NC0026565_Fact Sheet_20220406

Fact Sheet
NPDES Permit No. NCOO26565
Permit Writer/Email Contact Gary Perlmutter, [e-mail]:
Date: April 6, 2022
Division/Branch: NC Division of Water Resources / NPDES Municipal Permitting Unit
Fact Sheet Template: Version 09Jan2017
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 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant / Facility Name:
Town of Ramseur / Ramseur WWTP
Applicant Address:
P.O. Box 545 / 724 Liberty Street, Ramseur, NC 27316
Facility Address:
4735 Roundleaf Rd, Ramseur, NC 27316
Permitted Flow:
0.480 MGD
Facility Type/Waste:
MAJOR Municipal / 94.8% domestic, 5.2% industrial'
Facility Class:
Grade II
Treatment Units:
Aeration Basin, Clarifier, Polishing Pond (Lagoon), Chlorination,
Dechlorination, Sludge Storage (Lagoon)
Pretreatment Program (Y/N)
Yes
County:
Randolph
Region
Winston-Salem
Footnote:
1. Based on 0.0250 MGD permitted industrial flow.
Briefly describe the proposed permitting action and facility background: The Town of Ramseur had
applied for an NPDES permit renewal for its WWTP, received by DWR on November 5, 2020. Review of
the application found it to be complete. This 0.480 MGD facility serves the Town of Ramseur (pop. —1690).
Page 1 of 12

The WWTP is classified as a POTW that treats domestic and industrial wastewater with an active
pretreatment program involving one Significant Industrial User (SIU). The pretreatment program includes
a Short -Term Monitoring Program (STMP) involving 14 Parameters of Concern (POCs).
2. Receiving Waterbody Information
Receiving Waterbody Information
Outfall(s) / Receiving Stream(s):
Outfall 001 / Deep River
Stream Segment:
17-(10.5)d2
Stream Classification:
C
Drainage Area (mi2):
349
Summer 7Q10 (cfs)
11
Winter 7Q10 (cfs):
23
30Q2 (cfs):
-
Average Flow (cfs):
350
IWC (% effluent):
6
2020 NC 303(d) listed / parameter:
Copper
Subject to TMDL / parameter:
State-wide Mercury TMDL
Basin / Sub -basin / HUC:
Cape Fear / 03-06-09 / 03030003
USGS Topo Quad:
E20NW / Ramseur, NC
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized in Table 1 for the period of June 2017-May 2021.
Table 1. Effluent Data Summary Outfall 001.
Parameter
Units
Average
Max
Min
Permit Limit 1
Flow'
MGD
0.194
1.602
0.027
MA = 0.480
BOD5
mg/L
11.9
146
< 2
MA = 30.0
WA = 45.0
BOD removal
%
94.5
99.1
83.0
> 85
TSS
mg/L
10.6
66
< 7.5
MA = 30.0
WA = 45.0
TSS removal
%
94.8
99._
78.2
> 85
NH3-N (summer)
mg/L
7.8
21.6
0.3
MA = 18.0
WA = 35.0
NH3-N (winter)
mg/L
8.3
19.8
0.4
Monitor & Report
DO
mg/L
6.1
7.8
5.8
DA > 5.0
Page 2 of 12

Parameter
Units
Average
Max
Min
Permit Limit 1
pH
S.U.
6.9
7.5
6.7
6.0 — 9.0
Temperature
°C
18.6
34.0
3.0
Monitor & Report
Fecal Coliform
(geometric mean)
#/100 mL
1.7
3200
< 1
MA = 200
WA = 400
TRC
µg/L
All non -detects at < 15, < 10 and < 1
DM = 28 3
Total Nitrogen
(NO2 + NO3 + TKN)
mg/L
10.74
24.35
3.47
Monitor & Report
Total Phosphorus
mg/L
2.79
6.77
1.37
Monitor & Report
Total Copper
µg/L
303
3792
4
Monitor & Report
Total Mercury
ng/L
1.3
3.5
< 1.0
Monitor & Report
1 MA = Monthly Average, WA = Weekly Average, DM = Daily Maximum; DA = Daily Average.
2 Average for CY2020 = 0.210 MGD, 44% of design flow.
3 Values < 50 µg/L considered compliant.
High values of BOD in October 2017 and TSS in July 2018 were caused by stratification and algal growth
in the lagoon, respectively. See attached DMR notes.
Units for Total Copper were not specified in the current permit, which resulted in values being expressed
in the default unit of mg/L in submitted DMRs. Data reviewed in the original lab reports are expressed in
µg/L. Because the DWR database is linked to the current permit, correction to the units for this parameter
cannot be made until the next permit is issued.
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/L 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 (DO) and Temperature
(Conductivity and Fecal Coliform were removed in the 2007 permit based on Division guidance). Instream
monitoring locations in the current permit include one upstream at — 50 ft upstream of the outfall and one
downstream at NCSR 2628, — 4.0 miles from the outfall.
Instream monitoring is waived so long as the Permittee is a member of the Upper Cape Fear River Basin
Association (UCFRBA). The nearest UCFRBA monitoring stations are B5070000 - DEEP RIVER AT SR
2615 AT RAMSEUR (upstream; —0.75 miles from the outfall) and B5100000 - DEEP RIVER AT SR 2628
HINSHAW TOWN RD NEAR PARKS CROSSROADS (downstream; same as in the permit). Instream
data from June 2017—December 2020 were obtained from the DWR Monitoring Coalition Coordinator and
compared with concurrent effluent data, and against state water quality standards where applicable. Data
were tested statistically for significant differences among means using Single Factor ANOVA; where
differences were detected, follow-up testing was conducted using two -sample t tests. Level of significance
is 0.05. Instream data review findings for each parameter are summarized in Table 2 below.
Page 3 of 12

Table 2. Instream and concurrent effluent monitoring summary statistics.
Parameter
Upstream
Downstream
Effluent
Standard
Dissolved Oxygen (DO),
mg/L
Average = 8.4
Range: 6.2-13.2
Average = 8.2
Range: 5.9-12.8
Average = 6.1
Range: 5.8-6.7
5.0
Temperature, °C
Average = 20.1
Range: 2.7-31.8
Average = 19.9
Range: 2.2-30.7
Average = 20.6
Range: 3.0-32.0
32.0
Specific Conductance,
µS/cm
Average = 182
Range: 65-406
Average = 179
Range: 66-423
NA
NA
Dissolved Oxygen (DO) — DO remains in the permit as a parameter of concern for aquatic life. Reviewed
instream DO data showed seasonal variation with summer lows and winter highs at both instream locations.
Instream summer minima were above the 5 mg/L daily average water quality standard for non -trout waters
(15A NCAC 02B .0211) at both locations. No statistically significant differences were detected between
average temperature values of the two instream locations. While the overall average of the effluent DO was
lower than that instream, it does not seem to affect the instream DO.
Temperature Temperature remains in the permit as a parameter of concern for aquatic life. Reviewed
instream temperature data showed seasonal patterns of summer highs and winter lows at both locations.
Summer temperature maxima at both stations were below the water quality standard of 32°C for lower
piedmont and coastal plain waters (15A NCAC 02B .0211). No statistically significant differences were
detected between average temperature values of the two instream locations. Review of paired up- to
downstream temperatures found no exceedences of the 2.8°C increase standard (15A NCAC 02B .0211).
Effluent temperatures are very similar to instream temperatures; the effluent does not appear to affect
instream temperature.
Conductivity — Conductivity is not in the current permit; neither effluent nor instream monitoring is
required. However, the facility has a pretreatment program involving one SIU (a metal finisher), and
instream Specific Conductance data are available for review. Review of the data found no statistically
significant differences between upstream and downstream Specific Conductance, suggesting no effluent
effects.
Fecal Coliform — Instream monitoring for Fecal Coliform is not required in the current permit, as the
receiving water is neither Class B nor is it impaired due to Fecal Coliform as per Division guidance.
No changes are proposed concerning instream monitoring.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): YES.
Name of Monitoring Coalition: Upper Cape Fear River Basin Association (UCFRBA).
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): From July 2016 through June
2021, a total of 14 limit exceedences were reported (Table 3). The exceedences resulted in 12 Notices of
Violation (NOVs), one Notice of Deficiency (NOD) and one no action. Most exceedences were due to an
algal bloom in the finishing pond from June -August 2018; the Fecal Coliform exceedance was due to a high
rain event that exceeded design flow and inhibited chlorination. The one Ammonia exceedance, in May
2021, did not result in a violation action.
Page 4 of 12

Table 3. Monitoring Report Violations: 2016-2021.
Parameter -IIINViolation
Type
Number of Violations
BOD
Monthly Average Exceeded
1
BOD
Weekly Average Exceeded
3
Fecal Coliform
Weekly Geometric Mean Exceeded
1
Ammonia-N
Monthly Average Exceeded
1
TSS
Monthly Average Exceeded
3
TSS
Weekly Average Exceeded
5
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed 17 of 17 quarterly chronic toxicity tests from March 2017 through March
2021.
Summarize the results from the most recent compliance inspection: The most recent facility inspection,
conducted on 01/10/2019, reported that the facility to be satisfactory; compliance issues in 2018 relating to
an algal bloom in the finishing pond are noted.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following stream flows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 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 1 SA 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/L for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: Year-round BOD
limits in the current permit are based on the TBEL of 30/45 mg/L monthly average/weekly average, and
have been in the permit since 2007 or earlier. No changes are proposed.
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/L (summer) and 1.8 mg/L (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 µg/L) and capped at 28 µg/L (acute impacts). Due to analytical issues, all TRC values
reported below 50 µg/L are considered compliant with their permit limit.
Page 5 of 12

Describe any proposed changes to ammonia and/or TRC limits for this permit renewal. Ammonia limits
in the current permit are toxicity -based, first placed in the permit before 2007 Ammonia was reviewed in
the attached Wasteload Allocation (WLA) sheet using the flow design of 0.48 MGD and receiving stream
low flows of 7Q 10s = 11 cfs and 7Q 10w = 23 cfs. The resulting allowable concentrations were found to be
the same as the current limits. The current Ammonia limits will be maintained in the permit.
WLA calculations for TRC cap the allowable concentration at 28 µg/L, the same value as the current permit
limit. The current TRC limit will be maintained in the permit.
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 Y2 detection limit for "less than" values; and 4) stream flows 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 data set of six effluent and upstream Hardness results, from quarterly sampling from March 2020—June
2021, were provided by the ORC upon request. Average upstream hardness was 36 mg/L, greater than the
default value of 25 mg/L, and therefore were used in the RPA.
A reasonable potential analysis was conducted on effluent toxicant data collected from June 2017—May
2021. 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.
• 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: None.
• 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: Arsenic,
Cadmium, Total Chromium, Cyanide, Lead, Nickel, Silver, Zinc.
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.
Page 6 of 12

Describe proposed toxicity test requirement: The facility is a POTW with a chronic WET limit at 6%
effluent, which will continue at a quarterly frequency. The WET limit is based on the Instream Waste
Concentration (IWC) as calculated from the design flow of 0.48 MGD and the receiving stream 7Q10s of
11 cfs (WET Permitting Limits and Monitoring Requirements guidance memo, 8/2/1999).
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/L) will receive
an MMP requirement. Industrials are evaluated on a case -by -case basis, depending on 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/L) and/or if any individual value exceeds a TBEL value
of 47 ng/L.
Describe proposed permit actions based on mercury evaluation: Quarterly low-level mercury monitoring
is required in the current permit as well as a Mercury TMDL Reopener special condition. Submitted
mercury data from July 2017—June 2021 were reviewed for TMDL evaluation. Results included detections
with no annual averages exceeding the WQBEL of 189.4 ng/L and no individual values exceeding the
TBEL of 47 ng/L (Table 4). Because the design flow is < 2 MGD, no MMP is required; quarterly monitoring
for mercury and the Mercury TMDL Reopener special condition were removed from the permit.
Table 4. Mercury Effluent Data Summary
1E7
2018
2019
2020
202i
# of Samples
3
4
5
4
1
Annual Average Conc. ng/L
0.5
1.0
0.7
1.5
1.4
Maximum Conc., ng/L
0.50
1.90
1.60
3.5
1.40
TBEL, ng/L
47
WQBEL, ng/L
189.4
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: The current permit has a
permit-reopener special condition for any additional effluent monitoring deemed necessary to support water
quality protection and restoration efforts in the receiving stream. Ramseur WWTP had participated in a
basin -wide survey for the emerging contaminants 1,4-Dioxane and PFAS chemical group in 2019. Three
rounds of influent sampling were conducted in July, August, and September 2019. Reviewed data from the
sampling found effluent concentrations to be below the EPA Drinking Water Health Advisory Levels
(HALs) for 1,4-Dioxane and that for PFAS + PFOA (Table 5).
Table 5. Influent Monitoring Results of Emerging Contaminants, 2019.
Parameter
Average (Range) HAL
Page 7 of 12

1,4-Dioxane, µg/L
2.04 (< 1.0-2.08)
35
PFOA + PFOS, ng/L
22.39 (9.45-47.7)
70
The POTW lies downstream of where the discharge from Asheboro WWTP enters the Deep River, a
discharge that has reported high levels of 1,4-Dioxane. The Ramseur WWTP discharges into a Class C
waterbody with the nearest WS boundary at 43.9 miles downstream. Based on the calculated mass loading
of average 1,4-Dioxane concentrations reported from July —September 2019 and associated average
discharge flow, the calculated instream concentration is 0.001 µg/L. With limited data (< 12 samples),
monthly monitoring for this parameter will be added to the permit.
The supplemental sampling reopener special condition is maintained in the permit. An additional permit
reopener special condition regarding 1,4-Dioxane based on changes toward limits, monitoring or treatment
has been added to the permit.
Based on detection of PFAS chemicals in the influent from the 2019 samplings, which was also provided
as an attachment to the NPDES application received on 1/20/2022, monitoring of PFAS chemicals were
added to the permit at a frequency of 2/year. Since an EPA method for sampling and analyzing PFAS in
wastewater is not currently available, the PFAS monitoring requirement in the permit includes the effective
date that is delayed until the first full calendar quarter beginning 6 months after EPA has a final wastewater
method in 40 CFR 136 published in the Federal Register. This date may be extended upon request if there
are no NC -certified labs.
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: A three-year compliance schedule
with a WER study option for the new Copper limits has been added to 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.
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/TSSfor Monthly Average, and 45 mg/L for BOD5/TSSfor 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.
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
Page 8 of 12

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 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.
All parameters in the current permit are monitored according to 15A NCAC 2B .0500.
For instream monitoring, refer to Section 4.
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. 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 6. Current Permit Conditions and Proposed Changes.
Parameter
Current Permit'
Proposed Change
Basis for Condition/Change
Page 9 of 12

Flow
0.48 MGD
No change
15A NCAC 2B .0505
BOD5
MA = 30.0 mg/L
WA = 45.0 mg/L
Monitor weekly
No change
TBEL. Secondary treatment standards /
40 CFR 133 / 15A NCAC 2B .0406.
State WQ reporting requirements 15A
NCAC 2B .0500.
TSS
MA = 30.0 mg/L
WA = 45.0 mg/L
Monitor weekly
No change
TBEL. Secondary treatment standards /
40 CFR 133 / 15A NCAC 2B .0406.
State WQ reporting requirements 15A
NCAC 2B .0500.
NH3-N
Summer
MA = 18.0 mg/L
WA = 35.0 mg/L
Summer
Monitor only
Monitor 2/month
No change
WQBEL. Calculation results based on
statewide 1.0/1.8 mg/L summer/winter
values in wasteload allocations to
protect against NH3-N toxicity (see
WLA sheet attached).
DO
DA > 5.0
Monitor weekly
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200.
pH
6-9 SU
Monitor weekly
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200.
Temperature
Monitor weekly
No change
State WQ reporting requirements 15A
NCAC 2B .0500.
Fecal Coliform
MA = 200 /100 mL
WA = 400 /100 mL
Monitor weekly
No change
WQBEL. State WQ standard, 15A
NCAC 2B .0200. and .0500.
Total Residual
Chlorine (TRC)
DM = 28 µg/L
Monitor 2/week
No change
WQBEL. State WQ acute standard,
15A NCAC 2B .0200
Total Nitrogen
(NO3+NO2 + TKN)
Monitor quarterly
No change
State WQ reporting requirements 15A
NCAC 2B .0500.
Total Phosphorus
Monitor quarterly
No change
State WQ reporting requirements 15A
NCAC 2B .0500.
Total Hardness
No requirement
Add quarterly
monitoring at
effluent and
instream, upstream
of discharge
Hardness -dependent dissolved metals
water quality standards, approved in
2016, need effluent and instream
hardness data for calculations of permit
limitations.
Total Copper
Monitor quarterly
MA = 175 µg/L
DM = 204 µg/L
Add 3-yr
compliance schedule
with WER study
option
WQBEL. Reasonable potential to
exceed allowable discharge
concentration (RP) found.
Parameter
Current Permit'
Proposed Change
Basis for Condition/Change
Total Mercury
Monitor quarterly
TMDL permit
reopener special
condition
Remove from
permit
In accordance with 2012 Statewide
Mercury TMDL Implementation, per
facility size and monitoring data
criteria.
Page 10 of 12

Toxicity Test
Chronic
Ceriodaphniadubia
Pass/Fail at 6 /0
effluent
No change
WQBEL. No toxics in toxic amounts.
15A NCAC 2B.0200 and 15A NCAC
2B.0500.
1,4-Dioxane
No requirement
Add monthly
monitoring
Based limited influent data showing
detection, more results are needed to
evaluate.
PFAS
No requirement
Add monitoring
2/year with delayed
implementation
Based limited influent data showing
detection, more results are needed to
evaluate. Implementation delayed until
after EPA certified method becomes
available.
Electronic Reporting
Electronic Reporting
Special Condition
Update condition to
remove submittal of
hardcopies and
extended Phase 2
deadline to 2025.
In accordance with EPA Electronic
Reporting Rule 2015.
Footnote.
1. MGD = Million gallons per day; MA = Monthly Average; WA = Weekly Average; DM = Daily
Maximum.
13. Public Notice Schedule:
Permit to Public Notice: 11/23/2021, 2/12/2022
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. NPDES Division Contact:
If you have questions regarding any of the above information or on the attached permit, please contact Gary
Perlmutter at [phone] or via email at [e-mail].
15. Fact Sheet Addendum (if applicable):
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes; comments were
provided by the Southern Environmental Law Center (SELC) regarding the disclosure of emerging
contaminants PFAS and 1,4-Dioxane during the permitting process. Information regarding PFAS and 1,4-
Dioxane in the draft permit fact sheet is from sampling conducted in 2019 and the data from which are
available on the Division's website. The Division requested supplemental information on 1/4/2022, which
was then received on 1/7/2022 via a Chemical Addendum package to the permit application. It should be
noted that the Permittee included information on 1,4-Dioxane on the Chemical Addendum form in addition
to providing additional material on PFAS as supplemental. The limited dataset (n = 3 for each parameter)
precludes assessment for limitations or management strategies but necessitates monitoring to build a more
robust dataset for such assessment.
Page 11 of 12

The proposed 1,4-Dioxane monitoring requirement and the 1,4-Dioxane permit reopener special condition
address 1,4-Dioxane. In addition, a PFAS monitoring requirement special condition has been added to
address PFAS. These changes were sent out in a second draft permit, public noticed on 11/23/2021.
Comments were received from SELC; none from any other party.
Second Draft SELC comments included:
• Ramseur has not adequately disclosed discharges of PFAS and 1,4-Dioxane.
• Monitoring for PFAS cannot wait for EPA to publish a final wastewater method.
• Ramseur should use its pretreatment authority to control any industrial sources.
The Division disagrees with the first two comments, responding that the monitoring requirements placed
in the permit are adequate to address the paucity of data currently available from Ramseur. Further,
monitoring for PFAS will begin when a final method is published and state laboratories are certified in the
new method. A reminder to update the Town's pretreatment program is noted in the cover letter to the final
permit. Ramseur is required to comply with pretreatment conditions found in 15A NCAC 02H .0900.
If Yes, list changes and their basis below:
Revisions based on first draft, public noticed on 11/23/2021:
• Quarterly monitoring of 1,4-Dioxane have been increased to monthly to build a more robust dataset
for evaluation.
• A PFAS monitoring special condition has been added to the permit with a frequency of 2/year to
be implemented six months after EPA publishes a final wastewater method in 40 CFR Part 136 in
the Federal Register. The schedule is to allow time for laboratories to receive state certification for
the method.
• Permit expiration date has been extended to January 31, 2027 to better fit a five-year cycle.
No changes have been made to the second draft, public noticed on 2/12/2022.
16. Fact Sheet Attachments (if applicable):
• 2018 NC Final 303(d) list, page 12
• Effluent summary charts and tables
• DMR notes explaining high reported values
• Instream Monitoring summary charts and tables
• Monitoring Report (MR) Violations page
• WET testing and Self -Monitoring Summary, page 91
• Compliance Inspection Report
• NH3/TRC WLA Calculations sheet
• RPA Spreadsheet Summary
• Dissolved Metals Implementation Freshwater
• Permittee-collected Hardness data
• Mercury WQBEL/TBEL Evaluation data and summary table
• Emerging Compounds Influent Monitoring Data
• Public Notice Affidavit
• Comments by SELC and DWR responses
• Chemical Addendum package from Permittee
• Comments by SELC to the second draft permit
Page 12 of 12

A B I C I D I E I F I G I H I I I J I K I L I M
N I 0 I P
1
2
3
4
5
6
7
8
9
0
11
12
14
15
16
17
18
19
20
21
22
23
24
25
26
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
NPDES/PT
POC Review Form
1. Facility's General Information
Version: 2022.03.04
Date of (draft) Review
11/23/2021
a. POC review due to:
e. Contact Information
Date of (final) Review
4/4/2022
Municipal NPDES renewal
Regional Office (RO) (Winston-Salem Regional
Office (WSRO)
NPDES Permit Writer
Gary Perlmutter
New Industries
RO PT Staff
Alexander Lowe and Jim
Gonsiewski
RO NPDES Staff
(Lon Snider
Pennittee-Facility Name
Town of Ramseur- Ramseur WWTP
WWTP expansion
0
Facility PT Staff, email I Lisa Ostheus olisaopretreat56gmail.com>
NPDES Permit Number
NC0026565
Stream reclassJadjustment
0
f. Receiving Stream
NPDES Permit Effective Date
9/1/2016
Outfall relocation/adjustment
0
Duffel! I
NPDES Permit Renewal
Application Date
4/30/2021
7010 updateReceiving
0
9 Stream:
Deep River
OA, cis:
350
NPDES Permit Public Notice
Date
10/23/2021, 2/12/2022
Other, explain below
0
Stream Class
C
7Q10 (S), cis:
11
eDMR data evaluated from:
6/1 /2016 I to I 5/31/2021
Comments on POC review trigger:
Oufall Lat.
35' 43' 07" N
Outfall Long.
79. 39' 0T N
a. WWTP Capacity Summary
Duffel! 11
Current Permitted Flow, mgd
0.480
Designed Flow,
mgd
g d
0.480
Permit renewal
Receiving Stream:
QA, cis:
Permitted SIU Flow, mgd
0.0250
d. IU Summary
Stream Class
7Q10, cfs:
b. PT Docs. Summary
# IUs
1
Oufan Lat.
Outfall Long.
IWS approval date
5/5/2021
# Ms
1
Comments:
L/STMP approval date:
10/2/2015
# Gills
1
# NSCIUs
0
Based on SIU discharge, monitoring for 1,4-Dioxane and PFAS monitroing is recommended.
H W A
m #
approval date
Industrial User (IU) Name
2/8/2018
IU Activity
# IUs w/Local
Permits or Other
Types
IU Conventional
0
2.
Pollutants
Industrial Users' Info
IU Non Conventional Pdlutans & Toxic Pollutant
IUP Effective Date
3 1
'E
Matlab, Inc.
a33.11 Metal Finisher,
pH,
Temperature
Cd, Cr, Cu, CN, Pb, Hg, Ni, Ag, TTO, Zn
7/30/2021
a 0
m 3
0
a a
Z
s
Comment:
3. Comments from NPDES pw
Facility Summary and NPDES regulatory action:
Comments from NPDES pw to PT staff (Central, RO, Facility):
The Town of Ramseur had applied for an NPDES permit renewal for
received by DWR on November 5, 2020. Review of the application
its WWTP,
found it to be
Please maintain the following POC-NPDES
required pollutants:
pH, Temperature, Cd, Cr, Cu, Pb, Hg, Ni, Ag, TTO, Zn
complete. This 0.480 MGD facility serves the Town of Ramseur (pop.
WWTP is classified as a POTW that treats domestic and industrial
with an active involving one Significant Industrial
—1690). The
wastewater
User
POC that need to be added/mgdigea in
USTMP sampling plan:
1 4-Dioxane, PFAS
pretreatment program
(SIU).
POC that may be removed from USTMP
sampling plan:
ORC's comments on IU/POC:
Additional pollutants added to USTMP due
to POTWs concerns:
NPDES pw's comments on IUs
4. Status of Pretreatment Program (check all that apply)
Status of Pretreatment Program (check all that apply)
❑
1) facility has no SIU's, does have Division approved Pretreatment
Program that is INACTIVE
❑
2) facility has no SIU's, does not have Division approved Pretreatment
Program
0
3) facility has Sills and DWQ approved Pretreatment Program
❑
3a) Full Program with LTMP
0
3b) Modified Program with STMP
4) additional conditions regarding Pretreatment attached or listed below
17
5) facility's sludge is being land applied or composted
n
•
❑
6) facility's sludge is incinerated (add
7) facility's sludge is taken to a landfill,
8) other
Beryllium and Mercury sampling
if yes which landfill:
accord
ng to § 503.43)
Sludge Disposal Plan:
Land application
55
Sludge Permit No:
W40010528
Page 1
26565 POC Review Form 2022

PARAMETER
AU Name
AU ID
Description
Little Troublesome Creek
13502 From SR2600 to Haw River
IR CATEGORY CRITERIA STATUS Ai
Benthos (Nar, AL, FW)
NORTH CAROLINA 2020 303(D) LIST
Haw Cape Fear River Basin
AU Number
Classification Length or Area Units
16-7-(2)
WS-IV;NSW
0.9
FW Miles
REASON FOR RATING 303D YEAR
'5 lExceeding Criteria Fair, Poor or Severe Bioclassification 2020
Cape Fear River Basin
1111111111MM.m=1111111
Deep
DEEP RIVER
4128 From Haskett Creek to Gabriels Creek
17-(10.5)d1 C
2.7 FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS
REASON FOR RATING 303D YEAR
Chlorophyll a (40 µg/I, AL, NC)
DEEP RIVER
129771
5 Exceeding Criteria
Exceeding Criteria with Statistical
Confidence
From Gabriels Creek to Brush Creek
17-(10.5)d2 C
2008
18.2 FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS
REASON FOR RATING 303D YEAR
Copper (7 µg/I, AL, FW)
5 Data Inconclusive
Legacy Category 5 Total Metals
Assessment
Deep River
17-(3.7)
WS-IV;CA:*
2.0 FW Miles
4136 From Guilford County SR 1334 to dam at Oakdale Cotton Mills, Inc. (Town of Jamestown water supply
intake)
PARAMETER
IR CATEGORY CRITERIA STATUS
REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW)
Exceeding Criteria
Fair, Poor or Severe Bioclassification 2018
Penwood Branch
4161 From source to Haskett Creek
17-12-1
6.1 FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS
REASON FOR RATING 303D YEAR
Benthos (Nar, AL, FW)
Sandy Creek
4164 From source to SR 2495
5 Exceeding Criteria
Fair, Poor or Severe Bioclassification 2006
17-16-(1)a WS-III
16.1 FW Miles
PARAMETER
IR CATEGORY CRITERIA STATUS
REASON FOR RATING 303D YEAR
Chlorophyll a (40 µg/I, AL, NC)
5 Exceeding Criteria
Exceeding Criteria with Statistical
Confidence
2018
7/21/2021 NC 2020 303d List- Approved by EPA June 23,2021
Page 12 of 188

Ramseur WWTP
Effluent Monitoring NC0026565
0.60
0.50
0.40
0
� 0.30
0.20
0.10
0.00
Al
oti' otio oti'' o''' otio otio 01' 01' 01' 01'
Flow
• Mo Avg -Limit
• • •• •
••N ••
•
•• ••
• • • ••• •• •N•� • •• ••�• •
90
80
70
60
�� 50
o
E 40
30
20
10
0
Biological Oxygen Demand (BOD)
Wk Avg ♦ Mo Avg WA Limit — — MA Limit
otio' otio' otio otio oti° otiti otiti otio
Summary Statistics
N 1460
Avg 0.194
SD 0.171
Min 0.027
Max 1.602
Summary Statistics
N 213
Avg 11.9
SD 13.1
Min 2.0
Max 146.0
Summary Statistics
N 214
Avg 10.6
SD 12.6
Min 2.5
Max 66.0
Page 1 of 4 GB Perlmutter 11/23/2021

Effluent Monitoring NCOO26565
Ramseur WWTP
40.0
35.0
30.0
25.0
J
n 20.0
15.0
pH
• Effluent - - - L. Limit U. Limit
9.5 -
9.0 -
8.5 -
8.0 -
IU
• • •
O�� O� O,� O,� O,� Off° ol> O�y O1�
Summary Statistics
summer
N 55
Avg 7.8
SD 5.0
Min 0.3
Max 21.6
winter
N 43
Avg 8.3
SD 6.2
Min 0.4
Max 19.8
Summary Statistics
N 904
Avg 6.1
SD 0.3
Min 5.8
Max 7.8
Summary Statistics
N 904
Avg 6.9
SD 0.1
Min 6.7
Max 7.5
Page 2 of 4 GB Perlmutter 11/23/2021

Ramseur WWTP
Effluent Monitoring
N C0026565
40
35
30
25
;-' 20
15
10
5
0
Temperature
- IP slie 8 ifilfr% _if —I .
- 1 1 et
s d Is 1 si
ik
jet
IV V
t tit
411
oti oti oti oti oti° oti° oti° oti otiy oti
\o o\vti\� \ti°\� y°\y�\n h\ti`'\� y\N• o\tiw\� y\°\ti
1,000.0
E
100.0
4
U
E 10.0
0
v
C7
Fecal Coliform
Wk Avg • Mo Avg WA Limit - - - MA Limit
•
•
•A•
N •
sit AA
•
• %.
••
•• •
•
•
•
• •
• N •
• •N • •
-- 11=0
oti oti' oti oti' oti° oti° 61' 61' oti•
o�\moo\ti o\�\y�\ti\ti o\�4\ti
•
••• • • • sigainesbeat•
Summary Statistics
N 903
Avg 18.6
SD 8.1
Min 3.0
Max 34.0
Summary Statistics
N 212
Geomean 1.7
Min 1
Max 3200
Summa Statistics
N 26
Avg 9.26
SD 4.81
Min 1.73
Max 19.60
TKN
N 22
Avg 1.10
SD 0.85
Min 0.12
Max 3.15
NO2+NO3
N 32
Avg 10.74
SD 4.80
Min 3.47
Max 24.35
Page 3 of 4 GB Perlmutter 11/23/2021

Ramseur WWTP
Effluent Monitoring NC0026565
Summary Statistics
N 32
Avg 2.79
SD 1.13
Min 1.37
Max 6.77
Page 4 of 4 GB Perlmutter 11/23/2021

Ramseur WWTP DMR Notes NC0026565
October 2017
10/10: Effluent BOD - No dilution depleted at least 2.0 mg/I with a residual of at least 1.0 mg/I
Exceeded the weekly BOD limit during the 2nd & 3rd week and the monthly average BOD. Violation
resulted from stratification of the finishing pond.
June 2018
The Ramseur Wastewater Treatment Facility design incorporates an activated sludge treatment system
followed by a finishing pond prior to final discharge. During this reporting period the finishing pond
experienced excessive algae growth which adversely affected effluent quality and contributed to
noncompliance of a weekly and monthly TSS as well as a weekly BOD exceedance for the last week of
June.
July 2018
The Ramseur WWTP experienced elevated effluent Total Suspended Solids levels which exceeded the
weekly and monthly TSS limitations. The Ramseur WWTP treatment scheme includes an activated
sludge system with secondary clarification followed by a finishing lagoon prior to disinfection and
dechlorination. The elevated TSS concentrations were due to an excessive algal bloom in the lagoon.
Corrective measures have included treatment of the lagoon to reduce the algae issue.
August 2018
Exceeded Effluent weekly and monthly TSS due to algal bloom in finishing pond prior to discharge.
Corrective measures are being taken to reduce algae concentrations.
December 2018
The treatment plant received 1.2 inches of rainfall overnight from 12/27 to 12/28 and the flow increased
from 0.35 MGD to over 1.0 MGD during that period. The design flow capacity of this facility is 0.480
MGD. The fecal coliform sample was collected at 11:15 am on the 28th. The extraneous flow inhibited
the proper chlorination of the wastewater. In addition, the sample schedule was altered due to the
holiday. Normal sample schedule includes sampling on Tuesdays which affords time to resample if
needed.

Ramseur WWTP Instream Monitoring NC0026565
Dissolved oxygen (DO), mg/L
Date Upstream Dnstream Effluent Standard
2017-06-06 7.8 7 6.2 5.0
2017-06-23 7.1 7.4 6 5.0
2017-07-14 6.9 6.9 5.9 5.0
2017-07-27 7 6.3 6 5.0
2017-08-07 6.8 6.1 6 5.0
2017-08-25 7 6.7 5.9 5.0
2017-09-15 7.2 6.8 5.9 5.0
2017-09-29 7.2 6.1 6 5.0
2017-10-31 9.2 8.7 6.1 5.0
2017-11-22 10.5 10.3 6 5.0
2017-12-08 11.3 10.7 6 5.0
2018-01-10 13.2 12.8 6.2 5.0
2018-02-19 10.2 9.9 6.1 5.0
2018-03-23 11.4 11.1 6.3 5.0
2018-04-20 8.9 8.8 6.1 5.0
2018-05-02 8.8 8.7 6 5.0
2018-05-31 6.9 6.6 6 5.0
2018-06-08 6.7 6.6 5.9 5.0
2018-06-19 6.8 7 6 5.0
2018-07-02 6.9 6.9 5.9 5.0
2018-07-18 6.6 6.8 5.9 5.0
2018-08-06 7.3 6.9 5.9 5.0
2018-08-31 7.2 6 6.2 5.0
2018-09-14 6.2 5.9 6.2 5.0
2018-09-28 7.5 7 6.2 5.0
2018-10-29 9.1 8.8 6.4 5.0
2018-11-09 8.8 8.4 6.5 5.0
2018-12-17 13.1 12.5 6.1 5.0
2019-01-18 11.5 10.9 6.2 5.0
2019-02-12 11 10.9 6 5.0
2019-03-01 11.2 10.9 6.1 5.0
2019-04-05 9.6 9 6 5.0
2019-05-08 7.8 7.2 6.1 5.0
2019-05-28 7.4 6.8 5.8 5.0
2019-06-20 7.2 7 6 5.0
2019-06-28 6.6 6.5 5.9 5.0
2019-07-08 6.2 6.4 5.8 5.0
2019-07-24 7.3 6.9 5.9 5.0
2019-08-02 7.3 6.3 5.8 5.0
2019-08-19 7.4 7.3 5.8 5.0
2019-09-12 6.9 6.8 5.8 5.0
2019-09-26 7.5 7.7 5.8 5.0
2019-10-25 8.4 8.8 5.8 5.0
2019-11-13 10.8 10.6 6.3 5.0
2019-12-31 10.8 10.7 6.7 5.0
2020-01-31 11 10.9 6.3 5.0
2020-02-12 10.9 10.9 6.5 5.0
1 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Dissolved oxygen (DO), mg/L
Date Upstream Dnstream Effluent Standard
2020-03-09 10.4 10.3 6.2 5.0
2020-04-07 10.5 10.2 6.2 5.0
2020-05-08 8.4 8.4 6.1 5.0
2020-05-20 8.9 8.7 6.4 5.0
2020-06-12 7 7.2 6.2 5.0
2020-06-26 7.2 7.2 6 5.0
2020-07-10 7.2 7.1 6 5.0
2020-07-28 6.2 6.2 5.9 5.0
2020-08-04 7.2 7 5.9 5.0
2020-08-21 6.7 6.6 5.8 5.0
2020-09-04 7.2 7.1 5.9 5.0
2020-09-24 7.5 7.3 6 5.0
2020-10-14 8.1 7.9 5.0
2020-10-15 6 5.0
2020-11-02 9 8.8 5.0
2020-11-03 6 5.0
2020-12-15 6.1 5.0
2020-12-17 11.2 11.2 5.0
N
Avg
SD
Min
Max
62 62 62
8.4 8.2 6.1
#N/A #N/A #N/A
6.2 5.9 5.8
13.2 12.8 6.7
14.0
12.0
10.0
E
8.0
6.0
4.0
2.0
0.0
Dissolved Oxygen (DO)
• Upstream • Effluent ♦ Dnstream -Standard
2 •
♦
• 2 n nr)no
•
2 !. n Asnivl
bSIN■ ■ li■�■1 ■
lON' yON' 10,E
Oh 'C O(O O' 0A'
2 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Dissolved oxygen (DO), mg/L
Date Upstream Dnstream Effluent Standard
t-Test: Two -Sample Assuming Unequal Variances
Upstream Dnstream
Mean 8.437097 8.183871
Variance 3.404995 3.383998
Observations 62 62
Hypothesized Mean Difference 0
df 122
t Stat 0.765246
P(T<=t) one -tail 0.222801
t Critical one -tail 1.657439
P(T<=t) two -tail 0.445603
t Critical two -tail 1.9796
3 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Temperature, water ('CJ
Date Upstream Dnstream D-U Diff Effluent Standard
2017-06-06 23.6 23.6 0 25 32
2017-06-23 26 26.2 0.2 24 32
2017-07-14 30.3 29.5 -0.8 27 32
2017-07-27 28.7 28.4 -0.3 28 32
2017-08-07 26.5 25.9 -0.6 25 32
2017-08-25 26 25.5 -0.5 25 32
2017-09-15 23.1 22.4 -0.7 21 32
2017-09-29 24.4 23.4 -1 23 32
2017-10-31 13.2 12.9 -0.3 11.8 32
2017-11-22 10.5 9.8 -0.7 9 32
2017-12-08 9.3 9 -0.3 7 32
2018-01-10 2.7 2.2 -0.5 3 32
2018-02-19 11.3 11 -0.3 12 32
2018-03-23 9.4 10.1 0.7 9 32
2018-04-20 16 15.4 -0.6 16 32
2018-05-02 18.5 18.1 -0.4 17 32
2018-05-31 24.3 24 -0.3 23 32
2018-06-08 26.4 25.6 -0.8 24 32
2018-06-19 29.9 28.6 -1.3 24 32
2018-07-02 29.9 29.7 -0.2 28 32
2018-07-18 29.3 27.8 -1.5 26 32
2018-08-06 27.5 27.4 -0.1 25 32
2018-08-31 27.4 26.9 -0.5 27 32
2018-09-14 24.6 24.8 0.2 27 32
2018-09-28 24.1 24.1 0 23 32
2018-10-29 15.3 15.2 -0.1 13 32
2018-11-09 15.4 15.1 -0.3 15 32
2018-12-17 7.7 7.7 0 7 32
2019-01-18 7.6 7.6 0 7 32
2019-02-12 9.3 9.5 0.2 8 32
2019-03-01 9.5 10 0.5 10 32
2019-04-05 14.1 14.6 0.5 14 32
2019-05-08 22.5 22.2 -0.3 24 32
2019-05-28 27.3 27.4 0.1 26 32
2019-06-20 26.2 26.1 -0.1 24 32
2019-06-28 27.6 27.1 -0.5 26 32
2019-07-08 28.9 28.5 -0.4 32 32
2019-07-24 23.8 24.8 1 28 32
2019-08-02 26.4 25.5 -0.9 27 32
2019-08-19 27.1 27.9 0.8 29 32
2019-09-12 28 27.6 -0.4 27 32
2019-09-26 25.1 24 -1.1 27 32
2019-10-25 16.1 16.1 0 23 32
2019-11-13 10.3 9.1 -1.2 16 32
2019-12-31 11.1 11.1 0 10 32
2020-01-31 7.8 7.9 0.1 10 32
2020-02-12 11.6 11.6 0 12 32
4 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NCOO26565
Temperature, water ('CJ
Date Upstream Dnstream D-U Diff Effluent Standard
2020-03-09 11.4 11.5 0.1 14 32
2020-04-07 20.3 19.2 -1.1 22 32
2020-05-08 17.6 17.6 0 22 32
2020-05-20 17.5 17.6 0.1 22 32
2020-06-12 26.1 26.1 0 28 32
2020-06-26 26.7 26.8 0.1 30 32
2020-07-10 27.2 27.3 0.1 31 32
2020-07-28 30.1 30 -0.1 29 32
2020-08-04 27.4 27.3 -0.1 30 32
2020-08-21 23.8 23.8 0 29 32
2020-09-04 29.1 28.9 -0.2 29 32
2020-09-24 19.9 20.1 0.2 19 32
2020-10-14 20.2 20.3 0.1 32
2020-10-15 17.9 32
2020-11-02 15.6 15.7 0.1 32
2020-11-03 18.5 32
2020-12-15 10 32
2020-12-17 9.4 9.3 -0.1 32
N
Avg
SD
Min
Max
62 62 62 62
20.4 20.2 -0.2 20.6
7.7 7.6 0.5 7.7
2.7 2.2 -1.5 3.0
30.3 30.0 1.0 32.0
35.0
30.0
25.0
20.0
U
15.0
10.0
5.0
0.0
Temperature
• Upstream • Effluent ♦ Dnstream -Standard
▪ ■. ri
• f+'
IF 0 I')
�� /\
L' ■
•
• erg • N■
Ore 0
5 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Temperature, water ('C)
Date Upstream Dnstream D-U Diff Effluent Standard
t-Test: Two -Sample Assuming Unequal Variances
Upstream Dnstream
Mean 20.38548 20.16774
Variance 59.48487 58.0196
Observations 62 62
Hypothesized Mean Difference 0
df 122
t Stat 0.158165
P(T<=t) one -tail 0.437294
t Critical one -tail 1.657439
P(T<=t) two -tail 0.874588
t Critical two -tail 1.9796
6 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Specific conductance (uS/cm)
Date Upstream Dnstream
2015-01-14 238
2015-02-03 238
2015-03-04 185
2015-04-07 232
2015-05-01 162
2015-05-15 210
2015-06-15 263
2015-06-30 207
2015-07-15 191
2015-07-29 261
2015-08-07 313
2015-08-20 269
2015-09-04 403
2015-09-18 406
2015-10-14 289
2015-11-03 168
2015-12-08 184
2016-01-11 137
2016-02-05 120
2016-03-16 122
2016-04-01 110
2016-05-03 201
2016-05-24 161
2016-06-17 193
2016-06-30 258
2016-07-18 192
2016-07-29 282
2016-08-11 244
2016-08-29 279
2016-09-21 96
2016-09-30 86
2016-10-07 127
2016-11-11 263
2016-12-02 265
2017-01-27 169
2017-02-10 189
2017-03-31 193
2017-04-28 189
2017-05-05 182
2017-05-19 201
2017-06-06 192
2017-06-23 149
2017-07-14 193
2017-07-27 239
2017-08-07 245
2017-08-25 173
2017-09-15 186
96
133
133
143
181
66
119
123
118
129
114
92
133
132
144
102
136
156
167
138
258
195
156
116
156
166
144
127
167
122
126
112
132
120
98
124
127
159
169
182
214
211
242
234
192
136
168
7 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Specific conductance (uS/cm)
Date Upstream Dnstream
2017-09-29 263
2017-10-31 237
2017-11-22 251
2017-12-08 255
2018-01-10 231
2018-02-19 201
2018-03-23 180
2018-04-20 174
2018-05-02 175
2018-05-31 147
2018-06-08 195
2018-06-19 238
2018-07-02 247
2018-07-18 238
2018-08-06 215
2018-08-31 205
2018-09-14 176
2018-09-28 174
2018-10-29 131
2018-11-09 126
2018-12-17 98
2019-01-18 120
2019-02-12 137
2019-03-01 114
2019-04-05 129
2019-05-08 119
2019-05-28 162
2019-06-20 125
2019-06-28 138
2019-07-08 134
2019-07-24 95
2019-08-02 147
2019-08-19 144
2019-09-12 200
2019-09-26 258
2019-10-25 135
2019-11-13 192
2019-12-31 140
2020-01-31 131
2020-02-12 102
2020-03-09 140
2020-04-07 128
2020-05-08 120
2020-05-20 92
2020-06-12 117
169
175
193
228
250
265
263
259
185
225
256
243
191
148
186
198
186
179
181
178
167
259
238
122
88
103
266
232
266
183
245
167
159
179
113
130
116
135
182
164
274
423
391
208
281
8 of 9 GB Perlmutter 11/23/2021

Ramseur WWTP Instream Monitoring NC0026565
Specific conductance (uS/cm)
Date Upstream Dnstream
2020-06-26 122 256
2020-07-10 124 154
2020-07-28 119 212
2020-08-04 116 256
2020-08-21 65 202
2020-09-04 178 132
2020-09-24 133 224
2020-10-14 120 241
2020-11-02 129 213
2020-12-17 96 226
N
Avg
SD
Min
Max
102 102
181.7 179.1
64.2 61.1
65.0 66.0
406.0 423.0
450
400
350
300
250
i 200
150
100
50
0
Specific Conductance
• Upstream
•
•
Dnstream
♦
♦
•
-•1 ♦ 4 • ? ♦� A• •♦ u
oil..
• 4♦
0:11 Ep f he reit it &
11r
♦ M '
♦ • ♦ ♦ ♦ • •�•• •
♦ •
ti• '1, do 'L, o ti• -5
tiO�� ti'O'� tiON' tiON' tiON' ti01' ti01'
t-Test: Two -Sample Assuming Unequal Variances
Upstream Dnstream
Mean 181.6961 179.1471
Variance 4117.303 3738.028
Observations 102 102
Hypothesized Mean Difference 0
df 202
t Stat 0.290463
P(T<=t) one -tail 0.38588
t Critical one -tail 1.652432
P(T<=t) two -tail 0.77176
t Critical two -tail 1.971777
9 of 9 GB Perlmutter 11/23/2021

MONITORING REPORT(MR) VIOLATIONS for:
Report Date: 07/13/21 Page 1 01 1
Permit: NC0026565 MRs Betweei 7 - 2016 and 7 - 2021 Region: %
Facility Name: % Param Nam( % County: %
Major Minor:
Violation Category:Limit Violation
Subbasin:%
Program Category: NPDES WW
Violation Action: %
PERMIT: NC0026565
FACILITY: Town of Ramseur - Ramseur WWTP
COUNTY: Randolph
REGION: Winston-Salem
Limit Violation
MONITORING OUTFACE
REPORT
LOCATION
PARAMETER
VIOLATION
DATE FREQUENCY MEASURE
UNIT OF
LIMIT
CALCULATED
VALUE
Over
VIOLATION TYPE VIOLATION ACTION
10-2017 001
10-2017 001
10-2017 001
06-2018 001
12-2018 001
05-2021 001
06-2018 001
06-2018 001
07-2018 001
07-2018 001
07-2018 001
08-2018 001
08-2018 001
08-2018 001
Effluent
Effluent
Effluent
Effluent
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
Nitrogen, Ammonia Total (as
N) - Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
10/14/17 Weekly mg/I
10/21/17 Weekly mg/I
10/31/17 Weekly mg/I
06/30/18 Weekly mg/I
12/29/18 Weekly #/100m1
05/31/21 2 X month mg/1
06/30/18 Weekly mg/I
06/30/18 Weekly mg/1
07/07/18 Weekly mg/I
07/28/18 Weekly mg/1
07/31/18 Weekly mg/1
08/04/18 Weekly mg/I
08/11/18 Weekly mg/1
08/31/18 Weekly mg/I
45 71 57.8 Weekly Average
Exceeded
45 85.5 90 Weekly Average
Exceeded
30 31.74 5.8 Monthly Average
Exceeded
45 47 4.4 Weekly Average
Exceeded
400 420 5 Weekly Geometric Mean
Exceeded
18 18.62 3.4 Monthly Average
Exceeded
45 53.33 18.5 Weekly Average
Exceeded
30
45
36.83
60
22.8
33.3
45 56.33 25.2
Monthly Average
Exceeded
Weekly Average
Exceeded
Weekly Average
Exceeded
30 47.36 57.9 Monthly Average
Exceeded
45 51 13.3 Weekly Average
Exceeded
45 47 4.4 Weekly Average
Exceeded
30 30.25 0.8 Monthly Average
Exceeded
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOD
None
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV
Proceed to NOV

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 IN I 2 LI 3 I NC0026565 111 121 19/01/10 117
Type
1810I
IIIIIIIIIII
Inspector Fac Type
19I S I 2011
21IIIIII IIIIIIIIIIIIIIIIII I IIIIII
P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671 I 70I I 711 172 I N I 731 1 74 71
I I
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)
Ramseur WWTP
Roundleaf Rd
Ramseur NC 27316
Entry Time/Date
02:15PM 19/01/10
Permit Effective Date
16/09/01
Exit Time/Date
03:45PM 19/01/10
Permit Expiration Date
21/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Daniel Mark Grose/ORC/336-824-8891/
Terry Cheyenne Lewallen/ORC/336-824-3939/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Terry Cheyenne Lewallen,PO Box 725 Ramseur NC 27316//336-824-3939/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate
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
Jennifer F Graznak DWR/WSRO WQ/336-776-9800/
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

31
NPDES yr/mo/day
NC0026565 111 121 19/01/10
117
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The inspection found the facility to be satisfactory. Please note these pertinent findings from the
inspection:
(1) The facility had several violations of Total Suspended Solids during the summer of 2018 (June,
July, August). During this time, the ORC stated that algae had grown in the finishing pond, which he
believes caused the violations. He treated the algae in the pond with copper sulfate.
(2) There is no sludge digester at the plant. Instead, solids from the secondary clarifier are
lime -stabilized in the sludge mixing tank prior to disposal in the 10-acre sludge storage lagoon on
site. This surface disposal method is covered under permit # WQ0010528 from the Division of Water
Resources.
Page# 2

Permit: NC0026565
Inspection Date: 01/10/2019
Owner - Facility: Ramseur WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable II ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ El ❑
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: The permit became effective on September 1, 2016 and will expire April 30, 2021.
Record Keeping Yes No NA NE
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 ❑ ❑ • ❑
operator 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?
Page# 3

Permit: NC0026565
Inspection Date: 01/10/2019
Owner - Facility: Ramseur WWTP
Inspection Type: Compliance Evaluation
Record Keeping
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
• ❑ ❑ ❑
❑ ❑ • ❑
Comment: Mr. Lewallen measures dissolved oxygen, temperature, and pH under field parameter
certification #5103. His thermometer was verified by Meritech on December 2, 2018. All
other samples are analyzed by Environment One. Mr. Lewallen delivers samples to the
Ramseur water treatment plant, and Environment One picks them up there.
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:
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: An ultrasonic meter is used to report influent flow on the DMRs. Carolina Technical
Services calibrated the meter on April 9, 2018.
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: Bar screenings are disposed of in the Town's dead animal pit on site.
Yes No NA NE
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? • ❑ ❑ ❑
Page# 4

Permit: NC0026565
Inspection Date: 01/10/2019
Owner - Facility: Ramseur WWTP
Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Are surface aerators and mixers operational? ❑ ❑ • ❑
Are the diffusers operational? • ❑ ❑ ❑
Is the foam the proper color for the treatment process? ■ ❑ ❑ ❑
Does the foam cover less than 25% of the basin's surface? • ❑ ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑ •
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El El •
Comment: The aeration basin appeared black in color, which the ORC said is due to a local dye
house that discharges to the plant.
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)
Comment:
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ • ❑ ❑
• ❑ ❑ ❑
Comment:
Effluent Sampling Yes No NA NE
Page# 5

Permit: NC0026565
Inspection Date: 01/10/2019
Owner - Facility: Ramseur WWTP
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
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 • El El El
representative)?
Comment: Composite sampling is not flow proportional due to the holding time of the 5-acre
finishing lagoon, which equalizes effluent flow. Time composite sampling is used
instead.
Lagoons Yes No NA NE
Type of lagoons?
# Number of lagoons in operation at time of visit? 1
Are lagoons operated in?
# Is a re -circulation line present? ❑ ❑ • ❑
Is lagoon free of excessive floating materials? ■ ❑ ❑ ❑
# Are baffles between ponds or effluent baffles adjustable? El El • El
Are dike slopes clear of woody vegetation? • El El El
Are weeds controlled around the edge of the lagoon? • ❑ ❑ ❑
Are dikes free of seepage? ■ El El El
Are dikes free of erosion? • El El El
Are dikes free of burrowing animals? • El El El
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ ❑ •
locations?
# If excessive algae is present, has barley straw been used to help control the growth? El El El
Is the lagoon surface free of weeds? • El El El
Is the lagoon free of short circuiting? • El El El
Comment: The 5-acre finishing pond the regulates effluent flow for the plant.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Yes No NA NE
Page# 6

Permit: NC0026565
Inspection Date: 01/10/2019
Owner - Facility: Ramseur WWTP
Inspection Type: Compliance Evaluation
Disinfection -Gas Yes No NA NE
Is the level of chlorine residual acceptable? ❑ ❑ ❑ •
Is the contact chamber free of growth, or sludge buildup? • ❑ ❑ ❑
Is there chlorine residual prior to de -chlorination? ❑ ❑ El •
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. ❑ ❑ ❑ •
7782-50-5)?
If yes, then is there a Risk Management Plan on site? ❑ ❑ ❑ •
If yes, then what is the EPA twelve digit ID Number? (1000- )
If yes, then when was the RMP last updated?
Comment: Chlorine gas is added in the manhole prior to the chlorine contact chamber. The ORC
lifted the manhole during the inspection so the inspectors could see the line.
De -chlorination Yes No NA NE
Type of system ? Gas
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ •
Is storage appropriate for cylinders? • El ❑ ❑
# Is de -chlorination substance stored away from chlorine containers? • ❑ ❑ ❑
Are the tablets the proper size and type? El El • El
Comment: Sulfur dioxide gas is added at the end of the chlorine contact chamber right before
discharge.
Are tablet de -chlorinators operational? El ❑ • ❑
Number of tubes in use?
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, El El El
and sampling location)?
Comment:
Page# 7

NH3/TRC WLA Calculations
Facility: Ramseur WWTP
PermitNo. NC0026565
Prepared By: Gary Perlmutter
Enter Design Flow (MGD): 0.48
Enter s7Q10 (cfs): 11
Enter w7Q10 (cfs): 23
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)
11
0.48
0.744
17.0
0
6.34
268
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)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
15.78 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
11
0.48
0.744
1.0
0.22
6.34
12.5
23
0.48
0.744
1.8
0.22
3.13
50.6
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Whole Effluent Toxicity Testing and Self Monitoring Summary
0
7I
V
0
Mar Jun Sep Dec
0
cc
•O
00
0)
00
NC0026565/001
Ramseur WWTP
Cf
7Q10: 11.0
NonComp: Single
chr lim: 6.0%
n m m o
0 0 0 0 0
1)
O
v
O
Jan Apr Jul Oct
Cf
0
N �
O
lac
0)
CC
NC0087866
Randleman Lake WTP-Piedmont Triad
Chr Monit: 90%
O
N
0
-I
C
.00
m
LL
a
N
n
0)
U
Oa i a
H
n C0 m
0 0 000 Ott
0 0
O
0
O
Jan Apr Jul Oct
NC0025445/001
Randleman WWTP
NonComp: Single
chr lim: 35%
0
0 0 i i
H
z
C
L
h
n000 m o
000000 CO Ott
U
O
I
V
0
Jan Apr Jul Oct
0
LL
O
Ea
0)
00
NC0025577/001
Red Springs WWTP
Ol
LL
7Q10: 0.07
NonComp: Single
chr lim: 90%
N
O
C
.00
CO0
z
rit
to
co m o
ssss
U
O
VI
O
Mar Jun Sep Dec
O
0
Y
0
n
O
00
0)
00
NC0083291/001
Reddies River WTP
V
0
d
r-
Ac P/F Monit: 90% Ft
V
sl
M
C
00
000
LL
C
N
N
a
L
LL
0
x x x
2
1
z
ao m o
0s0s
Page 91 of 120
Legend: P= Fathead minnow (Pimohales oromelasl. H=No Flow (facility is active). s = Solit test between Certified Labs

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
❑CHECK IF HQW OR ORW WQS
Ramseur WWTP
Grade II
NC0026565
001
0.480
Deep River
03030003
C
['Apply WS Hardness WQC
7Q10s (cfs)
7Q1Ow (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
11.00
23.00
350.00
I 9.12 -
Effluent Hardness
Upstream Hardness
Combined Hardness Chronic
Combined Hardness Acute
56.47 mg/L (Avg)
36 mg/L (Avg)
37.3 mg/L
37.54 mg/L
Effluent data from submitted DMRs; Hardness data
provided by ORC upon request
Data Source(s)
❑CHECK TO APPLY MODEL
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
0.7982
FW
4.6202
ug/L
Chlorides
Aquatic Life
NC
230
FW
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
4 Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
163.3741
FW
1262.7686
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
11.0921
FW
15.3611
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
4.6076
FW
119.1148
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
52.2259
FW
472.8457
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
0.5965
ug/L
Zinc
Aquatic Life
NC
177.8666
FW
177.4136
ug/L
26565 RPA 2021, input
11/23/2021

REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Date Data BDL=1/2DL Results
1 6/13/2017 52 52 Std Dev.
2 9/19/2017 44 44 Mean
3 12/12/2017 60 60 C.V.
4 3/13/2018 44 44 n
5 6/12/2018 52 52 10th Per value
6 9/25/2018 113 113 Average Value
7 12/18/2018 40 40 Max. Value
8 3/12/2019 41 41
9 6/11/2019 100 100
10 9/17/2019 57 57
11 12/10/2019 54 54
12 3/10/2020 46 46
13 6/9/2020 42 42
14 9/22/2020 53 53
15 12/15/2020 51 51
16 3/9/2021 46 46
17 6/15/2021 65 65
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
H2
Upstream Hardness
20.1777
56.4706
0.3573
17
41.60 mg/L
56.47 mg/L
113.00 mg/L
Date Data BDL=1/2DL Results
1 3/10/2020 36 36 Std Dev.
2 6/9/2020 36 36 Mean
3 9/22/2020 38 38 C.V. (default)
4 12/15/2020 34 34 n
5 3/9/2021 40 40 10th Per value
6 6/15/2021 32 32 Average Value
7 Max. Value
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
2.8284
36.0000
0.6000
6
33.00 mg/L
36.00 mg/L
40.00 mg/L
-3-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=1/2DL Results
1 6/13/2017 < 5 2.5 Std Dev.
2 9/19/2017 < 5 2.5 Mean
3 12/12/2017 < 5 2.5 C.V. (default)
4 3/13/2018 < 5 2.5 n
5 6/13/2017 < 5 2.5
6 9/19/2017 < 5 2.5 Mult Factor =
7 12/12/2017 < 5 2.5 Max. Value
8 3/13/2018 < 5 2.5 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
Par03
Beryllium
0.0000
2.5000
0.6000
8
1.90
2.5 ug/L
4.8 ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
-4-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par04
Cadmium
Date Data BDL=1/2DL Results
1 6/13/2017 < 1 0.5 Std Dev.
2 9/19/2017 < 1 0.5 Mean
3 12/12/2017 < 1 0.5 C.V. (default)
4 3/13/2018 < 1 0.5 n
5 6/13/2017 < 1 0.5
6 9/19/2017 < 1 0.5 Mult Factor =
7 12/12/2017 < 1 0.5 Max. Value
8 3/13/2018 < 1 0.5 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
Par05
Chlorides
0.0000
0.5000
0.6000
8
1.90
0.500 ug/L
0.950 ug/L
Date Data
BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points =
58
NO DATA
NO DATA
NO DATA
0
N/A
N/A mg/L
N/A mg/L
26565 RPA 2021, data
- 5 - 11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par06
Chlorinated Phenolic Compounds
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
Par07
Total Phenolic Compounds
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
Mult Factor = N/A
Max. Value N/A ug/L
Max. Pred Cw N/A ug/L
26565 RPA 2021, data
- 6 - 11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par08
Chromium III
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
Par09
Chromium VI
NO DATA
NO DATA
NO DATA
0
N/A
N/A pg/L
N/A pg/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
N/A
N/A pg/L
N/A pg/L
-7-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par10
Chromium, Total
Date Data BDL=1/2DL Results
1 6/13/2017 < 5 2.5 Std Dev.
2 9/19/2017 < 5 2.5 Mean
3 12/12/2017 < 5 2.5 C.V. (default)
4 3/13/2018 < 5 2.5 n
5 6/13/2017 < 5 2.5
6 9/19/2017 < 5 2.5 Mult Factor =
7 12/12/2017 < 5 2.5 Max. Value
8 3/13/2018 < 5 2.5 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
Pall
Copper
0.0000
2.5000
0.6000
8
1.90
2.5 pg/L
4.8 pg/L
Date Data BDL=1/2DL Results
1 6/13/2017 5 5 Std Dev.
2 9/19/2017 4 4 Mean
3 12/12/2017 5 5 C.V.
4 3/13/2018 5 5 n
5 6/12/2018 10 10
6 9/25/2018 3792 3792 Mult Factor =
7 12/18/2018 18 18 Max. Value
8 3/12/2019 12 12 Max. Pred Cw
9 6/11/2019 113 113
10 9/17/2019 609 609
11 12/10/2019 19 19
12 3/10/2020 131 131
13 6/9/2020 46 46
14 9/22/2020 17 17
15 12/15/2020 18 18
16 3/9/2021 43 43
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
942.2432
302.9375
3.1104
16
2.91
3792.00 ug/L
11034.72 ug/L
26565 RPA 2021, data
- 8 - 11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par12
Cyanide
Date Data BDL=1/2DL Results
1 6/13/2017 < 5 5 Std Dev.
2 9/19/2017 < 5 5 Mean
3 12/12/2017 < 5 5 C.V. (default)
4 3/13/2018 < 5 5 n
5 6/13/2017 < 5 5
6 9/19/2017 < 5 5 Mult Factor =
7 12/12/2017 < 5 5 Max. Value
8 3/13/2018 < 5 5 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
Par13
Fluoride
0.0000
5.00
0.6000
8
1.90
5.0 ug/L
9.5 ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
26565 RPA 2021, data
- 9 - 11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par14
Lead
Date
6/13/2017 < 5
9/19/2017 < 5
12/12/2017 < 5
6/13/2017 < 5
9/19/2017 < 5
12/12/2017 < 5
3/13/2018 < 5
BDL=1/2DL Results
2.5 Std Dev.
2.5 Mean
2.5 C.V. (default)
2.5 n
2.5
2.5 Mult Factor =
2.5 Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
Par15
Mercury
0.0000
2.5000
0.6000
7
2.01
2.500 ug/L
5.025 ug/L
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
N/A
N/A ng/L
N/A ng/L
-10-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par16
Molybdenum
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
Date Data BDL=1/2DL Results
1 6/13/2017 < 10 5 Std Dev.
2 9/19/2017 < 10 5 Mean
3 12/12/2017 < 10 5 C.V. (default)
4 3/13/2018 < 10 5 n
5 6/13/2017 11 11
6 9/19/2017 < 10 5 Mult Factor =
7 12/12/2017 < 10 5 Max. Value
8 3/13/2018 < 10 5 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
2.1213
5.7500
0.6000
8
1.90
11.0 pg/L
20.9 pg/L
-11-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par19
Selenium
Date Data BDL=1/2DL Results
1 Std Dev.
2 Mean
3 C.V.
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
Par20
Silver
NO DATA
NO DATA
NO DATA
0
N/A
N/A ug/L
N/A ug/L
Date Data BDL=1/2DL Results
1 6/13/2017 < 1 0.5 Std Dev.
2 9/19/2017 < 1 0.5 Mean
3 12/12/2017 < 1 0.5 C.V. (default)
4 3/13/2018 < 1 0.5 n
5 6/13/2017 < 1 0.5
6 9/19/2017 < 1 0.5 Mult Factor =
7 12/12/2017 < 1 0.5 Max. Value
8 3/13/2018 < 1 0.5 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
0.0000
0.5000
0.6000
8
1.90
0.500 ug/L
0.950 ug/L
-12-
26565 RPA 2021, data
11/23/2021

REASONABLE POTENTIAL ANALYSIS
Par21
Zinc
Date Data BDL=1/2DL Results
1 6/13/2017 26 26 Std Dev.
2 9/19/2017 36 36 Mean
3 12/12/2017 42 42 C.V. (default)
4 3/13/2018 36 36 n
5 6/13/2017 182 182
6 9/19/2017 140 140 Mult Factor =
7 12/12/2017 123 123 Max. Value
8 3/13/2018 65 65 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
Par22
0
58.9158
81.2500
0.6000
8
1.90
182.0 ug/L
345.8 ug/L
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
. Maximum data
points = 58
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
-13-
26565 RPA 2021, data
11/23/2021

Ramseur WWTP - Outfall 001
NC0026565 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 0.48 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 0.4800
1Q10S (cfs) = 9.12
7Q1OS (cfs) = 11.00
7Q1OW (cfs) = 23.00
30Q2 (cfs) = NO 30Q2 DATA
Avg. Stream Flow, QA (cfs) = 350.00
Receiving Stream: Deep River HUC 03030003
WWTP/WTP Class: Grade II
IWC% @ 1Q10S = 7.542579075
IWC% @ 7Q1OS = 6.335149864
IWC% @ 7Q1OW = 3.133423181
IWC% @ 30Q2 = N/A
IW%C @ QA = 0.212120521
Stream Class: C
COMBINED HARDNESS (mg/L)
Acute = 37.54 mg/L
Chronic = 37.3 mg/L
PARAMETER
TYPE
NC STANDARDS OR EPA CRITERIA
_1
a
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Chronic Applied Acute
Standard
11 # Det. Max Pred Cw Allowable Cw
Arsenic
Arsenic
C
C
150 FW(7Q10s) 340
10 HH/WS(Qavg)
ug L
ug/L
8 0
Note: n < 9
Limited data set
4.8
C.V. (default)
NO DETECTS
Acute (FW): 4,507.7
_ _
Chronic (FW): 2,367.7
Max MDL = 5 _ _ _
Chronic (HH): 4,714.3
Max MDL = 5
_ _ _ _ _
no detects
_ _ _ _ _
Beryllium
NC
6.5 FW(7Q10s) 65
ug/L
0 0
N/A
Acute: 861.77
___ _ _______ _ ___
Chronic: 102.60
Cadmium
NC
0.7982 FW(7Q10s) 4.6202
ug/L
8 0
Note: n < 9
Limited data set
0.950
C.V. (default)
NO DETECTS
Acute: 61.255
_ _ _ _ _ _ _ _
Chronic: 12.600
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No detects
Chlorides
NC
230 FW(7Q10s)
mg/L
0 0
N/A
Acute: NO WQS
___ _ _ ---- _ _ -----------------------------
Chronic: 3,630.5
Chlorinated Phenolic Compounds
NC
1 A(30Q2)
ug/L
0 0
N/A
Acute: NO WQS
-- _ _ _ _ _
-----IWC?------------------------------
Chronic:
Total Phenolic Compounds
NC
300 A(30Q2)
ug/L
0 0
N A
Acute: NO WQS
— — — — — — — —
Chronic: IWC?
— — — — — — — — — — — — — —
Chromium III
NC
163.3741 FW(7Q10s) 1262.7686
µg/L
0 0
N A
Acute: 16,741.9
-- _ _ _ ---- _ _ -----------------------------
Chronic: 2,578.9
Chromium VI
NC
11 FW(7Q10s) 16
µg L
0 0
N/A
Acute: 212.1
-- _ _ _ ----- _ _ ------------------------------
Chronic: 173.6
Chromium, Total
NC
µg'L
8 0
Note: n < 9
Limited data set
4.8
C.V. (default)
NO DETECTS
Max reported value = 2.5
Max MDL = 5
no detects
Page 14 of 15
26565 RPA 2021, rpa
11/23/2021

Ramseur WWTP
NC0026565
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
Outfall 001
Qw = 0.48 MGD
Copper
NC
11.0921 FW(7Q10s) 15.3611
ug/L
16 16
11,034.72
Acute: 203.66
___ _ _______ _ ___
Chronic: 175.09
2 value(s) > Allowable Cw
_ _ _ _ _ _ _ _ _ _ ___
RP shown - apply Monthly Monitoring with Limit
Cyanide
NC
5 FW(7Q10s) 22
10
ug/L
8 0
Note: n < 9
Limited data set
9.5
C.V. (default)
NO DETECTS
Acute: 291.7
_ _ _ _ _ _ _ _ _
Chronic: 78.9
Max MDL = 10
_ _ _ _ _ _ _ _ _ _ _ _ _ _
Fluoride
NC
1800 FW(7Q10s)
ug/L
0 0
N/A
Acute: NO WQS
— _ _ _ Chronic:----28,412.9_ ----------------------------
Lead
NC
4.6076 FW(7Q10s) 119.1148
ug/L
7 0
Note: n < 9
Limited data set
5.025
C.V. (default)
NO DETECTS
Acute: 1,579.232
_ _ _ _ _ _ _ _ _
Chronic: 72.731
Max MDL = 5
_ _ _ _ _ _ _ _ _ _ _ _ _ _
no detects
Mercury
NC
12 FW(7Q10s)
0.5
ng/L
0 0
N/A
Acute: NO WQS
— _ _
Chronic:----- 189.4 —
— — — — — — — — — — —
Molybdenum
NC
2000 HH(7Q10s)
ug/L
0 0
N/A
Acute: NO WQS
-- Chronic:----31,569.9
------
Nickel
Nickel
NC
NC
52.2259 FW(7Q10s) 472.8457
25.0000 WS(7Q10s)
µg/L
µg/L
8 1
Note: n < 9
Limited data set
20.9
C.V. (default)
Acute (FW): 6,269.0
_ _ _ _ _ _ _
Chronic (FW): 824.4
No_value > Allowab_le_Cw
Chronic (WS): 394.6
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Selenium
NC
5 FW(7Q10s) 56
ug/L
0 0
N/A
Acute: 742.5
-------------------------
Silver
NC
0.06 FW(7Q10s) 0.5965
ug/L
8 0
Note: n < 9
Limited data set
0.950
C.V. (default)
NO DETECTS
Acute: 7.909
_ _ _ _ _ _ _ _ _
Chronic: 0.947
Max MDL = 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _
no detects
Zinc
NC
177.8666 FW(7Q10s) 177.4136
ug/L
8 8
Note: n < 9
Limited data set
345.8
C.V. (default)
Acute: 2,352.2
_ _ _ _ _ _ _ _ _ _ _ _ _
Chronic: 2,807.6
No value > Allowable Cw
_ _ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
0 0
N/A
Acute:
0 0
N/A
Acute:
-- Chronic: ------------
Page 15 of 15
26565 RPA 2021, rpa
11/23/2021

FACILITY: Ramseur WWTP Outfall 001
NPDES PERMIT: NC0026565
Dissolved to Total Metal Calculator
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
Receiving
Stream
summer
7Q10 (CFS)
Receiung
Stream
summer 7Q10
(MGD)
Rec. Stream
1Q10
[MGD]
NPDES
Flow Limit
[MGD]
Total Suspended
Solids
-Fixed Value-
(mg/L)
Combined
Hardness
chronic
(mg/L)
Combined
Hardness
Acute
(mg/L)
Instream
Wastewater
Concentration
(Chronic)
Instream
Wastewater
Concentration
(Acute)
Hardness
Average (mg/L)
EffluentUpstream
Hardness
Average
(mg/L)
11.0000
7.0968
5.8839
0.4800
10
37.297
37.544
6.3351
7.5426
36
56.4706
PARAMETER
Dissolved Metals Criteria
after applying hardness
equation
Chronic
Acute
[ug/I]
[ug/I]
US EPA
Translators- using
Default Partition
Coefficients
(streams)
Total Metal Criteria Total Metal =
Dissolved Metal + Translator
Chronic
Acute
Upstream Hard Avg (mg/L) = 36
EFF Hard Avg (mg/L) = 56.4706
[ug/I]
[ug/I]
Cadmium (d)
Cd -Trout streams
Chromium III (d)(h)
Chromium VI (d)
0.20
0.20
33
11
1.17
0.73
255
16
0.252
0.252
0.202
1.000
0.80
0.80
163.37
11.00
4.62
2.87
1262.77
16.00
Chromium, Total (t)
Copper (d)(h)
Lead (d)(h)
3.9
0.85
5.3
22
0.348
0.184
N/A
11.09
4.61
N/A
15.36
119.11
Nickel (d)(h)
23
204
0.432
Ni - WS streams (t)
Silver (d)(h,acute)
0.06
0.60
1.000
52.23
472.85
N/A
0.06
0.60
Zinc (d)(h)
51
51
0.288
177.87 177.41
Beryllium
1.000
6.5
65
Arsenic (d)
1.000
150
340
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
(d) = dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(h) = hardness -dependent dissolved metal standard. See 15A NCAC 02B .0211 for more information.
(t) = based upon measurement of total recoveable metal. See 15A NCAC 02B .0211 for more information.
The Human Health standard for Nickel in Water Supply Streams is 25 mg/L which is Total Recoverable metal standard.
The Human Health standard for Arsenic is 10 µg/L which is Total Recoverable metal standard.

Permit No. NC0026565
NPDES Implementation of Instream Dissolved Metals Standards - Freshwater Standards
The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.
Table 1. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter
Acute FW, µg/1
(Dissolved)
Chronic FW, µg/1
(Dissolved)
Acute SW, µg/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 1.1g/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151 [In hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.136672-[ln hardness](0.041838)} • e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.101672-[ln hardness](0.041838)} • e^{0.7998[ln hardness]-4.4451}
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[In hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[In hardness]-1.460}
Lead, Chronic
WER*{1.46203-[ln hardness](0.145712)} • e^{1.273[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. NC0026565
Silver, Acute
WER*0.85 • e^{1.72[In hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^{0.8473[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. NC0026565
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 + s7Q 10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
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+a)] [10-6] }
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (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)
s7Q 10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0026565
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)
56.5
Data provided by Permittee
Average Upstream Hardness, mg/L
(Total as CaCO3)
36
Data provided by Permittee
7Q10 summer (cfs)
11
Reported in previous permit Fact
Sheet
1Q10 (cfs)
9.12
Calculated in RPA spreadsheet
Permitted Flow (MGD)
0.480
Design flow
Date: July 20, 2021
Permit Writer: Gary Perlmutter
Page 4 of 4

Environment 1, Incorporated
P.O. BOX 7085, 114 OAKMONT DRIVE
GREENVILLE, N.C. 27835-7085
SUEZ WATER (RAMSEUR WWTP)
NADINE BLACKWELL
P.O. BOX 1279
CLEMMONS ,NC 27012
Drinking;Water .ID,. 37715j
Waete,Natet' ID1 10:.
PHONE [phone]
FAX [phone]
ID#: 956 T
DATE COLLECTED: 03/10/20
DATE REPORTED : 03/27/20
REVIEWED BY:
Effluent Upstream Analysis Method
PARAMETERS Date Analyst Code
Ar:nonia Nitrogen as N, mg/I 4.00
Total Kjeldahl Nitrogen as N,mg/I 5.30
Nitrate -Nitrite as N, mg/1 0.52
Total Phosphorus as P, mg/1 2.80
Total Hardness, :ng/l 46
Copper, ug/1 131
Total Nitrogen, mg/1 (calc) 5.82
03/11/20 BLD 350.1 R2-93
03/13/20 AKS 351.2 R2-93
03/11/20 AKS 353.2 R2-93
03/13/20 BLD 365.4-74
03/16/20 TMR 2340C-11
03/16/20 LFJ EPA200.7

Environment 1, Incorporated
P.O. BOX 7085, 114 OAKMONT DRIVE
GREENVILLE, N.C. 27835-7085
SUEZ WATER (RAMSEUR WWTP)
NADINE BLACKWELL
P.O. BOX 1279
CLEMMONS ,NC 27012
Drinking:,,Nater;LID 1, 3771.5'
-Waeteria ter. SD:.10
PHONE [phone]
FAX [phone]
ID#: 956 T
DATE COLLECTED: 06/09/20
DATE REPORTED : 06/18/20
REVIEWED BY:
Effluent Upstream Analysis Method
PARAMETERS Date Analyst Code
Ammonia Nitrogen as N, mg/1
Total Kjeldahl Nitrogen as N,mg/l
Nitrate -Nitrite as N, mg/1
Total Phosphorus as P, mg/I
Total Hardness, mg/1
Copper, ug/l
Total Nitrogen, mg/I (calc)
4.69
5.19
0.73
2.12
46
5.92
06/10/20 TCW 350.1 R2-93
06/16/20 TLH 351.2 R2-93
06/16/20 DTL 353.2 R2-93
06/16/20 DTL 365.4-74
06/15/20 GNB 2340C-11
06/15/20 LFJ EPA200.7

Anaa haupdg6
)AKMONT DRIVE
AENVILLE, N.C. 27858
SUEZ WATER (RAMSEUR WWTP)
NADINE BLACKWELL
P.O. BOX 1279
CLEMMONS , NC 27 012
PARAMETERS
Ammonia Nitrogen as N, mg/1
Total Kjeldahl Nitrogen as N,mg/l
Nitrate -Nitrite as N, mg/1
Total Phosphorus as P, mg/l
Total Hardness, mg/1
Copper, ug/l
Total Nitrogen, mg/1 (calc)
Drinking Water ID: 371
w_ate water,ID: 10
PHONE [phone](
FAX [phone];
ID#: 956 T
DATE COLLECTED? 09/22/20
00/12/20
DATE REPORTED
REVIEWED BY:
Analysis Method
Effluent Upstream Anal Y
Date Analyst Code
12.16 09/24/20 KES 350.1 R2-93
12.44 09/29/20 TLH 351.2 R2-93
0.17 09/24/20 TLH 353.2 R2-93
3.55
09/29/20 KES 365.4-74
��
09/28/20 JMS 2340C-11
10/05/20 LFJ EPA200.7

,Lokatugml
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
i7
ECCIpcg(gaco
RAMSEUR WWTP
724 LIBERTY STREET
P.O. BOX 545
RAMSEUR ,NC 27316
PARAMETERS
Ammonia Nitrogen as -N, mg/I
--Total Ijjeldahl Nitrogen as N,tng/I
Nitrate -Nitrite as N, mg/I
"Total Phosphorus as P, mg/l
Total Hardness, mg/I
Copper, ng/I
Total Nitrogen, mg/1 (calc)
262) 750. 28
FAX '[phone]
ID#: 473 T
DATE COLLECTED: 12/15/20
DATE REPORTED 12/30/20
REVIEWED BY:
Effluent Upstream Analysis Method
Date Analyst Code
yZ •a
-r6s 7`7 �. b
(eta,'
Z
2.34 12/16/20 KES 350,1 R2-93.
4,15 12/23/20 TLH 351.2 R2-93
1.05 12/16/20 DTL 353.2 R2-93
4.7 12/23/20 KES 365.4-74
34 12/21/20 TMR 2340C-11
18 12/21/20 LFJ EPA200.7
5.20

.1.1Pawhilogild
114 OAKMONT DRIVE'
GREENVILLE, N.C. 27858
RAMSEUR WWTP
724 LIBERTY STREET
P.O. BOX 545
RAMSEUR ,NC 27316
PARAMETERS
ID##: 473 T
rAX (2$2) 756-0633
DATE COLLECTED: 03/09/21
DATE REPORTED : 03/29/21
REVIEWED BY:
Effluent Upstream Analysis Method
Date Analyst Code
- Ammonia Nitrogen as N, mg/1 3.88
Total Kjeldahl Nitrogen as N,mg/I 4,98
Nitrate+Nitrite as N, mg/I 1.00
'-'Total Phosphorus as P, mg/I 2.23
Total Hardness, mg/1 4G
Copper, ug/l 43
.. Total Nitrogen, mg/I (calc) 5,98
03/10/21 DTL 350.1 R2-93
03/16/21 KES 351.2 R2-93
03/11/21 DTL 353,21R2-93
03/16/21 DTL 365,4-74
03/15/21 DIJ 2340C-11
03/15/21 LFJ EPA200.7
l7/1714

T W T©T gntt
114 OAKMONT DRIVE
GREENVILLE, N.C. 27858
tom
RAMSEUR WWTP
724 LIBERTY STREET
P.O. BOX 545
RAMSEUR, NC 27316
PARAMETERS
Ammonia Nitrogen as N, mg/1
Total Kjeldahl Nitrogen as N,mg/1
Nitrate+Nitrite as N, mg/1
'.Total Phosphorus as P, mg/1
Total Hardness, mg/1
Copper, ug/1
Total Nitrogen, mg/1 (talc)
Komitcof
PHONE [phone]
FAX [phone]
ID#: 473 T
DATE COLLECTED: 06/15/21
DATE REPORTED : 06/28/21
REVIEWED BY:
Effluent Upstream Analysis Method
Date Analyst Code
13.56 06/22/21 TCW 350.1 R2-93
17,25 06/17/21 TLH 351.2 R2-93
0.08 06/21/21 TLH 353.2 R2-93
5,41 06/17/21 RES 365.4-74
6S 32 J % 06/21/21 BLV 2340C-11
06/17/21 LFJ EPA200.7
17.33

11/23/21 WQS = 12 ng/L
Facility Name Ramseur WWTP / NC0026565
/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 =
6/13/17 < 1
9/19/17 < 1
12/12/17 < 1
3/13/18 < 1
6/12/18 < 1
9/25/18 1
12/18/18 1.9
3/12/19 < 1
6/11/19 < 1
7/23/19 1.6
9/17/19 < 1
12/10/19 < 1
3/10/20 3.5
6/9/20 1.1
9/22/20 < 1
12/15/20 1
3/9/21 1.4
No Limit Required
No MMP Required
0.5
0.5
0.5
0.5
0.5
1
1.9
0.5
0.5
1.6
0.5
0.5
3.5
1.1
0.5
1
1.4
11.000
0.480
cfs
WQBEL = 189.42 ng/L
47 ng/L
0.5 ng/L - Annual Average for 2017
1.0 ng/L - Annual Average for 2018
0.7 ng/L - Annual Average for 2019
1.5 ng/L - Annual Average for 2020
1.4 ng/L - Annual Average for 2021

Ramseur WWTP / NC0026565
Mercury Data Statistics (Method 1631E)
2017
2018
2019
2020
2021
# of Samples
3
4
5
4
1
Annual Average, ng/L
0.5
1.0
0.7
1.5
1.4
Maximum Value, ng/L
0.50
1.90
1.60
3.50
1.40
TBEL, ng/L
47
WQBEL, ng/L
189.4

Proof Of Publication in
COURIER -TRIBUNE
NCDENR/DWQINPDES
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 276991617
STATE OF NORTH CAROLINA, RANDOLPH COUNTY
To Whom It May Concern:
This is to certify the advertisement attached hereto has been
published in COURIER -TRIBUNE 1 time(s) in issues dated:
November 26, 2021
the last day of said publication being the
26th day of November, 2021
Notary Public, Stat
Wisconsin, County of Brown
My commissiaFl expires
sworn to before me and subscribed in my presence by this the
26th day of November, 2021
FEE: $95.42
AD #: 0001435026
ACCT: 54948
AMY KOKOTT
Notary Public
State of Wisconsin
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 NC0026565
Ramseur WWTP The North Caroli-
na Environmental Management
Commission proposes to issue a
NPDES wastewater discharge per-
mit 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 Resour-
ces (DWR) may hold a public hear-
ing should there be a significant
degree of public interest. Please
mail comments and/or informa-
tion 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. Additional in-
formation on NPDES permits and
this notice may be found on our
website: http://deq.nc.gov/about/
divisions/water-resources/water-
resou rces-permits/wastewater-
branch/npdes-wastewater/
public-notices,or by calling (919)
707-3601. The Town of Ramseur [P.
O. BOx 545, Ramseur, NC 27316]
has requested renewal of NPDES
Permit NC0026565 for its Ramseur
WWTP located in Randolph Coun-
ty. This permitted facility permit-
ted discharges treated municipal
and industrial wastewater to the
Deep River, a Class C water in the
Cape Fear River Basin. Some of
the parameters in the permit are
water -quality limited. This dis-
charge may affect future alloca-
tions in this segment of the Deep
River.
It: 11/26/21
Page 1 of 1

SOUTHERN
ENV RONMENTAL
CENTER
Via U.S. e-mail
Gary Perlmutter
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
601 West Rosemary Street, Suite 220 Telephone [phone]
Chapel Hill, NC 27516 Facsimile 919-929-9421
December 17, 2021
RE: Southern Environmental Law Center Comments on NPDES Wastewater
Permit NC0026565 — Ramseur WWTP
Dear Mr. Perlmutter:
The Southern Environmental Law Center offers the following comments on Draft
National Pollutant Discharge Elimination System ("NPDES") Permit NC0026565, issued by the
North Carolina Department of Environmental Quality ("DEQ") to the Town of Ramseur.
The permit allows Ramseur to discharge wastewater likely contaminated with per- and
polyfluoroalkyl substances, or PFAS, from its wastewater treatment plant ("WWTP") into
downstream drinking water supplies in the Cape Fear River basin. Communities in Sanford,
Harnett, Dunn, and Fayetteville are downstream of the treatment plant and their drinking water
supplies have previously contained PFAS,1 which are known to harm human health. Based on
previous sampling, Ramseur's discharge almost certainly contains PFAS. The town did not,
however, disclose its discharge of PFAS in its permit application, and DEQ did not evaluate
limits for the chemicals in its draft permit, as required by the Clean Water Act and state laws.
Because Ramseur did not disclose its PFAS discharges in its application, any permit issued by
the agency will necessarily prohibit all discharges of the chemicals. DEQ has the authority to
issue a permit that allows discharges, but it cannot do so by ignoring what pollutants are in the
discharge. DEQ, therefore, must require disclosure of PFAS and include necessary limits in the
town's permit.
EPA's PFAS Strategic Roadmap recently affirmed that "existing NPDES authorities" can
be used to "reduce discharges of PFAS at the source."2 EPA's plan further confirms that the
Clean Water Act pretreatment program can be used to control sources of PFAS, and the agency
plans to "require pretreatment programs to include source control."3 North Carolina has already
1 EPA, Occurrence Data for the Unregulated Contaminant Monitoring Rule (UCMR) 3, https://perma.cc/2EXD-
AKPQ.
2 EPA, PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024 at 14, https://perma.cc/LK4U-RLBH.
3 Id.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

faced a PFAS drinking water crisis. Because communities continue to suffer from exposure to
these chemicals, DEQ must act now to stop PFAS from entering our rivers, streams, and drinking
water supplies. The need for action is most urgent in the Cape Fear River, where sources
upstream from Chemours, such as Ramseur, are significant contributors to PFAS contamination.
For each permit issued for facilities that discharge PFAS, DEQ must use its existing authority
under the Clean Water Act to require disclosure and evaluate limits.
Similarly, previous sampling has indicated that Ramseur's discharge likely contains 1,4-
dioxane, another toxic chemical. Ramseur also did not disclose whether it discharges 1,4-dioxane
and DEQ did not evaluate limits for the chemical in its draft permit. Instead, the draft permit
includes a monthly monitoring requirement for the toxic chemical. Monitoring is not a substitute
for the mandatory permitting process that DEQ must conduct.
In order to comply with the Clean Water Act, DEQ should withdraw this draft permit,
return Ramseur's application, and re -start the permitting process after the town makes the
necessary disclosures.
A. The Ramseur WWTP discharges toxic PFAS.
Sampling conducted in 2019 reveals that the influent to Ramseur's WWTP has contained
PFAS concentrations above 499 parts per trillion ("ppt").4 Because the treatment plant is not
equipped to remove PFAS, it is almost certain that Ramseur is releasing PFAS into the Cape
Fear River basin, a source of drinking water for nearly one million North Carolinians. It is also
likely that the influent data is an underestimate of how much PFAS the town is releasing in its
wastewater discharge. PFAS sampling conducted at WWTPs often find that concentrations of
PFAS increase from the influent to the effluent because treatment plant influent often contains
PFAS precursors that cannot be found using certain analytical methods. As studies have found,
there can be a "substantial increase" in specific PFAS after wastewater treatment, and that the
"degradation of precursor compounds is a significant contributor to PFAS contamination in the
environment."5
PFAS are a serious threat to human health and the environment. Two of the most
commonly studied PFAS—perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate
("PFOS")—have been found to cause developmental effects to fetuses and infants, kidney and
testicular cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis, lower
birth weight and size, obesity, decreased immune response to vaccines, reduced hormone levels,
and delayed puberty.6 In 2016, EPA established a lifetime health advisory of 70 ppt for the
4 2019 Sampling Data — Ramseur WWTP (Attachment 1).
5 Ulrika Eriksson, et al., Contribution of precursor compounds to the release of per- and polyfluoroalkyl substances
(PFASs) from waste water treatment plants (WWTPs), 61 J. ENvIRoN. SCI.80-90 (2017); see also Mich. Dep't of
Env't, Great Lakes, and Energy, Summary Report: Initiatives to Evaluate the Presence of PFAS in Municipal
Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan, at 9-10, https://perma.cc/C2Z8-DT99.
6 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENVTL. HEALTH
PERSPECTIVES 5, A 107 (2015); U.S. EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories, at 2,
https://perma.cc/CX95-N67K.

combined concentrations of PFOA and PFOS in drinking water. EPA has since updated toxicity
assessments for the chemicals, suggesting that the health values for the chemicals should be
magnitudes lower. The updated toxicity assessments would translate to health advisories of .006
ppt for PFOA and .029 ppt for PFOS.8 Epidemiological studies show that other PFAS similarly
harm human health at low levels.9 Given that PFAS concentrations less than 1 ppt can be
harmful to human health, DEQ cannot ignore sampling data showing that Ramseur may be
discharging PFAS at 499 ppt, or even higher.
B. The Ramseur WWTP likely discharges 1,4-dioxane, another toxic chemical.
Sampling at the Ramseur WWTP from 2019 also found 1,4-dioxane in the treatment
plant's influent.10 Because the treatment plant is also not equipped to remove 1,4-dioxane, it is
likely that Ramseur is releasing the chemical in its wastewater. 1,4-dioxane is a clear, man-made
chemical that is a byproduct of many industrial processes.11 The chemical is toxic to humans,
causing liver and kidney damage.12 As a result of the harms caused by 1,4-dioxane, EPA
established a drinking water health advisory with an associated lifetime cancer risk of one -in -
one -million at a concentration of 0.35 parts per billion ("ppb"),13 and North Carolina's rules
prohibit the release of 1,4-dioxane that would cause or contribute to an exceedance of 0.35 ppb
in water supply waters.14
C. DEQ must require Ramseur to disclose any PFAS or 1,4-dioxane that the town is
discharging from its treatment plant.
The Clean Water Act prohibits the discharge of any pollutant without a NPDES permit.
The discharge of a specific pollutant (or group of pollutants) cannot be permitted if it is not
disclosed in a NPDES permit application. Therefore, Ramseur is required to disclose any
discharges of PFAS or 1,4-dioxane in its permit application —as DEQ recognized in its 2017
enforcement action against Chemours.
7 EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories at 2.
8 Garret Ellison, No safe PFAS exposure level? EPA toxicity drafts point that way, MLIVE, Nov. 20, 2021,
https://perma.cc/S7GW-DUCA.
9 EPA, Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium Salt
(CASRN 13252-13-6 and CASRN 62037-80-3) (2021), https://perma.cc/FG6A-TXQ9.
10 2019 Sampling Data — Ramseur WWTP (Attachment 1).
11 EPA, Technical Fact Sheet—1,4-Dioxane, at 1-2 (2017), https://perma.cc/NM9K-2P84 ("EPA 1,4-dioxane fact
sheet").
12Id.; EPA, Integrated Risk Information System, Chemical Assessment Summary: 1,4-dioxane at 2,
https://perma.cc/B2A2-R4M5.
13 EPA, 2018 Edition of the Drinking Water Standards and Health Advisories, at 4 (2018), https://perma.cc/N8N4-
BA3R; N.C. Div. of Water Res., I,4-dioxane Monitoring in the Cape Fear River Basin of North Carolina: An
Ongoing Screening, Source Identification, and Abatement Verification Study, at 2 (2017), https://perma.cc/7MMR-
B9SQ.
14 Frequently Asked Questions (FAQ), Special Order by Consent (SOC) for the City of Greensboro T.Z. Osborne
WWTP, https://perma.cc/E8YY-8YFV (interpreting 15A N.C. Admin Code 2B.0208).

If a NPDES permit applicant does not adequately disclose its release of a pollutant, the
applicant does not have approval to discharge the pollutant.15 Disclosure is considered adequate
when the applicant provides enough information for a permitting agency to "be[] able to judge
whether the discharge of a particular pollutant constitutes a significant threat to the
environment."16 To meet this burden, an applicant must include all relevant information,
including the concentration, volume, and frequency of the discharge.17 The Clean Water Act
places the burden of disclosure on the permit applicant because they are in the best position to
know what is in their discharge.'$
The EPA has stressed the need for disclosure of pollutants during the permitting process:
[D]ischargers have a duty to be aware of any significant pollutant levels in their
discharge. [...] Most important, [the disclosure requirements] provide the
information which the permit writers need to determine what pollutants are likely
to be discharged in significant amounts and to set appropriate permit limits. [...]
[P]ermit writers need to know what pollutants are present in an effluent to
determine approval permit limits in the absence of applicable effluent
guidelines.' 9
The EPA Environmental Appeals Board's decision in In re: Ketchikan Pulp Company further
emphasized the importance of disclosure,20 and this decision has been adopted by the Fourth
Circuit. In Piney Run Pres. Ass 'n v. Cty. Comm 'rs of Carroll Cty., Maryland, the Fourth Circuit
stated:
The Ketchikan decision therefore made clear that a permit holder is in compliance
with the [Clean Water Act] even if it discharges pollutants that are not listed in its
permit, as long as it only discharges pollutants that have been adequately
disclosed to the permitting authority. [...] To the extent that a permit holder
discharges a pollutant that it did not disclose, it violates the NPDES permit
and the [Clean Water Act].2'
15 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998); Piney Run Pres. Ass 'n v. Cty. Comm'rs of Carroll Cty.,
Maryland, 268 F.3d. 255 (4th Cir. 2001); Southern Appalachian Mountain Stewards v. A & G Coal Corp., 758 F.3d
560 (4th Cir. 2014).
16 Piney Run, 268 F.3d at 268 ("Because the permitting scheme is dependent on the permitting authority being able
to judge whether the discharge of a particular pollutant constitutes a significant threat to the environment, discharges
not within the reasonable contemplation of the permitting authority during the permit application process, whether
spills or otherwise, do not come within the protection of the permit shield.").
17 See In re Ketchikan Pulp Co., 7 E.A.D. 605 ("In explaining the provisions of 40 C.F.R. § 122.53(d)(7)(iii), which
required dischargers to submit quantitative data relating to certain conventional and nonconventional pollutants that
dischargers know or have reason to believe are present in their effluent, the [EPA] stated: `permit writers need to
know what pollutants are present in an effluent to determine appropriate limits in the absence of effluent
guidelines.'").
18 S. Appalachian Mountain Stewards, 758 F.3d at 566.
19 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33,526-31 (May 19, 1980).
20 See In re Ketchikan Pulp Co., 7 E.A.D. 605.
21 Piney Run, 268 F.3d. at 268 (emphasis added).

Moreover, municipalities that own and operate wastewater treatment plants are
required to "fully and effectively exercise[] and implement[]" their authority to
"[i]dentify the character and volume of pollutants contributed to the [publicly owned
treatment works]" by Industrial Users.22
DEQ has acknowledged that disclosure of toxic pollutants, including PFAS, is required
by the Clean Water Act and state water quality laws. In its enforcement action against The
Chemours Company, LLC for the company's discharge of GenX and other PFAS into the Cape
Fear River, the agency stated:
Part of the permit applicant's burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose "all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 2H .0105(j) (emphasis added). [...] These disclosure obligations are
critical, in part, because they define the scope of the Clean Water Act's "permit
shield." While compliance with the express terms of an NPDES permit generally
"shields" the permittee from liability for violations of 33 U.S.C. § 1311, the
permit does not shield the permittee from liability where the pollutant being
discharged was not within the "reasonable contemplation" of the permitting
agency when it issued the permit due to nondisclosure by the permittee.23
The agency further acknowledged that the company had violated its NPDES permit and
state water quality laws by "failing to fully disclose all known toxic components reasonably
expected to be in [the company's] discharge."24
DEQ's position in the Chemours enforcement case was correct and should be applied to
Ramseur in this permit renewal. Ramseur likely discharges PFAS and 1,4-dioxane, and the town
was required to disclose the pollutant in its permit application so that DEQ can "judge whether
the discharge" "constitutes a significant threat to the environment."25 Because Ramseur failed to
do so,26 DEQ does not have the information it needs to make an informed decision on the town's
application.27 DEQ must require Ramseur to disclose any discharge of PFAS or 1,4-dioxane in
the town's permit application before moving forward with the draft permit.
22 40 C.F.R. § 403.8(f)(1)(vi)(B).
23 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 67 (N.C. Super. 2018)
(citing 33 U.S.C. § 1342(k), Piney Run Pres. Ass v. Cty. Comm 'rs of Carroll Cty., MD, 268 F.3d 255, 265 (4th
Cir. 2001)).
24 Id. at 33.
25 Piney Run, 268 F.3d at 268.
26 See Town of Ramseur, Permit Renewal, Application No. NC0026565, Nov. 10, 2020.
27 See S. Appalachian Mountain Stewards, 758 F.3d at 566 ("[T]he CWA and its implementing regulations focus on
the information that the permit applicant must gather and provide to the permitting agency, so that it can make a
fully informed decision to issue the requested permit.").

In addition, DEQ's mandated monitoring for 1,4-dioxane does not absolve
Ramseur's obligation to disclose its 1,4-dioxane discharge in its application. Without
disclosure during the application process, the agency cannot evaluate the discharge for
compliance with permitting requirements and the public does not have sufficient
information to meaningfully review and comment on the draft permit. Because public
notice and informed participation are mandated by law,28 monitoring reports sent only to
the agency after the permit has been issued cannot be considered adequate disclosure.
D. DEQ must analyze appropriate effluent limits for PFAS and 1,4-dioxane in
Ramseur's NPDES permit.
Because Ramseur is likely discharging PFAS and 1,4-dioxane, DEQ must consider
appropriate permit limits for these chemicals. Ramseur can then comply with any limits in its
permit by properly regulating its industries —for instance, by requiring industries to use
alternative chemicals, or to install treatment technology to remove pollutants from their
wastewater before sending it to the town's treatment plant.
The Clean Water Act requires permitting agencies to, at the very least, incorporate,
technology -based effluent limitations on the discharge of pollutants.29 North Carolina water
quality laws further state that municipalities must be treated like an industrial discharger if an
industry "significantly impact[s]" a municipal treatment system.30 In this situation, the agency
must consider technology -based effluent limits for the municipality, even if effluent limits and
guidelines have not been published and adopted.
Effective treatment technologies for PFAS and 1,4-dioxane are available. A granular
activated carbon treatment system has been used at Chemours' facility to reduce PFAS as high as
345,000 ppt from a creek contaminated by groundwater beneath the facility to nearly
nondetectable concentrations.31 Similarly, 1,4-dioxane can be removed using advanced oxidation
processes, such as using ultraviolet light in combination with hydrogen peroxide.32 Such a
process has been used at the Tucson International Airport Area Superfund Site to remove legacy
1,4-dioxane contamination.33 DEQ must consider the feasibility of Ramseur's industries
installing similarly effective treatment technologies.
28 40 C.F.R. § 124.10 (a); 15A N.C. Admin. Code 2H.0109(a).
29 40 C.F.R. § 125.3(a); see also 33 U.S.C. § 1311.
3° 15A N.C. Admin Code 02B .0406 (a), (e).
31 Ted Schoenberg, Parsons, Old Outfall 002 GAC Pilot Study Interim Results Report, Chemours Fayetteville, North
Carolina Facility, 4-5 (Aug. 5, 2019), https://perma.cc/DU3Y-25AW; Parsons, Old Outfall 002 Surface Water
Sampling Results (Sept. 30, 2019) at Table 1, https://perma.cc/6BYQ-RNXZ.
32 Amie C. McElroy, et al., 1,4-Dioxane in drinking water: emerging for 40 years and still unregulated, 7 CURRENT
OPINION IN ENv'T SCIENCE & HEALTH 117, 119 (2019), https://perma.cc/P8L3-CC5G.
33 See Advanced Treatment for 1,4-Dioxane — Tucson Removes Contamination Through UV -oxidation, TROJANUV
CASESTUDIES (2019), https://perma.cc/Z95X-D6A5; see also Educational Brochure, TUCSON AIRPORT AREA
REMEDIATION PROJECT, https://perma.cc/XUH8-W4DZ.

If these limits are not enough to ensure compliance with water quality standards, then
water quality -based effluent limits must be included in the town's permit.34 PFAS are known to
harm human health, and their discharge threatens to violate multiple water quality standards,
including the state toxic substances standard.35 DEQ itself has stated in its lawsuit against
Chemours that PFAS "meet the definition of `toxic substance' under North Carolina rules.36
DEQ has also applied the toxic substances standard to 1,4-dioxane, interpreting the standard to
require concentrations of 1,4-dioxane be less than 0.35 ppb in rivers and streams that serve as
drinking water supplies.37 In order to comply with the Clean Water Act, therefore, DEQ must
limit Ramseur's discharge so that it will not cause, or contribute to concentrations of 1,4-dioxane
exceeding 0.35 ppb in any downstream drinking water supplies.38
Once appropriate limits are included in a Ramseur's NPDES permit, the town must
regulate its industries so that industries do not cause the treatment plant to violate its own
NPDES permit.39 This is how the Clean Water Act "assures the public that [industrial]
dischargers cannot contravene the [Clean Water Act's] objectives of eliminating or at least
minimizing discharges of toxic and other pollutants simply by discharging indirectly through
[wastewater treatment plants] rather than directly to receiving waters."40 As is appropriate, the
pretreatment program is intended to place the burden of treating polluted discharges on the entity
that creates the pollution, rather than on the taxpayers that support municipally owned treatment
plants. Moreover, municipalities like Ramseur that own and operate wastewater treatment plants
are required to "immediately and effectively to halt or prevent any discharge of pollutants to the
[publicly owned treatment works] which reasonably appears to present an imminent
endangerment to the health or welfare of persons."41 Together, these laws ensure that such
municipally owned treatment plants do not become dumping grounds for uncontrolled industrial
waste.
Ramseur, therefore, cannot allow industries to cause its treatment plant to violate the
town's own NPDES permit.42 Ramseur could prevent violations of its permit by requiring
industries to use alternative chemicals, or to install treatment technology to remove PFAS or 1,4-
34 15A N.C. Admin. Code 2H.0112(c) (stating that DWR must "reasonably ensure compliance with applicable water
quality standards and regulations."); see 33 U.S.C. § 1311(b)(1)(c) (requiring that permit limits be established as
necessary to comply with water quality standards).
35 15A N.C. Admin. Code 2B.0208(a).
36 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 32 (N.C. Super. 2018)
(stating that "the process wastewater from [Chemours'] Fluoromonomers/Nafion® Membrane Manufacturing Area
contains and has contained substances or combinations of substances which meet the definition of "toxic substance"
set forth in 15A N.C.A.C. 2B .0202," referring to GenX and other PFAS).
37 N.C. Div. of Water Res., I, 4-dioxane Monitoring in the Cape Fear River Basin of North Carolina: An Ongoing
Screening, Source Identification, and Abatement Verification Study, at 2 (2017), https://perma.cc/3RK6-8T4D.
38 40 C.F.R. § 122.44(d)(1)(i); see also 15A N.C. Admin. Code 2B.0203 ("Water quality based effluent limitations
and management practices for direct or indirect discharges of waste or for other sources of water pollution shall be
developed by the Division such that the water quality standards and best usage of receiving waters and all
downstream waters will not be impaired.").
39 40 C.F.R. § 403.8(f)(1).
40 General Pretreatment Regulations for Existing and New Sources, 52 Fed. Reg. 1586, 1590 (Jan. 14, 1987)
(codified at 40 C.F.R. § 403).
41 40 C.F.R. § 403.8(f)(2)(ii).
42 Id. § 403.8(f)(1).

dioxane from their wastewater before sending wastewater to the town's treatment plant. In
Michigan, for instance, municipalities have been effectively reducing their PFAS discharges by
requiring industrial users to install treatment technology. Municipalities in Michigan had
discovered that industries, such as metal finishers, paper manufacturers, and fabric/leather
treaters, were sending PFAS-contaminated wastewater to their treatment plants.43 After industrial
users installed treatment systems to remove PFAS, PFOS levels in the discharges of several
treatment plants were reduced by up to 99 percent.44 By including appropriate limits in
Ramseur's NPDES permit (as well as permits for other municipalities), DEQ can put the burden
of cleaning up toxic pollution on the industries that create it.
In summary, DEQ must require Ramseur to disclose any discharges of PFAS or 1,4-
dioxane in its permit application so that DEQ and the public have adequate information to
evaluate the discharge. If the town does not make that disclosure, any discharge of these
chemicals is illegal and subject to agency or citizen enforcement. DEQ must then evaluate
available treatment technologies and impose necessary limits. Because the draft permit fails to
meet these requirements, it should be withdrawn.
Thank you for considering these comments. Please contact me at 919-967-1450 or
[e-mail] if you have any questions regarding this letter.
Sincerely,
e5'----a
Jean Zhuang
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516
919-967-1450
43 Michigan.gov, Michigan PFAS Action Response Team, Wastewater Treatment Plants/Industrial Pretreatment
Program, https://perma.cc/2AZ7-ASHH.
44 Id.

ATTACHMENT 1

POTW Name:
Town of Ramseur WWTP
NPDES #:
NC0026565
Influent Grab (ng/L)
CAS Number
Analyte Name
Acronym
7/8/2019
Lab Qualifer(s)
8/6/2019
Lab Qualifer(s)
9/4/2019
Lab Qualifer(s)
375-22-4
Perfluorobutanoic acid
PFBA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<0.311)
344
ND
U (<1.24)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
335-76-2
Perfluorodecanoic acid
PFDA
0.586
ND
U (<1.25)
ND
U (<1.24)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-85-9
Perfluoroheptanoic acid
PFHpA
1.24
ND
U (<1.25)
ND
U (<1.24)
355-46-4
Perfluorohexanesulfonic acid
PFHxS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
307-24-4
Perfluorohexanoic acid
PFHxA
6.97
4.77
4.64
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<0.31)
ND
U (<1.25)
ND
U (<1.24)
375-95-1
Perfluorononanoic acid
PFNA
0.782
ND
U (<1.25)
ND
U (<1.24)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<0.316)
ND
U (<1.25)
ND
U (<1.24)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-MeFOSAA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2706-90-3
Perfluoropentanoic acid
PFPeA
41.8
103
313
376-06-7
Perfluorotetradecanoic acid
PFTeA (PFTA)
0.761
ND
U (<1.25)
ND
U (<1.24)
72629-94-8
Perfluorotridecanoic acid
PFTriA (PFTrA)
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
62037-80-3
Gen-X
HFPO-DA
ND
U (<10.90)
ND
U (<43.9)
ND
U (<43.3)
757124-72-4
4:2 Fluorotelomer sulfonate
4:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
27619-97-2
6:2 Fluorotelomer sulfonate
6:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
39108-34-4
8:2 Fluorotelomer sulfonate
8:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
335-67-1
Perfluorooctanoic acid
PFOA
2.93
2
1.96
1763-23-1
Perfluorooctanesulfonic acid
PFOS
6.52
45.7
8.06
Sum of PFOA and PFOS
9.45
47.7
10.02
Total PFAS
61.589
499.47
327.66
Influent Grab ug/L)
7/8/2019
Lab Qualifer(s)
8/6/2019
Lab Qualifer(s)
9/4/2019
Lab Qualifer(s)
1, 4 - Dioxane
ND
U (<1.0)
2
2.08
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
B - Analyte found in the sample and associated method blank.
J - The reported value is an estimate. The value is less than the Reporting Limit.
U - The sample was not detected in the sample at the Reporting Limit.

Responses to Comments for Ramseur WWTP
January 27, 2022
Comments from SELC
Comment: DEQ must require Ramseur to disclose any discharges of PFAS or 1,4-Dioxane in its permit
application so that DEQ and the public have adequate information to evaluate the discharge. If the town
does not make that disclosure, any discharge of these chemicals is illegal and subject to agency or citizen
enforcement. DEQ must then evaluate available treatment technologies and impose necessary limits.
Because the draft permit fails to meet these requirements, it should be withdrawn.
DWR Response: The City of Ramseur had submitted results of PFAS and 1,4-Dioxane sampling
conducted in 2019 to the Division, and these results are available online via the Division's Emerging
Compound Facility Sampling map application
(https://ncdenr.maps.arcgis.com/apps/instant/attachmentviewer/index.html?appid=ed308373c97e4a2
3a29210fa53a3d404&center=-
78.8049%2C35.4812&level=9&attachmentlndex=0&selectedLayerld=Buffer of Facility to Data 5130&
defaultObjectld=70). This information was supplemented with a Chemical Addendum, received by the
Division on 1/20/2022.
The submitted data represent three samplings, a total of which is insufficient to adequately assess
Ramseur's discharge of PFAS and 1,4-Dioxane chemicals. Therefore, the monitoring requirement for
1,4-Dioxane as proposed is appropriate to gather effluent data needed to properly assess discharge
concentrations and appropriate actions including potential limits and treatment strategies.
Based on detection of PFAS chemicals in the influent from the 2019 samplings, which was also provided
via as an attachment to the NPDES application received on 1/20/2022, monitoring of PFAS chemicals has
been added to the permit at a frequency of 2/year. Since an EPA method for sampling and analyzing
PFAS in wastewater is not currently available, the PFAS sampling requirement in the Permit includes a
compliance schedule which delays the effective date of this requirement until the first full calendar
quarter beginning 6 months after EPA has a final wastewater method in 40 CFR136 published in the
Federal Register. This date may be extended upon request and if there are no NC -certified labs.

rtamseur
Where Family and Friends Meet
TOWN OF RAMSEUR
724 Liberty Street, PO Box 545
Ramseur, North Carolina 27316
336-824-8530 / 336-824-4111
COMMISSIONERS MAYOR TOWN CLERK / FINANCE OFFICER
Jim McIntosh VICKI CAUDLE Carol Akers
J.C. Parrish
Tim Cranford DEPUTY TOWN CLERK / FINANCE OFFICER
Joy Hooker
Diana Brower Adrienne Hagood
January 7, 2022
Mr. Michael Montebello
NC Department of Environmental Quality
Division of Water Resources
Water Quality Permitting - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Town of Ramseur WWTP
NPDES Permit Renewal - Chemical Addendum
Permit # 0026565
Dear Mr. Montebello:
As a supplement to the Ramseur Wastewater Treatment Plant NPDES Application Package that is currently under review, the
Town of Ramseur is submitting additional information per Session Law 2018-5, Senate Bill 99, Section 13.1(r). At the
request of the Division of Environmental Quality (DEQ), the Town conducted additional WWTP influent sampling in July,
August, and September 2019 for 1,4-Dioxane_ The analysis was done in accordance with EPA Method 624.1, which is a
certified method in 40 CFR Part 136. Accordingly, the Town is providing a Chemical Addendum to the NPDES Application
for the 1,4 Dioxane influent sampling results.
Additionally, at the request of DEQ, the Town performed WWTP influent sampling for a series of PFOA/PFAS analytes in
July, August, and September 2019. This sampling is not certified by the Town as there is not a 40 CFR Part 136 certified
analysis method for the analytes. This data was previously provided to DEQ following the three sampling events in 2019.
Although this data is not being certified by the Town and was already provided to DEQ, we are providing a summary of the
results as an attachment to this for clarity.
The following attachments are being provided as a supplement to the Ramseur WWTP NPDES Permit Application.
Attachment 1:
Attachment 2:
Attachment 3:
Chemical Addendum to NPDES Application
Lab Reports from 1,4 Dioxane Sampling Results
Uncertified Emerging Compound Sampling Data Summary
PIease let us know if you have any questions on the information provided.
Respectfully,
TO)WN OF RAMSEU
McIntosh, ORC
Mayor Pro Tem/Commissioner

EPA Identification Number
FRSID110006710648
Pollutant (Required)
NPDES Number
NC0026565
Method Number (if
CAS number Applicable)
Facility Name
Town of Ramseur WWTP
Outfall Number
001
Reason Pollutant Believed Present in Discharge
Estimated Concentration (If
Known)
1,4 Dioxane
123-91-1
EPA624.1
Influent sampling results (July, August, September 2019)
Median of three influent
sampling events (July, August,
September 2019) was 2 ug/L

NPDES#: Oaz
Phone: 33 '19z Y;xlI
Fax:
Email:
Project:
P.O.#:
Turn Around Time*
*RUSH work needs prior approval,
Charges Apply
3-5 Da s 24 - 48 Firs
Lab Use Only
X X
p 0
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Temperature Upon
Receipt:
Compositor #
Jug #
Report results in: , mg/L 1 mg/kg L ug/L
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Comments:
ry.
Client: 51'7- 14,r 0
Address: q1 g s Gecuft-cici
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Attenton: (Larne¢ 131>z/fv
How would you like your report senf
Circle all that apply: Email (preferred}, Fax,
Are these results for regulatory purposes? Yes No Le
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8/9/18 Chain of Custody Record (COC)
ICI ERITECH, INC.
ENVIRONMENTAL LABORATORIES
642 Tamco Rd. Phone: [phone]
. ,i Reidsville NC 27320 Fax: [phone]
d4 4A..:.
Email: [e-mail]
www.meritechlabs.com
Sampling Dates & Times
m
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Date
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Start
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Sample Location and/or ID #
Method of
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Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Nadine Blackweel & Terry LewaIlan
Client: Suez Environmental
4735 Roundleaf Rd
Ramseur, NC 27316
Report Date: 7/19/2019
NPDES#: NC0026565
Date Sample Rcvd: 7/10/2019
Meritech Work Order # 071019173 Sample: Influent Grab 7/8/19
Parameters Results Analysis Date Reporting Limit Method
1,4 Dioxane + Trip Blank Attached 7/11/19 EPA 624,1
1 hereby certify that 1 have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

MERITECH, INC.
Environmental Laboratories
Laboratory Certification #165
Client: Suez Water / Ramseur WWTP Meritech ID#: 071019173
Project: 1,4 Dioxane Analysis: 07/11/19
Client Sample ID: Influent Analyst: VWV
Sample Collection: 07/08/19 Dilution Factor: 1
Report Date: 07/15/19
EPA 624.1 VOLATILE ORGANICS
Parameter Result
1,4-Dioxane (p-Dioxane) < 1.00 ug/L
Trip Blank < 1.00 ug/L
Batclt Blank = Below Reporting Limit (Yes) / No
Internal Standards method criteria acceptable (Yes) / No
Surrogate Recoveries
Toluene-d8
Bromofluorobenzene
Spike Conc Spike Recovery Limits
30 ug/1:. 97% 67-151%
30 ug/L 97% 45-161%
* - if "no" is selected, see second page for details.
I hereby certify that 1 have reviewed and approve these data.
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]
Laborat ry Repre tive
1

NPDES#: 0026,565
hone: 3 z-%1 31-3et
Fax:
Email:
Project:
Turn Around Time*
*RUSH work needs prior approval,
Charges Aonlv
Std(10 days) 3 s 24 - 48 Hrs
Lab Use Only
pH OK?
Cl OK?
On Ice?
Ces / No
Person Taking Sample (Sign/Print):
Test(s) Required
7J--
...,:,
4.g.-
O.
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*** Dechlorination (<0.5 ppm) of Ammonia, Cyanide, Phenol and TKN samples must be done in the field prior to preservation. ***
Comments:
r- g
Client: 544 7:4241efr-/Palvt-iiviuki-r
Address: 4736
RIZ knit/Av. 141,-, 7_7
Attention: Atad67-0 8&a-kt..-6/1
How would you like your report sent
Circle all that apply: Email (preferred} , Fax
,c) us.
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8/9/18 Chain of Custody Record (COC)
MERITECH INC.
ENVIRONMENTAL LABORATORIES
642 Tamco Rd. Phone: [phone]
z .
Reidsville NC 27320 Fax [phone]
Email: [e-mail]
www.meritechlabs.com
Sampling Dates & Times
L End
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Client Sample ID:
Sample Collection:
MERITECH, INC.
Environmental Laboratories
Laboratory Certification #165
Suez Water / Ramseur WWTP
1,4-Dioxane
Influent
08/06/19
Meritech ID#:
Analysis:
Analyst:
Dilution Factor:
Report Date:
EPA 624.1 VOLATILE ORGANICS
Parameter
1,4-Dioxane (p-Dioxane)
Trip Blank
Batch Blank = Below Reporting Limit
Internal Standards method criteria acceptable
Surrogate Recoveries
Toluene-d8
Bromofluorobenzene
Result
2.00 ug/L
< 1.00 ug/L
(Yes V No
f Vesl / No
080819164
08/12/19
VWV
1
08/16/19
Spike Cone Spike Recovery Limits
30 ug/L 101% 67.151%
30 ug/L 97% 45-161%
* -If "no" is selected, see second page for details.
I hereby certify that I have reviewed and approve these data.
Laboratory Rep`rsentative
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Nadine Blackwell
Client: Suez Environmental
4735 Roundleaf Rd
Ramseur, NC 27316
Report Date: 8/20/2019
NPDES#: NC0026565
Date Sample Rcvd: 8/8/2019
Meritech Work Order # 080819164 Sample: Influent Grab 8/6/19
Parameters Results Analysis Date Reporting Limit Method
1,4 Dioxane + Trip Blank Attached 8/12/19 EPA 624.1
I hereby certify that 1 have reviewed and approve these data.
Laboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

NPDES#: l% 7----4c6(QS
Phone: 33%-
Fax:
Email:
Project:
P_O.#:
Turn Around Time*
*RUSH work needs prior approval,
Charees Aoply
3-5 Days 24-48Hrs
Lab Use Only
On Ice? pH OK?
Yes / No CI OK?
Temperature Upon
Receipt:
U
O
W
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7
Report results in: mg/L [ mg/kg i t ug/L
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Received by Lab: ^ t '; mat n Time:: y n
Person Taking Sa ple (Sig 4'Plrint): tik
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pies must be done in the field prior to preservation. ***
Comments:
m
Client: 54'Z1{r
Address:Z3 a CL1Ldr
Ract-.5-oxit,-4ILA- C- 73I
,Attention: NAV/Vtet
How would you like your report sent
Circle all that apply: Email (preferred) , Fax,
Are these results for regulatory purposes? Yes No ,f#
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3/9/18 Chain of Custody Record (COC)
MERITECH INC.
ENVIRONMENTAL LABORATORIES
•,4 .„ 642 Tamco Rd_ Phone: [phone]
Reidsville NC 27320 Fax: [phone]
- Email: [e-mail]
www.meritechlabs.com
Sampling Dates & Times
End
Time
A
a
O
v
Start
Time I
.0
0
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Date
Cr
Sample Location and/or ID #
--t-
Method of
Shipment:
Fed Ex
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Other

Client:
Project:
Client Sample ID:
Sample Collection:
MERITECH, INC.
Environmental Laboratories
Laboratory Certification #165
Suez Water / Ramseur WWTP
1,4-Dioxane
Influent
09/04/19
Meritech ID#:
Analysis:
Analyst:
Dilution Factor:
Report Date:
EPA 624.1 VOLATILE ORGANICS
Parameter
1,4-Dioxane (p-Dioxane)
Trip Blank
Batch Blank = Below Reporting Limit
Internal Standards method criteria acceptable
Surrogate Recoveries
Toluene-d8
Bromofluorobenzene
Result
2.08 ug/L
< 1.00 ug/L
(Yes) / No
(Yes) / No
09051984
09/06/19
VWV
2
09/09/19
Spike Cone Spike Recovery Limits
30 ug/L 110%
30 ug/L 102%
* - If "no" is selected, see second page for details.
I hereby certify that 1 have reviewed and approve these data.
642 Tamco Road * Reidsville, NC 27320
[phone] * [e-mail]
67-151%
45-16I%

Meritech, Inc.
Environmental Laboratory
Laboratory Certification No. 165
Contact: Nadine Blackwell
Client: Suez Environmental
4.735 Roundleaf Rd
Ramseur, NC 27316
Report Date: 9/11/2019
NPDES#: NC0026565
Date Sample Rcvd: 9/5/2019
Meritech Work Order # 09051984 Sample: Influent Grab 9/4/19
Parameters Results Analysis Date Reporting Limit Method
1,4 Dioxane + Trip Blank Attached 9/6/19 EPA 624.1
1 hereby certify that 1 have reviewed and approve these data.
baboratory Representative
642 Tamco Road, Reidsville, North Carolina 27320
tel.[phone] fax.[phone]

11Z ‘.a
ENTI-1ALPY
A 1. v r l c, i
Narrative Summary
EU # 0919-708 R 23 of 33

Enthalpy Analytical Narrative Summary
Company
Suez Water Ramseur
Job#
0919-708 PFAS — Legacy 24 + Gen-X ,
Client Project #
n/a
Custody Hunter Allen of Enthalpy Analytical Wilmington received the sample on
09/08/19 on ice at 2.6°C. Braidy May of Enthalpy Analytical Wilmington
observed the samples were in good condition on 09/09/19.
Prior to, during, and after analysis, the sample was stored in the laboratory
with access only by authorized personnel of Enthalpy Analytical, LLC.
Analysis The sample was analyzed by isotope dilution method for PFAS using
Waters Acquity UPLC equipped with Xevo TQ MS (LC/MS/MS "Kili").
For aqueous samples, 250mL aliquot was weighed and spiked with
Extraction Standard (ES). The sample was then mixed well and
centrifuged.
Cleanup procedures were performed on the supernatant and then
extracted via SPE. Each final sample extract was transferred to an
autosampler vial and spiked with 400 µL of Injection Standard (IS), prior
to analysis.
Calibration The analytes and labeled standards in the initial calibration exhibited
RSDs less than 50% with exception of the following:
M8FOSA and d3-N-MeFOSAA
All analytes passed the R2 coefficient correlation criteria. Per DoD QSM
5.3 Table B-15, the ICAL is acceptable for all analytes since R2 met
criteria. All analytes will be reported.
The ICV and continuing calibration (concal) injections met the ±30%
recovery criteria and ±50% ES recovery criteria for all analytes of
interest.
QC Notes The QC injections of the initial extraction did not meet method criteria
requiring re -extraction of samples. The QC of re -extracted samples met
the ±50% criteria for ES recoveries with the exception of analyte
M2PFTeDA, which fell below the lower limit in the method blank.
However, this compound was recovered within limits for the OPR for
both native and labeled criteria. Therefore, the data are considered
acceptable and no impact on sample data.
EN-1-H A LI'Y
No analytes were detected above the LOD (MDL) in the method blank.
The samples were extracted within the 14-day from collection holding
time (initial extraction — Sept 17 and re -extraction — Sept 20). Extracts
EU # 0919-708 R 24 of 33

QC Notes
(continued)
Reporting Notes
Enthalpy Analytical Narrative Summary
(continued)
were analyzed within the 28-days from extraction to analysis holding time
required by the method.
Results from the re -extraction are included in this report.
Analyte PFPeA had elevated values that were not consistent with past
patterns. After investigation, it was concluded the values were valid and
are reported.
Some analytes in the samples fell outside the limits for ES recoveries.
Although the cause was undetermined, it is theorized to be matrix effects.
Based on the native results in the OPR meeting criteria, the out -of- range
ES recoveries have no impact on the accuracy of the target analyte
(native) compounds. Therefore, the data are considered acceptable.
These analyses met the requirements of the TNI Standard. Any
deviations from the requirements of the reference method or TNI
Standard have been stated above.
The results presented in this report are representative of the samples as
provided to the laboratory.
The samples, calibrations and standards for the data presented in this
report were analyzed at 2714 Exchange Drive, Wilmington, NC 28405.
ENTH A LP'
EU # 0919-708 R 25 of 33

NCDENR/DWQ/NPDES
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 276991617
STATE OF NORTH CAROLINA, RANDOLPH COUNTY
To Whom It May Concern:
This is to certify the advertisement attached hereto has been
published in COURIER -TRIBUNE 1 time(s) in issues dated:
February 12, 2022
the last day of said publication being the
12th day of February, 2022
Legal Cle
Led
Notary Public, State is onsin, County of Brown
CP
My commissl 1 expires
sworn to before me and subscribed in my presence by this the
12th day of February, 2022
FEE: $56.68
AD #: 0001444202
ACCT: 54948
Proof Of Publication in
COURIER -TRIBUNE
AMY KOKOTT
Notary Public
State of Wisconsin
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 NC0026565
Ramseur WWTP
The North Carolina Environmental
Management Commission propos-
es 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 af-
ter 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 inter-
est. Please mail comments and/or
information requests to DWR at
the above address. Interested per-
sons 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/division:
/water-resources/water-
reso urces-perm its/wastewater-
branch/npdes-
wastewater/pub lic-notices,
or by calling [phone]. The
Town of Ramseur [P. O. Box 545
Ramseur, NC 27316] has requested
renewal of NPDES Permit
NC0026565 for its Ramseur WWTP,
located in Randolph County. This
permitted facility permitted dis-
charges treated municipal and in-
dustrial wastewater to the Deep
River. a Class C water in the Cape
Fear River Basin. Some of the pa-
rameters in the permit are water -
quality limited. This discharge
may affect future allocations in
this segment of the Deep River.
it: 2/12/2022
Page 1 of 1

SOUTHERN
ENVIRONMENTAL
NVRONMENTAL
LAW
CENTER
Via U.S. e-mail
Gary Perlmutter
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
601 West Rosemary Street, Suite 220 Telephone [phone]
Chapel Hill, NC 27516 Facsimile 919-929-9421
March 2, 2022
Re: Southern Environmental Law Center Comments on the 2nd Draft NPDES
Permit NC0026565 Renewal — Ramseur Wastewater Treatment Plant
Dear Mr. Perlmutter:
The Southern Environmental Law Center offers the following comments on the second
draft renewal for National Pollutant Discharge Elimination System ("NPDES") Permit
NC0026565, issued by the North Carolina Department of Environmental Quality ("DEQ") to the
Town of Ramseur.
It is a first step for Ramseur to submit information on PFAS and 1,4-dioxane as part of
the permitting process, but the town has not adequately disclosed any discharges of these
chemicals. DEQ admits as much in concluding that the data is "insufficient to adequately assess
Ramseur's discharge of PFAS and 1,4-Dioxane chemicals."' In addition, while failing to request
adequate information from the town on its PFAS discharges, DEQ delays mandatory monitoring
for PFAS. Finally, the agency fails to require Ramseur to use its pretreatment authority to
identify and control industrial sources of PFAS and 1,4-dioxane, and to evaluate limits on the
chemicals as part of the permitting process.
1. Ramseur has not adequately disclosed discharges of PFAS and 1,4-dioxane.
The information that Ramseur provided on PFAS and 1,4-dioxane is inadequate
and does not constitute disclosure. The agency concedes that it does not have enough
information to "be[] able to judge whether the discharge of a particular pollutant
constitutes a significant threat to the environment,"2 and therefore, that there has not been
adequate disclosure.
1 Ramseur WWTP, Draft Fact Sheet, Responses to Comments for Ramseur WWTP, Jan. 27, 2022.
2 Piney Run Pres. Ass 'n v. Cty. Comm 'rs of Carroll Cly., Maryland, 268 F.3d. 255, 268 (4th Cir. 2001) ("Because
the permitting scheme is dependent on the permitting authority being able to judge whether the discharge of a
particular pollutant constitutes a significant threat to the environment, discharges not within the reasonable
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

First, the data that the town provided was only on the influent of the treatment
plant, not on the town's discharges. As a result, DEQ has no information on the amount
of PFAS or 1,4-dioxane in the treatment plant's wastewater discharge. Even more, as
discussed in prior comments, influent data cannot substitute for effluent data, as influent
data often underestimates PFAS levels in treatment plant effluent. As studies have found,
there can be a "substantial increase" in specific PFAS after treatment, and the
"degradation of precursor compounds is a significant contributor to PFAS contamination
in the environment."3 The data submitted is also from 2019 and is several years old. DEQ
does not have any current information on 1,4-dioxane or PFAS levels at the plant. DEQ
did not appear to request, and Ramseur did not submit, any new data for this permitting
process.
As discussed in prior comments, without adequate disclosure of PFAS and 1,4-
dioxane, DEQ cannot authorize Ramseur to discharge the chemicals and any discharge of
them is unlawful.4
2. Monitoring for PFAS cannot wait for EPA to publish a final wastewater method.
While citing a lack of data for its failure to limit PFAS in Ramseur's discharge, DEQ
delays any monitoring of the chemicals until EPA publishes a final PFAS method for wastewater
in the Federal Register. But the lack of a final, EPA -approved method cannot be a barrier for
controlling PFAS discharges. When there is no approved analytical method, the Clean Water Act
states that permit applicants "may use any suitable method but must provide a description of the
method."5
PFAS testing methods have proliferated in recent years. In addition to targeted methods
for potable and non -potable waters, commercial labs offer testing of up to 75 PFAS.6 The Total
Oxidizable Precursor (TOP) Assay and Total Organic Fluorine methods can provide valuable
information on PFAS discharges that targeted methods cannot provide. Recent experience of
states, municipalities, and non -governmental organizations demonstrate the ability to test for
PFAS. Many states, including North Carolina, have issued draft or final permits that require
contemplation of the permitting authority during the permit application process, whether spills or otherwise, do not
come within the protection of the permit shield.").
3 Ulrika Eriksson, et al., Contribution of precursor compounds to the release of per- and polyfluoroalkyl substances
(PFASs) from waste water treatment plants (WWTPs), 61 J. ENVIRON. SCI.80 (2017); see also Mich. Dep't of Env't,
Great Lakes, and Energy, Summary Report: Initiatives to Evaluate the Presence of PFAS in Municipal Wastewater
and Associated Residuals (Sludge/Biosolids) in Michigan, at 9-10, https://perma.cc/C2Z8-DT99.
4 Letter from Southern Environmental Law Center, to Gary Perlmutter, NC DEQ, Southern Environmental Law
Center Comments on NPDES Wastewater Permit NC0026565 — Ramseur WWTP (Dec. 17, 2021) (Attachment 1);
see also In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998); Piney Run, 268 F.3d. 255 (2001); Southern
Appalachian Mountain Stewards v. A & G Coal Corp., 758 F.3d 560 (4th Cir. 2014).
5 40 C.F.R. § 122.21(g)(7)(i).
6 PFAS Testing, EUROFINS, https://www.eurofinsus.com/environment-testing/pfas-testing/ (last updated Oct. 18,
2021).
2

entities to control PFAS and submit discharge monitoring reports to demonstrate compliance.
Municipalities and utilities have tested for PFAS in wastewater and intake water,8 as well as
treated drinking water.9 NGOs have tested wastewater and surface waters for dozens of PFAS.1°
This experience demonstrates that dischargers like Ramseur can detect a wide variety of PFAS
through broadly available and relatively inexpensive testing.
3. Ramseur should use its pretreatment authority to control any industrial sources.
Sampling conducted in 2019 found that the influent to Ramseur's wastewater treatment
plant has contained PFAS concentrations above 499 parts per trillion.11 But the draft permit only
requires monitoring for 1,4-dioxane and PFAS and therefore does nothing to control such
discharges or protect downstream communities. EPA's PFAS Strategic Roadmap affirmed that
"existing NPDES authorities" can be used to "reduce discharges of PFAS at the source."12 The
same applies for 1,4-dioxane. EPA plans to use such existing authorities to "require pretreatment
programs to include source control" in order "to protect wastewater treatment plant discharges
and biosolid applications."13 Given that North Carolina continues to suffer from a drinking water
crisis caused by Chemours, DEQ should immediately begin requiring municipalities like
Ramseur to use existing NPDES authorities to prevent industrial discharges of PFAS and 1,4-
dioxane.
Using existing authority is the only way that Ramseur and other municipalities can
protect communities downstream and avoid violating the Clean Water Act's prohibitions on pass
through and interference. As the EPA previewed in its Roadmap, PFAS can harm or interfere
with wastewater treatment plant discharges and biosolid applications, and it is essential to control
7 N.C. Dep't of Envt. Quality, The Chemours Company FC, LLC, NPDES Permit NC0089915 (Sept. 18, 2020),
https://deq.nc.gov/media/16999/download; Colo. Dep't of Public Health and the Envt. Suncor Energy (USA) Inc.,
Draft Permit C00001147 (Nov. 12, 2021),
https://drive.google.com/drive/folders/1g5A3sQ_zkpGOdkwblyTspRht8HfJ -F; Pennsylvania Dep't of Envt.
Protection, Horsham Air Guard Station, NPDES Permit No. PA0245046 (Oct. 2020),
https://files. dep. state.pa.us/Water/Wastewater%20Management/eDMRPortalFiles/Permits/PA0245046_NPDES_PE
RMIT_20210323_Final_V 2.pdf.
8 PFAS/1,4-dioxane Information, CITY OF BURLINGTON, N.C., https://www.burlingtonnc.gov/2121/PFAS14-
DIOXANE-INFORMATION (last visited Feb. 16, 2022); MICHIGAN DEP'T OF ENV'T, GREAT LAKES, AND ENERGY,
SUMMARY REPORT: INITIATIVES TO EVALUATE THE PRESENCE OF PFAS IN MUNICIPAL WASTEWATER AND
ASSOCIATED RESIDUALS (SLUDGE/BIOSOLIDS) IN MICHIGAN (2020),
https://www.michigan.gov/documents/egle/wrd-pfas-initiatives 691391_7.pdf.
9 Latest PFAS Test Results, CAPE FEAR PUB. UTIL. AUTH., https://www.cfpua.org/779/Latest-PFAS-Test-Results
(last visited Feb. 16, 2022); Drinking Water Resources: Public Water System PFAS Information and Resources,
CALIFORNIA STATE WATER RES. CONTROL BD., https://www.waterboards.ca.gov/pfas/drinking_water.html (last
updated Dec. 20, 2021).
10 Letter from Southern Environmental Law Center, to City of Burlington, on Notice of Intent to Sue the City of
Burlington for Violations of the Clean Water Act and the Resource Conservation and Recovery Act at 9-25 (Nov. 7,
2019), https://www.southernenvironment.org/wp-content/uploads/legacy/words_docs/2019_11_07_-
Notice_of Intent_-_City_of Burlington_.pdf.
11 2019 Sampling Data — Ramseur WWTP (Attachment 2).
12 EPA, PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024 at 14, https://perma.cc/LK4U-RLBH.
13 Id.
3

industrial discharges "to protect" plant discharges and biosolid management systems,14 and
therefore, to prevent interference.15
Municipalities like Ramseur have the tools to prohibit PFAS and 1,4-dioxane discharges
from being introduced into publicly owned treatment works ("POTWs") like Ramseur's.16 First,
the Clean Water Act pretreatment program allows municipalities to promptly identify any
dischargers, and it puts the burden on industries to produce information about their discharges.
As EPA has recognized, industrial users are "in a better position than the POTW to know what
pollutants are currently being discharged and are most likely to be discharged in the future."17
The permitting process requires requiring industrial users to identify their pollutants in an
industrial waste survey,'$ and when applying for a pretreatment permit, to disclose "effluent
data," including on internal wastestreams when necessary to evaluate pollution controls.'9
Significant industrial users are further required to provide information "[p]rincipal products and
raw materials ... that affect or contribute to the [significant industrial user's] discharge."20
Ramseur's POTW has one significant industrial user. If that discharger is responsible for
PFAS or 1,4-dioxane in the POTW's influent, then it must be held accountable for its
pollution —preventing contamination of sludge and effluent. At the very least, that industry
should be required to conduct sampling of its waste stream to determine if it is a source of these
chemicals into Ramseur's treatment plant.
Once Ramseur identifies any industrial sources of PFAS or 1,4-dioxane, the Clean Water
Act also gives the town the tools to control those sources. For instance, POTWs can establish
local limits for PFAS or 1,4-dioxane.21 POTWs also have discretion to set permit limits for
industrial users through a case -by -case analysis "based on the discharger's current loading, its
need for a continued loading allocation, its ability to apply pretreatment to achieve certain
discharge pollutant levels (i.e. treatability), or any other factor that the POTW determines is
relevant."22 Controls can go beyond pretreatment permit limits and "may contain but need not be
limited to" conditions including "[r]equirements for the installation of pretreatment technology,
pollution control, or construction of appropriate containment devices designed to reduce,
eliminate, or prevent the introduction of pollutants into the treatment works."23 Ramseur should
14 Id.
15 Interference occurs when a discharge disrupts POTW operation or sludge use or disposal and violates the facility's
NPDES permit or other applicable laws. 40 C.F.R. § 403.3(k).
16 See EPA, INDUSTRIAL USER PERMITTING GUIDANCE MANUAL at 3-1 to 3-2 (2012),
https://www.epa.gov/sites/default/files/2015-10/documents/industrial_user_permitting_ manual_full.pdf (describing
requirements for pretreatment program, including "Authority to regulate all Industrial Users contributing wastewater
to the POTW.").
17 Id.
18 EPA, INTRODUCTION TO THE NATIONAL PRETREATMENT PROGRAM at 4-3 (2011),
https://www.evansvillegov.org/egov/documents/1499266949_62063.pdf.
19 INDUSTRIAL USER PERMITTING GUIDANCE MANUAL, supra note 16 at 4-2 to 4-3.
20 40 CFR § 122.21(j)(6)(ii)(C).
21 See EPA, LOCAL LIMITS DEVELOPMENT GUIDANCE at 5-11 to 5-21 (2004),
https://www3.epa.gov/npdes/pubs/final_locallimits_guidance.pdf.
22 Id. at 6-12.
23 EPA OFFICE OF WASTEWATER MGT., EPA MODEL PRETREATMENT ORDINANCE at 24 (2007),
https://www3.epa.gov/npdes/pubs/pretreatment_model_suo.pdf.
4

use these tools here to stop any industrial sources of PFAS or 1,4-dioxane from entering the
POTW.
In addition, as discussed in our prior comment letter, the Clean Water Act requires that
DEQ consider limits on PFAS and 1,4-dioxane in all NPDES permits.24 By declining to require
more of the permittee, DEQ continues to put the burden of PFAS and 1,4-dioxane pollution on
downstream communities. The status quo —a watershed contaminated by PFAS and 1,4-
dioxane—is unacceptable and DEQ must use its existing authority to address all sources of these
toxic chemicals. Given that these chemicals are toxic at such low levels and communities have
been exposed to them for decades, waiting for future permit cycles to fulfill permitting
requirements —and to control pollution at the source —fails to provide the necessary protection.
Thank you for considering these comments. Please contact me at 919-967-1450 or
[e-mail] if you have any questions regarding this letter.
Sincerely,
Jean Zhuang
-...1)04 lZ tvo----
Geoff Gisler
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516
919-967-1450
24 See Letter from Southern Environmental Law Center, to Gary Perlmutter, NC DEQ, supra note 4 (Attachment 1).
5

ATTACHMENT 1

SOUTHERN
ENV RONMENTAL
CENTER
Via U.S. e-mail
Gary Perlmutter
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]
601 West Rosemary Street, Suite 220 Telephone [phone]
Chapel Hill, NC 27516 Facsimile 919-929-9421
December 17, 2021
RE: Southern Environmental Law Center Comments on NPDES Wastewater
Permit NC0026565 — Ramseur WWTP
Dear Mr. Perlmutter:
The Southern Environmental Law Center offers the following comments on Draft
National Pollutant Discharge Elimination System ("NPDES") Permit NC0026565, issued by the
North Carolina Department of Environmental Quality ("DEQ") to the Town of Ramseur.
The permit allows Ramseur to discharge wastewater likely contaminated with per- and
polyfluoroalkyl substances, or PFAS, from its wastewater treatment plant ("WWTP") into
downstream drinking water supplies in the Cape Fear River basin. Communities in Sanford,
Harnett, Dunn, and Fayetteville are downstream of the treatment plant and their drinking water
supplies have previously contained PFAS,1 which are known to harm human health. Based on
previous sampling, Ramseur's discharge almost certainly contains PFAS. The town did not,
however, disclose its discharge of PFAS in its permit application, and DEQ did not evaluate
limits for the chemicals in its draft permit, as required by the Clean Water Act and state laws.
Because Ramseur did not disclose its PFAS discharges in its application, any permit issued by
the agency will necessarily prohibit all discharges of the chemicals. DEQ has the authority to
issue a permit that allows discharges, but it cannot do so by ignoring what pollutants are in the
discharge. DEQ, therefore, must require disclosure of PFAS and include necessary limits in the
town's permit.
EPA's PFAS Strategic Roadmap recently affirmed that "existing NPDES authorities" can
be used to "reduce discharges of PFAS at the source."2 EPA's plan further confirms that the
Clean Water Act pretreatment program can be used to control sources of PFAS, and the agency
plans to "require pretreatment programs to include source control."3 North Carolina has already
1 EPA, Occurrence Data for the Unregulated Contaminant Monitoring Rule (UCMR) 3, https://perma.cc/2EXD-
AKPQ.
2 EPA, PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024 at 14, https://perma.cc/LK4U-RLBH.
3 Id.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

faced a PFAS drinking water crisis. Because communities continue to suffer from exposure to
these chemicals, DEQ must act now to stop PFAS from entering our rivers, streams, and drinking
water supplies. The need for action is most urgent in the Cape Fear River, where sources
upstream from Chemours, such as Ramseur, are significant contributors to PFAS contamination.
For each permit issued for facilities that discharge PFAS, DEQ must use its existing authority
under the Clean Water Act to require disclosure and evaluate limits.
Similarly, previous sampling has indicated that Ramseur's discharge likely contains 1,4-
dioxane, another toxic chemical. Ramseur also did not disclose whether it discharges 1,4-dioxane
and DEQ did not evaluate limits for the chemical in its draft permit. Instead, the draft permit
includes a monthly monitoring requirement for the toxic chemical. Monitoring is not a substitute
for the mandatory permitting process that DEQ must conduct.
In order to comply with the Clean Water Act, DEQ should withdraw this draft permit,
return Ramseur's application, and re -start the permitting process after the town makes the
necessary disclosures.
A. The Ramseur WWTP discharges toxic PFAS.
Sampling conducted in 2019 reveals that the influent to Ramseur's WWTP has contained
PFAS concentrations above 499 parts per trillion ("ppt").4 Because the treatment plant is not
equipped to remove PFAS, it is almost certain that Ramseur is releasing PFAS into the Cape
Fear River basin, a source of drinking water for nearly one million North Carolinians. It is also
likely that the influent data is an underestimate of how much PFAS the town is releasing in its
wastewater discharge. PFAS sampling conducted at WWTPs often find that concentrations of
PFAS increase from the influent to the effluent because treatment plant influent often contains
PFAS precursors that cannot be found using certain analytical methods. As studies have found,
there can be a "substantial increase" in specific PFAS after wastewater treatment, and that the
"degradation of precursor compounds is a significant contributor to PFAS contamination in the
environment."5
PFAS are a serious threat to human health and the environment. Two of the most
commonly studied PFAS—perfluorooctanoic acid ("PFOA") and perfluorooctane sulfonate
("PFOS")—have been found to cause developmental effects to fetuses and infants, kidney and
testicular cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis, lower
birth weight and size, obesity, decreased immune response to vaccines, reduced hormone levels,
and delayed puberty.6 In 2016, EPA established a lifetime health advisory of 70 ppt for the
4 2019 Sampling Data — Ramseur WWTP (Attachment 1).
5 Ulrika Eriksson, et al., Contribution of precursor compounds to the release of per- and polyfluoroalkyl substances
(PFASs) from waste water treatment plants (WWTPs), 61 J. ENvIRoN. SCI.80-90 (2017); see also Mich. Dep't of
Env't, Great Lakes, and Energy, Summary Report: Initiatives to Evaluate the Presence of PFAS in Municipal
Wastewater and Associated Residuals (Sludge/Biosolids) in Michigan, at 9-10, https://perma.cc/C2Z8-DT99.
6 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENVTL. HEALTH
PERSPECTIVES 5, A 107 (2015); U.S. EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories, at 2,
https://perma.cc/CX95-N67K.

combined concentrations of PFOA and PFOS in drinking water. EPA has since updated toxicity
assessments for the chemicals, suggesting that the health values for the chemicals should be
magnitudes lower. The updated toxicity assessments would translate to health advisories of .006
ppt for PFOA and .029 ppt for PFOS.8 Epidemiological studies show that other PFAS similarly
harm human health at low levels.9 Given that PFAS concentrations less than 1 ppt can be
harmful to human health, DEQ cannot ignore sampling data showing that Ramseur may be
discharging PFAS at 499 ppt, or even higher.
B. The Ramseur WWTP likely discharges 1,4-dioxane, another toxic chemical.
Sampling at the Ramseur WWTP from 2019 also found 1,4-dioxane in the treatment
plant's influent.10 Because the treatment plant is also not equipped to remove 1,4-dioxane, it is
likely that Ramseur is releasing the chemical in its wastewater. 1,4-dioxane is a clear, man-made
chemical that is a byproduct of many industrial processes.11 The chemical is toxic to humans,
causing liver and kidney damage.12 As a result of the harms caused by 1,4-dioxane, EPA
established a drinking water health advisory with an associated lifetime cancer risk of one -in -
one -million at a concentration of 0.35 parts per billion ("ppb"),13 and North Carolina's rules
prohibit the release of 1,4-dioxane that would cause or contribute to an exceedance of 0.35 ppb
in water supply waters.14
C. DEQ must require Ramseur to disclose any PFAS or 1,4-dioxane that the town is
discharging from its treatment plant.
The Clean Water Act prohibits the discharge of any pollutant without a NPDES permit.
The discharge of a specific pollutant (or group of pollutants) cannot be permitted if it is not
disclosed in a NPDES permit application. Therefore, Ramseur is required to disclose any
discharges of PFAS or 1,4-dioxane in its permit application —as DEQ recognized in its 2017
enforcement action against Chemours.
7 EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories at 2.
8 Garret Ellison, No safe PFAS exposure level? EPA toxicity drafts point that way, MLIVE, Nov. 20, 2021,
https://perma.cc/S7GW-DUCA.
9 EPA, Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium Salt
(CASRN 13252-13-6 and CASRN 62037-80-3) (2021), https://perma.cc/FG6A-TXQ9.
10 2019 Sampling Data — Ramseur WWTP (Attachment 1).
11 EPA, Technical Fact Sheet—1,4-Dioxane, at 1-2 (2017), https://perma.cc/NM9K-2P84 ("EPA 1,4-dioxane fact
sheet").
12Id.; EPA, Integrated Risk Information System, Chemical Assessment Summary: 1,4-dioxane at 2,
https://perma.cc/B2A2-R4M5.
13 EPA, 2018 Edition of the Drinking Water Standards and Health Advisories, at 4 (2018), https://perma.cc/N8N4-
BA3R; N.C. Div. of Water Res., I,4-dioxane Monitoring in the Cape Fear River Basin of North Carolina: An
Ongoing Screening, Source Identification, and Abatement Verification Study, at 2 (2017), https://perma.cc/7MMR-
B9SQ.
14 Frequently Asked Questions (FAQ), Special Order by Consent (SOC) for the City of Greensboro T.Z. Osborne
WWTP, https://perma.cc/E8YY-8YFV (interpreting 15A N.C. Admin Code 2B.0208).

If a NPDES permit applicant does not adequately disclose its release of a pollutant, the
applicant does not have approval to discharge the pollutant.15 Disclosure is considered adequate
when the applicant provides enough information for a permitting agency to "be[] able to judge
whether the discharge of a particular pollutant constitutes a significant threat to the
environment."16 To meet this burden, an applicant must include all relevant information,
including the concentration, volume, and frequency of the discharge.17 The Clean Water Act
places the burden of disclosure on the permit applicant because they are in the best position to
know what is in their discharge.'$
The EPA has stressed the need for disclosure of pollutants during the permitting process:
[D]ischargers have a duty to be aware of any significant pollutant levels in their
discharge. [...] Most important, [the disclosure requirements] provide the
information which the permit writers need to determine what pollutants are likely
to be discharged in significant amounts and to set appropriate permit limits. [...]
[P]ermit writers need to know what pollutants are present in an effluent to
determine approval permit limits in the absence of applicable effluent
guidelines.' 9
The EPA Environmental Appeals Board's decision in In re: Ketchikan Pulp Company further
emphasized the importance of disclosure,20 and this decision has been adopted by the Fourth
Circuit. In Piney Run Pres. Ass 'n v. Cty. Comm 'rs of Carroll Cty., Maryland, the Fourth Circuit
stated:
The Ketchikan decision therefore made clear that a permit holder is in compliance
with the [Clean Water Act] even if it discharges pollutants that are not listed in its
permit, as long as it only discharges pollutants that have been adequately
disclosed to the permitting authority. [...] To the extent that a permit holder
discharges a pollutant that it did not disclose, it violates the NPDES permit
and the [Clean Water Act].2'
15 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998); Piney Run Pres. Ass 'n v. Cty. Comm'rs of Carroll Cty.,
Maryland, 268 F.3d. 255 (4th Cir. 2001); Southern Appalachian Mountain Stewards v. A & G Coal Corp., 758 F.3d
560 (4th Cir. 2014).
16 Piney Run, 268 F.3d at 268 ("Because the permitting scheme is dependent on the permitting authority being able
to judge whether the discharge of a particular pollutant constitutes a significant threat to the environment, discharges
not within the reasonable contemplation of the permitting authority during the permit application process, whether
spills or otherwise, do not come within the protection of the permit shield.").
17 See In re Ketchikan Pulp Co., 7 E.A.D. 605 ("In explaining the provisions of 40 C.F.R. § 122.53(d)(7)(iii), which
required dischargers to submit quantitative data relating to certain conventional and nonconventional pollutants that
dischargers know or have reason to believe are present in their effluent, the [EPA] stated: `permit writers need to
know what pollutants are present in an effluent to determine appropriate limits in the absence of effluent
guidelines.'").
18 S. Appalachian Mountain Stewards, 758 F.3d at 566.
19 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33,526-31 (May 19, 1980).
20 See In re Ketchikan Pulp Co., 7 E.A.D. 605.
21 Piney Run, 268 F.3d. at 268 (emphasis added).

Moreover, municipalities that own and operate wastewater treatment plants are
required to "fully and effectively exercise[] and implement[]" their authority to
"[i]dentify the character and volume of pollutants contributed to the [publicly owned
treatment works]" by Industrial Users.22
DEQ has acknowledged that disclosure of toxic pollutants, including PFAS, is required
by the Clean Water Act and state water quality laws. In its enforcement action against The
Chemours Company, LLC for the company's discharge of GenX and other PFAS into the Cape
Fear River, the agency stated:
Part of the permit applicant's burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose "all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 2H .0105(j) (emphasis added). [...] These disclosure obligations are
critical, in part, because they define the scope of the Clean Water Act's "permit
shield." While compliance with the express terms of an NPDES permit generally
"shields" the permittee from liability for violations of 33 U.S.C. § 1311, the
permit does not shield the permittee from liability where the pollutant being
discharged was not within the "reasonable contemplation" of the permitting
agency when it issued the permit due to nondisclosure by the permittee.23
The agency further acknowledged that the company had violated its NPDES permit and
state water quality laws by "failing to fully disclose all known toxic components reasonably
expected to be in [the company's] discharge."24
DEQ's position in the Chemours enforcement case was correct and should be applied to
Ramseur in this permit renewal. Ramseur likely discharges PFAS and 1,4-dioxane, and the town
was required to disclose the pollutant in its permit application so that DEQ can "judge whether
the discharge" "constitutes a significant threat to the environment."25 Because Ramseur failed to
do so,26 DEQ does not have the information it needs to make an informed decision on the town's
application.27 DEQ must require Ramseur to disclose any discharge of PFAS or 1,4-dioxane in
the town's permit application before moving forward with the draft permit.
22 40 C.F.R. § 403.8(f)(1)(vi)(B).
23 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 67 (N.C. Super. 2018)
(citing 33 U.S.C. § 1342(k), Piney Run Pres. Ass v. Cty. Comm 'rs of Carroll Cty., MD, 268 F.3d 255, 265 (4th
Cir. 2001)).
24 Id. at 33.
25 Piney Run, 268 F.3d at 268.
26 See Town of Ramseur, Permit Renewal, Application No. NC0026565, Nov. 10, 2020.
27 See S. Appalachian Mountain Stewards, 758 F.3d at 566 ("[T]he CWA and its implementing regulations focus on
the information that the permit applicant must gather and provide to the permitting agency, so that it can make a
fully informed decision to issue the requested permit.").

In addition, DEQ's mandated monitoring for 1,4-dioxane does not absolve
Ramseur's obligation to disclose its 1,4-dioxane discharge in its application. Without
disclosure during the application process, the agency cannot evaluate the discharge for
compliance with permitting requirements and the public does not have sufficient
information to meaningfully review and comment on the draft permit. Because public
notice and informed participation are mandated by law,28 monitoring reports sent only to
the agency after the permit has been issued cannot be considered adequate disclosure.
D. DEQ must analyze appropriate effluent limits for PFAS and 1,4-dioxane in
Ramseur's NPDES permit.
Because Ramseur is likely discharging PFAS and 1,4-dioxane, DEQ must consider
appropriate permit limits for these chemicals. Ramseur can then comply with any limits in its
permit by properly regulating its industries —for instance, by requiring industries to use
alternative chemicals, or to install treatment technology to remove pollutants from their
wastewater before sending it to the town's treatment plant.
The Clean Water Act requires permitting agencies to, at the very least, incorporate,
technology -based effluent limitations on the discharge of pollutants.29 North Carolina water
quality laws further state that municipalities must be treated like an industrial discharger if an
industry "significantly impact[s]" a municipal treatment system.30 In this situation, the agency
must consider technology -based effluent limits for the municipality, even if effluent limits and
guidelines have not been published and adopted.
Effective treatment technologies for PFAS and 1,4-dioxane are available. A granular
activated carbon treatment system has been used at Chemours' facility to reduce PFAS as high as
345,000 ppt from a creek contaminated by groundwater beneath the facility to nearly
nondetectable concentrations.31 Similarly, 1,4-dioxane can be removed using advanced oxidation
processes, such as using ultraviolet light in combination with hydrogen peroxide.32 Such a
process has been used at the Tucson International Airport Area Superfund Site to remove legacy
1,4-dioxane contamination.33 DEQ must consider the feasibility of Ramseur's industries
installing similarly effective treatment technologies.
28 40 C.F.R. § 124.10 (a); 15A N.C. Admin. Code 2H.0109(a).
29 40 C.F.R. § 125.3(a); see also 33 U.S.C. § 1311.
3° 15A N.C. Admin Code 02B .0406 (a), (e).
31 Ted Schoenberg, Parsons, Old Outfall 002 GAC Pilot Study Interim Results Report, Chemours Fayetteville, North
Carolina Facility, 4-5 (Aug. 5, 2019), https://perma.cc/DU3Y-25AW; Parsons, Old Outfall 002 Surface Water
Sampling Results (Sept. 30, 2019) at Table 1, https://perma.cc/6BYQ-RNXZ.
32 Amie C. McElroy, et al., 1,4-Dioxane in drinking water: emerging for 40 years and still unregulated, 7 CURRENT
OPINION IN ENv'T SCIENCE & HEALTH 117, 119 (2019), https://perma.cc/P8L3-CC5G.
33 See Advanced Treatment for 1,4-Dioxane — Tucson Removes Contamination Through UV -oxidation, TROJANUV
CASESTUDIES (2019), https://perma.cc/Z95X-D6A5; see also Educational Brochure, TUCSON AIRPORT AREA
REMEDIATION PROJECT, https://perma.cc/XUH8-W4DZ.

If these limits are not enough to ensure compliance with water quality standards, then
water quality -based effluent limits must be included in the town's permit.34 PFAS are known to
harm human health, and their discharge threatens to violate multiple water quality standards,
including the state toxic substances standard.35 DEQ itself has stated in its lawsuit against
Chemours that PFAS "meet the definition of `toxic substance' under North Carolina rules.36
DEQ has also applied the toxic substances standard to 1,4-dioxane, interpreting the standard to
require concentrations of 1,4-dioxane be less than 0.35 ppb in rivers and streams that serve as
drinking water supplies.37 In order to comply with the Clean Water Act, therefore, DEQ must
limit Ramseur's discharge so that it will not cause, or contribute to concentrations of 1,4-dioxane
exceeding 0.35 ppb in any downstream drinking water supplies.38
Once appropriate limits are included in a Ramseur's NPDES permit, the town must
regulate its industries so that industries do not cause the treatment plant to violate its own
NPDES permit.39 This is how the Clean Water Act "assures the public that [industrial]
dischargers cannot contravene the [Clean Water Act's] objectives of eliminating or at least
minimizing discharges of toxic and other pollutants simply by discharging indirectly through
[wastewater treatment plants] rather than directly to receiving waters."40 As is appropriate, the
pretreatment program is intended to place the burden of treating polluted discharges on the entity
that creates the pollution, rather than on the taxpayers that support municipally owned treatment
plants. Moreover, municipalities like Ramseur that own and operate wastewater treatment plants
are required to "immediately and effectively to halt or prevent any discharge of pollutants to the
[publicly owned treatment works] which reasonably appears to present an imminent
endangerment to the health or welfare of persons."41 Together, these laws ensure that such
municipally owned treatment plants do not become dumping grounds for uncontrolled industrial
waste.
Ramseur, therefore, cannot allow industries to cause its treatment plant to violate the
town's own NPDES permit.42 Ramseur could prevent violations of its permit by requiring
industries to use alternative chemicals, or to install treatment technology to remove PFAS or 1,4-
34 15A N.C. Admin. Code 2H.0112(c) (stating that DWR must "reasonably ensure compliance with applicable water
quality standards and regulations."); see 33 U.S.C. § 1311(b)(1)(c) (requiring that permit limits be established as
necessary to comply with water quality standards).
35 15A N.C. Admin. Code 2B.0208(a).
36 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 32 (N.C. Super. 2018)
(stating that "the process wastewater from [Chemours'] Fluoromonomers/Nafion® Membrane Manufacturing Area
contains and has contained substances or combinations of substances which meet the definition of "toxic substance"
set forth in 15A N.C.A.C. 2B .0202," referring to GenX and other PFAS).
37 N.C. Div. of Water Res., I, 4-dioxane Monitoring in the Cape Fear River Basin of North Carolina: An Ongoing
Screening, Source Identification, and Abatement Verification Study, at 2 (2017), https://perma.cc/3RK6-8T4D.
38 40 C.F.R. § 122.44(d)(1)(i); see also 15A N.C. Admin. Code 2B.0203 ("Water quality based effluent limitations
and management practices for direct or indirect discharges of waste or for other sources of water pollution shall be
developed by the Division such that the water quality standards and best usage of receiving waters and all
downstream waters will not be impaired.").
39 40 C.F.R. § 403.8(f)(1).
40 General Pretreatment Regulations for Existing and New Sources, 52 Fed. Reg. 1586, 1590 (Jan. 14, 1987)
(codified at 40 C.F.R. § 403).
41 40 C.F.R. § 403.8(f)(2)(ii).
42 Id. § 403.8(f)(1).

dioxane from their wastewater before sending wastewater to the town's treatment plant. In
Michigan, for instance, municipalities have been effectively reducing their PFAS discharges by
requiring industrial users to install treatment technology. Municipalities in Michigan had
discovered that industries, such as metal finishers, paper manufacturers, and fabric/leather
treaters, were sending PFAS-contaminated wastewater to their treatment plants.43 After industrial
users installed treatment systems to remove PFAS, PFOS levels in the discharges of several
treatment plants were reduced by up to 99 percent.44 By including appropriate limits in
Ramseur's NPDES permit (as well as permits for other municipalities), DEQ can put the burden
of cleaning up toxic pollution on the industries that create it.
In summary, DEQ must require Ramseur to disclose any discharges of PFAS or 1,4-
dioxane in its permit application so that DEQ and the public have adequate information to
evaluate the discharge. If the town does not make that disclosure, any discharge of these
chemicals is illegal and subject to agency or citizen enforcement. DEQ must then evaluate
available treatment technologies and impose necessary limits. Because the draft permit fails to
meet these requirements, it should be withdrawn.
Thank you for considering these comments. Please contact me at 919-967-1450 or
[e-mail] if you have any questions regarding this letter.
Sincerely,
e5'----a
Jean Zhuang
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516
919-967-1450
43 Michigan.gov, Michigan PFAS Action Response Team, Wastewater Treatment Plants/Industrial Pretreatment
Program, https://perma.cc/2AZ7-ASHH.
44 Id.

ATTACHMENT 2

POTW Name:
Town of Ramseur WWTP
NPDES #:
NC0026565
Influent Grab (ng/L)
CAS Number
Analyte Name
Acronym
7/8/2019
Lab Qualifer(s)
8/6/2019
Lab Qualifer(s)
9/4/2019
Lab Qualifer(s)
375-22-4
Perfluorobutanoic acid
PFBA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-73-5
Perfluorobutanesulfonic acid
PFBS
ND
U (<0.311)
344
ND
U (<1.24)
335-77-3
Perfluorodecanesulfonic acid
PFDS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
335-76-2
Perfluorodecanoic acid
PFDA
0.586
ND
U (<1.25)
ND
U (<1.24)
307-55-1
Perfluorododecanoic acid
PFDoA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
375-85-9
Perfluoroheptanoic acid
PFHpA
1.24
ND
U (<1.25)
ND
U (<1.24)
355-46-4
Perfluorohexanesulfonic acid
PFHxS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
307-24-4
Perfluorohexanoic acid
PFHxA
6.97
4.77
4.64
68259-12-1
Perfluorononanesulfonic acid
PFNS
ND
U (<0.31)
ND
U (<1.25)
ND
U (<1.24)
375-95-1
Perfluorononanoic acid
PFNA
0.782
ND
U (<1.25)
ND
U (<1.24)
754-91-6
Perfluorooctanesulfonamide
PFOSA
ND
U (<0.316)
ND
U (<1.25)
ND
U (<1.24)
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-MeFOSAA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2706-90-3
Perfluoropentanoic acid
PFPeA
41.8
103
313
376-06-7
Perfluorotetradecanoic acid
PFTeA (PFTA)
0.761
ND
U (<1.25)
ND
U (<1.24)
72629-94-8
Perfluorotridecanoic acid
PFTriA (PFTrA)
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
2058-94-8
Perfluoroundecanoic acid
PFUnA
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
62037-80-3
Gen-X
HFPO-DA
ND
U (<10.90)
ND
U (<43.9)
ND
U (<43.3)
757124-72-4
4:2 Fluorotelomer sulfonate
4:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
27619-97-2
6:2 Fluorotelomer sulfonate
6:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
39108-34-4
8:2 Fluorotelomer sulfonate
8:2 FTS
ND
U (<0.311)
ND
U (<1.25)
ND
U (<1.24)
335-67-1
Perfluorooctanoic acid
PFOA
2.93
2
1.96
1763-23-1
Perfluorooctanesulfonic acid
PFOS
6.52
45.7
8.06
Sum of PFOA and PFOS
9.45
47.7
10.02
Total PFAS
61.589
499.47
327.66
Influent Grab ug/L)
7/8/2019
Lab Qualifer(s)
8/6/2019
Lab Qualifer(s)
9/4/2019
Lab Qualifer(s)
1, 4 - Dioxane
ND
U (<1.0)
2
2.08
Lab Qualifiers
ND - Analyte concentration is not detected above the detection limit.
B - Analyte found in the sample and associated method blank.
J - The reported value is an estimate. The value is less than the Reporting Limit.
U - The sample was not detected in the sample at the Reporting Limit.