reclamation facility (WRF) constructed by Chatham Park with initial capacity of 0.25 MGD and
possible future expansion to 0.5 MGD, with treated water used for spray irrigation or reused for
other purposes in the Chatham Park development. The decentralized WRF would be funded and
constructed by Chatham Park. Phase 2 would consist of a preliminary plan to construction a
regional WWTP with a 1.75 MGD capacity discharging to the Haw River. Alternative 2 has
lower cost than Alternative 4 on a present worth basis but does have higher Phase 1 construction
costs compared to Alternative 4. The agreement between the Town of Pittsboro and City of
Sanford requires that all wastewater flow up to 2 MGD must be pumped to Sanford's Big
Buffalo WWTP. Alternative 2 cannot meet this requirement; therefore, this alternative is
considered infeasible and is rejected.
Alternative 3 — Expand Existing WWTP, Regional Treatment Plants: Phase 1 of this alternative
would include one major component: expansion of the existing WWTP to 1.249 MGD.
Separately, a decentralized WRF would be constructed by Chatham Park with initial capacity of
0.25 MGD and possible future expansion to 0.5 MGD, with treated water used for spray
irrigation or reused for other purposes in the Chatham Park development. The Chatham Park
WRF would be constructed by Chatham Park concurrently with Phase 1. Phase 2 would include
construction of a future regional WWTP discharging to the Haw River with initial capacity of
I.25 MGD with future expansion to 2.75 MGD. The regional WWTP is a preliminary plan that
3

would be fully developed as a separate Phase 2 project. The present worth cost analysis of this
alternative is 25 percent higher than the present worth cost for Alternative 2 or Alternative 4 with
no advantages to outweigh the additional cost. In addition, Alternative 3 has the disadvantages of
more steps, greater treatment requirements, and more complicated operations. Because of these
disadvantages and higher costs, this alternative was rejected.
Alternative 4 — Convert Existing WWTP to Equalization Capacity, Pump to Sanford, Regional
WWTP, Regional WWTP: Phase 1 of this alternative would include two major components: (1)
conversion of the existing WWTP to equalization only with a capacity of 1.1 million gallons
through installation of two new equalization pumps and forcemain and conversion of existing
tanks to equalization tanks with other treatment units at the WWTP being cleaned and left in
place; and (2) construction of a 3 MGD peak -flow pump station (2 MGD average daily flow) at
the existing WWTP and approximately 14 miles of forcemain to pump wastewater to Sanford's
Big Buffalo Creek WWTP. Separately, a decentralized WRF would be constructed by Chatham
Park with initial capacity of 0.25 MGD and possible future expansion to 0.5 MGD, with treated
wastewater pumped to the existing WWTP site to be discharged to Roberson Creek to the
existing Pittsboro WWTP site and discharged to Roberson Creek with some reuse water
provided for an industrial customer. Phase 2 would consist of construction of a future regional
WWTP with capacity of 1.91 MGD discharging to the Haw River. The regional WWTP is a
preliminary plan that would be fully developed as a separate Phase 2 project. This is the
preferred Alternative because it preserves and expands equalization functions of the existing
WWTP, avoids the need for the Town to treat wastewater, maximizes the treatment capabilities
of Sanford's WWTP, and meets the terms of the agreement with Sanford.
F. Environmental Consequences and Mitigative Measures
The proposed project does include expansion of wastewater conveyance and treatment capacity
to serve anticipated growth and development with the Town of Pittsboro and a portion of the
planned Chatham Park Development. Anticipated impacts and associated mitigation for direct
impacts and secondary and cumulative impacts (SCI) are summarized below. These impacts and
mitigative measures are described in detail in the Engineering Report/Environmental Information
Document Revision No. 4 December 29, 2020 (ER/EID) prepared by the Town of Pittsboro and
reviewed by the Division. SCI are covered in "Appendix N: Secondary and Cumulative Impacts
S(CI) Document June 2020", included in the ER/EID.
Topography and Soils: Construction at the WWTP site will include some minor permanent
impacts to topography and soils from excavation, filling, and grading. Construction of the
forcemain will have temporary impacts to soils and topography as the line is installed, but soils
will be replaced and topography restored to pre -project conditions. Soil loss during construction
will be minimized by following a DEQ-approved Erosion and Sedimentation Control Plan. A
Floodplain Development Permit will be obtained from the Town of Pittsboro for installation of
the forcemain. Future development will impact topography and soils through excavation, filling,
and grading changes to build developments. Impacts to floodplains will be minimized through
the Town's Flood Damage Prevention Ordinance, which regulates development in floodways,
floodplains, and Special Flood Hazard Areas. The Chatham Park master plan does not allow
development in the 100-year floodplain or floodway. The master plan identifies ground slopes
4

greater than 20 percent and requires avoidance of disturbance of such slopes to the maximum
extent possible. Chatham County's Soil Erosion and Sedimentation Control program regulates
ground disturbing activity.
Land Use: Impacts to land use are not expected to be significant. The proposed alignment for the
forcemain primarily follows existing utility and Department of Transportation (DOT) rights -of -
way. Work at the WWTP will occur within the existing property boundaries with no impact to
land use. The Chatham Park master plan has been approved by the Town with the goal that land
use will guide future development rather than future development guiding land use. The
Chatham Park development process requires Small Area Plans to be prepared by Chatham Park
and approved by the Town to encourage development in a planned manner and deter urban
sprawl.
Wetlands: Significant impacts to wetlands are not anticipated. Directional drilling will be used
for crossing wetlands associated with perennial streams. Open cutting may be used for crossing
wetlands associated with intermittent streams where the total crossing, including buffers, is less
than 150 feet. Impacted areas will be restored to original grade and stabilized. Most impacts will
be temporary, but some permanent impacts will be necessary for maintenance easements. Such
easements may result in conversion of some areas from forested cover to herbaceous vegetation.
Erosion and sedimentation control measures will be implemented. SCI related to development
will be minimized through adherence to Water Supply Watershed regulations for Protected Areas
and Critical areas; the Town's stormwater ordinance and stormwater control measures developed
for Chatham Park documented in the master plan, stream buffers for the Haw River, Roberson
Creek, and Stinking Creek.
The Town of Pittsboro's Riparian Buffer Protection Ordinance includes the following general
requirements: 50-foot buffer adjacent to surface waters, excluding wetlands, with a Zone 1 buffer
30 feet from the water's edge and Zone 2 buffer 20 feet beyond the Zone 1 buffer. Wetlands
adjacent to surface waters or within 50 feet of surface waters shall be considered part of the
riparian buffer. Development in the North Village area will include buffers of 300 feet adjoining
the top of the Haw River western bank in Section 1.1; 1,000 feet adjoining the top of the Haw
River western bank in Section 1.5; 100 feet adjoining the top of each bank (200 feet total) for
perennial streams; 100 feet adjoining the top of each bank for intermittent streams in the sections
that discharge to the Haw River; and 50 feet adjoining the top of each bank (100 feet total) for
other intermittent streams that drain to the Roberson River. Development in the South Village
area will include buffers of 50 feet adjoining the top of each bank (100 feet total) for intermittent
and perennial streams shown on the National Resource Conservation Service (NRCS) soil survey
and 100 feet adjoining the top of each bank (200 feet total) for perennial streams shown on the
United States Geologic Survey (USGS) topographic maps. Additionally, the Chatham Park Open
Space Element requires an additional 50 feet of open space adjacent to the riparian buffer on
each side of the portions of Roberson Creek that are located in Chatham Park; an additional 150
feet of open space or park land along the south side of Roberson Creek in Chatham Park; and
approximately 250 acres of open space and/or park land in the far southeast corner of Chatham
Park.
5

Important Farmlands: Significant impacts to important farmlands are not anticipated.
Construction will take place on the existing WWTP site, utility easements, DOT rights -of -way.
Although some land that will be crossed by the forcemain includes soils designated as prime and
unique farmland, these lands are not currently in agricultural use. Impacts to such areas will be
temporary, with trenches back -filled after construction. Development is planned for areas that
not farmed with no conversion of farmlands anticipated, thus no SC1 to important farmlands are
expected.
Public Lands and Scenic, Recreational, and State Natural Areas: Significant impacts to public
lands, scenic, recreational, or state natural areas in the project area or service area are not
anticipated. The forcemain route runs adjacent to Endor Iron Furnace and the Town's Rock Ride
Park, but these resources will not be disturbed. Chatham Park's master plan includes open space
elements, parks, and buffers to minimize impacts to state and federal lands near the proposed
development areas. Riparian buffers and maintenance of existing forest habitat as well as storm
water management plans will mitigate impacts to the Haw River and surrounding natural areas.
Cultural Resources: Impacts to cultural and historic resources are not anticipated. The North
Carolina State Historic Preservation Office (SHPO) noted that it is unlikely that significant
archaeological sites will be affected by the project and did not recommend an archaeological
survey but did request that caution be used during installation of the forcemain in the vicinity of
the Endor Iron Furnace (September 8, 2017, ER 17-1469). The forcemain route will stay within
an existing utility easement owned by the City of Sanford adjacent to the Endor Iron Furnace to
avoid any impacts. An historic assessment has been conducted for Chatham Park's North Village
to identify historic resources, including the Griffin House, which has been donated to the NC
Preservation Society, and the Riddle-George-Straughan historic cemetery, which will be
preserved as the North Village is developed. A similar assessment will be done for Chatham
Park's South Village as development plans proceed.
Air Quality: No significant impacts to air quality are anticipated. Construction activities may
cause a temporary increase in vehicle emissions as well dust. Construction equipment will be
properly equipped with emission controls, and contractors will spray down soil piles or dry
material as necessary to minimize dust. SCI will be minimized through adherence to erosion and
dust control measures during construction. The Chatham Park master plan includes a transit plan
to encourage multi -modal transportation options such as bicycles, pedestrians, and fixed route
transit to reduce car traffic and associated emissions in the Chatham Park development.
Noise Levels: No significant permanent noise impacts are anticipated. Construction activities
will be limited to normal daytime working hours. Construction equipment will include mufflers
and noise suppression equipment as appropriate. SC1 will be mitigated through adherence to the
Town of Pittsboro's noise ordinance as well as Chatham Park's transit plan encouraging multi -
modal transportation options to help minimize vehicular traffic and associated noise levels.
Water Resources: No significant impacts to water resources are anticipated. The forcemain route
crosses Roberson Creek, Turkey Creek, Rocky River, Deep River, and numerous unnamed
tributaries to these waters. Directional drilling will be used for crossing perennial streams and
associated wetlands, with open cut used for crossing intermittent streams and associated
6

wetlands. Impacts from construction activities will be mitigated through use of a DEQ-approved
Erosion and Sedimentation Control Plan and adherence to permit and buffer requirements from
the Division of Water Resources and U.S. Army Corps of Engineers. SCI related to development
will be minimized through adherence to Water Supply Watershed regulations for Protected Areas
and Critical areas; the Town's stormwater ordinance and stormwater control measures developed
for Chatham Park documented in the master plan, stream buffers for the Haw River, Roberson
Creek, and Stinking Creek. (See the discussion under wetlands for detailed information on buffer
requirements.)
Forest Resources: Significant impacts to forest resources are not expected. Construction will take
place on the cleared WWTP site, and the forcemain route largely follows existing easements and
rights -of -way that have already been cleared. A small amount of clearing will be required for
some portions of the route. Clearing will be minimized to the extent possible. Future
development will result in some forest clearing. Riparian buffer requirements will protect some
forested areas. Buffer areas will be maintained. The Chatham Park Tree Protection Element and
Landscaping Element include specific provisions to mitigate forest resource impacts and include
measures to retain or replace specific percentages of trees.
Shellfish or Fish and Their Habitats: Significant impacts to shellfish, fish, and their habitats are
not expected. Directional drilling will be used for crossing perennial streams to minimize direct
construction impacts. Area streams do provide habitat for a number of state and/or federally
listed threatened or endangered species including the Cape Fear Shiner (Notropis mekistocholas),
Brook Floater (Alasmidonta varicose), Carolina Creekshell (Villosa vaughaniana), Creeper
(Strophitus undulatus), and Triangle Floater (Alasmidonta undulata). In addition, area streams
are tributary to the Haw River, which provides critical habitat for the endangered Cape Fear
Shiner. The U.S. Fish and Wildlife Service noted that with the SCI measures detailed in
Appendix N of the ER/EID, no adverse impacts are anticipated. These SC1 measures include the
following: (1) expanded buffers, (2) limitations on development in the floodplain and steep
slopes, (3) no change in 1-year 24-hr storm event hydrograph, (4) no change in peak discharge
rates for 1 to 10 year 24-hr storm events, (5) retention of 85% of suspended solids on -site,
adverse impacts are not anticipated. The U.S. Fish and Wildlife Service encourages the Town to
include them in design and review of stormwater monitoring by providing copies of the
Stormwater Element Annual Compliance Reports.
Wildlife and Natural Vegetation: No significant impacts to wildlife and natural vegetation are
expected. Construction activities will take place at the existing WWTP site and in existing
easements and rights -of -way. The project areas do not include habitat for any threatened and
endangered terrestrial wildlife species. Wildlife may be temporarily disturbed or displaced
during construction activities but are expected to return upon completion of construction
activities. Impacts from future development will be mitigated through maintenance of buffers
and open space requirements, parks, tree protection, and landscape requirements that are part of
the Chatham Park master plan. The Chatham Park development will include River Park, which
will maintain a wildlife corridor near the Haw River. The federally endangered Harperella
(Ptilimnium nodosum) plant occurs on gravel or rocky shoals or sandbars along certain streams,
with a population in the Deep River in Chatham County. This species is sensitive to changes in
water flow. The U.S. Fish and Wildlife Service noted that with the SCI measures detailed in
Appendix N of the ER/EID, no adverse impacts are anticipated. These SCI measures include the
7

following: (1) expanded buffers, (2) limitations on development in the floodplain and steep
slopes, (3) no change in 1-year 24-hr storm event hydrograph, (4) no change in peak discharge
rates for 1 to 10 year 24-hr storm events, and (5) retention of 85% of suspended solids on -site.
Introduction of Toxic Substances: The project is not expected to introduce toxic substances into
the environment. The contractor will take appropriate actions to prevent spills of gasoline, diesel
fuels, lubricants, and hydraulic fluids and will follow EPA's Spill Prevention Control and
Countermeasures rule as appropriate.
The U.S. Fish and Wildlife Service reviewed the proposed project and concluded that with
measures outlined in the ER/EID Appendix N implemented appropriately, threatened and
endangered species should not be adversely impacted (October 1, 2020). The North Carolina
Wildlife Resources Commission, Natural Heritage Program, and DWR Raleigh Regional Office
do not object to the proposed project. The U.S. Army Corps of Engineers was consulted and did
not object to the project. The North Carolina Department of Natural and Cultural Resources does
not anticipate impacts to historic resources as a result of the project the project (September 8,
2017, ER 17-1469).
G. Public Participation, Sources Consulted
The Town held public meetings on November 9, 2020, and December 14, 2020 via
videoconference due to the COVID-19 pandemic. Both meetings included a presentation about
the proposed project and an opportunity for questions and comments from the Board of
Commissioners and the general public. Board members did not object to the project but asked
several questions as summarized with responses as follows:
• Comment: Is the 1.91 MGD from Alternative 4 what was left on the permit?
Response: 1.91 MGD is based on the 20-year demand curve (4.41 MGD minus the Phase
1 capacity of 2.5 MGD). The 1.97 MGD is the permit capacity for discharge to the Haw
River.
• Comment: Clarification requested to the 1.91 MGD discharge to the Haw River from the
future Phase 2 plant. Commenter's understanding is that the Town's total discharge is
3.22 MGD with 1.249 going to Roberson Creek and the remaining 1.971 going to the
Haw River.
Response: when the Town reaches Phase 2, the number might be a little higher than
1.91; this is why the numbers appear to be off
• Comment: Is the projection for 2.0 MGD capacity to last 8-10 years from 2017?
Response: The numbers are based on the growth project report. The Capacity Graph
shows proposed timeframes and how needs will change with time.
• Comment: (Regarding graph in the presentation) Would the plant have to be fully
operational for the 2.5 MGD
Response: Where the red line crosses the 2.5 MGD on the graph, the Town will be out of
sewer capacity.
8

• Comment: Does construction have to be completed and ready to start up while also
dealing with the pump station and forcemain? The initial version of the ER/EID was
submitted in 2016, and it's now almost 2021 and just now getting to permitting. If that
2.5 MGD is good for 8-10 years, then the Town needs to start on Phase 2 as soon as
possible.
Response: Phase 2 will not take as long because a permit will not have to be obtained
and the agreements are already in order.
• Comment: Will the ER-EID come off the table once the Town begins to pump sewer to
Sanford?
Response: No.
• Comment: Will the proposed infrastructure in the ground have the ability to increase
sewer capacity without constructing a separate or new force main?
Response: The Town might need to construct another intermediate pump station or
replace the pumps in the Phase 1 pump station; however, the force main pope is sized
where it could remain in the ground unchanged.
• Comment: How much additional capacity could the force main pipe handle?
Response: That number will be researched and reported back to the Board.
• Comment; If the Town were to consider the Interbasin Transfer (IBT), how long would
that process take?
Response: Rule of thumb is 3-5 years as the Town would have to go through the EMC
board for approval.
• Comment: If the Town placed a pipe in the right-of-way and pumped back from Sanford,
would that impact IBT volume rules?
Response: Yes, it does; if you get water back in return, however, it is unlikely to off -set
all the wastewater flow sent to Sanford.
• Comment: What is the loan origination fee?
Response: It's a lump sum of money paid directly by the Town and not rolled into the
loan.
• How did we reach $686,000?
Response: Mathematical response provided.
• Comment? Is the reserve fee paid each year until reaching 2.5 MGD in flow or for the
duration length of the agreement?
Response: The loan is paid over a 20-year term, and the Chatham Park portion is paid
over a 10 year term.
• Comment: Will the 30-day FONSI notice period start as of the meeting date?
Response: No, comments would be submitted to the Division and sent out to the pubic
9

before the 30 days begins.
• Comment: What does `future regional treatment plant" refer to?
Response: The combined wastewater improvements planned for Pittsboro and Chatham
Park
• Comment: Does the reuse water sent to 3M reduce the overall discharge?
Response: Yes, that is correct.
• Comment: How is discharge affected if the Town finds another reuse water customer?
Response: That would benefit the Town even more.
• Comment: Are any plans for alternative discharge to be considered? Could the Town
treat 1.249 MGD at the plant and discharge zero to Roberson Creek if the Town had
another location to discharge?
Response: Yes, but only if the Town finds enough demand in reuse water.
• Comment: If we are going to use 8-10 MGD now, we will need much more capacity
soon. The Town may need to increase flow going to Sanford as building another
wastewater treatment plant will likely take a long time.
Response: The Town may want to consider that as soon as possible.
In addition to the above questions and comments from the Board, the following comments were
received from the public:
• Comment: Chatham Park will be operating its own plan and will need customers. I
assume those customers will not contribute to the capital costs of the Sanford line. The
lag time between the Sanford line becoming operational and state of loan payments is not
many years. How much growth outside of Chatham Park can be reasonably expected in a
short period to add new customers to the Town's system and the Town's portion of loan
payments?
Response: Based on growth projects, approximately 241 new connections per year are
anticipated within the Town, with Chatham Park anticipated to add another 390
connections per year. Note that Chatham Park residents are Town residents and
customers and will be charged user rates by the towns. Also note that, depending on
development patterns, sewer infrastructure, and timing, and portion of Chatham Park
wastewater flow may be directed to the Pittsboro pump station rather than the
decentralized plant.
• Comment: How can the Town reasonably expect to add the equivalent of 14 subdivisions
of 100 homes outside of Chatham Park in just two years or less?
Response: The growth rates in the ER/EID are not intended to imply 1,400 connections in
the first two years. The number is intended to show anticipated connections required in a
reasonable but not specific amount of time to produce no net increases in rates paid by
customer base. The Town currently has approximately $2.0 million in retained sewer
10

fund earnings that could be used to fund the initial loan payments as the customer base
grows. The approval of the Sanford sewer force main and associated wastewater
improvements project allows the Town the ability to authorize development that is
currently delayed or behind schedule to be reactivated and facilitate growth of the
Town's utility customer base.
• Comment: As a business owner in Town, commenter is pleased to see the project moving
forward and looks forward to construction completion.
Response: Comment noted and appreciated.
The current user charge for a typical residential customer is $72 per month for water and sewer
service combined, based on the average use of 3,200 gallons per month. An analysis of rates
based on existing users shows an increase of $23 per month (approximately 58°/a) for typical
users. However, the Town does not plan to raise rates for existing users. Rapid development will
add new users to the system to pay for additional costs. The Town has an approved agreement
with Chatham Park for assistance with paying for 62.5 percent of the loan for this project as well
as a portion of the Sanford Capacity Reserve Charge. The agreement also includes funding from
Chatham Park if there is a shortfall in user revenues prior to connecting new users. With this
agreement in place, the Town does not anticipate an increase in rates for existing customers.
Sources consulted about this project for information or concurrence included
1) Town of Pittsboro
2) Chatham County
3) North Carolina Department of Environmental Quality
- Wildlife Resources Commission
-Natural Heritage Program
-DEQ Raleigh Regional Office
- Division of Air Quality
- Division of Water Resources
- Division of Forest Resources
-Division of Environmental Assistance and Customer Service
- Division of Waste Management
4) North Carolina Department of Natural and Cultural Resources
5) North Carolina State Clearinghouse
6) North Carolina Department of Public Safety
7) U.S. Fish and Wildlife Service
8) U.S. Army Corps of Engineers
11

Figure 5.2
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rov orn„,,eoRr From Pittsboro to Sanford
Legend
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Figure 1.2
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STATE OF NORTH CAROLINA
DEPARTMENT OF ADMINISTRATION
ROY COOPER MACHELLE SANDERS
GOVERNOR SECRETARY
February 9, 2021
Ms. Jennifer Haynie
North Carolina Depailiient of Environmental Quality
Division of Water Infrastructure
1633 Mail Service Center
Raleigh, North Carolina 27699-1633
Re: SCH File # 21-E-4300-0811; Town of Pittsboro Wastewater Treatment Plant
Dear Ms. Haynie:
The above referenced environmental impact information has been reviewed through the State
Clearinghouse under the provisions of the North Carolina Environmental Policy Act.
Attached to this letter are additional comments made in the review of this document. Because
of the nature of the comments, it has been determined that no further State Clearinghouse review
action on your part is needed for compliance with the North Carolina Environmental Policy Act.
The attached comments should be taken into consideration in project development.
Sincerely,
Crystal Best
State Environmental Review Clearinghouse
Attachments
Mailing Address: Telephone: [phone] Location:
NC DEPARTMENT OF ADMINISTRATION Fax: [phone] WEST JONES STREET
1301 MAIL SERVICE CENTER COURIER #51-01-00 RALEIGH, NORTH CAROLINA
RALEIGH, NC 27699-1301 Email: [e-mail]
Website: www.ncadmin.nc.gov

February 8, 2021
Re: Project Control #21-E-4300-0811
Town of Pittsboro Force Main to Sanford Sewer Project
North Carolina Department of Administration
State Environmental Review Clearinghouse:
I am respectfully submitting public comments on the Engineering Report & Environmental Information
Document for Wastewater Treatment System Improvements for the Town of Pittsboro, NCDWI Project #
CS370413-06.
The existing Town of Pittsboro WWTP capacity is 0.75 MGD.
According to the "Wastewater Capacity Reservation Agreement" between Chatham Park Investors (CPI)
& the Town of Pittsboro, the Town gets 0.75 MGD and CPI gets 1.25 MGD of the total 2.0 MGD capacity
in the force main to Sanford (CPI Agreement section 7.a).
CPI will pay 62.5% of the cost and receive 62.5% of the capacity (section 1.a) [62.5% x 2.0 MGD = 1.25
MGD]. CPI will issue Vouchers for development on their property to keep up with their allocation, but
they get "1.25 MGD of actual flow" (section 7.d) in the force main exclusively; "the Town shall not
allocate any of the 1.25 MGD to any person or legal entity other than CPI"(section 7.a). The cost of the
vouchers has not been included in the Engineering Report (ER) nor a discussion that CPI has complete
control over the issuance of the vouchers.
The capacity reservation for CPI has not been included in the Disadvantages Column of Table 5.3. The
existing Town of Pittsboro does not gain any additional sewer capacity by implementing Alternative 4,
Phase 1. All additional capacity is reserved for CPI.
While CPI property will be annexed in the future once it is developed, the map in Figure 1.2 clearly
shows that this is private land owned by one private company and the CPI contract is designed such that
the Preferred Alternative will solely benefit this one developer. Throughout the ER there is the
misleading use of the definition of "Town." The ER implies that all property in and around existing
Pittsboro will have access to the additional sewer capacity. However, that is not the case per the CPI
contract and this point was not discussed in the Report.
With the selection of the Preferred Alternative, there can be no addition or extension to the existing
collection system within the existing Town of Pittsboro. Existing residents and property owners cannot
develop in the existing Town because almost the entire Pittsboro WWTP capacity has been allocated
(only 17,000 gpd remain as of the Nov. 7, 2020 Board of Commissioners meeting) and there will be no
additional capacity for the existing Town with Alternative 4, phase 1. This effectively eliminates building
& annexation on property other than CPI, provides CPI with a monopoly on all land that has access to
municipal sewer capacity, and prevents future development within the existing Town itself.
The ER states that the Sanford Agreement "includes a provision that all wastewater generated up to 2.0
MGD is to be pumped to the Sanford Big Buffalo WWTP" (ER page 3). The ER states again on page 55

that "Alternative 2 became impractical because the City of Sanford indicated it would only enter into an
agreement if all of Pittsboro wastewater were pumped to Sanford." The ER does not include discussion
that CPI was granted an exception to this requirement. The Sanford Contract states specifically that
Pittsboro "deliver to Sanford all of its wastewater, saving and excepting any flow up to 0.5 MGD
delivered to the Pittsboro-Chatham Park Reclamation facility, up to the 2.0 MGD of capacity reserved
herein" (Sanford Contract Section II).
The ER states that this Sanford Contract requirement is the main reason that Alternative 4 was chosen
over Alternative 2 (page 3). This is an interesting stipulation — CPI can build and treat wastewater, but
Pittsboro cannot. Why would the requirement not be for ALL wastewater to be sent to Sanford? If CPI
was able to negotiate an exception, why not Pittsboro? If Pittsboro was granted the same exception as
CPI, then the existing Pittsboro WWTP could remain on-line and the existing Town would have acquired
additional sewer capacity.
How can Alternative 4 be the Preferred Alternative when it does not provide any additional sewer
capacity for the existing Town — all additional capacity is reserved solely for CPI. This important fact has
not been included in the Disadvantages Column in Table 5.3 of the Engineering Report. Also not included
was a discussion of sending wastewater to Durham instead of Sanford.
Alternative 4, Phase 1 appears to prevent growth & development in existing Pittsboro. All development
that needs public sewer would have to be done on land purchased from CPI, whose sewer system was
funded by Pittsboro taxpayers, through a loan from the State.
Thank you for your time.
Sincerely, C
:pdLi
Jacob Smith

1/22/2021
Project Search - State Clearinghouse
<-Back
Control No.: 21-E-4300-0811
Projec
Description: Proposed project is for the Town of Pittsboro. Project will convert
the Town's existing wastewater treatment plant (WWTP) to
provide equalization only and install a pump station and
forcemain to pump the Town's wastewater from
the WWTP site to the City of Sanford's Big Buffalo Creek
WWTP.
State Environmental Policy Act Environmental
Assessment/Finding of No Significant Impact
01/07/2021
02/08/2021
Type of Document:
Date Open:
l Review Close Date:
Applicant:
Contact:
NC Department of Environmental Quality
Jennifer Haynie
{ Phone: [phone] Ext: Fax Number: 1
[e-mail]
Email:
Web Site:
County: 1 CHATHAM
https://clearinghouse.nc.gov/SCH/projecisearch 1/1

TOWN OF
JAMES NASS
Mayor
CHRIS KENNEDY
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PITTSBORO, N.C. 27312
October 14, 2020
NC DEQ/DWR
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
BOARD OF COMMISSIONERS
Subject: NPDES Permit Renewal
Permit Renewal - Supplemental Information
Pittsboro WWTP
NPDES Permit #NC0020354
Chatham County
Dear Permitting Unit:
PAMELA BALDWIN
JAY FARRELL
MICHAEL A. FIOCCO
JOHN BONITZ
KYLE SHIPP
TELEPHONE
[phone]
FAX [phone]
We have recently been informed that a request for reduced monitoring could be made during the renewal
process. We are submitting this additional information to be considered during the renewal process. We are
requesting that monitoring for BOD5, TSS, NH3-N and Fecal Coliform be reduced under the "exceptionally
performing facilities" criteria to two times per week.
The attached data (summarized in the following table) indicates that the WWTP effluent has greatly exceeded
the minimum criteria for reduced monitoring. The most restrictive summer limits was used for calculating
removal rates. The data used for this 3-year analysis was for the period of July 2020 — August 2017.
Analysis of testing; results for the past three years:
Percent of Monthly Average Limit
Parameter
Monthly Limit
3-Year Average
% of Limit
BOD5
5.0 mg/1
1.1 mg/1
22 %
TSS
30.0 mg/L
1.6 mg/L
5 %
Fecal Coliform
200/100 ml
1.4 colonies/100 ml
1%
NH3-N
2.0 mg/1
0.30 mg/1
15%
CHARTERED 1787

- Number of Samples Over 200% of Monthly Average Limit
Parameter
200% of Monthly Limit
Number of Samples Over
BOD5
10.0 mg/1
7
TSS
60 mg/L
1
NH3-N
4.0
8
- Number of Samples Over 200% of Weekly Average Limit
Parameter
200% of Weekly Limit
Number of Samples Over
Fecal Coliform
800
4
In addition to the exceptional test results, the Pittsboro WWTP is in compliance with all other
criteria listed in Section B Approval Criteria of the October 22, 2012 guidance document
regarding reduction of monitoring frequencies.
The Town appreciates the Division's effort to reduce the regulatory and monetary burden on
systems that strive consistently to provide exceptional wastewater treatment. We thank you for
your consideration in these matters. If you have any additional questions or comments, please call
Jamie McLaurin at: 919/200-8927.
Sincerely,
", 61
John Poteat,
Director of Public Works
Town of Pittsboro

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
January 8, 2021
JOHN POTEAT — DIRECTOR OF PUBLIC WORKS
TOWN OF PITTSBORO
POST OFFICE Box 759
PITTSBORO, NORTH CAROLINA 27312
Subject: Permit No. WQ0024838
Town of Pittsboro WWTP
Reclaimed Water Generation and
Distribution System
Chatham County
Dear Mr. Poteat:
In accordance with your permit minor modification request received October 13, 2020, we are
forwarding herewith Permit No. WQ0024838 dated January 8, 2021, to the Town of Pittsboro for the
continued operation of the subject reclaimed water generation and distribution facilities.
The following modifications to the subject permit are as follows: This permit allows for reclaimed
water generated at the Chatham Park Water Recovery Center (Permit No. WQ0039375) to be conveyed to
the Town of Pittsboro WWTP and distributed under this permit to the user specified in Attachment B.
Please note that the reclaimed water distribution line connecting these two facilities have not been permitted
at the time of this permit's issuance, and this line shall be permitted before reclaimed water generated at
the Chatham Park Water Recovery Center can be distributed under this permit. Please not that Permit No.
WQ0039375 shall be modified to allow operation of their reclaimed water generation system, and to add
this permit as an offsite reclaimed water distribution user.
This permit shall be effective from the date of issuance through July 31, 2022, shall void Permit
No. WQ0024838 issued June 22, 2017, and shall be subject to the conditions and limitations therein. The
Permittee shall submit a renewal application no later than February 1, 2022.
Please pay attention to the monitoring requirements listed Attachments A and B for they may differ
from the previous permit issuance. Failure to establish an adequate system for collecting and maintaining
the required operational information shall result in future compliance problems.
The Division has removed the following permit conditions since the last permit issuance
dated June 22, 2017:
➢ Old Condition IL8. — This condition has been replaced by Condition IL 10.
➢ Old Condition IL9. — This condition has been replaced by Condition IL11.
➢ Old Condition IL 10. — This condition has been replaced by Condition 11.12.
➢ Old Condition 1IL6. — This condition has been replaced by Condition IIL10.
D_E
NUN fH (:Ai(1!INA
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
OepeNn.nl 0 EnnlrpnmenWi Quality

Mr. John Poteat
January 8, 2021
Page 2 of 3
➢ Old Condition VI.2. — This condition has been removed because the permit is not voidable.
The following permit conditions are new since the last permit issuance dated June 22, 2017:
➢ Conditions 11.5., 11.7., and 11.8. — These conditions were previously covered under Old
Condition 11.6., but have been separated into their own conditions.
➢ Condition 11.10. — Reclaimed water distribution lines shall be located at least 5 feet horizontally
from and 18 inches below any water line if practicable.
➢ Condition 11.11. — Reclaimed water distribution lines shall not be less than 50 feet from a well
unless the piping and integrity testing procedures meet water main standards in accordance
with 15A NCAC 18C.
➢ Condition 11.12. — Reclaimed water distribution lines shall meet the separation distances to
sewer lines in accordance with 15A NCAC 02T .0305.
➢ Condition 11.13. — The setbacks for storage units in effect at the time of initial permitting have
been added to the permit.
➢ Condition IIL5. — This condition has been modified from Old Condition IIL7. to allow
reclaimed water generated from the Chatham Park Water Recovery Center (WQ0039375) to
be distributed to the offsite users listed in Attachment B.
➢ Condition IIL9. — This condition requires that a protective vegetative cover be established and
maintained on all berms, pipe runs, erosion control areas, surface water diversions, and earthen
embankments.
➢ Condition III.10. — Metering equipment shall be tested and calibrated annually.
➢ Condition 111.12. — Continuous online monitoring and recording for turbidity or particle count
and flow shall be provided prior to storage and distribution of reclaimed water.
➢ Condition IV.6. — This condition requires that the Permittee maintain a record of all residuals
removed from this facility.
➢ Condition VI.10. — This permit shall not be renewed if the Permittee or any affiliation has not
paid the required annual fee.
If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding.

Mr. John Poteat
January 8, 2021
Page 3 of 3
If you need additional information concerning this permit, please contact Erick Saunders at (919)
707-3659 or [e-mail].
Sincerely,
S. Daniel Smith, Director
Division of Water Resources
cc: Chatham County Health Department (Electronic Copy)
Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)

THIS PAGE BLANK

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
RECLAIMED WATER GENERATION AND DISTRIBUTION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Town of Pittsboro
Chatham County
FOR THE
continued operation of a 300,000 gallon per day (GPD) reclaimed water generation and distribution system
consisting of:
an effluent reclaimed water pump station with a 315 gallon per minute (GPM), 40 horsepower (hp) pump;
an in -line turbidimeter; a chemical feed liquid sodium hypochlorite system with a 1,000 gallon storage tank;
520 linear feet (LF) of 8-inch reclaimed water line; 13 air release valves; a 500,000 gallon reclaimed water
storage tank between Old Sanford Rd. and NC 15; 26,200 LF of 8-inch reclaimed water line; and all
associated piping, valves, controls, and appurtenances
to serve the Town of Pittsboro WWTP, with no discharge of wastes to surface waters, pursuant to the
application received October 13, 2020, and in conformity with the Division -approved plans and
specifications considered a part of this permit.
This permit shall be effective from the date of issuance through July 31, 2022, shall void Permit No.
WQ0024838 issued June 22, 2017, and shall be subject to the following conditions and limitations:
I. SCHEDULES
1. The Permittee shall request renewal of this permit on Division -approved forms no later than February
1, 2022. [15A NCAC 02T .0105(b), 02T .0109]
2. Operation of the reclaimed water distribution facilities shall be contingent upon construction and
operation of permitted reclaimed water distribution lines immediately upstream and downstream of the
reclaimed water distribution facilities permitted herein. Specifications for future upstream and
downstream reclaimed water distribution lines shall include quality assurance testing procedures, which
shall be adhered to prior to operation of the reclaimed water distribution facilities permitted herein.
[G.S. 143-215.1]
WQ0024838 Version 2.1 Shell Version 200201 Page 1 of 8

II. PERFORMANCE STANDARDS
1. The Permittee shall maintain and operate the subject reclaimed water facilities so there is no discharge
to surface waters, nor any contravention of groundwater or surface water standards. In the event the
facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper
operation and maintenance, the Permittee shall take immediate corrective actions, including Division
required actions, such as the construction of additional or replacement reclaimed water generation and
distribution facilities, or cessation of reclaimed water distribution. [15A NCAC 02T .0108(b)(1)(A)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02T .0108(b)(1)(A)]
3. Effluent limitations for generated reclaimed water shall not exceed those specified in Attachment A.
[15A NCAC 02U .0301]
4. Reclaimed water shall only be utilized at the sites and for the activities specified in Attachment B. [15A
NCAC 02U .0401(g)]
5. All reclaimed water valves, storage facilities, and outlets shall be tagged or labeled to warn the public
or employees that the water is not intended for drinking [15A NCAC 02U .0403(b)]
6. All reclaimed water piping, valves, outlets, and other appurtenances shall be color -coded, taped, or
otherwise marked to identify the source of the water as being reclaimed water as follows:
a. All reclaimed water piping and appurtenances shall be either colored purple (Pantone 522 or
equivalent) and embossed or integrally stamped or marked "CAUTION: RECLAIMED WATER -
DO NOT DRINK" or be installed with a purple (Pantone 522 or equivalent) identification tape or
polyethylene vinyl wrap. The warning shall be stamped on opposite sides of the pipe and repeated
every three feet or less;
b. Identification tape shall be at least three inches wide and have white or black lettering on purple
(Pantone 522 or equivalent) field stating "CAUTION: RECLAIMED WATER - DO NOT
DRINK". Identification tape shall be installed on top of reclaimed water pipelines, fastened at least
every 10 feet to each pipe length and run continuously the entire length of the pipe; and
c. Existing underground distribution systems retrofitted for the purpose of conveying reclaimed water
shall be taped or otherwise identified as noted in II.6.a. and II.6.b. This identification need not
extend the entire length of the distribution system but shall be incorporated within 10 feet of
crossing any potable water supply line or sanitary sewer line.
[15A NCAC 02U .0403(c)]
7. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that permits operation
by personnel authorized by the entity that operates the reclaimed water system. [15A NCAC 02U
.0403(d)]
8. Hose bibs shall be located in locked, below grade vaults that shall be labeled as being of non -potable
quality. As an alternative to the use of locked vaults with standard hose bib services, other locking
mechanisms such as hose bibs that can only be operated by a tool may be placed above ground and
labeled as non -potable water. [15A NCAC 02U .0403(e)]
9. There shall be no direct cross -connections between the reclaimed water and potable water systems,
unless such connection has been approved by the Department pursuant to 15A NCAC 18C .0406. [15A
NCAC 02U .0403(f)]
10. Reclaimed water distribution lines shall be located at least 5 feet horizontally from and 18 inches below
any water line if practicable. If these separation distances cannot be met, the piping and integrity testing
procedures shall meet water main standards in accordance with 15A NCAC 18C. [15A NCAC 02U
.0403(g), 02U .0403(h)]
WQ0024838 Version 2.1 Shell Version 200201 Page 2 of 8

11. Reclaimed water distribution lines shall not be less than 50 feet from a well unless the piping and
integrity testing procedures meet water main standards in accordance with 15A NCAC 18C, but in no
case shall they be less than 25 feet from a private well. [15A NCAC 02U .0403(g), 02U .0403(i)]
12. Reclaimed water distribution lines shall meet the separation distances to sewer lines in accordance with
15A NCAC 02T .0305. [15A NCAC 02U .0403(g), 02U .0403(j)]
13. The facilities herein were permitted per the following setbacks:
a. The storage and treatment units were originally permitted July 22, 2008. The setbacks for storage
and treatment units originally permitted or modified from September 1, 2006 to June 17, 2011 are
as follows (all distances in feet):
i. Each habitable residence or place of assembly under separate ownership: 100 1
ii. Each private or public water supply source: 100
iii. Surface waters: 50
iv. Each well with exception of monitoring wells: 100
v. Each property line: 0 2, 3
Habitable residences or places of assembly under separate ownership constructed after the
facilities herein were originally permitted or subsequently modified are exempt from this
setback.
2
Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
3 Section 22.(c)(2) of Session Law 2013-413 exempts final reclaimed water effluent storage
facilities constructed prior to June 18, 2011 from having a setback to property lines.
[15A NCAC 02T .0912(a)]
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the subject facilities as a non -discharge system. [15A NCAC
02U .0101]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include:
a. A description of the operation of the system in detail to show what operations are necessary for the
system to function and by whom the operations are to be conducted;
b. A sampling and monitoring plan to evaluate quality of reclaimed water within the distribution
system to provide quality assurance at the time of reuse, and specify actions to be taken in response
to unsatisfactory monitoring results;
c. A map of all reclaimed water distribution lines;
d. A description of anticipated maintenance of the system;
e. Provisions for safety measures, including restriction of access to the site and equipment; and
f. Spill control provisions that include response to upsets and bypasses, including control,
containment, and remediation, and contact information for personnel, emergency responders, and
regulatory agencies.
[15A NCAC 02U .0801(a)]
WQ0024838 Version 2.1 Shell Version 200201 Page 3 of 8

3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, the Permittee shall designate and employ a certified
operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T
.0117]
4. An operator certified by the Water Pollution Control System Operators Certification Commission
(WPCSOCC) of a grade equivalent or greater than the facility classification shall be on call 24 hours
per day. [15A NCAC 02U .0401(e)]
5. Only reclaimed water generated from the Pittsboro WWTP (Permit No. NC0020354) and the Chatham
Park Water Recovery Center (Permit No. WQ0039375) shall be conveyed in the reclaimed water
distribution facilities permitted herein. [15A NCAC 02U .0101]
6. The Permittee shall prohibit public access to the wastewater treatment and storage facilities. [15A
NCAC 02T .0108(b)(1)(A)]
7. The Permittee shall dispose or utilize generated residuals in a Division -approved manner. [15A NCAC
02T .1100, 02U .0802].
8. The Permittee shall not divert or bypass untreated or partially treated reclaimed water from the subject
facilities unless diverted to an alternate treatment or collection system. [15A NCAC 02T
.0108(b)(1)(A)]
9. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02U .0801(g)]
10. Metering equipment shall be tested and calibrated annually. [15A NCAC 02U .0801(d)]
11. An automatically activated standby power source or other means to prevent improperly treated
wastewater from entering the storage and distribution system shall be provided. [15A NCAC 02U
.0401(d)]
12. Continuous online monitoring and recording for turbidity or particle count and flow shall be provided
prior to storage and distribution of reclaimed water. [15A NCAC 02U .0401(b)]
13. If turbidity exceeds 10 NTUs or if the permitted pathogen levels cannot be met, all effluent shall be
prohibited from entering the storage and distribution system, and shall be disposed of in accordance
with Permit No. NC0020354 until the reclaimed water standards are met at the generating facilities.
[15A NCAC 02U .0401(c)]
14. The Permittee shall provide notification to the public and its employees about the use of reclaimed
water, and that reclaimed water is not intended for drinking Such notification shall be provided to
employees in a language they can understand. [15A NCAC 02U .0501(a)(2)]
15. The Permittee shall develop and implement an education program to inform users and its employees
about the proper use of reclaimed water. Educational material shall be provided to all residents and/or
other facilities provided with reclaimed water, and these materials shall be maintained consistent with
the reclaimed water uses. All educational materials shall be made available to the Division upon
request. [15A NCAC 02U .0501(a)(4)]
WQ0024838 Version 2.1 Shell Version 200201 Page 4 of 8

IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
facility's impact on groundwater and surface water. [15A NCAC 02T .0108(c)]
2. A Division -certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. [15A NCAC 02H .0800]
3. The Permittee shall monitor the generated reclaimed water at the frequencies and locations for the
parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
4. The Permittee shall maintain adequate records tracking the amount of reclaimed water distributed and
shall include the following information:
a. Date reclaimed water distributed; and
b. Volume of reclaimed water distributed to each site specified in Attachment B (monthly total).
Monthly tracking records shall be summed and reported on Form NDMR (see Attachment A) under
parameter WQ01 (Flow, Reclaimed Water Distributed). This value shall represent the total volume of
reclaimed water distributed for that month. [15A NCAC 02T .0108(c)]
5. Three copies of all monitoring data (as specified in Conditions IV.3. and IV.4.) on Form NDMR for
each PPI shall be submitted on or before the last day of the following month. If no activities occurred
during the monitoring month, monitoring reports are still required documenting the absence of the
activity. All information shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(1)]
6. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. This record shall
include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02U .0802(b)]
7. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Date of flow measurement device calibration;
b. Date of turbidimeter calibration;
c. Date and results of power interruption testing on alternate power supply;
d. Visual observations of the plant and plant site; and
e. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.); and
f. Record of all discharges of reclaimed water to surface waters or the land surface, including the date
of occurrence, estimated volume, and corrective action taken.
[15A NCAC 02U .0801(h)]
WQ0024838 Version 2.1 Shell Version 200201 Page 5 of 8

8. Noncompliance Notification:
The Permittee shall report to the Raleigh Regional Office, telephone number [phone], within
24 hours of first knowledge of the following:
a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate wastewater treatment.
c. Any failure resulting in a discharge untreated or partially treated wastewater to surface waters.
d. Any failure resulting in a discharge of reclaimed water directly to surface waters or any unpermitted
release of reclaimed water to land surface greater than or equal to 5,000 gallons. Unpermitted
releases less than 5,000 gallons to land surface shall be documented by the Permittee in accordance
with Condition IV.7.f. but do not require Regional Office notification.
e. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
f. Ponding in or runoff from the irrigation sites.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Raleigh Regional Office within five days
of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure
the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)]
V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the reclaimed
water generation and distribution facilities. [15A NCAC 02U .0801(i)]
2. The Permittee shall inspect the reclaimed water generation and distribution facilities to prevent
malfunctions, facility deterioration, and operator errors that may result in discharges of wastes to the
environment, threats to human health, or public nuisances. The Permittee shall maintain an inspection
log that includes the date and time of inspection, observations made, and maintenance, repairs, or
corrective actions taken. The Permittee shall maintain this inspection log for a period of five years
from the date of the inspection, and this log shall be made available to the Division upon request. [15A
NCAC 02U .0801(h), 02U .0801(i)]
3. Division authorized representatives may, upon presentation of credentials, enter and inspect any
property, premises, or place related to the reclaimed water generation and distribution facilities
permitted herein at any reasonable time for determining compliance with this permit. Division
authorized representatives may inspect or copy records maintained under the terms and conditions of
this permit, and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]
WQ0024838 Version 2.1 Shell Version 200201 Page 6 of 8

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.6B, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division -approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit, there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T .0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T .0105(c)(6)]
5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall
submit a permit modification request on Division -approved forms. The Permittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor -owner. [G.S. 143-
215.1(d3)]
6. The Permittee shall retain a set of Division -approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0105(o)]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .0105(j)]
8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02U;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T .0110]
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9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T .0120(b), 02T .0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T .0120(c)]
Permit issued this the 8th day of January 2021
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0024838
WQ0024838 Version 2.1 Shell Version 200201 Page 8 of 8

ATTACHMENT A — LIMITATIONS AND MONITORING REQUIREMENTS
PPI 001— Reclaimed Water Generation System Effluent
Permit Number: WQ0024838
Version: 2.1
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Code
Parameter Description
Units of
Measure
Monthly Monthly
Average Geometric Mean
Daily Minimum
Daily Maximum
Measurement
Frequency 1
Sample
Type
00310
BOD, 5-Day (20 °C)
mg/L
10
15
3 x Week
Composite
50060
Chlorine, Total Residual
mg/L
3 x Week
Grab
31616
Coliform, Fecal MF, M-FC Broth, 44.5 °C
#/100 mL
14
25
3 x Week
Grab
00610
Nitrogen, Ammonia Total (as N)
mg/L
4
6
3 x Week
Composite
00530
Solids, Total Suspended
mg/L
5
10
3 x Week
Composite
00076
Turbidity, HCH Turbidimeter
NTU
10
Continuous
Recorder
1. Please note that the monitoring requirements (i.e. measurement frequency and sample type) have been aligned with those requirements in Permit No. NC0020354. Accordingly, the Permittee
may report the same data for parameters BOD5 (00310), Fecal Coliform (31616), Ammonia (00610), and TSS (00530) for Permit No. NC0020354 (i.e., no additional monitoring).
PPI 002 — Distributed Reclaimed Water
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Code
Parameter Description
Units of
Measure
Monthly
Total
Monthly
Geometric Mean
Daily Minimum
Daily Maximum
Measurement
Frequency
Sample
Type
WQ01
Flow, Reclaimed Water Distributed
gallons
Monthly
Estimate
WQ0024838 Version 2.1 Attachment A
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ATTACHMENT B — APPROVED CONJUNCTIVE SITES AND USES
APPROVED USERS FOR OFFSITE DISTRIBUTION
Town of Pittsboro — Town of Pittsboro WWTP
Permit Number: WQ0024838 Version: 2.1
Site
Facility Name
Owner
County
User Permit Number
Latitude
Longitude
Approved Uses
01
3M — Pittsboro WWTP
3M Company
Chatham
WQ0020808
35.660812°
-79.167153°
Cooling water
1. Utilization records for these sites are not required to be reported on Form NDAR-1.
WQ0024838 Version 2.1 Attachment B Page 1 of 1

FIGURE 1— SITE MAP
Town of Pittsboro — Town of Pittsboro WWTP
Permit Number: WQ0024838
Version: 2.1
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WQ0024838
Figure 1
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WQ0024838
Figure 2
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