NC0021211_Permit (Issuance)_20220301

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481 CA
44 a \_:
ROY COOPER 1 t.
Governor r'
ELIZABETH S.BISER
Secretary y%wow.
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
March 1, 2022
Tonya A. Mann, Utilities Director
City of Graham
Graham WWTP
P.O. Drawer 357
Graham, North Carolina 27253
Subject: Final NPDES Permit Renewal
Permit NC0021211
Graham WWTP
Alamance County
Grade IV Biological WPCS
SIC Code 4952
Dear Ms. Mann:
Division personnel have reviewed and approved your application for renewal ofthe subject permit.
Accordingly, we are forwarding the attached NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007
(or as subsequently amended).
The following changes were made to the draft permit sent to you on January 13, 2022, after
the public notice:
• A footnote to the 5.0 MGD effluent limitations sheet [A. (2.)] was added that after one year
following expansion, sampling frequency for TSS may be reduced to 2/week if no
violations have occurred.
• The title for Effluent Pollutant Scans special condition [A. (6.)] was modified to include
2" species testing, and a sentence was added to clarify 2nd species toxicity testing
frequency.
The final permit has the following changes identified in the letter sent on January 13, 2022
as part of the public notice:
• The topographic map was updated to show instream monitoring locations.
• Regulatory citations have been added to the permit.
• Based on the City's request to modify the permit to authorize a plant expansion to 5.0 MGD,
review and approval of the submitted Engineering Report/Environmental Information
DEQ North CarolinallorthSalisbury DepaStreetrtment1 of Environmental Quality I I Division of Water Resources
512 1617 Mall Service Center Raleigh North Carolina 27699 1617
6011411,10.1 el Emiredmentol +� /'.. 919.707.9000

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Document for the proposed expansion, an Effluent Limits and Monitoring Requirements
sheet for 5.0 MGD has been added to the permit [See A. (2.)].
• Instream monitoring parameters have been split into a separate section [See A. (3.)].
• Parameter codes have been added to the Effluent Limitations and Monitoring Requirements
sheet [See A. (1.) and A. (2.)], Instream Monitoring Requirements [See A. (3.)] and the
Effluent Pollutant Scan [See A. (4.)] sections.
• A footnote has been added to specify that 2/week sampling shall not occur on two
consecutive days [See A. (1.), Footnote 3].
• Based on the implementation of nutrient(TN and TP) load limits,their effective dates have
been removed from the permit [See A. (1.)].
• Based on the implementation of nutrient (TN and TP) load limits, the Nitrogen
Optimization special condition has been removed from the permit.
• The Division is implementing dissolved metals standards in all permits, per the 2016
revisions to State water quality standards.As such, the NPDES Permitting Unit will need
site-specific effluent hardness data and instream hardness data, upstream of the discharge,
for each facility monitoring these metals in order to calculate permit limitations. Effluent
hardness and instream hardness sampling, upstream of the discharge, have been added to
the permit at a monitoring frequency of quarterly [See A. (1.)and A. (2.)].
• Based on limited dataset from the investigative sampling in 2019 indicating detectable
levels in the influent, monthly effluent monitoring for 1,4-Dioxane has been added to the
permit [See A. (1.) and A. (2.)].
• Based on Mercury TMDL evaluation showing mercury values reported at levels> 1 ng/L
and since the permitted flow is greater than 2 MGD, the Mercury Minimization Plan
(MMP) special condition is retained in the permit with wording modified to continue and
maintain the MMP [See A. (9.)].
• Based on DWR Instream Conductivity Monitoring Guidance, since the facility has a
pretreatment program with Significant Industrial Users (SIUs), instream (upstream and
downstream) effluent monitoring for Conductivity has been added to the permit [See
Section A. (1.)].
• Wording in Special Conditions A. (4.)Chronic Toxicity Permit Limit, and A. (5.)Effluent
Pollutant Scan have been updated to allow for electronic submittal. Please review each
special condition carefully.
• Special Condition A. (5.) — Effluent Pollutant Scan has been modified to include the
specific three years in which the Effluent Pollutant Scans shall be performed(2023, 2024,
and 2025). In addition, at the end of the Special Condition, 2nd species Toxicity Testing
Requirements for municipal permit renewals per Federal Regulations [40 CFR
122.21(j)(5)] have been added.
• A permit reopener special condition has been added to modify 1,4-Dioxane monitoring,
treatment and/or compliance [See A. (10.)].
• A special condition to monitor effluent PFAS chemicals 2/year has been added to the
permit,to be effective six(6)months after EPA has a final wastewater method in 40
CFR136 method published in the Federal Register.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs)and program reports.The requirement to continue reporting discharge monitoring
data electronically using the NC DWR's Electronic Discharge Monitoring Report(eDMR)
internet application has been added to your NPDES permit [See A. (9.)].
North Cana Department ronm Quality I Division W Rerces
r„CARJL,D
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512 North Salisburyroli Street 11617ofEnvi Mail Service ental Center I Raleigh,Northofater Carolina sou27699-1617
^+-^^�^-., a+ /'' 919.707.9000

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Pretreatment updates in response to NPDES permit renewal:
• On September 28,2022, 180 days after the effective date of this NPDES permit renewal,
the City of Graham is required to submit to the Division a written technical evaluation of
the need to revise local limits(i.e., an updated IWS/HWA-AT/L-STMP,or documentation
of why is not needed). This action may include revising, updating, or adding to the list of
Significant Industrial Users(SIUs) regardless of timeframe.
o Submit the updated Long-Term Monitoring Plan(LTMP)
• Review pollutants of concern (POCs) and update the LTMP to reflect
pollutants in industrial user permits(IUPs).
o As part of the local limits assessment, please submit the updated Headworks
Analysis(HWA).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty(30)days following receipt ofthis letter.This request must 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(6714 Mail Service Center,Raleigh,North Carolina 27699-6714).Unless
such demand is made, this decision shall be fmal and binding.
The NPDES standard conditions (Parts II, III, and IV) are the same as in your current permit
except that agency and division names have been updated. The latest version is available at
https://bit.ly/3k5NFaL and can be viewed online or downloaded as a PDF file.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect
the legal requirements to obtain other permits which may be required by the Division of Water
Resources or any other Federal, State,or Local governmental regulations.
If you have any questions concerning this permit, please contact Gary Perlmutter at (919) 707-
3611 or via email at [e-mail].
Sincerely,
c-n—ID.o'c'u, 1
Signed byy:A u- f,.''`
'—C464531431644FE...
for S. Daniel Smith, Director
Division of Water Resources,NCDEQ
Hardcopy: NPDES Files
Central Files •
eCopy: US EPA Region 4
DWR/WSS/Aquatic Toxicology Branch/Zachary Thomas and Cindy Moore
DWR/WSS/Ecosystems Branch/Mark Vander Borgh
Q 4 North Carolina Department of Environmental Quality I Division of Water Resources
DE512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
eew.e.mmunw. vi0 /"/ 919.707.9000

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
DWR/Winston-Salem Regional Office/Water Quality Operations/Lon Snider
DWR/Winston-Salem Regional Office/Public Water Supply/Eric Hudson
DWR/NPDES Industrial Permitting/Min Xiao
DWI /Trupti Desai
_E % _ North Carolina Department of Environmental Quality Division of Water Resources
'�J/� 512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617
. �a\/'/v 919.707.9000

DocuSign Envelope ID:8E082A79-8333-48A7-99 79-64 9 541 5481CA
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1,other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of Graham
is hereby authorized to discharge wastewater from a facility located at the
Graham WWTP
1204 East Gilbreath Street
Graham,NC 27253
Alamance County
to receiving waters designated as Haw River in the Cape Fear River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I,II, III and IV hereof.
This permit shall become effective April 1, 2022.
This permit and authorization to discharge shall expire at midnight on May 31, 2026.
Signed this day March 1, 2022.
Dowsbned by:
AtidUlti ittAtianith
C464531431844FE...
for S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B4 9 54 1 54 81CA
Permit NC002 121 1
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore,the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements,terms, and provisions included herein.
The City of Graham is hereby authorized to:
1. Continue to operate an existing 3.5 MGD wastewater treatment system consisting of the
following:
• Mechanical bar screen
• Grit collection
• Two primary clarifiers
• Two aeration basins
• Three digesters
• Chlorination
• Four final clarifiers
• De-chlorination
• Sand filters
• Final(post)aeration
• Lime stabilization
• Rotary drum sludge thickener
• Sludge storage
The facility is located at the Graham Wastewater Treatment Plant, 1204 East Gilbreath Street,
Graham, in Alamance County;
2. After receiving an Authorization to Construct and from the Division, construct a 5.0 MGD
wastewater treatment system; and after the Division receives the Engineer Certification of
construction completion, operate above system.
3. Discharge from said treatment works at the location specified on the attached map into Haw
River, classified WS-V;NSW waters in the Cape Fear River Basin.
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC0021211
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (3.5 MGD)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Grade IV Biological Water Pollution
Control System [1 5A NCAC 08G .0302]
a. During the period beginning on the effective date of the permit and lasting expansion to 5.0 MGD
(and receipt of the Engineer's Certificate of completion) or until expiration, the Permittee is
authorized to discharge treated domestic and industrial wastewater from Outfall 001. Such
discharges shall be limited and monitored I by the Permittee as specified below:
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location
or
Flow 50050 3.5 MGD Continuous Recording Influe Effluent t
nt
Total Monthly Flow 82220 Monitor and Report Monthly Recording Influent or
(MG/mo) or Calculated Effluent
BOD,5-day,20°C 2 12.0 mg/L 18.0 mg/L 2/week 3 Composite Influent and
April 1 —October 31 Effluent
C0310
BOD,5-day,20°C 2 24.0 mg/L 36.0 mg/L 2/week 3 Composite Influent and
November 1 —March 31 Effluent
Total Suspended Solids C0530 30.0 mg/L 45.0 mg/L 2/week 3 Composite
Influent and
(TSS)2 g 9 p Effluent
Ammonia(NH3 as N) 4.0 mg/L 12.0 mg/L 2/week 3 Composite Effluent
April 1 —October 31 C0610
Ammonia(NH3 as N) 8.0 mg/L 24.0 mg/L 2/week 3 Composite Effluent
November 1 —March 31
Dissolved Oxygen(DO) 00300 Daily Average Z 5.0 mg/L Daily Grab Effluent
pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab Effluent
Temperature(°C) 00010 Monitor and Report Daily Grab Effluent
Fecal Coliform 31616 200/100 mL 400/100 mL 2/week 3 Grab Effluent
(geometric mean)
Total Residual Chlorine 50050 28.0pg/L DailyGrab Effluent
(TRC)4
Conductivity(pmhos/cm) 00094 Monitor and Report Daily Grab Effluent
TKN(mg/L)5 00625 Monitor and Report Weekly Composite Effluent
NO2-N+NO3-N(mg/L)5 00630 Monitor and Report Weekly Composite Effluent
Total Nitrogen(TN)(mg/L)5 C0600 Monitor and Report Weekly Calculated Effluent
TN Load e, QM600 Monitor and Report(Ib/mo) Monthly Calculated Effluent
QY600 56,315 lb/yr Annually
Total Phosphorus(TP) C0665 Monitor and Report Weekly Composite Effluent
(mg/L)
TP Load 6,7QM665 Monitor and Report(lb/mo) Monthly Calculated Effluent
QM665 7,079 lb/yr Annually
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC002121 1
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location 2
Total)a Hardness(as CaCO3) 00900 Monitor and Report Quarterly Grab Effluent
1,4-Dioxane 9 82388 Monitor and Report Monthly Grab Effluent
Chronic Toxicity 10 TGP3B Quarterly Composite Effluent
Effluent Pollutant Scan NC01 Monitor and Report Footnote 11 Footnote 11 Effluent
Footnotes:
1. Submit discharge monitoring reports electronically using NC DWR's eDMR application system. See A.(11.).
2. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15%of the respective influent value(85%
removal).
3. Sampling 2/week must occur on any two non-consecutive days during the calendar week.
4. The facility shall monitor TRC when using chlorination for disinfection. The Division shall consider all effluent total
residual chlorine values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall
continue to record and submit all values reported by a North Carolina certified laboratory(including field-certified),even
if these values fall below 50 µg/L.
5. TKN is Total Kjeldahl Nitrogen;NO3-N and NO2-N are Nitrate and Nitrite Nitrogen,respectively.TN=TKN+NO2-N
+NO3-N.
6. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See A. (8.),
Calculation of Total Nitrogen or Total Phosphorus Loads.
7. Compliance with mass limits shall be determined in accordance with A. (6.)Nutrient Allocations,and A. (7.) Annual
Limits for Total Nitrogen or Total Phosphorus.
8. Effluent Total Hardness sampling should be performed in conjunction with testing for hardness-dependent metals
(cadmium,copper,lead,nickel, silver,and zinc).
9. Samples must be reported to a minimum of PQL< 1 µg/L using an appropriate 40 CFR Part 136 method.
10. Whole Effluent Toxicity will be monitored using the Pass/Fail Ceriodaphnia dubia at 14%effluent. Samples shall be
taken in March,June, September and December. See A.(4.).
11. The Permittee shall perform three Effluent Pollutant Scans during the term of this permit. See A.(5.).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC0021211
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (5.0 MGD)
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Grade IV Biological Water Pollution
Control System [15A NCAC 08G .0302]
a. During the period beginning upon receipt of the Engineer's Certificate of completion for expansion
to 5.0 MGD and lasting until expiration, the Permittee is authorized to discharge treated domestic
and industrial wastewater from Outfall 001. Such discharges shall be limited and monitored r by
the Permittee as specified below:
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location
r
Flow 50050 5.0 MGD Continuous RecordingInfluent
Effluent
Total Monthly Flow 82220 Monitor and Report Monthly Recording Influent or
(MG/mo) or Calculated Effluent
BOD,5-day,20°C 2 8.4 mg/L 12.6 mg/L Daily Composite Influent and
April 1 —October 31
C0310 Effluent
BOD,5-day,20°C 2 16.8 mg/L 25.2 mg/L Daily Composite Influent and
November 1 —March 31 Effluent
Total Suspended Solids C0530 30.0 mg/L 45.0 mg/L Dail 3 Composite Influent and
(TSS)2 g g y Effluent
Ammonia(NH3 as N) 2.8 mg/L 8.4 mg/L Daily Composite Effluent
April 1 —October 31
C0610
Ammonia(NH3 as N) 5.6 mg/L 16.8 mg/L Daily Composite Effluent
November 1 —March 31
Dissolved Oxygen(DO) 00300 Daily Average z 5.0 mg/L Daily Grab Effluent
pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab Effluent
Temperature(°C) 00010 Monitor and Report Daily Grab Effluent
Fecal Coliform 31616 200/100 mL 400/100 mL Daily Grab Effluent
(geometric mean)
Total Residual Chlorine 50050 28.0 /L DailyGrab Effluent
(TRC)4 µ9
Conductivity(pmhos/cm) 00094 Monitor and Report Daily Grab Effluent
TKN(mg/L)5 00625 Monitor and Report Weekly Composite Effluent
NO2-N+NO3-N(mg/L)5 00630 Monitor and Report Weekly Composite Effluent
Total Nitrogen(TN)(mg/L)5 C0600 Monitor and Report Weekly Calculated Effluent
TN Load s, QM600 Monitor and Report(Ib/mo) Monthly Calculated Effluent
QY600 56,315 lb/yr Annually
Total Phosphorus(TP) C0665 Monitor and Report Weekly Composite Effluent
(mg/L)
TP Load 5,7QM665 Monitor and Report(Ib/mo) Monthly Calculated Effluent
QM665 7,079 lb/yr Annually
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC002121 1
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location 2
Total Hardness(as CaCO3) 00900 Monitor and Report Quarterly Grab Effluent
1,4-Dioxane 9 82388 Monitor and Report Monthly Grab Effluent
Chronic Toxicity 10 TGP3B Quarterly Composite Effluent
•
Effluent Pollutant Scan NC01 Monitor and Report Footnote 11 Footnote 11 Effluent
Footnotes:
I. Submit discharge monitoring reports electronically using NC DWR's eDMR application system. See A.(11.).
2. The monthly average effluent BOD5 and TSS concentrations shall not exceed 15%of the respective influent value(85%
removal).
3. After one(1)year from expansion to 5.0 MGD,sampling frequency may be reduced to 2/week for TSS if no violations
have occurred.
4. The facility shall monitor TRC when using chlorination for disinfection. The Division shall consider all effluent total
residual chlorine values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall
continue to record and submit all values reported by a North Carolina certified laboratory(including field-certified),even
if these values fall below 50 µg/L.
5. TKN is Total Kjeldahl Nitrogen;NO3-N and NO2-N are Nitrate and Nitrite Nitrogen,respectively.TN=TKN+NO2-N
+NO3-N.
6. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See A.(8.),
Calculation of Total Nitrogen or Total Phosphorus Loads.
7. Compliance with mass limits shall be determined in accordance with A.(6.)Nutrient Allocations,and A. (7.)Annual
Limits for Total Nitrogen or Total Phosphorus.
8. Effluent Total Hardness sampling should be performed in conjunction with testing for hardness-dependent metals
(cadmium,copper,lead,nickel,silver,and zinc).
9. Samples must be reported to a minimum of PQL<1 µg/L using an appropriate 40 CFR Part 136 method.
10. Whole Effluent Toxicity will be monitored using the Pass/Fail Ceriodaphnia dubia at 19%effluent. Samples shall be
taken in March,June, September and December. See A.(4.).
11. The Permittee shall perform three Effluent Pollutant Scans during the term of this permit. See A.(5.).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-8495415481CA
Permit NC002121 1
A.(3.) INSTREAM MONITORING REQUIREMENTS [15A NCAC 02B .0200]
INSTREAM CHARACTERISTIC
MEASUREMENT FREQUENCY SAMPLE TYPE SAMPLE LOCATION I
Parameter Code
June-September 3/week Upstream,
Dissolved Oxygen(DO),mg/L 00300 Grab Downstream
October-May 1/week
June-September 3/week Upstream,
Temperature(°C) 00010 Grab Downstream
October-May 1/week
June-September 3/week Upstream,
Conductivity(pmhos/cm)2 00094 Grab Downstream
October-May 1/week
Total Hardness(as CaCO3), 00900 1/quarter Grab U
mg/L2
Footnotes:
1. Upstream is at Highway 54; Downstream is at NCSR 2158. Instream monitoring for DO, Temperature and
Conductivity is provisionally waived in light of the Permittee's participation in the Upper Cape Fear River Basin
Association (UCFRBA). Instream monitoring shall be immediately reinstated and the Division shall be notified
immediately should the Permittee end its participation in the UCFRBA.
2. The Permittee shall sample instream hardness, upstream of the facility's discharge. The sample shall be
representative of the hardness in the receiving stream.
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DocuSign Envelope ID 8E082A79-8333-48A7-9979-B495415481 CA
Permit NC0021211
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(Quarterly) [15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 14% at 3.5 MGD and 19% at 5.0
MGD.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"(Revised December 2010, or
subsequent versions) or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised December 2010, or subsequent versions). The tests will be performed during the months of
March, June, September, and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility.Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted fmal effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple-concentration testing shall be performed at a minimum, in
each of the two following months as described in"North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised-December 2010, or subsequent versions).
All toxicity testing results required as part of this permit condition will be entered electronically using
the Division's eDMR system for the months in which tests were performed, using the parameter code
TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,NC 27699-1621
Or,results can be sent to the email,[e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required,the permittee will complete the information located at the top of the aquatic toxicity(AT)test
form indicating the facility name, permit number, pipe number, county, and the month/year of the
report with the notation of"No Flow"in the comment area of the form. The report shall be submitted
to the Water Sciences Section at the address cited above.
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DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC0021211
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is based
on the toxicity testing quarter, which is the three-month time interval that begins on the first day of the
month in which toxicity testing is required by this permit and continues until the final day of the third
month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
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DocuSign Envelope ID 8E082A79-8333-48A7-9979-B4 9 541 54 81CA
Permit NC0021211
A. (5.) EFFLUENT POLLUTANT SCAN [G.S. 143-215.1(b)]
The Permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2023,2024,and 2025.Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria. Samples should be
collected with one quarterly toxicity test each year, and must represent seasonal variation [i.e., do not
sample in the same quarter every year]. Unless otherwise indicated, metals shall be analyzed as "total
recoverable."
Ammonia(as N) C0610 Trans-1,2-dichloroethylene 34546 Bis(2-chloroethyl)ether 34273
Chlorine(total residual,TRC) 50060 1,1-dichloroethylene 34501 Bis(2-chloroisopropyl)ether 34283
Dissolved oxygen 00300 1,2-dichloropropane C0541 Bis(2-ethylhexyl)phthalate CO100
Nitrate/Nitrite 00630 1,3-dichloropropylene 77163 4-bromophenyl phenyl ether 34636
Kjeldahl nitrogen 00625 Ethylbenzene 34371 Butyl benzyl phthalate 34292
Oil and grease 00556 Methyl bromide 34413 2-chloronaphthalene 34581
Phosphorus C0665 Methyl chloride 34418 4-chlorophenyl phenyl ether 34641
Total dissolved solids 70295 Methylene chloride 34423 Chrysene 34320
Hardness 00900 1,1,2,2-tetrachloroethane 81549 Di-n-butyl phthalate 39110
Antimony 01097 Tetrachloroethylene 34475 Di-n-octyl phthalate 34596
Arsenic 01002 Toluene 34010 Dibenzo(a,h)anthracene 34556
Beryllium 01012 1,1,1-tichloroethane 34506 1,2-dichlorobenzene 34536
Cadmium 01027 1,1,2-trichloroethane 34511 1,3-dichlorobenzene 34566
Chromium C0034 Trichloroethylene 39180 1,4-dichlorobenzene 34571
Copper 01042 Vinyl chloride 39175 3,3-dichlorobenzidine 34631
Lead 01051 Acid-extractable compounds: Diethyl phthalate 34336
Mercury(Method 1631E) COMER P-chloro-m-cresol 34452 Dimethyl phthalate 34341
Nickel 01067 2-chlorophenol 34586 2,4-dinitrotoluene 34611
Selenium 01147 2,4-dichlorophenol 34601 2,6-dinitrotoluene C0626
Silver 01077 2,4-dimethylphenol 34606 1,2-diphenylhydrazine 34346
Thallium 01059 4,6-dinitro-o-cresol 34657 Fluoranthene C0376
Zinc 01092 2,4-dinitrophenol 34616 Fluorene 34381
Cyanide 00720 2-nitrophenol 34591 Hexachlorobenzene C0700
Total phenolic compounds 32730 4-nitrophenol 34646 Hexachlorobutadiene C0702
Volatile organic compounds: Pentachlorophenol 39032 Hexachlorocyclo-pentadiene 34386
Acrolein 34210 Phenol 34694 Hexachloroethane 34396
Acrylonitrile 34215 2,4,6-trichlorophenol 34621 Indeno(1,2,3-cd)pyrene 34403
Benzene 34030 Base-neutral compounds: Isophorone 34408
Bromoform 32104 Acenaphthene 34205 Naphthalene 34696
Carbon tetrachloride 32102 Acenaphthylene 34200 Nitrobenzene 34447
Chlorobenzene 34301 Anthracene CO220 N-nitrosodi-n-propylamine 34428
Chlorodibromomethane 34306 Benzidine 39120 N-nitrosodimethylamine 34438
Chloroethane 85811 Benzo(a)anthracene C0526 N-nitrosodiphenylamine 34433
2-chloroethyl vinyl ether 34576 Benzo(a)pyrene 34247 Phenanthrene 34461
Chloroform 32106 3,4 benzofluoranthene 34230 Pyrene 34469
Dichlorobromomethane 32101 Benzo(ghi)perylene 34521 1,2,4-trichlorobenzene C0551
1,1-dichloroethane 34496 Benzo(k)fluoranthene 34242
1,2-dichloroethane 32103 Bis(2-chloroethoxy)methane 34278
Page 10 of 19

DocuSign Envelope ID.8E082A79-8333-48A7-9979-B4 9541 54 81CA
Permit NC002121 1
Reporting. Test results shall be reported electronically using the Division's eDMR system or on DWR
Form DMR-PPA-1(or on a form approved by the Director) by December 31' of each designated
sampling year. The Permittee must at least report completion ofthe test in the eDMR system by entering
"1"or"Y" for parameter code NC01 -Annual Pollutant Scan. If utilizing the DWR Form submit to the
following address:
NC DEQ/DWR/NPDES Files, 1617 Mail Service Center,Raleigh, North Carolina 27699-1617.
Or the form may be uploaded at: https://edocs.deq.nc.gov/Forms/NPDES_WW-EDMR-Supplemental-
Form
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that
Municipal facilities that are subject to the Effluent Pollutant Scan requirements listed above are also
subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.21(j)(5).
The US EPA requires four (4) toxicity tests for a test organism other than the test species currently
required in this permit. The multiple species tests should be conducted either quarterly for a 12-month
period prior to submittal of the permit renewal application, or four tests performed at least annually in
the four and one half year period prior to the application. Samples should be collected with one quarterly
toxicity test each year,and must represent seasonal variation [i.e.,do not sample in the same quarter
every year]. These tests shall be performed for acute or chronic toxicity, whichever is specified in this
permit. The multiple species toxicity test results shall be filed with the Aquatic Toxicology Branch at
the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Or,results can be sent to the email: [e-mail].
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E
(Toxicity Testing Data) of EPA Municipal Application Form 2A, when submitting the permit renewal
application to the NPDES Permitting Unit.
Page 11 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481 CA
Permit NC002 1211
A. (6.) NUTRIENT ALLOCATIONS [15A NCAC 02B .0270]
a. The following tables list the Total Nitrogen (TN) and Total Phosphorus (TP) allocations and offset
credits(if any)assigned to,acquired by,or transferred to the Permittee in accordance with the Jordan
Lake nutrient management rule(15A NCAC 02B .0270)and the status of each as of permit issuance.
The allocations are not enforceable limits nor do they supersede any TN or TP limit established
elsewhere in this permit or in the NPDES permit of a compliance association of which the Permittee
is a Co-Permittee Member.
Total Nitrogen Allocation
ALLOCATION AMOUNT1
ALLOCATION
TYPESOURCE DATE STATUS
Delivered(Ib/yr) Discharge(Ib/yr)
Base Assigned by Rule 8/11/09 45,615 56,315 Active
(T15A NCAC 02B.0270)
TOTAL 45,615 56,315 Active
Footnote:
1. Nitrogen Transport Factor=66%
Total Phosphorus Allocation
ALLOCATION ALLOCATION AMOUNT1
TYPESOURCE DATE STATUS
Delivered(Ib/yr) Discharge(Ib/yr)
Base Assigned by Rule 8/11/09 5,026 7,079 Active
(T15A NCAC 02B.0270)
TOTAL 5,026 7,079 Active
Footnote:
1. Phosphorus Transport Factor=56%
b. Any addition, deletion,or modification of the listed allocation(s)(other than to correct typographical
errors)or any change in status of any ofthe listed allocations shall be considered a major modification
of this permit and shall be subject to the public review process afforded such modifications under
state and federal rules.
Page 12 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B4 9 541 54 81CA
Permit NC0021211
A. (7.) ANNUAL LIMITS FOR TOTAL NITROGEN OR TOTAL PHOSPHORUS
[15A NCAC 02B .0270]
a. Total Nitrogen (TN) and Total Phosphorus(TP) allocations and load limits for NPDES dischargers
in the Jordan Lake watershed are annual limits and apply on a calendar year basis.
b. For any given calendar year, the Permittee shall be in compliance with the annual TN(or TP) Load
limit in this Permit if:
i. the Permittee's annual TN(or TP)Load is less than or equal to the effective limit, or
ii. the Permittee is a Co-Permittee Member of a compliance association.
c. If the Permittee is not a co-permittee member of a compliance association and the Permittee's
cumulative annual TN(or TP)discharge exceeds the effective TN(or TP)Load Limit in this permit
at any point during the calendar year, the Permittee is in violation of its TN (or TP) Load limit for
the remaining days of that year, and each day of such continuing violation shall constitute a separate
violation.
d. The TN(or TP)Load limit in this Permit may be modified as the result of allowable changes in the
Permittee's allocations.
i. Allowable changes include those resulting from purchase of TN (or TP) allocation from an
authorized mitigation banker,the Ecosystem Enhancement Program,or other source allowed
under applicable regulations; purchase, sale, trade, or lease of allocation between the
Permittee and other dischargers; regionalization; and other transactions approved by the
Division.
ii. The Permittee may request a modification of the TN (or TP) Load limit in this Permit to
reflect allowable changes in its allocation(s).
A. Upon receipt of timely and proper application, the Division will modify the permit
as appropriate and in accordance with state and federal program requirements.
B. Changes in TN (or TP) limits become effective on January 1 of the year following
permit modification. The Division must receive application no later than August 31
for changes proposed for the following calendar year.
iii. Any requests for modification should be sent to:
NC DEQ/DWR/NPDES Programs
Attn: Jordan Lake Watershed Coordinator
1617 Mail Service Center
Raleigh,NC 27699-1617
e. If the Permittee is a member and co-permittee of an approved compliance association on January 1
of a given year, its TN and TP discharges during that year are governed by that association's group
NPDES permit and the limits therein.
i. The Permittee shall be considered a Co-Permittee Member for any given calendar year in
which it is identified as such in Appendix A of the association's group NPDES permit.
ii. Association roster(s) and members' TN and TP allocations will be updated annually and in
accordance with state and federal program requirements.
Page 13 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481 CA
Permit NC0021211
iii. If the Permittee intends to join or leave a compliance association, the Division must be
notified of the proposed action in accordance with the procedures defined in the association's
NPDES permit.
A. Upon receipt of timely and proper notification,the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
B. Membership changes in a compliance association become effective on January 1 of
the year following modification of the association's permit.
f. The TN and TP monitoring and reporting requirements in this Permit remain in effect throughout the
term of the Permit and are not affected by the Permittee's membership in a compliance association.
A. (8.) CALCULATION OF TOTAL NITROGEN AND TOTAL PHOSPHORUS LOADS
[15A NCAC 02B .0270]
a. The Permittee shall calculate monthly and annual TN and TP Loads as follows:
i. Monthly TN(or TP)Load(lb/mo)=TN(or TP) x TMF x 8.34
where:
TN or TP = the average Total Nitrogen or Total Phosphorus concentration(mg/L)of
the composite samples collected during the month;
TMF = the Total Monthly Flow of wastewater discharged during the month
(MG/mo);and
8.34 = conversion factor, from(mg/L x MG)to pounds
ii. Annual TN(or TP)Load(lb/yr)=Sum of the 12 monthly TN(or TP)Loads for the calendar year.
b. The Permittee shall report monthly Total Nitrogen and Total Phosphorus results (mg/L and lb/mo) in the
appropriate discharge monitoring report for each month and shall report each calendar year's results (lb/yr)
with the December report for that year.
A. (9.) MERCURY MINIMIZATION PLAN(MMP) [G.S. 143-215.1 (b)]
The Permittee shall maintain and continue to implement the Mercury Minimization Plan (MMP)
developed in the previous permit term. The MMP shall continue to be available for inspection on-site.
The MMP should place emphasis on identification of mercury contributors and goals for reduction.
Results shall be summarized and submitted with the next permit renewal. Performance of the MMP will
meet the requirements of the TMDL(Total Maximum Daily Load)for mercury approved by USEPA on
October 12,2012,unless and until a Waste Load Allocation specific to this facility is developed and this
NPDES permit is amended to require further actions to address the Waste Load Allocation.
Page 14 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC002121 1
A. (10.) 1,4-DIOXANE RE-OPENER G.S. 143-215.1 (b)]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North
Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II, Sections B-
12 and B-13 of this permit,the Director of DWR may reopen this permit to modify permit requirements
to address 1,4-Dioxane monitoring, treatment and/or compliance upon evaluation of collected
monitoring data for potential effluent limits.
A. (11.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports(DMRs)and program
reports. The fmal NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)I
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit monthly DMRs electronically using the internet.The eDMR system may
be accessed at:https://deq.nc.gov/about/divisions/water-resources/edmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access,then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms(MR 1, 1.1,2,3)or alternative
forms approved by the Director.Duplicate signed copies shall be submitted to the following address:
NC DEQ/Division of Water Resources/Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Page 15 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC0021211
See"How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports;and
• Clean Water Act (CWA) Section 316(b)Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting"section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9),the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program)that is the designated entity
for receiving electronic NPDES data[see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-po llutant-discharge-
elim inat ion-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the"Reporting Requirements"section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to
the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed five(5)years and shall thereupon expire.At such time,monitoring
Page 16 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481CA
Permit NC0021211
data and reports shall be submitted electronically to the Division unless the Permittee re-applies for
and is granted a new temporary electronic reporting waiver by the Division. Approved electronic
reporting waivers are not transferrable. Only permittees with an approved reporting waiver request
may submit monitoring data and reports on paper to the Division for the period that the approved
reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part
II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system.For more information on North Carolina's
eDMR system,registering for eDMR and obtaining an eDMR user account,please visit the following
web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility offines and imprisonment for knowing violations."
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions.These records or copies shall be maintained for a period of at least three(3)years from
the date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 17 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-8495415481 CA
Permit NC0021211
A. (12.)PFAS MONITORING REQUIREMENT [G.S. 143-215.1(b.)]
This reporting requirement for the per- and polyfluoroalkyl substances (PFAS) parameters listed
under Table 1 of the Final Method 1633 takes effect the first full calendar quarter following six(6)
months after EPA publishes a 40 CFR part 136 Final PFAS Method for wastewater in the Federal
Register. Monitoring will be at a frequency of 2/year.
Find the current parameters listed under Table 1 of the August 2021 Draft Method 1633 Analysis of
Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by
LC-MS/MS at:
https://www.epa.gov/system/files/documents/2021-09/method 1633 draft aug-2021.pdf
•
Page 18 of 19

DocuSign Envelope ID:8E082A79-8333-48A7-9979-B495415481 CA
Permit NC0021211
r'
Upstream i
.• :i ,
�} 1.
\. r , j. .,+
• Graham WWTP
&Outfall 001 }~ ' 'IC ' "'
})
1 \ it • / u //l lljll
;-f:,')." -d:-. .1:,:k".-s••*.-... .:. - - \ 44/. "i
(-) -.r
. ` Downstream -;,e'"
City of Graham WWTP— NC0021211 •
1
USGS Quad:C21 SE i Mebane,NC Lat.: 36'02'44"N
Receiving Stream: Haw River Long.:79'22'06"W
Stream Class:WS-V;NSW Sub-basin:03-06-02
Basin:Cape Fear HUC:03030002 N Alamance County
Page 19 of 19

Fact Sheet Addendum
Comments and responses to Graham WWTP NPDES permit renewal draft.
A set of comments were sent by the City of Graham on 2/4/2022;these and the responses by DWR are as
follows:
Comment: The City requests "that the monthly monitoring requirement for 1,4-Dioxane be qualified to
end after a 2-year period (24 samples collected) as there is no reasonable potential to exceed the water
quality standard."
Response: The permit reopener for 1,4-Dioxane special condition [A. (10.)] adequately addresses this
comment; no further changes have been made.
Comment:"Plant influent wastewater characteristics are not anticipated to change significantly upon the
expansion of the plant from a 3.5 mgd capacity to a 5.0 mgd.Additionally, plant treatment processes will
be modernized during the expansion effort and WWTP effluent quality is anticipated to be improved
following the expansion. Request that monitoring frequency reduction from daily to 2 x week sampling
for BOD,TSS,Ammonia,and Fecal Coliform be initiated one year after the 5.0 mgd expansion if the WWTP
maintains compliance with all monitoring frequency reduction standards."
Response:Based on the proposed change of disinfection from chlorination to UV at 5.0 MGD, monitoring
frequency reduction of Fecal Coliform will be considered after three years of data have accumulated under
the UV treatment or at the next permit renewal. Similarly, based on the change in limits for BOD and
Ammonia at 5.0 MGD,monitoring frequency reduction for these parameters will be considered after three
years of data have accumulated under the 5.0 MGD limits or at the next permit renewal. Since limits for
TSS at 5.0 MGD have not changed,monitoring frequency reduction will be considered after one year data
accumulation after expansion to 5.0 MGD. A footnote to this effect has been added to the 5.0 MGD
effluent limitations page[A. (2.), Footnote 3].
Comment:The City requests"that BOD sampling be reduced from daily frequency to 3 x week frequency
given that the plant is already meeting monitoring frequency reduction standards prior to modernization
efforts.This will still provide 3 weekly samples to characterize BOD in the effluent."
Response: BOD monitoring is already set at 2/week at 3.5 mgd.
Comment: The City requests "that effluent conductivity sampling be reduced from daily frequency to
weekly.This will provide 52 results in a calendar year than can be used to evaluate effluent conductivity."
Response: Effluent conductivity frequency is set by rule 15A NCAC 02B .0508, and conductivity is not
among the target parameters listed in the Division's Guidance Regarding the Reduction of Monitoring
Frequencies in NPDES Permits for Exceptionally Performing Facilities(DWQ 2012). No changes have been
made.
Comment: "Request that toxicity testing be reduced from quarterly to annually given that the instream
waste concentration calculated is only 14%(at 3.5 mgd)and 19%(at 5.0 mgd)."
Response:Quarterly toxicity monitoring is designed to capture any seasonal differences as well as provide
a screening tool to assess effluent quality. Any reduction in toxicity monitoring frequency may miss
potential events of effluent quality affecting instream quality.And in addition,the Division expects toxicity

Fact Sheet Addendum
to be performed in conjunction with the effluent pollutant scan and should represent seasonal variability.
No changes have been made.