NC0037834_Fact Sheet_20170714

Fact Sheet
NPDES Permit No. NC0O37834
Permit Writer/Email Contact: Jennifer Busam, [e-mail]
Date: October 6, 2016
Division/Branch: NC Division of Water Resources/NPDES Compliance and Expedited Permitting Unit
Fact Sheet Template: Version 08Sept2016
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2' species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
City of Winston-Salem/ Archie Elledge Wastewater Treatment Plant
Applicant Address:
P.O. Box 2511, Winston-Salem, NC 27102
Facility Address:
2801 Griffith Road
Permitted Flow:
30.0 MGD
Facility Type/Waste:
MAJOR Municipal; 92% domestic, 8% industrial
Facility Class:
Class IV
Treatment Units:
Bar screens, grit basins, primary clarifiers, aeration basins, final
clarifiers, sodium hypochlorite and bisulfite feed for disinfection and
dechlorination, lime magnesium hydroxide blend and caustic feed for
alkalinity control, centrifuges with screw conveyors, sludge digestion,
polymer and iron salt feed, odor control systems, sludge drying facility,
waste sludge lagoons, instrument flow meter
Pretreatment Program (Y/N)
Yes
Page 1 of 16

County:
Forsyth
Region
Winston-Salem
Briefly describe the proposed permitting action and facility background: The Town of Winston-Salem
has applied for NPDES permit renewal, and submitted a renewal application dated December 16, 2013.
The Town of Winston-Salem has also requested Reduction of Monitoring Frequency for Exceptional
Performers based on NPDES guidance on June 23, 2015. At the time of application submission, the
facility served a population of 179,209 residents and operated a pretreatment program with 20 Significant
Industrial Users (SIUs), of those, 10 were Categorical Industrial Users (CIUs). Update: As of October
2016, the facility served 18 SIUs with 9 CIUs, losing both Microfibres, Inc. and Piedmont Aviation
Component Services since application submission in 2013.
2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001- Salem Creek (Middle Fork Muddy Creek)
Stream Segment:
12-94-12-(4)c
Stream Classification:
C
Drainage Area (mi2)•
67.3
Summer 7Q10 (cfs)
15
Winter 7Q10 (cfs):
18
Average Flow (cfs):
65
IWC (% effluent):
76
303(d) listed/parameter:
Yes- this segment is listed as impaired for zinc on the 2016
303(d) list.
Subject to TMDL/parameter:
A nutrient reopener condition for High Rock Lake is included
as a permit condition [A. (6)]
Subbasin/HUC:
Yadkin- PeeDee; 03-07-04; (HUC: 030401011305)
USGS Topo Quad:
C17SE Winston-Salem West
3. Effluent Data Summary
Effluent data is summarized below for the period July 2011 through July 2016.
Table. Effluent Data Summary
Page 2 of 16

Parameter
Units
Average
Max
Min
Flow
MGD
16.116
38.83
8.89
BOD summer
mg/1
4.307
18
<2
BOD winter
mg/1
5.294
22
2
NH3N summer
mg/1
0.561
12.9
<0.04
NH3N winter
mg/1
0.615
9.8
0.04
TSS
mg/1
5.989
56
<2.5
pH
SU
7.07
7.7
6.3
Temperature
°C
21.399
30
12
DO
mg/1
7.886
10.9
6.5
Conductivity
umhos/cm
725.016
892
534
TN
mg/1
15.54
37.1
5.8
TP
mg/1
3.125
16.16
0.18
Fecal Coliform
#/100 ml
17.29
4300
<1
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 conductivity, temperature, fecal
coliform, dissolved oxygen, BOD, and NH3-N. Review of available instream data from STORET from
January 2011 to December 2014 indicates that the dissolved oxygen standard of 5.0 mg/1 was maintained,
and there were no significant differences between upstream (Q2510000- Salem Creek) and downstream
(Q2600000- Muddy Creek) stations. The average over the period analyzed indicated that DO was 9.20
mg/L at Q2510000 and 9.00 mg/L at Q2600000. During the critical summer months (April -October),
minimum values of 5.8 mg/L upstream (Q2510000) and 5.5 mg/L (Q2600000) occurred with averages
between 7.65 mg/L and 7.59 mg/L respectively. This draft permit maintains the same instream monitoring
requirements.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): YES
Name of Monitoring Coalition: Yadkin -Pee Dee River Basin Association
Page 3 of 16

5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility has no
enforcements in the period from July 2011- July 2016. However, the facility did receive one violation for
exceeding permit limit by 13% for Total Fluoride in November 2011 on a weekly average, and one
violation for exceeding permit limit by 44% for Total Mercury in November 2011 on a daily maximum.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 22 of 23 quarterly chronic toxicity tests, as well as all 4 second species
chronic toxicity tests.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
on February 18, 2016 reported that the facility was well maintained and operated.
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: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): NA
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
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) for instream DO protection. No changes are
proposed from the previous permit limits.
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.
Page 4 of 16

Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: There are
proposed changes to decrease the limit for winter season to 2.4 mg/L monthly average and 7.2 mg/L
weekly average based on the ammonia nitrogen waste load allocation calculation to protect for NC's
chronic ammonia criteria.
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/2 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 July 2011 and
July 2016. 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: N/A
• 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: cadmium,
cyanide, zinc, dichlorobromomethane, and chlorodibromomethane
• 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: copper and fluoride
• Summary of new limits added based on RPA: N/A
• Summary of existing limits deleted based on RPA: fluoride
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.
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
Page 5 of 16

NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Major POTW, and a chronic WET limit at 76%
effluent will continue on a quarterly frequency.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Table. Mercury Effluent Data Summary
2016
2015
2014
2013
# of Samples
14
24
24
24
Annual Average Conc. ng/L
1.5
1.5
1.3
1.6
Maximum Conc., ng/L
8.3
5.73
5.8
8.0
TBEL, ng/L
47
WQBEL, ng/L
15.9
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. However, since the facility is >2 MGD and reported quantifiable levels of mercury (> 1
ng/1), a mercury minimization plan (MMP) has been added to the permit.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: NA
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: NA
Page 6 of 16

If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Municipals (if not applicable, delete and skip to Industrials)
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/I
BODS/TSS for Monthly Average, and 45 mg/I for BODS/TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BODS/TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 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
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 7 of 16

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.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was fmalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions:
Table. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 30.0 MGD
No change
15A NCAC 2B .0505
BODS
Summer:
MA 21.0 mg/L
WA 31.5 mg/L
Winter:
MA 30 mg/L
WA 45 mg/L
Reduction to 2/Week
monitoring at influent and
effluent
WQBEL. Based on protection of DO
standard. 15A NCAC 2B.0200,
Monitoring reduction per 15A
NCAC 2B .0508(b)(1)
NH3-N
Summer:
MA 1.2 mg/L
WA 3.6 mg/L
Winter:
MA 9 mg/L
WA 27 mg/L
No change to summer
Winter:
MA 2.4 mg/L
WA 7.2 mg/L
Reduction to 2/Week
monitoring at influent and
effluent
WQBEL. Based on protection of
State WQ criteria. 15A NCAC
2B.0200, Monitoring reduction per
15A NCAC 2B .0508(b)(1)
Delayed implementation of lower
winter limits, becoming effective
after 1 year after construction
upgrades when flow path alterations
between Archie Elledge NC0037834
and Muddy Creek NC0050342 are
complete. See special condition for
schedule of compliance.
DO
DA > 6.5 mg/L
No change
WQBEL. I SA NCAC 2B.0200
TSS
MA 30 mg/L
WA 45 mg/L
Reduction to 2/Week
monitoring at influent and
effluent
TBEL. Secondary treatment
standards/40 CFR 133 / 15A NCAC
2B .0406, Monitoring reduction per
15A NCAC 2B .0508(b)(1)
Page 8 of 16

Fecal coliform
MA 200 /100mL
WA 400 /100mL
Reduction to 2/Week
monitoring at influent and
effluent
WQBEL. State WQ standard, 15A
NCAC 2B .0200, Monitoring
reduction per 15A NCAC 2B
.0508(b)(1)
Total Residual
Chlorine
DA 22.5 µg/L
DM 22.5 µg/L
WQBEL. 15A NCAC 2B.0200
Total Nitrogen
Monitor only
No change
WQBEL. 15A NCAC 2B.0200
Total Phosphorus
Monitor only
No change
WQBEL. 15A NCAC 2B.0200.
Temperature
Monitor only
No change
WQBEL. 15A NCAC 2B.0200
Conductivity
Monitor monthly
No change
WQBEL. 15A NCAC 2B.0200
Total Cadmium
Monitor quarterly
Require reporting at the
lowest PQL of 0.5 µg/L
WQBEL. 15A NCAC 2B.0200
Total Copper
Monitor monthly
Remove copper effluent
monitoring based on no
RP
WQBEL. 15A NCAC 2B.0200
Cyanide
Monitor quarterly
No change
WQBEL. 15A NCAC 2B.0200
Fluoride
MA 2,381 µg/L
WA 2,381 µg/L
Remove fluoride effluent
monitoring and limit
based on no RP
WQBEL. 15A NCAC 2B.0200
Total Zinc
Monitor monthly
Quarterly monitoring
since the receiving stream
is listed as impaired for
zinc on the 303(d) list but
does not show reasonable
potential
WQBEL. 15A NCAC 2B.0200
Chronic Toxicity
Test
Chronic limit, 76%
effluent
No change
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
pH
6 — 9 SU
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200
Total Mercury
DM 0.016 µg/L
No limit, no monitoring
based on TMDL
evaluation
WQBEL. 15A NCAC 2B.0200
Page 9 of 16

Dichlorobromome
thane
No requirement
Monitor quarterly, grab
15A NCAC 02B .0505
(c)(3)(C)(xii)
WQBEL. WQ criteria, 15A NCAC
2B .0200. 15A NCAC 02B .0505
volatile organic
Chlorodibromome
htane
No requirement
Monitor quarterly, grab
15A NCAC 02B .0505
(c)(3)(C)(xii)
WQBEL. WQ criteria, 15A NCAC
2B .0200. 15A NCAC 02B .0505
volatile organic
Total Hardness
No requirement
Add effluent and
upstream monitoring
based on the new 2016
dissolved metal standards
WQBEL. 15A NCAC 2B.0200
Effluent Pollutant
Scan
Annual
Reduce to three times per
permit cycle
40 CFR 122
Potential Instream
Sampling
Exemption
Special condition
No change
15A NCGS 143-215.1 (b)
Mercury
Minimization Plan
No requirement
Add MMP special
condition
WQBEL. Consistent with 2012
Statewide Mercury TMDL
Implementation.
(MMP)
Electronic
Reporting
No requirement
Add Electronic Reporting
Special Condition
In accordance with EPA Electronic
Reporting Rule 2015.
Nutrient Reopener
for High Rock
Lake
No requirement
Add special condition
15A NCGS 143-215.1 (b)
Schedule of
Compliance for
Ammonia
Nitrogen
No requirement
Add special condition due
to ongoing construction,
implementation of lower
limit effective 5/31/2018
15A NCGS 143-215.1 (b)
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max, DA —
Daily Average
Page 10 of 16

13. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below: NA
The following technical corrections were made to the draft permit:
• Effluent data reported for silver was all less than detection at a detection level of less than 5 µg/L
or 2 µg/L. In accordance with 15A NCAC 2B. 0500 all test procedures must produce detection
and reporting levels that are below the permit discharge requirements. All data generated must be
reported to the approved detection level or lower reporting level of the procedure. Currently,
DWR's laboratory identifies the Practical Quantitation Level (PQL) for silver at < In/L. The
allowable discharge concentration for your facility is 0.079 µg/L. Therefore, future sampling for
silver as part of the facility's Pretreatment Program and Effluent Pollutant Scan should sample
silver down to the lower reporting level of the procedure which is < 1 µg/L. No limits or
additional monitoring requirements for silver were added to the permit at this time.
• Monitoring for zinc will remain in this permit. Monitoring for copper shall continue as a part of
your Pretreatment Program. Zinc and copper are parameters of concern since the receiving stream
is listed as impaired for these parameters on the 2014 303(d) list.
• The measurement frequency and sample type for the Effluent Pollutant Scan in section A. (1)
have changed in format to direct you to footnote 11.
• Footnote 12 in A. (1) has been updated to "Effluent hardness samples shall coincide with
sampling for metals."
• The expiration date has been extended from June 30, 2019 to June 30, 2022.
• The years identified for the Effluent Pollutant Scan in A. (3) have changed from 2016, 2017, and
2018 to 2017, 2019, ad 2021 due to the permit expiration change to June 30, 2022. Section A. (3)
has been updated to the current version.
• The Effluent Pollutant Scan has been updated to include the text "Monitor and Report" in section
A. (1).
• The mercury minimization plan (MMP) in section A. (5) shall be developed by December 28,
2017 and the condition has been updated to reflect that date and the current website link.
• Required units of measurement have been included for all parameters in section A. (1).
• The parameter code for Total Phosphorus has been corrected.
• Footnote 3 in section A. (1) has been simplified regarding 2/week monitoring for select
parameters.
• Footnote 1 in section A. (1) has been updated since the December 21, 2016 eDMR deadline has
passed.
• Footnote 9 in section A. (1) has been added for the sampling detection level for cyanide
compliance.
• The monitoring frequency for Total Nitrogen and Total Phosphorus has changed in Section A. (1)
from weekly to monthly per 15A NCAC 2B .0500. Weekly samples are no longer needed for the
Yadkin Pee -Dee River Basin nutrient management strategy.
NOTE: Mr. Frank Crump, MPA, Superintendent of Wastewater for the City of Winston-Salem has
agreed to shorter permit cycles in the future and has chosen a 5-year cycle for the 2017 permit
renewal. The extended expiration of 5 years takes Archie Elledge WWTP off schedule with its
Page 11 of 16

basin. Archie Elledge WWTP shall return to schedule with an expiration date of June 30, 2029 at a
future renewal. Shorter permit cycles, less than 5 years, for future renewals will be required to
meet this goal
Summary of Proposed Permitting Actions: Corrections to Select Parameters on Basis for
Condition/Change
Basis for Condition/Change column updated with correct basis for condition/change in bold
303(d) listed/parameter:
Yes- this segment is listed as impaired for zinc on the 2016 draft
303(d) list. And, this segment is listed as impaired on the 2014
303(d) list for zinc and copper.
Analysis of loading for zinc and copper was compared for the 303(d)-listing year of 2008 and 2016.
Loading for 2008 and 2016 were not statistically different from one another at both the 0.05 and 0.10
significance level for copper and zinc.
• Effluent copper averaged 3.306 µg/L for 2008 and 3.89 µg/L in 2016 for averaged monthly
samples. Effluent copper loading was 0.469 lbs/day in 2008 and 0.569 lbs/day in 2016.
• Effluent zinc averaged 96.361 µg/L for 2008 and 91.042 µg/L in 2016 for averaged monthly
samples. Effluent zinc loading was 13.726 lbs/day in 2008 and 13.409 lbs/day in 2016.
• These two years do not have significantly different values for both copper and zinc effluent
values. Monitoring for both parameters will continue.
Table. Current Permit Conditions and Proposed Changes Addendum
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
BODS
Summer:
Reduction to 2/Week
WQBEL. Based on protection of
MA 21.0 mg/L
monitoring at influent and
DO standard, and 1994 WLA.
WA 31.5 mg/L
effluent
Monitoring reduction per 15A
Winter:
NCAC 2B .0508(b)(1) and
MA 30 mg/L
Monitoring Frequency Reduction for
WA 45 mg/L
Exceptionally Performing Facilities
10/22/2012
NH3-N
Summer:
No change to summer
WQBEL. Based on protection of
MA 1.2 mg/L
Winter:
WQ criteria. Monitoring reduction
WA 3.6 mg/L
MA 2.4 mg/L
per 15A NCAC 2B .0508(b)(1)
Winter:
WA 7.2 mg/L
MA 9 mg/L
Delayed implementation of lower
WA 27 mg/L
Reduction to 2/Week
monitoring at influent and
effluent
winter limits, becoming effective
after 1 year after construction
upgrades when flow path alterations
between Archie Elledge NC0037834
and Muddy Creek NC0050342 are
complete. See special condition for
schedule of compliance.
Page 12 of 16

DO
DA > 6.5 mg/L
No change
WQBEL. Based on 1994 WLA and
for the protection of water quality.
Total Nitrogen
Monitor only
Monitor Monthly
15A NCAC 2B .0500, weekly
monitoring no longer needed for
the nutrient management strategy
implemented in permit in 1999
Total Phosphorus
Monitor only
Monitor Monthly
15A NCAC 2B .0500, weekly
monitoring no longer needed for
the nutrient management strategy
implemented in permit in 1999
Temperature
Monitor only
No change
15A NCAC 2B .0500
Conductivity
Monitor monthly
No change
15A NCAC 2B .0500
Total Cadmium
Monitor quarterly
Require reporting at 0.5
µg/L
15A NCAC 2b .0505(e)(4) for
lower reporting level of the
procedure
Total Copper
Monitor monthly
Remove copper effluent
monitoring, Keep
monitoring in LTMP
No reasonable potential shown to
violate WQS
Parameter of concern since the
receiving stream is listed as
impaired for copper on the 2014
303(d) list
Cyanide
Monitor quarterly
No change
Parameter of concern since the
MDL is 20 µg/L and the allowable
effluent concentration is 6.6 µg/L.
The MDL is based off a 1996
Archie Elledge cyanide study and
confirmed for the 2017 renewal.
Interference from multiple source
wastewater causes detection limit
issues at the facility for cyanide.
Fluoride
MA 2,381 µg/L
WA 2,381 µg/L
Remove fluoride effluent
monitoring and limit
No reasonable potential shown to
violate WQS
Total Zinc
Monitor monthly
Quarterly monitoring
Parameter of concern since the
receiving stream is listed as
impaired for zinc on the 2014
303(d) list
Total Mercury
DM 0.016 µg/L
No limit, no monitoring
Based on the statewide 2012
TMDL, monitoring conducted
during PPAs
Page 13 of 16

Dichlorobromome
thane
No requirement
Monitor quarterly
Reasonable potential shown to
violate allowable concentration;
limited data set, no sample >
allowable concentration
Chlorodibromome
htane
No requirement
Monitor quarterly
No reasonable potential but max >
allowable concentration; limited
data set
Total Hardness
No requirement
Add effluent and
upstream monitoring
Revised water quality
standards and EPA's guidelines
on hardness dependent metals.
Potential Instream
Sampling
Exemption
Special condition
No change
15A NCAC 02B.0500 et seq.
Schedule of
Compliance for
Ammonia
Nitrogen
No requirement
Add special condition
15A NCGS 143-215.1 (b), due to
ongoing construction.
Implementation of lower limit
effective 5/31/2018
4. Instream Data Summary (Continued)
The following instream parameters were not summarized in the initial fact sheet submitted
for public notice. Additional information for instream conductivity, temperature, fecal
coliform, BOD, and NH3-N can be found following from limited STORET data for
January 2011- September 2016. The permittee is a member of the Yadkin -Pee Dee River
Basin Association and monitoring is waived in light of their participation.
Conductivity remains a parameter of concern due to the presence of industrial dischargers.
Limited data was available from STORET showed that conductivity ranged from 78 uS/cm
to 1133 uS/cm with an average of 220 uS/cm from September 30, 2013- June 9, 2016 at
downstream station Q2600000 in Muddy Creek. No upstream data was available for
Q2510000 or Q2540000 for the analysis period to compare.
Temperature remains a parameter of concern for aquatic life. Comparable data for
upstream and downstream data were not available for Q2540000 (upstream), Q2570000
(downstream) and Q2600000 (downstream). Most samples were taken on different days
and spanned different time periods.
• Temperature minimums were 2 °C at Q2540000 (upstream), 7°C at Q2570000
(downstream- Salem Creek) and 13.1 °C (downstream- Muddy Creek). These values
were for winter months, with the exception of the 2°C at station Q2540000 that was
taken in September of 2011.
• Temperature maximums were 6.9 °C at Q2540000, 13 °C at Q2570000, and 29.5 °C
at Q2540000 (presumably an error since it was taken in January).
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• Temperatures averaged 5.24 °C at Q2540000 (upstream), 10.25 °C (downstream -
Salem Creek), and 21.26 °C at Q2600000 (downstream -Muddy Creek). There are
large differences in temperature ranges among these stations that could be
attributed to flow, location, error, or variability among the monitoring stations.
Fecal coliform remains a parameter of concern for human health. Data was available for
the Q2600000 (downstream -Muddy Creek) station only. Values ranged from 23 cfu/100mL
to 67000 cfu/100m1. The geometric mean for the data obtained was 213.78 cfu/100mL,
which is above the monthly average effluent limit for the permit. It is not known if the
facility is contributing to increased instream fecal coliform, but it is unlikely given the
facility's great compliance record and no violations attributed to fecal coliform effluent
exceedances.
Note: BOD and NH3-N instream monitoring was added in 1994 per request by the
permittee in a letter dated June 10, 1994. In the next renewal cycle, these parameters
should be evaluated for removal after discussion with the permittee.
BOD and NH3-N are parameters have been a permit requirement instream since the 1994.
No BOD data was in the STORET online data warehouse for the time period of January
2011- September of 2016. Ammonia data for Q2510000 (upstream) was available. At the
station, the minimum value was 0.03 mg/L, the maximum value was 1.14 mg/L and an
average of 0.19 mg/L was recorded for May 4, 2011 through June 9, 2016. No downstream
data was available in the STORET data warehouse for comparison.
9. Antibacksliding Review (continued)
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/1V0): Yes
If YES, confirm that antibacksliding provisions are not violated:
Fluoride and Mercury limits and monitoring have been removed from this permit renewal
based on new data and no reasonable potential to violate WQS for either parameter. A
statewide mercury TMDL has been implemented and the permittee is required to develop a
mercury minimization plan during this permit cycle and sample using the low detection
method during the three required priority pollutant analyses.
10. Monitoring Requirements (continued)
The facility requested reduction in monitoring frequencies on June 23, 2015 for BOD, TSS,
NH3-N and fecal coliform. All criteria for reduced monitoring were met for each
parameter during an analysis conducted on October 6, 2016. See attachments entitled
"DWQ Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits
Page 15 of 16

for Exceptionally Performing Facilities", the data review summary for the monitoring
frequency reeducation evaluation, and the original request from the permittee in the
attachments following.
14. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary and dissolved to total metal calculator
• Dissolved Metals Implementation/Freshwater or Saltwater
• Waste load allocation for TRC and NH3-N
• Monitoring Frequency Reduction Evaluation
• Effluent Data Analysis
• Monitoring Report Violations
• 2nd Species tests
• Instream data analysis
• Mercury WQBEL/TBEL evaluation
Page 16 of 16