NC0026573_Fact Sheet_20220728

Fact Sheet
NPDES Permit No. NC0026573
Permit Writer / Email Contact Diana Yitbarek / [e-mail]
Date: 7/28/2022
Division/Unit: NC DEQ Division of Water Resources / NPDES Municipal Permitting Unit
Fact Sheet Template: Version 01/09/2017
Permitting Action:
❑X Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
1. Basic Facility Information
Table 1. Facility Information
Facility Information
Applicant/Facility Name:
City of Morganton/Catawba River Pollution Control Facility
Applicant Address:
PO Box 3448, Morganton NC 28680-3448
Facility Address:
1000 Vine Arden Road, Morganton NC 28655
Permitted Discharge Flow:
8.0, 10.5, and 13.0 million gallons per day (MGD)
Facility Type/Waste:
Major Municipal/ 62 % Domestic and 38% industrial*
Facility Class:
Biological Class/Grade IV
Treatment Units:
Influent pump station/wet well, bar screening and grit removal structures, two
primary clarifiers, sludge holding tank, three peak flow storage
basins/equalization basins, three diffused aeration basins, three secondary
clarifiers, chlorine contact chamber, dechlorination, aerobic digestors,
dewatering centrifuge, and composting site
Pretreatment Program (Y/N)
Y
County:
Burke
Region
Asheville Regional Office (ARO)
*Percentages based on the facility's current operating design flow tier, 8.0 MGD and current industrial permitted flow, 3.1 MGD
Permitting Action: The City of Morganton (City) applied for NPDES permit renewal for the Catawba River Pollution
Control Facility in September 2019. The Facility has a design capacity of 8.0 MGD and is currently authorized to
discharge 8.0 MGD (up to 10.5 MGD and 13.0 MGD upon request) into the Catawba River. The Facility serves 18,468
residents in the City of Morganton and the Town of Glen Alpine. This Facility received authorization to construct in
2017 to improve the Facility and currently has no plans to expand.
The Facility receives pretreated industrial wastewater from three significant industrial users (SIUs), Case Chicken
Farm, UNIX Packaging, and Seiren (textile) in their pretreatment program. The City has a long-term monitoring plan
(LTMP) and the current industrial permitted flow to discharge by the SIUs is 3.64 MGD.
Page 1 of 18

Facility Background: In 1997, the Facility was granted an expansion to 10.5 MGD based on growth and capacity
issues; however, based on information provided in 2022, the facility is not yet ready to operate up to 10.5 MGD. By
2002, the Division had authorized an effluent limitation and monitoring page with a higher flow tier of 13.0 MGD.
Improvements to the treatment system were completed in June 2014 due to a Special Order by Consent (SOC) to
address compliance issues at the Facility. In 2017, the City also completed Improvement Projects to repurpose existing
aeration and equalization basins, among other improvements. At present, this fact sheet assessment is based on a
wastewater plant flow of 8.0 MGD, and the Facility has confirmed capacity to treat up to 8.0 MGD.
The Facility utilizes composting on site as the method of disposal of its municipal sewage biosolids under Division
permit WQ0002127. The compost is sampled and sold to the public.
2. Receiving Waterbody Information:
Table 2. Receiving Waterbodv Information62
Outfalls/Receiving Stream(s):
Outfall 001/Catawba River (35°46'42.8"N 81°39'33.5"W)
Stream Segment:
11-(34.5)
Stream Classification:
WS-IV and Critical Area (CA)
Drainage Area (mi2):
705*
Summer 7Q10 (cfs)
118*
Winter 7Q10 (cfs):
118
30Q2 (cfs):
Unknown
Average Flow (cfs):
1060*
Instream Waste Concentration
(IWC) (% effluent):
9.5 % at 8.0 MGD (7Q10S)
12.0 % at 10.5 MGD (7Q10S)
14.5 % at 13.0 MGD (7Q10S)
303(d) listed/parameter:
No
Subject to TMDL/parameter:
Yes/Mercury Statewide TMDL implemented in 2012.
Basin/Sub-basin/HUC:
Catawba/03-08-31/03050101
USGS Topo Quad/State Grid:
D12SW/ Morganton -North
* Stream flow values taken from previous fact sheet, 2002 - 2015 per Division's Guidelines
The receiving stream is the Catawba River, stream segment 11-(34.5) located between Lake James and Lake Rhodhiss
The stream is classified WS-IV CA. The class denotes use as a water supply, primary recreation, and critical area
waterbody. Because of its location downstream of Lake James Dam, the 7Q10 flow at this site has been estimated
over the years, by using the 25 cubic feet per second (cfs) instantaneous flow of the dam plus tributary flow from
several rivers which drain into the Catawba River upstream of the Morganton discharge point. Historical estimates
had the 7Q10 flow at 126 cfs at the WWTP. However, in 1994, the Division of Water Resources requested an updated
7Q10 due to the request for expansion and used 118 cfs for 10.5 MGD and 13.0 MGD. For consistency with the use
of the current 7Q10, this renewal uses a summer 7Q10 of 118 cfs for 8.0 MGD, 10.5 MGD, and 13.0 MGD.
Page 2 of 18

3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below from January 2016 through July 2021.
Table 3. Effluent Data Summary with permit limits Outfall 001
Parameter
Units
Average
Max
Min
Permit Limit
Flow
MGD
5.4
28.7
1.1
MA* 8.0MGD
BOD5
mg/1
14.7
632
1.8
MA 30.0 mg/I
WA* 45.0 mg/I
Total Suspended
Solids (TSS)
mg/1
17.64
755
2.5
MA 30.0 mg/I
WA 45.0 mg/I
NH3N
mg/1
20
-
MA 16.0 mg/I
WA 35.0 mg/I
Fecal Coliform
#/100 ml
5.8
(Geomean)
352000
1
MA 200/100m1
WA 400/100m1
pH
SU
6.8
7.6
5.8
6.0<pH<9.0
Dissolved Oxygen
(DO)
mg/1
8.2
10.9
5.9
DA*> 5.0 mg/I
Total Residual
Chlorine (TRC)
µgn
20.7
57
20
DM* 28.00 pg/I
Temperature
°C
20.4
28
9.6
Conductivity
umhos/cm
439.9
4523
127
Total Phosphorus
(TP)
mg/1
3.4
12
0.4
Total Nitrogen (TN)
mg/1
14.05
28.2
7.9
Total Copper
µg/1
20.8
281
1
*MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average.
Table 4. Effluent Data Summary from expanded effluent pollutant scan Outfall 001
Parameter
Units
Average
Max
Aluminum
µg/1
299.6
1010.0
Antimony
µg/1
17.0
26.0
Chromium
µg/1
1.1
2.5
Cyanide
µg/1
5.1
6.0
Dimethyl phthalate
µg/1
5.2
5.4
Methyl Bromide
µg/1
3.5
5.5
Mercury
ng/1
2.2
14.6
Molybdenum
µg/1
1.2
2.9
Nickel
µg/1
1.6
9.0
Selenium
µg/1
8.7
11.0
Silver
µg/1
1.3
6.0
Total Hardness (as
CaCO3)
m n
g
36.2
51.5
Zinc
µg/1
49.7
157.0
Page 3 of 18

Sample results for arsenic, beryllium, cadmium, chlorinated phenolic compounds, lead, and thallium were less
than the method detection limit. The compounds in the above table were analyzed in the reasonable potential
analysis (RPA), with the exception of aluminum, and discussed below in the RPA section of this fact sheet.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example, 1) to verify model predictions
when model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future total maximum daily load
(TMDL); 4) based on other instream concerns. Instream monitoring may be conducted by the Permittee,
and there are also Monitoring Coalitions established in several basins that conduct instream sampling for
the Permittee (in which case instream monitoring is waived in the permit as long as coalition membership
is maintained).
Instream data summary and instream monitoring proposed for this permit action:
The current permit requires instream [upstream (U) and downstream (D)] monitoring for conductivity,
dissolved oxygen, and temperature. In this permit renewal, U monitoring for total hardness will be required.
The U sampling point is located at — 250 ft of the outfall. The D sampling point is located — 2.3 miles from
the outfall on Huffman Bridge Road. No road closer to the outfall is intersecting the stream. The graphs
below summarize instream and effluent (Eff) data from the analyzed period, June 2016 - July 2021.
Figure 1. Average, maximum, and minimum instream and effluent data summary
700.0
600.0
500.0
400.0
300.0
200.0
100.0
0.0
Conductivity, umhos/cm DO, mg/I
IN I
Upstream
il
Effluent
Downstream
■ Average ■ Max ■ Min
20.0
15.0
10.0
5.0
0.0
Upstream Effluent
■ Average ■ Max ■ Min
Downstream
35.0
30.0
25.0
20.0 —
15.0
10.0
5.0
0.0
Temperature, °C
Upstream Effluent
•Average ■ Max ■ Min
Downstream
T-tests were run to analyze relationships between instream sample results. A statistically significant
difference is determined when the t-test p-value result is < 0.05.
Conductivity: As a major Facility with industrial sources, instream monitoring for conductivity is required
per 15A NCAC 2B .0508. The variances in downstream and upstream conductivity were up to 129
Page 4 of 18

umhos/cm, on 8/9/2017. The t-test concluded that there is statistically significant difference between
upstream and downstream conductivity.
DO: The minimum downstream DO detected was 3.7 mg/1, and the maximum DO differential between the
upstream and downstream samples was 8.9 mg/1. The t-test concluded that there is a statistically significant
difference between upstream and downstream DO. The review of instream data in the Catawba River
showed that the DO standard of 5 mg/1 [Per 15A NCAC 02B .0211 (6)] was being met upstream, but it is
failing to be met downstream of the WWTP.
Temperature: The maximum upstream, effluent, and downstream temperatures were 27 (9/2019), 28
(7/2020), and 32 (7/2019) degrees Celsius. The review of instream data in the Catawba River showed that
the T standard of 29 degrees Celsius was not met on a few certain occasions, nor the 2.8 degrees Celsius
temperature increase (For our purposes, natural water temperature is defined by the upstream temperature.)
The ttest concluded that there is statistically significant difference between the upstream and downstream
temperatures.
Hardness: Instream hardness sampling upstream of the discharge will be added to the permit at a
monitoring frequency of quarterly. The NC 2007-2014 Water Quality Standard (WQS) Triennial Review
was approved by the NC Environmental Management Committee (EMC) on November 13, 2014. The US
EPA subsequently approved the WQS revisions on April 6, 2016, with some exceptions. The NC Division
of Water Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in
all permits public noticed after April 6, 2016. The new standards for most metals include acute standards.
Further, the freshwater standards for several metals are expressed as the dissolved form of the metals, and
seven metals have hardness -dependent equations. As a result, the NPDES Permitting Unit will need site -
specific effluent hardness data and instream hardness data, upstream of the discharge for each facility
monitoring these metals in order to calculate permit limitations.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): NO
Name of Monitoring Coalition: NA
5. Compliance Summary
Below find summaries of compliance data from January 2016 to May 2021.
Compliance record with permit effluent limits (past 5 years):
The Facility received a total of 31 notices of violation (NOVs) for exceeding limits for BOD5, TSS, fecal
coliform, conductivity, DO, and pH. The Facility also received 47 enforcement cases for exceeding limits
for TSS, BOD5, fecal coliform, flow, TRC, and pH. The ARO, Linda Wiggs, is working with the Facility
to monitor the Facility's compliance performance. The report on limit violations that proceeded to NOV
and Enforcement Case were as follows:
Table 5. Facility's Compliance Summary of Events from January 2016 to May 2021
Parameter/Event
Daily Min.
Not
Reached
MA
Exceeded
WA
Exceeded
Weekly
Geometric
Mean
Exceeded
BOD5
Fecal
pH
TSS
23
Page 5 of 18

Summary of the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years):
The Facility passed eighteen of eighteen quarterly chronic toxicity tests at 9% effluent. Failed to comply
with all four 2nd species, but with the expedited compliance schedule from the aquatic toxicity branch, the
Facility was able to complete their four -second species test on 2/2021, 3/2021, 4/2021, 5/2021. All four
tests passed.
Summary of the results from the most recent compliance inspection:
The last Facility inspection conducted in August 2020 reported that no compliance issues were noted.
The Pretreatment team and the regional office noted that Case Farms (IUP# 1098) had 16.6% of sampling
violations for Oil & Grease in the 2nd six months of 2020; Seiren North America (IUP# 4002) had 16.6%
of sampling violations for Zinc in the 1st six months of 2020.
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: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): NA.
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Stream flow values were extracted from the previous fact sheets, 2002-2015.
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results. (If permit limits are more stringent than TBELs, describe how limits were developed)
The current permit limits for BOD are water quality limited and are based on the 1994 water quality
model results.
Ammonia and Total Residual Chlorine (TRC) Limitations
Limitations for ammonia are based on the protection of aquatic life utilizing an ammonia chronic criterion
of 1.0 mg/1 (summer) and 1.8 mg/1 (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1 (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Page 6 of 18

Proposed changes to ammonia and/or TRC limits for this permit renewal:
Ammonia
The current permit sets year-round limits for ammonia (MA 16.0 mg/1 and WA 35.0 mg/1) for the 8.0 MGD
flow tier based on the 1994 water quality model. For the 10.5 MGD and 13.0 MGD flow tiers, the permit
sets summer and winter limits according to the waste load allocation (WLA) calculations. Self -monitoring
data generally indicates ammonia concentrations of less than 5 mg/L, which indicates that the facility is
achieving ammonia removal through nitrification. As seen in the graph below, there are peaks in the
ammonia concentration at the end of 2018 and the beginning of 2019. As explained by the Permittee, during
this period, the plant had completed construction on the two new diffused bubbler aeration basins and was
placed online; therefore, the Facility experienced higher ammonia levels during this changeover time with
the nitrification process in its infant stages.
Figure 2. Ammonia effluent data summary
Ammonia, mg/I
25
20
15
10
5
0
01/2016 08/2016 03/2017 09/2017 04/2018 10/2018 05/2019 12/2019 06/2020 01/2021 07/2021
The permit only had a monthly average limit of 16 mg/1 until it was renewed in 2006, when a weekly
average limit of 35 mg/1 was implemented. The permit was renewed in 2011 with the same limits. The
current ammonia policy is to calculate an allowable ammonia limit based on aquatic toxicity using a target
of 1 mg/1 instream ammonia to protect aquatic life. If this calculated limit is more stringent than the limit
calculated by the water quality model, the more stringent limit is applied to the permit. Ammonia limit
calculated for protection of ammonia toxicity in the stream results in 8.4 mg/1, which is less than the existing
monthly average limit of 16 mg/l. Therefore, year-round limits are adjusted in this permit cycle for the 8.0
MGD flow tier as follows, MA 8.4 mg/1 and WA 25.3 mg/1.
For the 10.5 MGD and 13.0 MGD flow tiers, the ammonia limits were evaluated via the WLA and will be
the same as the previous permit cycle.
TRC
The Facility uses chlorination as its primary disinfection. The current permit limits TRC at 28 ug/L as a
daily maximum. Through this permit cycle, the Facility reported TRC values below 30 ug/L, with the
exception of summer 2020, when several reported TRC values exceeded the 30 ug/L but remained below
Page 7 of 18

50 ug/L. The TRC limit has been reviewed in the attached WLA and has been found to be protective. No
changes are proposed for TRC.
Reasonable Potential Analysis (RPA) for Toxicants
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of 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.
The RPAs were conducted for permitted flows of 8.0MGD, 10.5 MGD, and 13.0 MGD with a 7Q10S of
118 cubic feet per second (cfs), specific effluent hardness values, and default upstream hardness values.
During the public notice period, the Permittee corrected eDMR values; the RPA was updated accordingly.
Additionally, the RPA was corrected to replace the outstanding resource water (ORW) stream classification
in the original draft with the correct classification as WS-IV and CA. This correction updates the calculated
water quality standard (WQS) values and the RPA results. The answers below are based on the updated
RPA. Pollutants of concern included toxicants with positive detections and defined water quality
standards/EPA criteria and BPJ. Based on these analyses, the following permitting actions are proposed for
this permit:
RPAs were conducted on effluent toxicant data collected in the Permittee's January 2016 through July 2021
DMRs, and three effluent pollutant scans (2016, 2017, and 2018). Pollutants of concern included toxicants
with positive detections and associated water quality standards/criteria. The data set was limited for
antimony, beryllium, dimethyl phthalate, methyl bromide, and total phenolic compounds. 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:
For 8.0 MGD — Copper
For 10.5 MGD — Copper
For 13.0 MGD — Copper
To provide an opportunity for the City to develop a plan to assess sources of copper in order to
come in compliance with the limits in Section A. (1.) a 3-year schedule of compliance has been
added to the permit for 8.0 MGD. See Special Condition A. (9.)
• 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:
For 8.0 MGD — Silver. Method with the lowest PQL must be used. (See note below)
For 10.5 MGD — Silver. Method with the lowest PQL must be used.
For 13.0 MGD — Silver. Method with the lowest PQL must be used.
The City of Morganton reported Total Silver at less than detection, with detection levels < 1.0
µg/L and < 2.5 µg/L in the Effluent Pollutant Scans (or their DMR results). The City's
allowable discharge concentrations are 0.63 µg/L for Total Silver. DWR's laboratory identifies
the target Practical Quantification Limits (PQLs) for Total Silver as 1.0 µg/L.
Page 8 of 18

15A NCAC 2B .0505 (e) (4) requires that all test procedures must produce detection and
reporting levels that are below the permit discharge requirements and all data generated must be
reported to the approved detection level or lower reporting level of the procedure. If no approved
methods are capable of achieving a detection level below the permit discharge requirement (or
allowable discharge concentration) the Method with the lowest detection level must be used. The
City should use sufficiently sensitive test methods for all pollutants, including when performing
Effluent Pollutant Scans.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration:
For 8.0 MGD — Antimony.
For 10.5 MGD — Antimony.
For 13.0 MGD — Antimony.
• 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:
For 8.0 MGD: Arsenic, Cyanide, Lead, Molybdenum, Nickel, Selenium, Zinc, Total Phenolic
Compounds, Dimethyl phthalate, Methyl bromide.
For 10.5 MGD: Arsenic, Cyanide, Lead, Molybdenum, Nickel, Selenium, Zinc, Total Phenolic
Compounds, Dimethyl phthalate, Methyl bromide.
For 13.0 MGD: Arsenic, Cyanide, Lead, Molybdenum, Nickel, Selenium, Zinc, Total Phenolic
Compounds, Dimethyl phthalate, Methyl bromide.
15A NCAC 2B .0505 (e) (4) requires that all test procedures must produce detection and
reporting levels that are below the permit discharge requirements and all data generated must be
reported to the approved detection level or lower reporting level of the procedure. If no approved
methods are capable of achieving a detection level below the permit discharge requirement (or
allowable discharge concentration), the Method with the lowest detection level must be used.
The City should use sufficiently sensitive test methods for all pollutants, including when
performing Effluent Pollutant Scans.
• Additional Notes:
o Aluminum: In order to assess the impact of this compound in the stream, a monitoring
requirement for aluminum will be added on a quarterly basis. The 2018 Recommended
Aquatic Life Ambient Water Quality Criteria for Aluminum in Freshwaters depend on
a site's water chemistry parameters (pH, hardness, and dissolved organic carbon
(DOC)); therefore, this permit cycle the Division proposes quarterly monitoring for
DOC, in order to calculate the water quality standard (WQS) and conduct the RPA for
aluminum in the next permit cycle.
For 8.0 MGD: Aluminum and DOC
For 10.5 MGD: Aluminum and DOC
Page 9 of 18

For 13.0 MGD: Aluminum and DOC
RPA results as well as a copy of the Dissolved Metals Implementation Fact Sheet for freshwater are
included in the attachments of this Fact Sheet.
Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Major Publicly Owned Treatment Work (POTW),
and a quarterly chronic WET limit will continue to apply at Outfall 001 at 9.5 % effluent concentration
using Ceriodaphnia dubia for 8.0 MGD; 12.0 % for 10.5 MGD, and 14.5 % for 13.0 MGD.
Mercury Statewide Total Maximum Daily Load (TMDL) Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year) and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/1
Find summaries of compliance mercury data from May 2017 to October 2020 in Table 6. (Methods
1631E and 200.7)
Table 6. Mercury Effluent Data Summary — 8.0MGD
2017
2018
2019
2020
# of Samples
3
4
8
10
Mercury Annual Average (ng/1)
66.7
50.0
13.6
2.84
Mercury Annual Max (ng/1)
100.0
50.0
50.0
14.6
TBEL, ng/L
47
WQBEL, ng/L for 8.0 MGD
126.2
WQBEL, ng/L for 10.5 MGD
99.0
WQBEL, ng/L for 13.0 MGD
82.3
Page 10 of 18

Describe proposed permit actions based on mercury evaluation Since the facility is >2 MGD and reported
quantifiable levels of mercury (> 1 ng/1), a mercury minimization plan (MMP) was added to this permit in
the last permit cycle and will continue in this permit cycle.
Mercury evaluation results were available and used Method 1631E in 2019 and 2020. Previous sampling
events used Method 200.7. No annual average mercury concentration exceeded the WQBEL. Individual
mercury samples exceeded the TBEL when Method 200.7 was used; however, according to August 23,
2007, US EPA Memorandum, only the most sensitive methods such as Methods 1631E and 245.7 are
appropriate in most instances for use in deciding whether to set a permit limitation for mercury and for
sampling and analysis of mercury pursuant to the monitoring requirements within a permit. Therefore, the
sampling results obtained in 2017 and 2018, which used Method 200.7, are not considered to set a permit
limitation for this facility. The facility must continue to use only Method 1631E.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit:
During the 2010 permit renewal, effluent and instream monitoring for total nitrogen (TN) and total
phosphorous (TP) were included in the permit due to the impairment of Lake Rhodhiss (2010 NC 303(d)
List). In 2016, the instream monitoring for TN and TP was eliminated due to the Lake Rhodhiss being taken
off the 303(d) list. Lake Rhodhiss was listed in the 303d list for high pH and excessive algal production
beginning in 2006 and removed from it in 2014. Plans for the nutrient TMDL were dropped, as it was no
longer impaired. Due to lower pH and algal growth in the lake, the Division decided to change nutrient
monitoring frequencies from weekly to monthly and eliminate instream monitoring requirements for four
facilities (Marion, Morganton, Lenoir, and Valdese) discharging to Lake Rhodhiss.
The permit reflects a monthly nutrient (TP and TN) monitoring for 8.0 MGD and 10.5 MGD and weekly
monitoring for 13.0 MGD, as well as annual nutrient (TN and TP loads) monitoring for the 13.0 MGD
flow tier. TN and TP annual load monitoring requirements are added to the 10.5 MGD in this permit
cycle. See Special Condition A. (2.)
See in the Figure 3, the total phosphorus loading and the total nitrogen loading trends in the last permit
cycle.
Figure 3. Total Nitrogen and Total Phosphorus Annual Loading Summary from 1994 to 2021
400,000
0 'a
"' -- 300,000
Z 200,000
100,000
3 0
80,000
• 60,000
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12
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NC0026573-001 - Catawba River Pollution Control Facility
Out -fall Name: Effluent to
the Catawba River -- Outliers Removed:
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Page 11 of 18
25
20
15
10
5
6
5
4
3
2
6-5
6-0
5-5
5-0
4-5
4-0
3-5
30
• Annual Mean N Loading
▪ Annual Median N Loading
• Mean Nitrogen (mg/L)
• Annual Mean P Loading
▪ Annual Median P Loading
Mean Phosphorus (mg/L)
N Months no Flow Data
N Months no Nitrogen Data
N Months no Phosphorus Data
—Median Flow (MGD)
—Mean Flow (MGD)

Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA. The Facility
submitted a chemical addendum with no additional pollutants to report.
A PFAS monitoring Special Condition is added to the permit based on the absence of data for this group
of pollutants, significant industrial users (SIUs) discharges, and the receiving water stream classification,
W S-Iv.
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 3-year schedule of
compliance for copper was 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/TSS for Monthly Average, and 45 mg/l for BOD5/TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BOD5/TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge)
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
Page 12 of 18

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. For instream
monitoring, refer to Section 4.
The Division will maintain the effluent monitoring frequency requirements as the previous permit in
compliance with the monitoring frequencies set for Facilities Class IV described on 15A NCAC 2B
.0500.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. While NPDES regulated facilities would initially be required to submit additional
NPDES reports electronically effective December 21, 2020, EPA extended this deadline from December
21, 2020, to December 21, 2025. The current compliance date, effective January 4, 2021, was extended as
a final regulation change published in the November 2, 2020, Federal Register. This permit contains the
requirements for electronic reporting, consistent with Federal requirements.
12.Summary of Proposed Permitting Actions
Table 7. Current Permit Conditions and Proposed Changes for 8.0 MGD, 10.5 MGD, and 13.0 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
8.0 / 10.5 / 13.0 MGD
No changes
15A NCAC 2B .0505
Total Monthly Flow
(TMF)
None
Added TMF
requirement for 13.0
MGD -Monitor and
report continuously
For calculation of T.N. and T.P.
Loads
BOD5
For 8.0 MGD
MA 30.0 mg/1
WA 45.0 mg/1
For 10.5 MGD
MA 18.5 mg/1
WA 27.8 mg/1
For 13.0 MGD
MA 15.0 mg/1
WA 22.5 mg/1
No changes
TBEL. Secondary treatment
standards/40 CFR 133 / 15A NCAC
2B .0406.
TSS
MA 30 mg/1
WA 45 mg/1
For 8.0 / 10.5 / 13.0
MGD (All Flows)
No changes
TBEL. Secondary treatment
standards/40 CFR 133 / 15A NCAC
2B .0406.
NH3-N
For 8.0 MGD
MA 16.0 mg/1
WA 35.0 mg/1
For 8.0 MGD
MA 8.4 mg/1
WA 25.3 mg/1
WQBEL based on WLA
calculations for 8.0, 10.5, and 13.0
MGD
Page 13 of 18

For 10.5 MGD
(S) MA 6.6 mg/1
WA 19.8 mg/1
(W)MA 13.3mg/1
WA 35.0 mg/1.
For 13.0 MGD
(S) MA 5.6 mg/1
WA 16.8 mg/1
(W) MA 11.0 mg/1
WA 33.0 mg/1.
No changes for 10.5
MGD and 13.0 MGD
15A NCAC 2B .0500 — Surface
Water Monitoring: Reporting
Fecal coliform
(Geometric Mean)
MA 200 /100m1
WA 400 /100m1
for All flows
No changes
WQBEL. State WQ standard, 15A
NCAC 2B .0200.
pH
6 — 9 SU.
for All Flows
No changes
WQBEL. State WQ standard, 15A
NCAC 2B .0200
DO
Not less than 5 mg/1 for
effluent and instream
for All Flows** at
Variable Monitoring
Frequency***
No changes
WQBEL. State WQ standard, 15A
NCAC 2B .0200, 15A NCAC
2B.0500
TRC
DM 28.0 µg/1
for All Flows
No changes
WQBEL. Maximum daily limit to
protect acute toxicity
Temperature
Monitor and report
daily for effluent and
instream
for All Flows at
Variable Monitoring
Frequency***
No changes
15A NCAC 2B.0200 and 15A
NCAC 2B.0500
Conductivity
For All Flow: Monitor
and report daily for
effluent and instream
at Variable Monitoring
Frequency***
No changes
The facility has industrial
dischargers and pretreatment
program 15A NCAC 2B.0500
Hardness
None
Added Quarterly
monitoring upstream
and in effluent
for All Flows
Hardness -dependent dissolved
metals water quality standards
approved in 2016; facility with
pretreatment program
Antimony
None
Added Quarterly
monitoring in effluent
for All Flows
Based on the Reasonable Potential
Analysis, reasonable potential (RP)
exists. Limited dataset. Predicted
Max > Allowable Concentration
(Cw). Add quarterly monitoring.
The Method with lowest PQL must
be used
Total Copper
Quarterly monitoring
for 8.0 MGD, 10.5
MGD, and 13.0 MGD
Updated to monthly
monitoring for All
Flows monitoring and
Based on the Reasonable Potential
Analysis, RP exists. Add monthly
monitoring and limit
Page 14 of 18

added limits as
follows:
For 8.0 MGD
DM 96.1 ug/1
MA 85.9 ug/1
For 10.5 MGD
DM 76.8 ug/1
MA 68.0 ug/1
For 13.0 MGD
DM 64.9 ug/1
MA 57.0 ug/1
A 3-year compliance schedule for
copper was added to the permit to
provide an opportunity for the City
to develop a plan to assess sources
of copper to come in compliance
with the limit in Section A. (1)
Total Silver
None
Added monthly
effluent monitoring in
for All Flows
Based on the Reasonable Potential
Analysis: Predicted Max >
Allowable Cw, 4 values > allowable
Cw. Add monthly monitoring.
Method with lowest PQL must be
used
Total Phosphorus
(TP)
For 8.0 and 10.5 MGD -
Monitor and report
monthly
For 13.0 MGD -
Monitor and report
weekly
No changes
15A NCAC 2B .0500 — Surface
Water Monitoring and Reporting.
TP Load
For 13.0 MGD -
Monitor and report
annually
(as lb/yr)
Annual TP mass limit
of 33,200 lb/yr
For 13.0 MGD
continue monitoring
and reporting
requirement.
annual TP load limit
remains the same
For 10.0 MGD added
annual TP monitoring
and reporting
requirement.
Mass load limits were calculated in
2009 based on the Point Source
Action Plan, using the 2007-2009
average discharge flows and nutrient
concentrations.
Total Nitrogen (TN)
For 8.0 and 10.5 MGD -
Monitor and report
monthly
For 13.0 MGD -
Monitor and report
weekly
No changes
15A NCAC 2B .0500 — Surface
Water Monitoring and Reporting.
TN Load
For 13.0 MGD -
Monitor and report
annually
(as lb/yr)
For 13.0 MGD
continue monitoring
and reporting
requirement.
Mass load limits were calculated in
2009, using the 2007-2010 average
discharge flows, nutrient
concentrations.
Page 15 of 18

Annual TN mass limit
of 146,659 lb/yr
annual TN load limit
remains the same
For 10.0 MGD added
annual TN monitoring
and reporting
requirement.
Total Kjeldahl
Nitrogen (TKN)
Weekly monitoring for
13.0 MGD
No changes
TN monitoring
Nitrite and Nitrate (
NO2 + NO3)
Weekly monitoring for
13.0 MGD
No changes
TN monitoring
PFAS
None
Added PFAS
quarterly monitoring
requirement with
delayed
implementation
Facility discharges to WS-IV waters
and has an active Pretreatment
Program
Toxicity Test
Chronic limit,
9.0% for 8.0MGD,
12.0 % for 10.5 MGD
15.0 % for 13.0 MGD
Updated Chronic limit
for 8.0 MGD and 13.0
MGD,
9.5% for 8.0 MGD,
12.0 % for 10.5 MGD
14.5 % for 13.0 MGD
WQBEL. No toxics in toxic
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Updated according to RPA results
and Aquatic Toxicity Branch input.
Effluent Pollutant
Scan
Three times per permit
cycle for All flows
Next three scans must
be performed in each
of the following
years: 2024, 2025,
and 2026
40 CFR parts 423 and 122
Mercury
Minimization Plan
(MMP)
MMP
for All Flows
No changes
Consistent with EPA approved 2012
Statewide Mercury TMDL
Implementation.
Electronic
Reporting
Electronic reporting
special condition
for All Flows
Added language for
new electronic
reporting deadline
December 21, 2025
In accordance with EPA Electronic
Reporting Rule 2015 and Rule -
Phase 2 Extension
* MA - Monthly Average, WA — Weekly Average, DM — Daily Max.
**All Flows = 8.0, 10.5, and 13.0 MGD
*** Variable monitoring frequency is defined as follows: samples collected three times per week during June 1
through September 30 and once per week October 1 through May 31.
13. Public Notice Schedule
Permit to Public Notice: October 28, 2021 (First) and June 16, 2022 (Second)
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.
Page 16 of 18

14. NPDES Division Contact
If you have any questions regarding any of the above information or on the attached permit, please
contact Diana Yitbarek at [phone] or via email at diana.yitbarek@@ncdenr.gov.
15. Fact Sheet Addendum
Were there any changes made since the Draft Permit was public noticed (Yes/No): Yes.
The Division received comments from the Southern Environmental Law Center (SELC) and the Catawba
Riverkeeper Foundation on July 22, 2022, by Alyson Merlin (See full comments and responses in fact
sheet attachments).
Below is the list of permit changes after the draft permit was public noticed on June 14, 2022:
• The PFAS monitoring requirement was revised from 2/year to quarterly.
• Upon review of the most recent silver monitoring data, all the values were less than detect after
September 2019; however, to collect additional representative data, DEQ is increasing monitoring
frequency from quarterly to monthly
Below is the list of permit changes after the draft permit was public noticed on October 26, 2021:
• The permit expiration date was modified to February 26, 2027. Accordingly, the specified years for
the Effluent Pollutant Scans have been adjusted (2024, 2025, 2026). See Special Condition A. (6.).
• The authorization language in the Supplement to Permit Cover Sheet and Special Condition A. (1.) and
A. (2.) was updated to modify the requirements before the Facility is authorized to transition from the
8.0 MGD flow tier into the 10.5 MGD flow tier. This change was made to require an upgrade of the
Facility to meet the final limits for the 10.5 MGD effluent limitation page.
• Based on our review of the nutrient information, the proposed nutrients limits (Total Nitrogen (TN)
and Total Phosphorous (TP)) have been removed from the 10.5 MGD flow tier limitation page; as
well as monitoring requirements for Total Kjeldahl Nitrogen and Nitrite and Nitrate. TN and TP
annual load monitoring requirements for 10.5 MGD are added. [See Special Condition A. (2.).]
The limits for the 13.0 MGD flow tier page have been maintained at your request with the same limits
that was originally public noticed. The 13.0 MGD flow tier may not be used for an extended period of
time from your information, it is not appropriate to change the existing 13.0 MGD limits. When the
original NPDES permit was issued a review of the 13.0 MGD flow tier was conducted and approved,
so this flow tier will be maintained.
• The monitoring frequency for copper was corrected from quarterly to monthly. See Special Condition
A. (1.), A. (2.), and A. (3.)
• The weekly average limit for BODS for the 10.5 MGD flow tier was corrected from 45.0 to 27.8
mg/1.
Page 17 of 18

• The reasonable potential analysis (RPA) was corrected to replace the outstanding resource water
(ORW) stream classification in the original draft with the correct classification as WS-IV and CA.
This correction updates the calculated water quality standard (WQS) values and the RPA results:
o The limit for copper was updated for all flow tiers. See Special Condition A. (1.), A. (2.), and
A. (3.). Special Condition A. (9.) was updated to include a notation for the Permittee with the
option to request the removal of the Copper Schedule of Compliance.
o The monitoring requirement for zinc for 10.5 and 13.0 MGD was removed. See Special
Condition A. (2.), and A. (3.).
o The monitoring requirement for selenium for 13.0 MGD was removed. See Special Condition
A. (3.).
• Special Condition A. (6.) was also updated to include language about the additional toxicity sampling.
Samples must represent seasonal variation.
16. Fact Sheet Attachments:
1. RPA Sheets Summary for 8.0, 10.5, and 13.0 MGD. Each sheet contains: input information tab, data
analyzed tab, results summary tab, and dissolve to total metals calculation tab.
2. BOD and TSS Removal Rate calculations
3. NH3/TRC/Fecal Waste Load Allocation (WLA) Spreadsheet for 8.0, 10.5, and 13.0 MGD
4. Mercury TMDL Calculations for 8.0, 10.5, and 13.0 MGD
5. Toxicity Summary/WET testing
6. Pretreatment (PT) Summary and Pollutants of Concern (POC) Review Form
7. Renewal Application Addendums
Signed Effluent Pollutant Scans
Addendum Form 2A
Mercury Minimization Plan (MMP) summary
Chemical Addendum
8. NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
9. Compliance Inspection Report (August 2020)
10. Correspondence
11. 2018 Aluminum Criteria Fact Sheet
12. Public Comments and Responses
13. Public Water Supply Memo
14. Nutrient Load Limit Calculations
15. Affidavits (October 2021 and June 2022)
Page 18 of 18

tal Translators
/95% Confidence U
95% Probabilit
Freshwate
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 2. Parameters of Concern
Table 1. Project Information
U
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CHECK IF HQW OR ORW WQS
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131.1482
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Water Supply
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Water Supply
Water Supply
Water Supply
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Cadmium
Chlorides
Chlorinated Phenolic Compounds
Total Phenolic Compounds
EN
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Chromium VI
Chromium, Total
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Cyanide
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Catawba River Pollution Control Facility
NC0026573
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Facility Name
WWTPIWTP Class
NPDES Permit
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Apply WS Hardness WQC
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RECOMMENDED ACTION
No RP, Predicted Max < 50% of Allowable Cw- No
Monitoring required, other than pollutant scan (PS)
Limited Dataset (n<8 samples). Predicted Max<
50% of Allowable Cw. No detects (Max PQL 20
pg/L).
Predicted Max< 50% of Allowable Cw. No detects
(Max PQL 2.5 pg/L)
Limited Dataset (n<8 samples). Predicted Max <
50% of Allowable Cw- No Monitoring required, other
than PS
See Chromium, Total
See Chromium, Total
a: No monitoring required other than PS if all Total
Chromium samples are < 5 pg/L or Pred. max for
Total Cr is < allowable Cw for Cr VI.
RP exists. Predicted Max> Allowable Cw, 1 values
> allowable Cw-Add monthly monitoring and limit
No RP, Predicted Max < 50% of Allowable Cw- No
Monitoring required other than PS
No RP, Predicted Max < 50% of Allowable Cw All
values reported non -detect - No Monitoring
required other than PS
No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
REASONABLE POTENTIAL RESULTS
ri # Det. Max Pred Cw Allowable Cw
Acute (FW): 2,978.0
Cbronic(FVT) 1,577.4
Max MDL=10
Chronic(Ilti): 864.8 --
Max MDL=10
Acute: 569.33
Chronic: 68.35
Max MDL=20
Acute: 29.643
Chronic: 6.403
Max MDL =2.5
Acute: NO WQS
Chronic: 300.0
Max MDL=10
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Chronic: 115.7
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Acute: 699.486
Chronic:---- 32.427 --
MaxMDL=10
Acute: NO WQS
Chronic: 1,682.E
No value> Allowable Cw
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PARAMETER
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Chromium III
Chromium VI
Chromium, Total
Copper
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Molybdenum
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No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
Predicted Max > Allowable Cw, 4 values > allowable
Cw - Add quarterly monitoring. Method with lowest
PQL must be used
No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
RP exists. Predicted Max> 50% Allowable Cw - Add
monthly monitoring
Limited dataset. Predicted Max> Allowable Cw- Add
quarterly monitoring. Method with lowest PQL must
be used
No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
No RP, Predicted Max < 50% of Allowable Cw -
No Monitoring required other than PS
1
1
i
i.o
3
a
A
z
1
1 B
i a
.. i ,O ^
..
00
3
a
.o A
z
Acute: NO WQS
Chronic: 3996.129
No value> Allowable Cw
Acute: NO WQS
Chronic: 58.89032
No value> Allowable Cw
Acute: NO WQS
Chronic: 21032.25806
No value> Allowable Cw
Acute: NO WQS
Chronic: 1051.61290
No value> Allowable Cw
0.6
78.00000
C.V. (dciault)
16.29000
C.V. (default)
16.47000
C.V. (default)
3 2
Note: n<9
Limited data set
3 1
Note: n<9
Limited data set
3 1
Note: n<9
Limited data set
t
a
i
.
t
FW(7Q10s) 56
gl
a
w
o
131.3069 FW(7Q10s) 131.1482
380 WS(7Q10s)
a
3
,
0
a
3
N
0
a
3
o
U
Z
U
Z
U
Z
U
Z
z
U
Z
2
Z
N
N
N
E
E
Q
E
Q
E
0
Methyl Bromide

REASONABLE POTENTIAL ANALYSIS
H1
Effluent Hardness
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=1/2DL Results
1 7/14/2016 34.10 34.1 Std Dev. 14.3197
2 10/26/2017 51.50 51.5 Mean 36.2333
3 4/19/2018 23.10 23.1 C.V. (default) 0.6000
4 n 3
5 10th Per value 25.30 mg/L
6 Average Value 36.23 mg/L
7 Max. Value 51.50 mg/L
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
H2
Upstream Hardness
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Date Data BDL=1/2DL Results
1 25.00 25 Std Dev. N/A
2 Mean 25.0000
3 C.V. 0.0000
4 n 1
5 10th Per value 25.00 mg/L
6 Average Value 25.00 mg/L
7 Max. Value 25.00 mg/L
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
-4-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=1/2DL Results
1 5/18/2017 < 10 5 Std Dev.
2 7/11/2017 < 10 5 Mean
3 10/5/2017 < 10 5 C.V.
4 1/25/2018 < 1 0.5 n
5 4/19/2018 < 10 5
6 7/19/2018 < 10 5 MultFactor=
7 10/9/2018 < 10 5 Max. Value
8 1/29/2019 < 10 5 Max. Pred Cw
9 4/11/2019 < 10 5
10 7/15/2019 < 10 5
11 9/24/2019 < 10 5
12 10/15/2019 < 10 5
13 11/13/2019 < 10 5
14 12/10/2019 < 10 5
15 1/9/2020 < 10 5
16 2/21/2020 < 10 5
17 3/17/2020 < 10 5
18 4/21/2020 < 10 5
19 5/19/2020 < 10 5
20 6/15/2020 < 10 5
21 7/7/2020 < 10 5
22 8/12/2020 < 10 5
23 10/14/2020 < 10 5
24 1/12/2021 < 1 0.5
25 4/20/2021 < 2.5 1.25
26 7/20/2021 < 1 0.5
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
1.5921
4.3365
0.3671
26
1.16
5.0 ug/L
5.8 ug/L
Date Data BDL=1/2DL Results
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
1 7/14/2016 < 20 10 Std Dev. 5.4848
2 10/26/2017 < 20 10 Mean 6.8333
3 4/21/2018 < 1 0.5 C.V. (default) 0.6000
4 n 3
5
6 Mult Factor = 3.00
7 Max. Value 10.00 ug/L
8 Max. Pred Cw 30.00 ug/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-5-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par04
Cadmium
Date Data BDL=1/2DL Results
1 1/12/2016 < 0.2 0.1 Std Dev.
2 4/7/2016 < 0.2 0.1 Mean
3 5/18/2017 < 0.2 0.1 C.V.
4 7/11/2017 < 0.2 0.1 n
5 10/5/2017 < 0.2 0.1
6 1/25/2018 < 0.2 0.1 MultFactor=
7 4/19/2018 < 0.2 0.1 Max. Value
8 7/19/2018 < 0.2 0.1 Max. Pred Cw
9 10/9/2018 < 0.2 0.1
10 1/29/2019 < 0.2 0.1
11 4/11/2019 < 0.2 0.1
12 7/15/2019 < 0.2 0.1
13 9/24/2019 < 0.2 0.1
14 10/15/2019 < 0.2 0.1
15 11/13/2019 < 0.2 0.1
16 12/10/2019 < 0.2 0.1
17 1/9/2020 < 0.2 0.1
18 2/21/2020 < 0.2 0.1
19 3/17/2020 < 0.2 0.1
20 4/21/2020 < 0.2 0.1
21 5/19/2020 < 0.2 0.1
22 6/15/2020 < 0.2 0.1
23 7/7/2020 < 0.2 0.1
24 8/12/2020 < 0.2 0.1
25 10/14/2020 < 0.2 0.1
26 1/12/2021 < 1 0.5
27 4/20/2021 < 2.5 1.25
28 7/20/2021 < 1 0.5
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
0.2362
0.1696
1.3925
28
1.47
1.250 ug/L
1.838 ug/L
Date Data
7/14/2016 <
10/26/2017 <
4/21/2018 <
BDL=1/2DL Results
1 0.5 Std Dev.
10 5 Mean
10 5 C.V. (default)
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
2.5981
3.5000
0.6000
3
6.20
5.0 ug/L
31.0 ug/L
-6-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par10
Chromium, Total
Date Data BDL=1/2DL Results
7/14/2016 1 1 Std Dev.
5/18/2017 < 1 0.5 Mean
7/11/2017 < 1 0.5 C.V.
10/5/2017 2 2 n
1/25/2018 < 1 0.5
4/19/2018 < 1 0.5 MultFactor=
7/19/2018 < 1 0.5 Max. Value
10/9/2018 < 1 0.5 Max. Pred Cw
1/29/2019 < 1 0.5
4/11/2019 < 1 0.5
7/15/2019 < 1 0.5
10/15/2019 < 1 0.5
11/13/2019 < 1 0.5
12/10/2019 < 1 0.5
1/9/2020 < 1 0.5
2/21/2020 < 1 0.5
3/17/2020 < 1 0.5
4/21/2020 < 1 0.5
5/19/2020 < 1 0.5
6/15/2020 < 1 0.5
7/7/2020 < 1 0.5
8/12/2020 1 1
10/14/2020 < 1 0.5
1/12/2021 1.37 1.37
4/20/2021 2.5 2.5
7/20/2021 < 1 0.5
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
Pall
Copper
0.5059
0.7065
0.7160
26
1.30
2.5 pg/L
3.3 pg/L
Date Data BDL=1/2DL Results
1 1/12/2016 12 12 Std Dev.
2 4/7/2016 14 14 Mean
3 6/2/2016 16 16 C.V.
4 7/14/2016 12 12 n
5 10/6/2016 26 26
6 1/12/2017 < 1 0.5 MultFactor =
7 4/11/2017 13 13 Max. Value
8 5/18/2017 < 1 0.5 Max. Pred Cw
9 7/11/2017 26 26
10 10/5/2017 281 281
11 10/26/2017 10 10
12 1/25/2018 < 1 0.5
13 4/19/2018 < 1 0.5
14 7/19/2018 < 1 0.5
15 10/9/2018 68 68
16 1/29/2019 8 8
17 4/11/2019 6 6
18 7/15/2019 47 47
19 9/24/2019 2 2
20 10/15/2019 10 10
21 11/13/2019 10 10
22 12/10/2019 6 6
23 1/9/2020 33 33
24 2/21/2020 < 1 0.5
25 3/17/2020 7 7
26 4/21/2020 14 14
27 5/19/2020 9 9
28 6/15/2020 4 4
29 7/7/2020 7 7
30 8/12/2020 6 6
31 9/21/2020 34 34
32 10/14/2020 3 3
33 1/12/2021 5.89 5.89
34 4/20/2021 18.1 18.1
35 7/20/2021 5.92 5.92
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
47.5550
20.4831
2.3217
35
1.41
281.00 ug/L
396.21 ug/L
-7-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par12
Cyanide
Date Data BDL=1/2DL Results
1 5/18/2017 < 5 5 Std Dev.
2 7/11/2017 5 5 Mean
3 10/5/2017 5 5 C.V.
4 1/25/2018 < 5 5 n
5 1/12/2016 < 5 5
6 2/11/2016 < 5 5 Mult Factor =
7 3/3/2016 5 5 Max. Value
8 4/7/2016 < 5 5 Max. Pred Cw
9 5/18/2017 < 5 5
10 7/11/2017 5 5
11 10/5/2017 < 5 5
12 1/25/2018 5 5
13 4/19/2018 5 5
14 7/19/2018 < 5 5
15 10/9/2018 5 5
16 1/29/2019 < 6 5
17 4/11/2019 < 5 5
18 7/15/2019 < 5 5
19 9/23/2019 < 5 5
20 10/15/2019 < 5 5
21 11/13/2019 5 5
22 1/9/2020 < 5 5
23 2/20/2020 < 5 5
24 3/17/2020 < 5 5
25 4/21/2020 5 5
26 5/18/2020 5 5
27 6/15/2020 5 5
28 7/6/2020 5 5
29 8/12/2020 5 5
30 10/14/2020 5 5
31 1/11/2021 5 5
32 4/19/2021 6 5
33 7/20/2021 < 5 5
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
Par14
Lead
0.0000
5.00
0.0000
33
1.00
5.0 ug/L
5.0 ug/L
Date BDL=1/2DL Results
1 1/12/2016 < 10 5 Std Dev.
2 4/7/2016 < 10 5 Mean
3 5/18/2017 < 10 5 C.V.
4 7/11/2017 < 10 5 n
5 10/5/2017 < 10 5
6 1/25/2018 < 10 5 Mult Factor =
7 4/19/2018 < 10 5 Max. Value
8 7/19/2018 < 10 5 Max. Pred Cw
9 10/9/2018 < 10 5
10 1/29/2019 < 10 5
11 4/11/2019 < 10 5
12 7/15/2019 < 10 5
13 9/24/2019 < 10 5
14 10/15/2019 < 10 5
15 11/13/2019 < 10 5
16 12/10/2019 < 10 5
17 1/9/2020 < 10 5
18 2/21/2020 < 10 5
19 3/17/2020 < 10 5
20 4/21/2020 < 10 5
21 5/19/2020 < 10 5
22 6/15/2020 < 10 5
23 7/7/2020 < 10 5
24 8/12/2020 < 10 5
25 10/14/2020 < 10 5
26 1/12/2021 < 1 0.5
27 4/20/2021 < 2.5 1.25
28 7/20/2021 < 1 0.5
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
1.3438
4.5446
0.2957
28
1.11
5.000 ug/L
5.550 ug/L
-8-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par16
Molybdenum
Date Data BDL=1/2DL Results
1 5/18/2017 < 1 0.5 Std Dev.
2 7/11/2017 < 1 0.5 Mean
3 10/5/2017 < 1 0.5 C.V.
4 1/25/2018 < 1 0.5 n
5 4/19/2018 < 1 0.5
6 7/19/2018 < 1 0.5 MultFactor=
7 10/9/2018 < 1 0.5 Max. Value
8 1/29/2019 < 1 0.5 Max. Pred Cw
9 4/11/2019 < 1 0.5
10 7/15/2019 < 1 0.5
11 9/24/2019 < 1 0.5
12 10/15/2019 < 1 0.5
13 11/13/2019 < 1 0.5
14 12/10/2019 < 1 0.5
15 1/9/2020 < 1 0.5
16 2/21/2020 < 1 0.5
17 3/17/2020 < 1 0.5
18 4/21/2020 < 1 0.5
19 5/19/2020 < 1 0.5
20 6/15/2020 < 1 0.5
21 7/7/2020 < 1 0.5
22 8/12/2020 < 1 0.5
23 10/14/2020 < 1 0.5
24 1/12/2021 1.58 1.58
25 4/20/2021 2.91 2.91
26 7/20/2021 2.45 2.45
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
Date Data BDL=1/2DL Results
0.6209 1 5/18/2017 < 1 0.5 Std Dev.
0.7092 2 7/11/2017 < 1 0.5 Mean
0.8755 3 10/5/2017 < 2 1 C.V.
26 4 1/25/2018 < 1 0.5 n
5 4/19/2018 < 1 0.5
1.36 6 7/19/2018 < 1 0.5 MultFactor=
2.9 ug/L 7 10/9/2018 < 1 0.5 Max. Value
4.0 ug/L 8 1/29/2019 < 1 0.5 Max. Pred Cw
9 4/11/2019 < 1 0.5
10 7/15/2019 < 1 0.5
11 9/24/2019 < 1 0.5
12 10/15/2019 9 9
13 11/13/2019 < 1 0.5
14 12/10/2019 < 1 0.5
15 1/9/2020 < 1 0.5
16 2/21/2020 < 1 0.5
17 3/17/2020 < 1 0.5
18 4/21/2020 < 1 0.5
19 5/19/2020 < 1 0.5
20 6/15/2020 < 1 0.5
21 7/7/2020 < 1 0.5
22 8/12/2020 < 1 0.5
23 10/14/2020 < 1 0.5
24 1/12/2021 5.89 5.89
25 4/20/2021 2.5 2.5
26 7/20/2021 1.98 1.98
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
1.9541
1.1873
1.6458
26
1.60
9.0 pg/L
14.4 pg/L
-9-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par19
Selenium
Date Data BDL=1/2DL Results
1 5/18/2017 < 10 5 Std Dev.
2 7/11/2017 11 11 Mean
3 10/5/2017 < 10 5 C.V.
4 1/25/2018 < 10 5 n
5 4/19/2018 < 10 5
6 7/19/2018 < 10 5 Mult Factor =
7 10/9/2018 < 10 5 Max. Value
8 1/29/2019 < 10 5 Max. Pred Cw
9 4/11/2019 < 10 5
10 7/15/2019 < 10 5
11 9/24/2019 < 10 5
12 10/15/2019 < 10 5
13 11/13/2019 < 10 5
14 12/10/2019 < 10 5
15 1/9/2020 < 10 5
16 2/21/2020 < 10 5
17 3/17/2020 < 10 5
18 4/21/2020 < 10 5
19 5/19/2020 < 10 5
20 6/15/2020 < 10 5
21 7/7/2020 < 10 5
22 8/12/2020 < 10 5
23 10/14/2020 < 10 5
24 1/12/2021 1 1
25 4/20/2021 2.5 2.5
26 7/20/2021 1 1
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
1.7143
4.8269
0.3552
26
1.15
11.0 ug/L
12.7 ug/L
Date Data BDL=1/2DL Results
1 5/18/2017 < 1 0.5 Std Dev.
2 7/11/2017 < 1 0.5 Mean
3 10/5/2017 < 1 0.5 C.V.
4 11/14/2017 1 1 n
5 1/25/2018 < 1 0.5
6 4/19/2018 < 1 0.5 Mult Factor =
7 5/2/2018 1 1 Max. Value
8 7/19/2018 < 1 0.5 Max. Pred Cw
9 10/9/2018 < 1 0.5
10 1/29/2019 < 1 0.5
11 4/11/2019 < 1 0.5
12 7/15/2019 < 1 0.5
13 9/24/2019 6 6
14 10/15/2019 < 1 0.5
15 11/13/2019 < 1 0.5
16 12/10/2019 < 1 0.5
17 1/9/2020 < 1 0.5
18 2/21/2020 < 1 0.5
19 3/17/2020 < 1 0.5
20 4/21/2020 < 1 0.5
21 5/19/2020 < 1 0.5
22 6/15/2020 < 1 0.5
23 7/7/2020 < 1 0.5
24 8/12/2020 < 1 0.5
25 10/14/2020 < 1 0.5
26 1/12/2021 < 1 0.5
27 4/20/2021 < 2.5 1.25
28 7/20/2021 < 1 0.5
29 10/11/2021 < 1 0.5
30 1/10/2022 < 0.5 0.25
31 4/13/2022 < 0.5 0.25
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
0.9995
0.7177
1.3925
31
1.39
6.000 ug/L
8.340 ug/L
-10-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par21
Zinc
Date Data BDL=1/2DL Results
1 5/18/2017 156 156 Std Dev.
2 7/11/2017 149 149 Mean
3 10/5/2017 12 12 C.V.
4 1/25/2018 26 26 n
5 4/19/2018 < 1 0.5
6 7/19/2018 < 1 0.5 MultFactor=
7 10/9/2018 9 9 Max. Value
8 1/29/2019 14 14 Max. Pred Cw
9 4/11/2019 25 25
10 7/15/2019 13 13
11 9/24/2019 42 42
12 10/15/2019 17 17
13 11/13/2019 54 54
14 12/10/2019 10 10
15 1/9/2020 157 157
16 2/21/2020 77 77
17 3/17/2020 89 89
18 4/21/2020 38 38
19 5/19/2020 21 21
20 6/15/2020 24 24
21 7/7/2020 54 54
22 8/12/2020 16 16
23 10/14/2020 38 38
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
Aluminum
48.5547
45.3043
1.0717
23
1.52
157.0 ug/L
238.6 ug/L
Date Data
1 7/11/2017 1010
2 1/25/2018 39
3 7/19/2018 119
4 1/29/2019 85
5 7/15/2019 423
6 9/24/2019 181
7 1/9/2020 604
8 7/7/2020 221
9 1/12/2021 160
10 7/20/2021 154
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
BDL=1/2DL Results
1010 Std Dev.
39 Mean
119 C.V.
85 n
423
181 MultFactor =
604 Max. Value
221 Max. Pred Cw
160
154
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points = 58
301.8588
299.6000
1.0075
10
2.31
1010.000000 pg/L
2333.100000 pg/L
-11-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par23
Antimony
Use "PASTE SPECIAL -Values" then
"COPY" . Maximum data points = 58
Date Data BDL=1/2DL Results
1 7/14/2016 15 15 Std Dev. 10.5040
2 10/26/2017 26 26 Mean 15.3333
3 4/19/2018 < 10 5 C.V. (default) 0.6000
4 n 3
5
6 Mult Factor = 3.00
7 Max. Value 26.000000 Ng/L
8 Max. Pred Cw 78.000000 Ng/L
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
-12-
26573 RPA 8.0.xlsm, data
7/28/2022

REASONABLE POTENTIAL ANALYSIS
Par24
Dimethylphthalate
Date Data BDL=1/2DL Results
1 7/14/2016 5.43 5.43 Std Dev.
2 10/26/2017 < 10.3 5.15 Mean
3 4/19/2018 < 10 5 C.V. (default)
4 n
5
6 Mult Factor =
7 Max. Value
8 Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL -
Values" then "COPY" .
Maximum data points - 58
Par25
Methyl Bromide
0.2183
5.1933
0.6000
3
3.00
5.430000 pg/L
16.290000 pg/L
Date Data BDL=1/2DL Results
1 7/14/2016 < 5 2.5 Std Dev.
2 10/26/2017 5.49 5.49 Mean
3 4/19/2018 < 5 2.5 C.V. (default)
4 n
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL.
Values" then "COPY"
. Maximum data
points = 58
1.7263
3.4967
0.6000
3
Mult Factor = 3.00
Max. Value 5.490000 pg/L
Max. Pred Cw 16.470000 pg/L
-13-
26573 RPA 8.0.xlsm, data
7/28/2022

Date: 7/28/2022
Dissolved to Total Metal Calculator
I Facility Outfall 001
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
IM
d � M
w 2 Q E 6
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
PARAMETER
M
00
CD
03
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CO
03
CO
CO
Z
N
CO
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03
9
E
E
m
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N
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0
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0
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U
a
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N
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data direct!
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This calculator has been inserted into the RPA to calculate Total
O
CD
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m
M

tal Translators
/95% Confidence U
95% Probabilit
Freshwate
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 2. Parameters of Concern
Table 1. Project Information
E
CHECK IF HQW OR ORW WQS
J
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7
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7
J
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O
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LO
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LO CO
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952.9963
O
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11.1123
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81.0331
353.5552
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132.5961
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3.1226
38.9397
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132.5579
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z
z
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z
z
z
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z
z
z
z
z
z
z
z
z
z
z
z
z
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Aquactic Life
Human Health
Water Supply
Aquatic Life
Aquatic Life
Water Supply
Water Supply
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Water Supply
Aquatic Life
Water Supply
Aquatic Life
Aquatic Life
Aquatic Life
Water Supply
Water Supply
Water Supply
Water Supply
U
a)
N
Q
Arsenic
E
2
l)
Cadmium
Chlorides
Chlorinated Phenolic Compounds
Total Phenolic Compounds
E
-
E
0
0
Chromium VI
Chromium, Total
Copper
Cyanide
N
U
j
—
Lead
Mercury
Molybdenum
Nickel
Nickel
E
C
a)
N
U)
>
=
O
C
N
Aluminum
c-c
UE
C
Q
a)
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Q
_Ct
N
E
0
Methyl Bromide
N M W CD N. CO W 0 N CO Cr LC) O N- CO W O N CO Tr 0
O O O O O O O O N N N N N N
f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6
0-
Catawba River Pollution Control Facility
NC0026573
0
0
LC)
0
Rhodhiss Lake (Catawba River)
0
O
0
0
Facility Name
WWTPIWTP Class
NPDES Permit
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Apply WS Hardness WQC
Eirri
O
0
0
W
O
0
O
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0
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36.23 mg/L (Avg)
J
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E
N
J
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E
co
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N
J
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E
co
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N
Effluent Hardness
Combined Hardness Acute
a)
L
0
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0
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J
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NC0026573
RECOMMENDED ACTION
No - RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than pollutant scan (PS)
Limited Dataset (n<8 samples). Predicted Max> 50%
of Allowable Cw. No detects (Max PQL 20 pg/L).
Pr- edicted Max< 50% of Allowable Cw. No detects
(Max PQL 2.5 pg/L)
L- imited Dataset (n<8 samples). Predicted Max < 50%
of Allowable Cw - No Monitoring required, other than
PS
S- ee Chromium, Total
S- ee Chromium, Total
a: No monitoring required other than PS if all Total
Chromium samples are < 5 pg/L or Pred. max for
Total Cr is < allowable Cw for Cr VI.
R- P exists. Predicted Max > Allowable Cw, 1 values >
allowable Cw - Add monthly monitoring and limit
REASONABLE POTENTIAL RESULTS
it Det. Max Pred Cw Allowable Cw
Acute (FW): 2,349.9
Chronic (FW) 1,237.E
MaxMDL = 10
Chronic (IIII) 661.3
Max MDL = 10
i
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Acute: 23.657
Chronic: 5.06E
Max MDL=2.5
Acute: NO WQS
Chronic: 300.0
Max MDL = 10
Acute: 6,586.7
Chronic: 1,014.5
Acute: 110.6
Chronic: 90.8 — —
towable Cw
Max reported value = 2.5
Acute: 76.80
Chronic: 68.03—
1 value(s) > Allowable Cw
5.8
NO DETECTS
30.00
C.V. (default)
NO DETECTS
1.838
NO DETECTS
31.0
C.V. (default)
NO DETECTS
M
4
5
M °
z 7 J
v
\
_
3 0
Note: n <9
Limited data set
_
1 0
Note: n <9
Limited data set
_
°
To
\ °
m
m_
\
\
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\
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NC STANDARDS OR EPA CRITERIA
Chronic Applied Acute
Standard
150 FW(7Q10s) 340
10 IIII/WS(Qavg)
6.5 FW(7Q10s) 65
0.6140 FW(7Q10s) 3.4228
cq
122.9586 FW(7Q10s) 952.9963
11 FW(7Q10s) 16
8.2460 FW(7Q10s) 11.1123
§
0
0
z
z
z
z
z
z
z
PARAMETER
Arsenic
Arsenic
Beryllium
Cadmium
Total Phenolic Compounds
Chromium III
Chromium VI
Chromium, Total
Copper

N
L
8
N
C1
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Gl
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NC0026573
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
No RP, Predicted Max < 50 % of Allowable Cw. All
values reported non -detect - No Monitoring required
other than PS
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
- ---------------------------
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
Pr- edicted Max > Allowable Cw, 28 values > allowable
Cw - Add monthly monitoring. Method with lowest
PQL must be used
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
RP exists. Predicted Max > 50% Allowable Cw - Add
monthly monitoring
L- imited dataset. Predicted Max > Allowable Cw- Add
quarterly monitoring. Method with lowest PQL must
be used
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
Acute: 152.1
Chronic: 41.3
No value > Allowable Cw
Acute: 560.062
Chronic: 25.762 --
Max MDL = 10
Acute: NO WQS
- Chronic: 1,320.1
No value > Allowable Cw
Acute (FW): 2,443.6
Chronic (FW): 321.3
No value > Allowable Cw _
Chronic (WS) 206.3
No value > Allowable Cw
Acute: 387.0
Chronic: 41.3
No value > Allowable Cw
Acute: 2.283
Chronic: 0.495
28 value(s) > Allowable Cw
Acute: 916.4
- Chronic: 1,093.7
No value > Allowable Cw
Acute: NO WQS
Chronic: 3135.146
No value > Allowable Cw
Acute: NO WQS
Chronic: 46.20215
No value > Allowable Cw
Acute: NO WQS
Chronic: 16500.76805
No value > Allowable Cw
Acute: NO WQS
- Chronic: 825.03840
No value > Allowable Cw
5.550
NO DETECTS
O
s.
O
N
od
,.D
N
O
O
O
O
M
M
M
N
78.00000
C.V. (default)
16.29000
C.V. (default)
16.47000
C.V. (default)
-_.
O
00
M
,o
,o
N
7
,o
M
co
N
N
M
O
O
-�
3 2
Note: n<9
Limited data set
3 1
Note: n<9
Limited data set
3 1
Note: n<9
Limited data set
aN
aN
a a
aN
aN
a
a
O
5 FW(7Q10s) 22
3.1226 FW(7Q10s) 81.0331
0
a
O
,a
38.9397 FW(7Q10s) 353.5552
25.0000 WS(7Q10s)
5 FW(7Q10s) 56
0.06 FW(7Q10s) 0.3303
132.5579 FW(7Q10s) 132.5961
0
a
O
000
M
0
a
`p
0
a
00
O N
0
a
O
0
z
0
z
0
z
0 0
z z
0
z
0
z
0
z
0
z
0
z
0
z
0
z
a
a
m
U
a
a
J
Molybdenum
a a
u u
Z Z
£
3
a
N
co
N
N
Aluminum
c
£
.%
Dimethylphthalate
Methyl Bromide

Date: 7/28/2022
Dissolved to Total Metal Calculator
I Facility Outfall 001
In accordance with Federal Regulations, permit limitations must be written as Total Metals per 40 CFR 122.45(c)
IM
d � M
w2Q E f0
= m E I0
a= $ N
N Jo
3 7 N
Z � O
m
N
M
COMMENTS (identify parameters to PERCS Branch to maintain in facility's LTMP/STMP):
PARAMETER
CD
CD
06
Z
O
CD
CD
O
03
co
9
E
E
m
U
N
0,
N
co
E
0
I
a
U
rn
E
E
L
U
O
E
E
t
U
E
E
t
U
L
a
O
U
uo
Lo
L
TD
U
00
E
N
Z
.d.
a
w
W
W
O
CO
M
O
CD
O
CD
O
E
m
Dissolved to Total Metal Calculator
data direct!
Do NOT enter an
This calculator has been inserted into the RPA to calculate Total

tal Translators
/95% Confidence U
95% Probabilit
Freshwate
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 2. Parameters of Concern
Table 1. Project Information
E
CHECK IF HQW OR ORW WQS
J
O)
7
J
o)
7
J
O)
7
J
O)
7
J
i)
E
J
O)
7
J
O)
7
J
O)
7
J
O)
1
J
O)
1
J
O
7
J
O
7
J
O
7
J
O
7
J_
a)
C
J
O)
3
J
O)
1
J
O)
1
J
O)
7
J
O)
7
J
O)
7
J
O)
1
J
O)
1
J
O)
1
J
O)
1
O
Ln
O
O
M
N/A
in
O
3.4587
962.3658
coO
Q
Z
O
CO
N
N
N
82.1292
357.1464
Q
Z
CO
Ln
N
r
M
CO
O
133.9450
L3
L
i
2
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LL
>
LL
>
Q
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LL
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LL
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LL
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0.6189
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N—O
300
124.0154
z
8.3199
in
1,800
3.1595
39.2855
25.0000
in
CO
O
Oco
133.7367
Lb
o
o
0
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
Aquactic Life
Human Health
Water Supply
Aquatic Life
Aquatic Life
Water Supply
Water Supply
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Water Supply
Aquatic Life
Water Supply
Aquatic Life
Aquatic Life
Aquatic Life
Water Supply
Water Supply
Water Supply
Water Supply
U
a)
N
Q
Arsenic
E
2
l)
Cadmium
Chlorides
Chlorinated Phenolic Compounds
Total Phenolic Compounds
EN
_
E
O
t
0
Chromium VI
Chromium, Total
Copper
Cyanide
U
o
—
Lead
Mercury
Molybdenum
Nickel
Nickel
E
o
a)
N
U)
>
=
o
N
Aluminum
c-c
U E
C
Q
a)
a)
!Z
t
N
E
0
Methyl Bromide
N M W CD N. CO W 0 N M V 0 O N CO W 0 N M et 0
O O O O O O O O N N N N N N
f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6 f6
a a a a a a a a a a a a a a a a a a a a a a a a a
Catawba River Pollution Control Facility
NC0026573
0
O
0
O
Rhodhiss Lake (Catawba River)
0
O
0
0
Facility Name
WWTPIWTP Class
NPDES Permit
Flow, Qw (MGD)
Receiving Stream
HUC Number
Stream Class
Apply WS Hardness WQC
Eirri
O
0
0
W
O
O
O
O
O
co
O
N
0)
V! w in
c,) u w 3
u w ....
O • O N u O
36.23 mg/L (Avg)
Effluent Hardness
Combined Hardness Acute
2 `O
a)
7 • aa
( U
Q)
U
0
as
(V N
0 N O
co U
O
0 .O
I` i
Q
0 O
r
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o 2
z
a)
L
0
co
R
0
0
J
U
U
>
L
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E
a)
(6
L
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L
a)
E
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E
a)
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0
O
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0
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0
0
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0
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:
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Freshwater RPA
NCOO26573
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■
Effluent Hard: 0 value > 100 mg/L
Effluent Hard Avg = 36.23 mg/L
RECOMMENDED ACTION
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required, other than pollutant scan (PS)
L- imited Dataset (n<8 samples). Predicted Max>
50% of Allowable Cw. No detects (Max PQL 20
pg/L).
Pr- edicted Max< 50% of Allowable Cw. No detects
(Max PQL 2.5 pg/L)
L- imited Dataset (n<8 samples). Predicted Max <
50% of Allowable Cw - No Monitoring required, other
than PS
See Chromium, Total
See Chromium, Total
a: No monitoring required other than PS if all Total
Chromium samples are < 5 pg/L or Pred. max for
Total Cr is < allowable Cw for Cr VI.
R- P exists. Predicted Max > Allowable Cw, 2 values
> allowable Cw - Add monthly monitoring and limit
REASONABLE POTENTIAL RESULTS
11 # Det. Max Pred Cw Allowable Cw
Acute (FW): 1,963.4
Chronic (FW): 1,028.4
MaxMDL= 10____ _ ___
Chronic (HH): 536.1
Max MDL = 10
Acute: 375.35
Chronic: 44.56
Max MDL = 20
Acute: 19.973
Chronic: 4.243
Max MDL=2.5
Acute: NO WQS
Chronic: 300.0
Max MDL = 10
Acute: 5,557.4
Chronic: 850.3
Acute: 92.4
Chronic 75.4
towable Cw
Max reported value = 2.5
Acute: 64.90
Chronic: 57.04
2 value(s) > Allowable Cw
5.8
NO DETECTS
30.00
C.V. (default)
NO DETECTS
1.838
NO DETECTS
31.0
C.V. (default)
NO DETECTS
M
z
5
M
z I %
v
F.
\
3 0
Note: n < 9
Limited data set
1 0
Note: n < 9
Limited data set
Tot Cr valu
26 6
cq
&4n
\ 0
0
0
0
\
\
\
0
,d
NC STANDARDS OR EPA CRITERIA
Chronic Applied Acute
Standard
150 FW(7Q10s) 340
10 HH/WS(Qavg)
o
CZ
/
W
0.6189 FW(7Q10s) 3.4587
0
rn
124.0154 FW(7Q10s) 962.3658
11 FW(7Q10s) 16
8.3199 FW(7Q10s) 11.2380
w
u u
0
z
0
z
0
z
0
z
0
z
0
z
0
z
PARAMETER
Arsenic
Arsenic
E
!
Cadmium
Total Phenolic Compounds
Chromium III
Chromium VI
Chromium, Total
Copper
CN
{Ci
(
CNI

L
0
U)
LL
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0
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0
U
0
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CD
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N
U
NCOO26573
N- o RP, Predicted Max < 50% of Allowable Cw No
Monitoring required other than PS
No RP Predicted Max < 50 % of Allowable Cw. All
values reported non -detect - No Monitoring required
other than PS
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
N- o RP, Predicted Max < 50% of Allowable Cw No
Monitoring required other than PS
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
Pr- edicted Max > Allowable Cw, 28 values >
allowable Cw - Add quarterly monitoring. Method with
lowest PQL must be used
No RP, Predicted Max < 50% of Allowable Cw - No [
Monitoring required other than PS
RP exists. Predicted Max > 50% Allowable Cw - Add
quarterly monitoring
Limited dataset. Predicted Max > Allowable Cw- Add
quarterly monitoring. Method with lowest PQL must
be used
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
N- o RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required other than PS
Acute: 127.0
Chronic: 34.3
No value > Allowable Cw
Acute: 474.271
Chronic 21.662
Max MDL = 10
Acute: NO WQS
Chronic 1,097.0
No value > Allowable Cw
Acute (FW): 2,062.4
Chronic (FW): 269.3
No value > Allowable Cw
Chronic (WS): 171.4
No value > Allowable Cw
Acute: 323.4
Chronic: 34.3
No value > Allowable Cw
Acute: 1.947
Chronic: 0.411
28 value(s) > Allowable Cw
Acute: 773.5
Chronic: 916.9
No value > Allowable Cw
Acute: NO WQS
Chronic 2605.310
No value > Allowable Cw
Acute: NO WQS
Chronic 38.39404
No value > Allowable Cw
Acute: NO WQS
Chronic: 13712.15881
No value > Allowable Cw
Acute: NO WQS
Chronic 685.60794
No value > Allowable Cw
5.550
NO DETECTS
O
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N
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78.00000
C.V. (default)
16.29000
C.V. (default)
16.47000
C.V. (default)
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160 WS(7Q10s)
39.2855 FW(7Q10s) 357.1464
25.0000 WS(7Q10s)
CZ
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s
0.06 FW(7Q10s) 0.3372
133.7367 FW(7Q10s) 133.9450
380 WS(7Q10s)
5.6 WS(7Q10s)
2000 WS(7Q10s)
100 WS(7Q10s)
0
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Dimethylphthalate
Methyl Bromide

Date: 7/28/2022
Dissolved to Total Metal Calculator
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data direct!
Do NOT enter an
This calculator has been inserted into the RPA to calculate Total

City of Morganton/Catawba River Pollution Control Facility
NC0026573
N O oo c I N oo N N to N O to oo r1 m r\ Ol oo d- m% -1 N 00 Ol
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February-20
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October-20
November-20
December-20
January-21
February-21
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NH3/TRC WLA Calculations
Facility: City of Morganton/Catawba River Pollution Control Facility
PermitNo. NC0026573
Prepared By: Diana Yitbarek
Enter Design Flow (MGD): 8
Enter s7Q10 (cfs): 118
Enter w7Q10 (cfs): 118
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/l)
Less stringent than current permit limit.
Maintain limit at 28 ug/I to protect for
acute toxicity.
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Maintain 200/100 ml MA limit
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/I)
118 s7Q10 (CFS)
8 DESIGN FLOW (MGD)
12.4 DESIGN FLOW (CFS)
17.0 STREAM STD (MG/L)
0 Upstream Bkgd (mg/I)
9.51 IWC (%)
179 Allowable Conc. (mg/I)
Current year-round MA limit 16.0 mg/I based
on the 1994 water quality model.
2021 Update: MA summer limit, 8.4 mg/I
WA summer 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)
10.52 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
2021 Update: MA winter limit, 16.8 mg/I
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/1 to protect for acute toxicity
WA summer conc., mg/I
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
118
8
12.4
1.0
0.22
9.51
8.4
118
8
12.4
1.8
0.22
9.51
16.8
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

NH3/TRC WLA Calculations
Facility: City of Morganton/Catawba River Pollution Control Facility
PermitNo. NC0026573
Prepared By: Diana Yitbarek
Enter Design Flow (MGD):
Enter s7Q10 (cfs):
Enter w7Q10 (cfs):
10.5
118
118
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)
Less stringent than current permit limit.
Maintain limit at 28 ug/I to protect for
acute toxicity.
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Maintain 200/100 ml MA limit
118
10.5
16.275
17.0
0
12.12
140
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)
Maintain
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/I)
w7Q10 (CFS)
200/100m1 DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
8.25 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Maintain
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/1 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
118
10.5
16.275
1.0
0.22
12.12
6.66
118
10.5
16.275
1.8
0.22
12.12
13.3
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

NH3/TRC WLA Calculations
Facility: City of Morganton/Catawba River Pollution Control Facility
PermitNo. NC0026573
Prepared By: Diana Yitbarek
Enter Design Flow (MGD): 13
Enter s7Q10 (cfs): 118
Enter w7Q10 (cfs): 118
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/l)
Less stringent than current permit limit.
Maintain limit at 28 ug/I to protect for
acute toxicity.
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Maintain 200/100 ml MA limit
118
13
20.15
17.0
0
14.59
117
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)
6.86 Upstream Bkgd (mg/I)
IWC (%)
Allowable Conc. (mg/I)
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/1 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
118
13
20.15
1.0
0.22
14.59
5.6
118
13
20.15
1.8
0.22
14.59
11
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

m
J J
0 \ \
N 0A 0.0
C C
MERCURY WQBEL/TBEL EVALUATION
No Limit Required
MMP Required
0
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0
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W
CO
O
O O
O O
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-1
Cf
Permitted Flow =
ng/L - Annual Average for 2019
ng/L - Annual Average for 2020
ng/L - Annual Average for 2021
▪ % -1 Ol ▪ N Ol Ol 00 l0 00 l0 N N N % -1 l0
Ol O I� LC) m % -1 m Cr) N O O % -1
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▪ c-I Ol c-I N Ol Ol 00 00 i--1 l0 N N I� ci l0
% -1 N N 01 O m m N O O c-I
c-I m c-I c-I c-I c-I c-I N c-I c-I c-I T -1
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c-I c-I c-I c-I c-I c-I N N N N N N N N N N N N N
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# of Samples
J
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H
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m
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Whole Effluent Toxicity Testing and Self Monitoring Summary
V
O
V
0
Jan Apr Jul Oct
Basin: CTB31
PF: 13 IWC: 8.96
NC0026573/001
Morganton -Catawba R. PCF
NonComp: Single
chr lim: 9% @ 8MGD;
Oa a a
Q a1/41
a a
LL
a
n ca m o
0 0 0 0 0
Jan Apr Jul Oct
m
Mecklenburg
CO.
C
O
V
0
Z
Cerio24PF Lim: 90%
Oa a a
z
z
LL
CO m o
0 0 0 s o
V
O
V
0
v
Jan Apr Jul Oct
co
d
V
ro
CO
NC0022209/001
Motiva Enterprises LLC-Greensboro
Acu Fthd 24 PF Lim:
O
z
LL
n a m o
0 0 0 0 0
V
O
VI
0
v
MarJun Sep Dec
NC0022217/001
Motiva Enterprises LLC-Wake
O
O
0
r-1
24hr LC50 ac monit e
0
O
N
a-1
N
a -1
61
U
N
-17
LL
O
z
n a m o
0 0 0 0
V
O
VI
0
v
Jan Apr Jul Oct
cn
m
ro
m
O
2
O
U1
OC
NC0022187/001
Motiva Enterprises -Paw Creek
0
O
N
n
Cerio 24 PF Lim @ 90
Begin: 9/1/2015
Oa a
z
LL
Page 76 of 120
Legend: P= Fathead minnow (Pimphales promelas), H=No Flow (facility is active), s = Split test between Certified Labs

A
B I C ID E F I G I H 1 d I K I L IM
N I 0 I P
1
2
NPDES/PT POC Review Form
1. Facility's General Information
vn 20..04
3
Date of(draft)R Review
10/20/2021 (1st) 4/6/2022 (2nd)
c_ POC review due to:
e Contact Information
4
Date of(final)Review
7/21/2022
Municipal NPDES renewal
❑+
Regional Ofiice(RO) I0O
NPDES PermtWaer(pw)
Diana Yilbarek
New Industries
❑
RO PT Staff I stephanie.williamskoncdenr.Wv
I RONPDESStaff I stephaniewilliamskoncdenr.00v
5
6
Permillee-Facility Name
City a Morganton - Catawba River Pollution
Cantrot Facility
WWTPexpansim
❑
Facility PT Staff, email I)arnevGmoraantonnr
cm,
]
NPDES Permit Number
NC00265]3
Stream rectssladjustment
0
f. Receiving Stream
8
NPDES Permit Effective Date
5/1/2016
0.11 relocation/adjustment
❑
Ouffalll
9
NPDES Perrot Renewal Application
Date
9/3/2019
7Q10 update
❑'
Receiving Stream:
Catawba river
QA, cfs
1060
10
NPDES Permit Public Notice Bate
10/28/2021
Other, .plain below
0
Stream Class
WSN' CA
7Q10 (5), cfs
116
11
eDMR data evaluated from:
1/12016 1 to 7/30/2021
OO11me"ts on POC review trigger
Outll tat
SS 46428 N
00000 Long.
81.30335"W
12
a_ WWTP Capacity Summary
7010 was updated from 126 cub c feet Per
Outfall II
13
Current Permitted Flow, mgd
8.0 Im,Oesgnetl Flow, 80
second (cfs) to 118 cfs for the 8.0 MOO flaw
tier in 10/2021
0010,0ng Stream:
NA
QA, cfs
NA
14
Permiged SIU Flow, mgd
36
tl_ IU Summary
Stream Class
NA
7Q10, cfs:
NA
15
b_ PT Dots_ Summary
# IUs
Oda!! tat.
NA
00n11 Sons.
NA
16
IWSapproval date
10/24/2017
#SMs
3
Isthere a PWSdownstream of the FacilTy'souffa115! I ❑' YES ❑ NO
17
USTMP approval date:
3/1212005
#GUs
0
Comments:
18
#NSOUs
0
PwsNc0tt20t0 is bratedaboul5]miksfroa, ourcall.
19Types
HWA approval date
3/21/2014
# IUs w/Local
Permits or Other
0
20 r.
2. Industrial
Useri Information.
E
21 a#
Industrial User (IU)Name
IUAciivty
IUGonventional
Pollutants
IUNm Conventional P011utansBToxic Pollutant
IUP Effective Date
zz w
Case Farms
chicken
BOB,
T., pH, oil grease
CCM,amnona
v3n20r6
23 1-Seun
NUM AmerKa
Tex.BM,
COD, chrorrium, copper, nickel,phenol, selenium(monitor), zinc, PEAS
3/312017
24
UNIX Packaging LLC
Beverage
BM -MS, pH
COD
6/1.021
31
32
Comment The division recommendsasse
sing ammonia load from Case Farmland
PEAS from Steven
3. Comments from NPDES pw
33
Facility
Summary, background information,
and NPDES regulatory action:
Comments from NPDES pw to PT staff (Central, R0, Facility)_
34
The
Control
City of Morganton applied for NPDES permit
Facility in September 2019. The Facility
renewal for the Catawba River Pollution
had a design capacity of 10.5 MOO (there
Poo that are recommended to be
added/modified in USTMP
TN, TP, Phenols, Alumni., Antimony, PEAS
35
ae ongoing
8r0 MG0
conversations about this capacity)
(up to 10.5 MOO and 13.0 MOO upon
and is currently authorized to discharge
request) into the Catawba River.
ORC'scommentson IU/POC:
Provided recent data from Case Farms
36
Additionalpollutantsconcerns added to t/STMP due
to POIWs concerns:
None
37
NPOES pv's comments on IU/POG
None
38
4. Status of Pretreatment Program (check all that apply)
39
Status
of Pretreatment Program (check all
that apply)
40
41
42
43
44
45
46
la
0
la
❑'
❑
la.
1) facility has no SIU's, does have Division
2) facility has no SIU's, does not have
3) facility has Sills and OWQ approved
3a)Full Program with LTMP
3b) Modified Program with STMP
4) additional canditians regarding Pretreatment
5) facility's sludge is being land applied
approved Pretreatment Program that is INACTIVE
Division approved Pretreatment Program
Pretreatment Program
attached or listed below
or composted
47
48
la.
❑
6) facility's sludge is incinerated (add Beryllium
7) facility's sludge is taken to a landfill,
and Mercurysam piing according to § 50343)
Ryes which landfill_
49
■
8) other
50
51
52
Sludge Disposal Plan:
The City of Morganton util¢es composting as it' s method of disposal of municipal sewage dosolids. If solids do not meet requirements to be sold to the pudic the material is re- instated into the
mixing process and put back on a bed to cure again. If more material is on site than the Facility can handle, the excess material will be disposed of in the landfill.
53
Sludge Permit No:
W00002127
54
55
PW: Find LJSTMP document, HWA spreadsheet, DMR, previousand new NPDES permit for next section.
56
0
OO
Parameter of Concern
(POC) Check List
New
NPDES
POC
Previous
NPDES
POC
Required by
EPA PT(1)
POC due to
Sludge (2)
POC due to
SIU (3)
POTW
POC (4)
%
Removal
Rate
USTMP
Effluent Freq
NPDES
Effluent Freq
PQLs review
Comment
5]
a
PQL from
L/STMP, ug/I
Required PQL
per NPDES
permit
Recomm.
POL, ugll
58
0
Flow
0
0
0
❑
59
0
BOD
L:I
0
0
❑
2000.0
60
0
TSS
0
0
0
❑
2000.0
61
0
NH3
0
0
0
❑
Joao
62
0
Arsenic
0
❑
❑
❑
❑
10.0
2.0
Recomm. Updating POL to 2.0 ug/L
63
❑
Barium
0
❑
0
❑
❑
fi4
0
Beryllium(5)
0
❑
0
0
❑
65
❑+
Cadmium(1)
0
0
'❑
0
0
❑
2.0
os
Recom . updating POLto63 ug/L
66
0
Chromium (1)
❑
❑
3
0
❑
❑
5.0
100
67
❑'
Copper(1)
0
❑'
❑'
0
0
❑
2,0
2.0
68
0
Cyanide
0
❑
0
0
0
10.0
69
❑+
Lead(1)
0
0
0
0
0
0
10.0
2.0
Recomm. Updating POL to 2.0 ug/L
70
0
Mercury(5)
❑
❑
❑+
❑
❑
0.001
0.001
71
0
Molybdenum
❑
0
0
0
0
100.0
100
Recomm Updating PDLto10.0 ug/L
72
❑v
Nickel(1)
❑
❑
0
0
0
❑
10.0
5.0
Recomm. Updating PQL to 5.0 ug/L
73
❑'
Selenium
❑
❑
0
0
❑
10.0
74
❑'
Silver
0
0
0
❑
❑
5.0
1.0
Must update POLto 1.0 ug/L
75
L7
Zinc(1)
❑
❑
0
❑+
0
❑
_0/
12.0
76
0
Sludge Flow to Dispose
0
0
❑
77
0
% Solids to Disposal
❑+
❑
❑
48
L7
Oil a Grease
0
❑
49
0
TN
❑+
❑+
❑
❑
Recomm. Adding g to LIMP
80
❑'
TP
L7
0
❑
0
Recomm. Adding g to LIMP
81
❑+
Total Phenols
❑
❑
0
0
Recomm. Adding a to LIMP
82
❑'
Aluminum
0
❑
❑
❑
Recomm. Adding 0 to LIMP
83
❑'
PFAS
0
0
0
0
Recomm. Adding 0 to LIMP
84
❑'
Antimony
0
❑
0
0
Recomm. Adding g to LTMP
85
9
0
0
0
0
86
❑
0
❑
0
0
87
❑
0
❑
0
0
ea
8
90
91
92
93
94
95
97
98
Footnotes:
(1)Ahvays in the LTM%STMP due to EPA -PT requi emnt
(2) Only in LTMP/STMP R listed in sludge permit
(3) Only in LTMP/STMP while SIU stilldisehargest° POTW
(4)Only in LTMPSTMP when pollutant is stillof concern to POTW
(5) In LTM%STMP, if sewage sludge is incinerated
Please use bluefont forthe info updated by pw
Please use red font for POC that are recommended to be added to the USTMP sampling plan
.1131ue shaded cell(D58:Ha]): Parameters usually included under that POC list
99 IIIIIIIII - 6. Pretreatment updates in response to NPDES permit renewal
100 NPOES Permit Effective Date 9/1420221180 days after effective (date): I 2/28/2023I Permit write, please add list of required/recommended PT updates in NPDES permit cover letter_
Page 1
26573 POC Review Form xlsm

Pretreatment Program Info Database
for Program Name Morganton
WWTP Name City of Morganton
Program Approval Date
Pretreatment Status
Region
County
NPDES Number
NPDES Effective Date
NPDES Expire Date
POTW is Primary WWTP
Design Flow mgd
WWTP SIU's
WWTP CIU's 0
3
date Inactive
07/01/1983
Full
ARO
Burke
NC0026573
05/01/2016
02/29/2020
TRUE
10.5000
Program SIUs
Program ClUs
printed on: 10/6/2021
Stream Information
7Q10 Flow cfs / mgd
1Q10 Flow cfs / mgd
Stream Classification
IWC % at 7Q10 12.11
118
96.21
WS-IV
/ 76.23
/ 62.18
Basin Number CTB31
Receiving Stream Name CATAWBA RIVER
Last PAR Rec 02/19/2021
Current Fiscal 05/08/2019
Year PCI Done
Last Audit on 05/13/2015
13/0 Design mgd is SIU permitted
13 I
0
34.70
PAR Due Date 03/01 /2022
Audit Year Next19/20
Permitted SIU flow (mgd) [Pt_SIU) 11411
mercury
1631
required
yes
HWA LTMP � IWS SUO ERP �1
Date Next Due
06/01/2022
Date Received by DWR
12/29/2020
08/11/2005
06/05/2017
03/06/2013
12/16/2019
Date Approved
08/12/2005
10/24/2017
03/28/2013 02/05/2020
Adopt Date Required
Date Adopted
03/04/2013
Info in this Box from Pt Contacts
PT_Pro
g.Prime
Formal Name
Phonel
ext
Fax
Date Date Date
Attended Attended Attended
HWA Wksp IUP Wksp PAR Wksp
Mr. Timothy Arney (Prim 11828-438-5376
I 1(828) 433-8593 II 1/30/2019 15/22/2019 11/29/2019
[e-mail]
Pretreatment Coordinator PO Box 3448
28680-3448
J
JPretreatment Related NOVs from DWQ
2/28/1997
NOD; 2/13/97 PCI; SUO corrections, flow data for an
DWR Central Office Contact
DWR Regional Contact
Keyes McGee
Linda Wiggs

EPA Identification Number
Pollutant (Required)
NPDES Number
NC0026573
Method Number
CAS number (if Applicable)
Facility Name
Catawba River Pollution Control Facility
Outfall Number
1
Reason Pollutant Believed Present in Discharge
There are No additional pollutants to be reported.
Estimated Concentration (If
Known)
g/e -AIA- i 1 --,
1
Eli Self - Superintendent & ORC Date

Blue Ridge Labs
POBox 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BILL #:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jut-16
16-Aug-16
14-Jul-16
BRL-2016-0543
Lab Sample ID: LSID-2016-01994
Client Sample ID: E0714M
t-s
Parameter
Ag
As
Cd
Cr
Cu
Ni
Pb
Sb
Se
Total Phosphorus
Zn
Hardness
Hg
Result MQL
Analysis Analysis
Unit Method Time Date Analyst
Reported By:
$ 0.001
* 0.01
* 0.0002
0.001 0.001
0.012 0.001
0.001 0.001
0.01
0.015 0.01
% 0.01
0.873 0.02
0.056 0.001
34.1 0.03
* 0.0001
A1!!f
S. ' l s h' nsan, D.R. Wessinger
mg/1 200.7 1994 13:08 7/21/2015 KCJ
mg/1 200.7 1994 13:08 7/21/2016 KCJ
mg/1 200.7 1994 13:08 7/21/2016 KCJ
mg/l 200.7 1994 13:08 712112016 KCJ
mg/1 200.7 1994 13:08 712112016 KCJ
mg/200.7 1994 13:08 7/21/2016 KCJ
mgll 200.7 1994 13:08 7/21/2016 KCJ
mg/1 200.7 1994 13:08 7/21/2416 KCJ
mg/1 200.7 1994 13:08 7/21/2015 KCJ
mg/1 200.7 1994 13:08 7/21/2016 KCJ
mg/1 200.7 1994 13:08 7/21/2016 KCJ
mg/1 234013 1997 13:08 7/21/2016 KCJ
mg/1 245.1 1994 13:05 8/3/2016 KCJ
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275 •
Page 2 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jul-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LSID-2016-01995
E0714TN
Analysis Analysis
Result MQL Unit Method Time Date
Nitrate + Nitrite Nitrogen (N2+
Total Kjeldahl Nitrogen (TKN)
Reported By:
3.88 0.08 mg/I 4500-NO3-E 15:40 7/28/2016
10.2 0.5 mg/1 4500-Norg B 11:15 7/28/2016
S. Jfhnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 3 of 15
Analyst
KCJ
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client : City of Morganton
P. O. Box 3448
Morganton, NC 28655
Attention: Ms. C. Benton
Date Received: 14-Jul-16
Report Date: 16-Aug-16
Sample Date: 14-Jul-16
BRL #: BRL-2016-0543
Lab Sample ID: LSID-2016-01996
Client Sample ID: E0714NH3
Analysis Analysis
Parameter Result MQL Unit Method Time Date Analyst
Ammonia Nitrogen 3.36 0.5 mg/1 SM4500 199 15:47 7/21/2016 KCJ
Reported By:
S. J. nson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 4 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client : City of Morganton
P. O. Box 3448
Morganton, NC 28655
Attention: Ms. C. Benton
Date Received: 14-Jul-16
Report Date: 16-Aug-16
Sample Date: 14-Jul-16
BRL #: BRL-2016-0543
Lab Sample ID: LSID-2016-01997
Client Sample ID: E0714TDS
Parameter
TDS
Analysis Analysis
Result MQL Unit Method Time Date Analyst
307 1 mg/1 2540C 1997 11:20 7/21/2016 KCJ
Reported By:
S. nson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 5 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client : City of Morganton
P. O. Box 3448
Morganton, NC 28655
Attention: Ms. C. Benton
Date Received: 1 4-Jul- 16
Report Date: 16-Aug-16
Sample Date: 14-JuI-16
BRL #: BRL-2016-0543
Lab Sample ID: LSID-2016-01998
Client Sample ID: E0714TL
Analysis Analysis
Parameter Result MQL Unit Method Time Date Analyst
Be 0.02 mg/1 EPA 200.7 12:22 7/26/2016 Summit
TI 0.02 mg/I EPA 200.7 12:22 7/26/2016 Summit
Reported By:
S. nson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 6 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
Date Received: 14-Jul-16
Report Date: 16-Aug-16
Sample Date: 14-Jul-16
BRL #: BRL-2016-0543
Lab Sample ID: LSID-2016-01999
Client Sample ID: E0714CN
Analysis Analysis
Parameter Result MQL Unit Method Time 7/21/2016te
Analyst
Rcj
Cyanide 0.005 0.005 mg/1 4500-CN-E 1 16:42
Reported By:
Johnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 7 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jul-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LSID-2016-02000
E0714624
Internal QC data on attached vendor report.
Parameter
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dichloropropylene
2-Chloroethylvinyl Ether
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon Tertachloride
Chlorobenzene
Ch Iorodibromomethane
Chloroethane
Chloroform
Analysis Analysis
Result MQL Unit Method Time Date Analyst
Reported By:
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.01 mg/I EPA 624 21:04 7/21/2016 Summit
0.05 mg/I EPA 624 21:04 7/21/2016 Summit
0.05 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit ,
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.00.5 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mgJ1 EPA 624 21:04 7/21/2016 Summit
S. J.( f1son, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 8 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jul-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LS1D-2016-02000
E0714624
Dichlorobromomethane
Ethybenzene
Methyl Bromide
Methyl Chloride
Methylene Chloride
Tetrachloroethene
Toluene
Trans-1,2-dichloroethene
Trichloroethene
Vinyl Chloride
Reported By:
Result MQL
Unit
Analysis Analysis
Method Time Date Analyst
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/I EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
0.005 mg/1 EPA 624 21:04 7/21/2016 Summit
S. hnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 9 of 15

° Labs
��l���������������������
PO Box 2940
Lenoir, NC 28645
828-728-0149
Attention:
Date Received:
Report Date:
Sample Date:
Lab Sample 00;
Client Sample ID:
City of Morganton
9.O.Box J44G
Morganton, NC 28655
Ms. C.Benton
l4-Jul'l6
|6-Aug-|6
|4-Jul-l0
BRL-2016'0543
LSlD'2018-02001
E0714625
Parameter
|2 n
1,2'Dich|ombcnzone
1,2'Diphenyl-hydruzinc
1,3'Didb|nmhznzeoo
1,4'DicNnrnbcnzcnc
2.4,6'Tcicblorup6ono|
2.4'Dioblorophcoo|
2.4'Dimedhy|yhono|
2.4'Dinitrnpheno|
2.4'Dindroto|ucnc
2,6'Diuk,otolucoo
2'ChlornoaphdhaJznc
2'C6kunybeoo|
2'rJitrophcno|
3.3''Dich|onvhcnzidinc
3`46cnzoOuommbone
4.6'Dinh,o'o'crcon|
Reported By:
Internal UCdata onattached vendor report.
Analysis Analysis
0ud Method Time Date Analyst
mg/1 EPA 625 I04 7/23/2016 Summit
mg/1 EPA 625 3:04 7/23/2010 Summit
mg/1 EPA625 9:04 7/23/2016 Summit
mg/1 EPA 625 3:04 7/23/2016 Summit
mQ/| EPA625 3:04 7/23/2016 Summit
mg/1 EPA625 3:04 7/23/2016 Summit
mg/1 BPA625 3:04 7/23/2016 Summit
mg/1 BBA625 3:04 7/23/2016 Summit
mg/1 EP&d25 3:04 7/23/2016 Summit
mg/1 E9&625 3:04 7/23/2016 Summit
m@/| BfA625 3:04 7/23/2016 Summit
m8/1 ElA625 3:04 7/23/2016 Summit
mg/1 EPA625 3:04 7/23/2016 Summit
mA/) EPA 625 3:04 7/23/2016 Summit
mg/1 GPA625 3:04 7/23/2016 Summit
mg/1 B9&625 3:04 7/23/2016 Summit
m@/| EPA625 3:04 7/23/2016 Summit
mg/1 EPA 625 3:04 7/23/2016 Summit
°Concentrations are below Minimum QoundficubooLimit except where noted.
NC Lubunurury Certificate No. 275
Page 10o[ 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jul-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LSID-2016-02001
E0714625
Analysis Analysis
Parameter Result MQL Unit Method Time Date Analyst
4-chlorophenyl phenyl ether 0.001 mg/I EPA 625 3:04 7/23/2016 Summit
4-Nitrophenol
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[g,h,i]perylene
Benzo[k]fluoranthene
bis (2-Chloroethoxy) methane
bis (2-Chloroethyl) ether
bis (2-Chloroisopropyl) ether
bis (2-Ethylhexyl) phthalate
Butylbenzylphthalate
Chrysene
Di-n-butylphthalate
Di-n-octylphthalate
Reported By:
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/l EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 ring/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/l EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
0.001 mg/l EPA 625 3:04 7/23/2016 Summit
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/l EPA 625 3:04 7/23/2016 Summit
0.001 mg/I EPA 625 3:04 7/23/2016 Summit
S. hnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 11 of 15

RidgeBlue Labs
PO Box2940
Lenoir, NC 28645
828-728-0149
b|uehdgeiQbS|eDnir@�rnmQi|.COrn
Attention:
Date Received:
City of Morganton
P.O.Box 3440
MorgantOD, NC 28655
Ms. C.Bcntoo
|4' ul-lh
|6-Aug'|6
)4-Jul-|O
B}QL'2016-0543
l.S[C-2016'02001
E0714625
Parameter Result MQL
Dibeoz[a,h]unthruccuc
Diethy|phda|mc
Dbmeth |phthalatu
F|unruothcno
F|uorcnc
Hrxucb|orohcnzeoc
8oxuch|ornhuzudieno
Hcxucb)nrncydupeotadion
Rcxach|nrnndhanc
lndeno[|.2.]'cd]py,cno
|xnphornnu
N'Y4i\ruyv'di'n'propylam ine
N'Nitrouodimuthylam ine
N'Nitrnmodiphcny|amino
Naphthalene
Nitrobenzene
p'Ch|opo'm'coon|
Pentachlorophenol
Reported By:
Analysis Analysis
Unit Method Time Date Analyst
* O.00| mg/l EPA &5 3:04 7/23/2010 Summit
* 0.001 mg/l EPA635 3:04 7/23/2816 Summit
0.00543 0.081 mg8 EPA625 3:04 7/23/2010 Summit
* 0.001 m&/| EPA025 3:04 7/23/2016 Summit
* 0.001 mQ/| EpA625 3:04 7/23/2016 Summit
* 0.001 mg/| EpA625 3:04 7/23/2016 Summit
* 0�00\ mg/| EPA 625 3:04 7/23/2016 Summit
* 0.001 mg/| BPA625 3:04 7/23/2016 Summit
* 0.001 m8/| EpA625 3:04 7/23/2016 Summit
* 0.001 m8/| EyA62S 3:04 7/23/2016 Summit
* 0.001 mg/| EPA 625 3:04 7/23/2016 Summit
* 0.001 m&/| EPA 625 3:04 7/23/2016 Summit
* 0.001 m8/| EPA 625 3:04 7/23/2016 Summit
* 0.001 mQ/| EPA625 3:04 7/23/2010 Summit
* 0.001 mg/| EPA625 3:04 7/23/2016 Summit
* 0.001 mg/| EPA625 3:04 7/23/2016 Summit
* O.00| mg/| EPA 625 3:04 7/23/2016 Summit
* 0.005 mg/| EPA 625 3:04 7/23/2016 Summit
S. J ;ri ouoo,D.R. Wessinger
°Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory CerbficateNo. %75
Page 12o[ 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Phenanthrene
Phenol
Pyrene
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Jul-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LSID-2016-02001
E0714625
Reported By:
Result MQL
Analysis Analysis
Unit Method Time Date Analyst
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
0.001 mg/1 EPA 625 3:04 7/23/2016 Summit
S. ohnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 13 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client : City of Morganton
P. O. Box 3448
Morganton, NC 28655
Attention: Ms. C. Benton
Date Received: 14-Jul-16
Report Date: 16-Aug-16
Sample Date: 14-Jul-16
BRL #: BRL-2016-0543
Lab Sample ID: LSID-2016-02002
Client Sample ID: E0714PL
Parameter
Phenols
Result MQL
Unit
Method Time
0.012 0.01
Reported By:
420.1 1978
Analysis Analysis
Date Analyst
17:14 7/28/2016 KCJ
S. J. JWnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 14 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
14-Ju1-16
16-Aug-16
14-Jul-16
BRL-2016-0543
LSID-2016-02003
E07140G
Parameter
Result MQL
Unit
Analysis Analysis
Method Time Date Analyst
Fats, Oil & Grease
3.1
Reported By:
mg/1 5520B 2001 15:29 7/27/2016
S. Johnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 15 of 15
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client
Attention:
Date Received:
Report Date:
Sample Date:
BRL 14:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. D. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov- I 7
26-Oct-17
BRL-2017-0889
LSID-2017-03441
E1026624
Paraineter
Rest] It
1,1,l-Trichloroethane
1,1,2,2-Tetrach loroeth asp e
1,1,2-Trichloroethane
1,1-Dichloroethane
1,1-Dich1oroethene
I ,2-Dichloraethane
1.2-Dichloropropane
1,3-Dichloropropylene
2•Chloroethylvinyl Ether
Acrolein
Acrvlonitrile
Benzene
Bromoform
Carbon Tertachloride
Chlorobenzene
Ch lorodibromomethane
Chloroethane
Chloroform
Reported Fly:
£eu &(1___
MQL Unit Method
0.005
0.005
0.005
0.005
0.005
0.005
0.005
0.005
0.01
0.05
0.05
0,005
0.005
0.005
0.005
0.005
0.005
0.005
me EPA 624
mgil EPA 624
mgil
mgil
mg/1
mg/1
mg/1
mg/1
mg,I
mg/1
mg/1
m gel
mgil
mg/1
mg/l
mg/1
mgf1
mgll
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
Analysis
Tim e
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
23:45
Analysts
Date Analyst
11/1/2017
11/1/2017
1 1/1/2017
11/1/2017
11/1/2017
3l'1/2017
11/1/2017
11/1/2017
11/1/2017
11/1/2017
11/112017
11/1/2017
11/1/2017
11/1/2017
111112017
11/1/2017
11/1/2017
11/1/2017
S A, ohnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 1 of 14
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summ it

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03441
E1026624
Dichlorobromomethane
Ethybenzene
Methyl Bromide
Methyl Chloride
Methylene Chloride
Tetrachloroethene
Toluene
Trans-1,2-dichloroethene
Trichloroethene
Vinyl Chloride
Reported By:
Analysis Analysis
Result MQL Unit Method Time Date Analyst
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
0.00549 0.005 mg/I EPA 624 23:45 11/1/2017 Summit
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
* 0.005 mg/l EPA 624 23:45 11/1/2017 Summit
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
* 0,005 mg/1 EPA 624 23:45 1 1/1/201 7 Summit
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
* 0.005 mg'1 EPA 624 23:45 1 1/1.201 7 Summit
* 0.005 mg/1 EPA 624 23:45 11/1/2017 Summit
S. eohnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 2 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Cyanide
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct- l 7
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03442
E1026CN
Reported By:
Analysis Analysis
Result MQL Unit Method Time Date Analyst
* 0.005 mgll 4500-CN-E 1 17:08 10/27/2017 KCJ
nson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 3 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
N2+N3
TKN
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct- ] 7
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03443
E 1026N
Result MQL
3.70 0.08
7.28 0.5
Reported By:
[e-mail]
Unit Method
me/1 SM194500-N 13:19
mg/1 SM 19 4500-N 13:03
Analysis Analysis
Time Date Analyst
10/27/2017
10/30/2017
S. L,1F6hnson, D.R. Wessinger
x Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 4 of 14
KCJ
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Ammonia Nitrogen
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03444
E1026NH3
Reported By:
Analysis Analysis
Result MQL Unit Method Time Date Analyst
1.26 0.5 mg/1 SM4500 199 9:35 10/3012017 KCJ
t����
S. J. 4, son, D.R. Wessinger
c
Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 5 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03445
E1026H
Parameter
Hardness
Reported By:
Result MQL
51.5 0.03
Unit Method
Analysis Analysis
Time Date Analyst
mg/1 2340B 1997 14:24 1 1/ 14/2017 KCJ
S. J /nson, D.R. Wessinger
4
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 6 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03446
E1026625
1,2,4-Trichlorobenzene
1,2-Dichlorobenzene
1,2-Diphenyl-hydrazine
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4.6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethvlphenol
2,4-Dinitrophenol
2.4-Dinitrotoluene
2,6-Dinitrotoluene
2-Chloronaphthalene
2-Chlorophenol
2-Nitrophenol
3.3'-Dichlorobenzidine
3,4 benzofluoranthene
4, 6- D i n itro-o-creso l
4-Bromopheny I-p heny tether
Reported By:
Result MQL
* 0.0103
* 0.0103
* 0.41
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0513
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
S.
[e-mail]
U nit
mg/1
mg/1
mg/I
mg/1
mg/1
mg/1
mg/1
mg/ l
mg/1
mg/1
mg/1
mg/1
mg/I
mg/I
mg/l
mg/1
mg/l
mg/1
Method
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
hnson, D.R. Wessinger
Analysis Analysis
Time Date Analyst
22:50 1 1 /612017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11i612017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11i6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 7 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL :
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LS 1D-2017-03446
E1026625
4-chlorophenyl phenyl ether
4-Nitrophenol
Acenaphthene
Accnaphthylene
Anthracene
Benzidine
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[g,h,i]perylene
Benzo[k]fluoranthene
his (2-Chloroethoxy) methane
his (2-Chloroethyl) ether
bis (2-Chloroisopropyl) ether
bis (2-Ethylhexyl) phthalate
Butylbenzylphthalate
Chrysene
Di-n-butylphthalate
Di-n-octylphthalate
Reported By:
Result MQL
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
• 0.0103
* 0,0103
* 0.0103
• 0.0103
* 0.0103
* 0,0103
* 0.0103
* 0.0103
Unit
mg/1
mg/1
mg."l
mg/I
mg/1
mgI
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
m«;1
mg/l
mg/l
rng/l
mg/I
Method
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
Analysis
Time
Analysis
Date Analyst
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6,2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 11/6/2017 Summit
22:50 1l/6/2017 Summit
22:50 11i6!2017 Summit
S. J 7' son, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 8 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Cite of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LS1D-2017-03446
E1026625
Parameter Result MQL
Di benz[a,h]anthracene
Dibenzofuran
Diethvlphthalate
Dimethylphthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadine
Hexachloroethane
lndeno[ 1,2,3-cd]pyrene
Isophorone
m&p Cresol
N -N itroso-di-n-propylam i ne
N-Nitrosodimethylamine
N-N itrosod i pheny [amine
Naphthalene
Nitrobenzene
Reported By:
* 0.0103
* 0.041
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
• 0.0103
* 0.0103
* 0.0103
* 0.041
* 0.0103
* 0.0103
* 0.0103
* 0.0103
* 0.0103
[e-mail]
Unit
mg/ 1
mg/1
mg/1
mg1
mg/1
mg/1
my/1
mgI
m g.1
mg11
rng/1
mg'I
mg]
mg/1
mg/1
mg/1
mg1
mg/I
Method
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
S. J.Irftson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No, 275
Page 9 of 14
Analysis Analysis
Time Date Analyst
22:50 11/6/2017
22:50 11/6/2017
22:50 11/6/2017
22:50 11/6/2017
22:50 I1/6/2017
22:50 11/6/2017
22:50 11/6/2017
23:50 11 /6.;2017
22:50 11/6/2017
22;50 11/6/2017
22:50 11/6/2017
22:50 1.1162017
22:50 11 /6/2017
22:50 11/6/2017
22:50 11/6'2017
22:50 11/6/2017
22:50 11/6/2017
22:50 11/6/2017
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
blueridgela [e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. 0. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03446
E1026625
Analysis Analysis
Parameter Result MQL Unit Method Time Date Analyst
p-Chloro-m-cresol * 0.0103 mg/1 EPA 625 22:50 1 1/6/2017 Summit
Pentachlorophenol * 0.0513 mg/1 EPA 625 22:50 11/6/2017 Summit
Phenanthrene * 0.0103 mg/] EPA 625 22:50 11/6/2017 Summit
Phenol * 0.0103 mg/1 EPA 625 22:50 11/6/2017 Summit
Pyrene * 0.0103 mg/1 EPA 625 22:50 11/6/2017 Summit
Reported By:
S. J. J- son, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 10 of 14

Blue Ridge .Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Ag
As
Cd
Cr
Cu
Ni
Pb
Sb
Se
Total Phosphorus
Zn
Hg
Be
'11
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03447
E1026M
Result MQL
* 0.001
* 0.01
* 0.0002
* 0.001
0.010 0.001
0.001 0.001
* 0.01
0.026 0.01
0.01
3.39 0.02
0.037 0.001
* 0.0001
* 0.02
* 0.02
Reported By:
Unit Method
mg/1 200.7 1994
mg/1 200.7 1994
mg;1 200.7 1994
mg/1 200.7 1994
mg/1 200.7 1994
mg/1 200.7 1994
mg/1 200.7 1994
mg/1 200,7 1994
mg/1 200.7 1994
mg/1 200.7 1994
mg/1 200.7 1994
mg/1 245.1 1994
mg/1 EPA 200.7
mg/1 EPA 200.7
Analysis Analysis
Time Date Analyst
14:24 11/14/2017
14:24 1 1/14/2017
€ 4:24 11114/2017
14:24 11 /1412017
€ 4:24 11/14/2017
14:24 11/14/2017
14:24 11/14/2017
14:24 11/14/2017
14:24 11/14/2017
14:24 11/14/2017
14:24 11/14/2017
14:20 11/8/2017
15:05 11/3/2017
15:05 1 1/3/2017
S. J..J on, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 11 of 14
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KC.1
KCJ
KCJ
KCJ
KCJ
Summit
Summit

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
TDS
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03448
E1026TDS
Reported By:
Result MQL
278 1
Analysis
Unit Method Time
mg/1 2540C 1997 11:22
S. JIfnson, D.R. Wessinger
Analysis
Date Analyst
10/27/2017 KCT
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 12 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Pa ramete r
Fats. Oil & Grease
City or Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov-17
26-Oct-17
BRL-2017-0889
LSID-2017-03449
E 1 0260G
Result MQL
Reported By:
Unit Method
Analysis
Time
Analysis
Date Analyst
mg/1 5520B 2001 11:28 10/31 i2017 KCJ
S..l4linson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 13 of 14

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
blueridgela [e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Phenols
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
26-Oct-17
16-Nov- 17
26-Oct-17
BRL-2017-0889
LSID-2017-03450
E1026PL
Reported By:
Result MQL
Analysis Analysis
Unit Method Time Date Analyst
* 0.01 mg 1 420.1 1978 16:15 11/14/2017 KCJ
S. J. "son, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 14 of 14

Blue Ridge Labs
PO .Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Ag
As
Cd
Cr
Cu
Mo
Ni
Pb
Se
Total Phosphorus
Zn
Hardness
He
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr- i 8
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01056
E0419M
Result
0.532
*
23.1
*
Reported By:
1-04-zn 1
MQL Unit Method
0.001 mg/1 200.7 1994
0.01 mgll 200.7 1994
0.0002 mgjl 200.7 1994
6.001 mg/1 200.7 1994
0.001 mg/1 200.7 1994
0.001 mg/1 200.7 1994
D.001 mgll 200.7 1994
0.01 met 200,7 1994
0.01 mgti 200.7 1994
0.02 mg/1 200.7 1994
0.001 mgil 200.7 1994
0.03 mg;1 2340E 1997
0.0001 mg/1 245.1 1994
S. J. i nson, U.R. Wessinger
Analysis Analysis
Time Date
12:49
12:49
12:49
12:49
12:49
12:49
12:49
12:49
12:49
12:49
12:49
12:49
15:16
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5/2/2018
5, 2/2018
5/2/2018
4/25/2018
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 1 of 15
Analyst
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Be
TI
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LS1D-2018-01057
E0419BE
Reported By:
Result MQL
* 0.001
* 0.02
Unit Method
mg/1 EPA 200.7
mg/1 EPA 200.7
S. J , nson, D.R. Wessinger
Analysis Analyst
Time Date
15:11 4/27/2018
19:23 4/27/2018
1
* Concentrations are below Minimum Quantification Limit except where noted_
NC Laboratory Certificate No. 275
Page 2 of 15
Analyst
Summit
Summit

Blue Ridge Labs
P4 Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Ammonia Nitrogen
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01058
E0419NH3
Reported By:
Result MQL
0.56 0.5
S. J
Unit Method
mg/1 SM4500 199
nson, D.R. Wessinger
Analysis Analysi
Time Date
10:01 4/26'2018
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 3 of 15
Analyst
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
N2+N3
TKN
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01059
E0419TKN
Result
2.67
6.34
Reported By:
Analysis
MQL Unit Method Time
0.08 mg/1 SM 19 4500-N 14:12
0.5 mg/1 SM 19 4500-N 9:42
J
•mot,-y
S. J. ohnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 4 of 15
Analysis
Date Analyst
4/27/2018 KCJ
4/27i2018 i KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
TDS
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01060
E04I9TDS
Reported By:
Result MQL
247
Unit
Analysis
Method Time
Analysis
Date j Analyst
mg/1 2540C 1997 11:14 4/26/2018
S. Johnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 5 of 15
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
Date Received: 19-Apr-18
Report Date: 02-May-18
Sample Date: 19-Apr-18
BRL #: BRL-2018-0222
Lab Sample ID: LS1D-2018-01061
Client Sample ID: E0419625
Parameter
1,2,4- Tri c h lorobenzene
1,2-Dichlorobenzene
1,2-Diphenyl-hydrazine
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4,6-Trich lorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
2-Chloronaphthalene
2-Chlorophenol
2-Nitropheno]
3,3'-Dich lorobenzidine
3,4 benzofluoranthene
4,6-Dinitro-o-cresol
4-Bromophenyl-pheny tether
Reported By:
Result MQL
* 0.01
* 0.01
* 0.04
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.05
* 0.01
* 0.01
0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
Unit
mg/1
mg/1
mg/I
mg/I
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg'l
mg/1
mg/1
mg/1
mg/1
Method
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
S. J. , sT son, D.R. Wessinger
Analysis Analysi
Time Date
Analyst
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 425;2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 6 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01061
E0419625
4-chlorophenyl phenyl ether
4-Nitrophenol
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[g,h,i]perylene
Benzo [k] flu oranthe ne
bis (2-Chloroethoxy) methane
bis (2-Chloroethyl) ether
bis (2-Chloroisopropyl) ether
bis (2-E.thylhexyl) phthalate
Butylbenzylphthalate
Chrysene
Di-n-butylphthalate
Di-n-octylphthalate
Reported By:
Result MQL
* 0.01
* 0.01
* 0.01
* 0.0I
• 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
0.01
* 0.01
0.01
0.01
* 0.01
0.01
* 0.01
0.01
Un it
mg/I
mg/1
mg/I
mg/1
mg/I
mg/1
mg/1
mg/I
mg/1
mg/1
mg/1
mg/1
mg/I
mg/ 1
mg/1
mg/1
mg/1
mg/1
Method
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
Analysis Analysi
Time Date
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
18:03
4'25i2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4./25/2018
4/25/2018
4125i2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4/25/2018
4125/2018
S. Jnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page7of 15
Analyst
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit
Summit

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01061
E0419625
Parameter Result
Dibenz[a,h]anthracene
Diethylphthalate
Di methy 1phthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadine
Hexachloroethane
Indeno[1,2,3-cd]pyrene
Isophorone
N-N itroso-di-n-propylamine
N-N itrosod i m ethy lam in e
N-N itrosod ipheny lam ine
Naphthalene
Nitrobenzene
p-Chloro-m-cresol
Pentachlorophenol
Reported By:
MQL
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
* 0.01
0.01
* 0.01
* 0.01
* 0.01
• 0.01
* 0.05
S. J
Unit Method
mg/I
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/I
mg/1
mg/I
mg/1
mg/1
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
EPA 625
son, D.R. Wessinger
Analysis Analysi
Time Date Analyst
18.03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
18:03 4/25/2018 Summit
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 8 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
blueridgela [e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Phenanthrene
Phenol
Pyrene
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01061
E0419625
Reported By:
Result MQL
* 0.01
* 0.01
* 0.01
Analysis Analysi
Unit Method Time Date Analyst
mg/1 EPA 625 18:03 4/25/2018 Summit
mg/1 EPA 625 18:03 4/25/2018 Summit
nib/] EPA 625 18:03 4/25/2018 Summit
S. '! h' nson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 9 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Cyanide
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01062
E0419CN
Reported By:
Result MQL
0.005
Unit Method
rn '1 4500-CN-E 1
S. ' . Johnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 10 of 15
Analysis Analysi
Time Date
17:02 4/24/2018
Analyst
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, PVC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01063
E04190G
Fats. Oil & Grease
Reported By:
Analysis
Result MQL Unit Method Time
1.4 1 mgrl 5520B 2001 10:33
yam".
S.: +ohnson, D.R. Wessinger
Analysi
Date
4/26/2018
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 11 of 15
Analyst
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
Phenols
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LS1D-2018-01064
E0419PL
Result MQL
* 0.01
Reported By:
Unit
Analysis
Method Time
Analysi�
Date Analyst
mg,/1 Pheno1420.] 16:14 4/26/2018
S. Johnson, D.R. Wessinger
* Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 12 of 15
KCJ

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LSID-2018-01065
E0419624
1,1,1-Trichloroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1-Dich]oroethane
1,1-Dichloroethene
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dich]oropropylene
2-Chloroethylvinyl Ether
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon Tertachloride
Chlorobenzene
Chlorod ibromom ethane
Chloroethane
Chloroform
Reported By:
Result MQL
5
5
5
5
5
5
5
5
10
50
50
5
5
5
5
5
5
5
Unit
ug/1
ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
ug/1
ugl1
uWl
ug/l
ugl l
ug/l
ug/1
ug/l
ug/l
ug/1
ugll
Method
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
EPA 624
S. J,121 nson, D.R. Wessinger
Analysis Analysi�
Time Date Analyst
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
17:48 4/20/2018 Summit
Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 13 of 15

Blue Ridge Labs
PO Box 2940
Lenoir, NC 28645
828-728-0149
[e-mail]
Client :
Attention:
Date Received:
Report Date:
Sample Date:
BRL #:
Lab Sample ID:
Client Sample ID:
Parameter
City of Morganton
P. O. Box 3448
Morganton, NC 28655
Ms. C. Benton
19-Apr-18
02-May-18
19-Apr-18
BRL-2018-0222
LS1D-2018-01065
E0419624
Result
Dichlorobromomethane
Ethybenzene
Methyl Bromide
Methyl Chloride
Methylene Chloride
Tetrachloroethene
Toluene
Trans-1,2-dichloroethene
Trichloroethene
Vinyl Chloride
Reported By:
MQL
* 5
* 5
* 5
* 5
* 5
* 5
* 5
* 5
* 5
* 5
Analysis Analysi•
Unit Method Time Date Analyst
ug/1 EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
ug'1 EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
ugil EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
ugil EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
ug/1 EPA 624 17:48 4/20/2018 Summit
S. J. nson, D.R. Wessinger
Concentrations are below Minimum Quantification Limit except where noted.
NC Laboratory Certificate No. 275
Page 14 of 15

Attachment A —Request for Missing Information
40 CFR 122.21(f](2)
1.1
Email address of facility contact [e-mail]
40 CFR 122.21(0(3)
1.2
NAICS Code(s)
Description (optional)
221320
Sewage treatment plants or facilities
40 CFR 122.21(0(4)
1,3 Email address of operator [e-mail]
Ci.morganton.nc.us
40 CFR 122.21(0(9)
1.4 Does your facility use cooling water?
❑ Yes 'No 4 SKIP to Item 1.6
Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at 40 CFR 125,
Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your NPDES permitting authority
to determine what specific information needs to be submitted and when.)
1.5
40 CFR 122.21(0(10)
1.6
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)? (Check all that apply. Consult
with your NPDES permitting authority to determine what information needs to be submitted and when.)
O Fundamentally different factors (CWA Water quality related effluent limitations (CWA Section
Section 301(n)) 302(b)(2))
O Non -conventional pollutants (CWA ❑ Thermal discharges (CWA Section 316(a))
Section 301(c) and (g))
❑ Not applicable
40 CFR 122.22(a) and (d)
1.7
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name) Eli Self
Official title Superintendent & ORC
Signature tia
Date signed

Attachment A —Request for Missing Information
Table 2. EPA Application Form 2A Missing Information
40 CFR 122.21(j)(1)
1.1 Email address of facility contact [e-mail]
1.2
Applicant email address [e-mail],nc.us
1.3 Email address of the organization transporting the discharge for treatment prior to discharge NA
1.4 Email address of the organization receiving the discharge for treatment prior to discharge NA
1.5
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122,21(n)? (Check all that apply. Consult
with your NPDES permitting authority to determine what information needs to be submitted and when,)
❑ Discharges into marine waters (CWA Section "Water quality related effluent limitation (CWA
301(h)) Section 302(b)(2))
❑ Not applicable
1.6 Email address of contractor responsible for operational or maintenance aspects of the treatment works Al A
40 CFR 122.21(jj(6)
1.7 _ Indicate the number of SIUs and NSCIUs that discharge to the PDTW
Number of SIUs
Number of ClUs
2 SIU & 1 NSCIU
40 CFR 122.22(a) and (d)
1,8
Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name) Eli Self
Official title Superintendent & ORC
Signature
Date signed f

NC Department of Environment and Natural Resources
Model Mercury Minimization Plan
Background
The North Carolina Department of Environment and Natural Resources, Division of Water Resources
(DENR), has issued a statewide total maximum daily load (TMDL) for mercury. The TMDL responds to
a statewide fish consumption advisory for mercury. The TMDL calls for a 67% reduction in mercury
levels from the year 2002 baseline mercury loading. The ultimate goal of the TMDL is to ensure safe -
levels of mercury in fish throughout North Carolina for human consumption.
As explained in the TMDL, 98 percent of mercury in North Carolina waters comes from atmospheric
sources — the vast majority of which are located outside of the State. Under the Clean Water Act,
atmospheric deposition of mercury into surface waters is regarded as a nonpoint source. Minor amounts
of mercury are discharged directly into surface waters by industrial and municipal point sources as a
group. Specifically, the TMDL determined that point sources contribute less than two (2) percent of the
annual mercury loadings to State waters. The TMDL allocates two percent of the statewide allowable
loadings collectively to the point source sector. This does not mean that an individual discharger may not
have significant levels of mercury in its discharge in terms of local water quality considerations. While
we expect such instances to be rare based upon the Department's review of statewide mercury data,
dischargers with higher mercury loadings will be expected to implement more aggressive mercury
controls.
Notably, unlike any other source, local governments actually reduce mercury loadings in the environment
by first filtering mercury out in the treatment of public drinking water (particularly where the source of
raw drinking water is surface water) and then a second time when wastewater is treated.
In order to implement the two percent point source sector wasteload allocation, the Department has
developed a point source permitting strategy which is located at
http://portal.ncdenr.org/web/wq/ps/mtu/tmdl/tmdls/mercury . The Environmental Management
Commission has approved both the TMDL and the Permitting Strategy. The permitting strategy calls for
certain point sources to develop and implement mercury minimization plans (MMPs). For POTWs, an
MMP will be required if the facility has (1) a permitted design capacity of more than two million gallons
per day and (2) mercury at quantifiable levels in their effluent. MMPs feature best management practices
and have been implemented successfully in numerous states around the country. The attached document
is [Utility name]'s MMP.
Typically, MMPs focus on pretreatment controls — a local government's interaction with non -domestic
users of its sewer system as well as outreach to the public at large regarding the proper use and disposal of
household products containing mercury.
The MMP approach is intended as a reasonable, low-cost approach toward making some progress toward
managing the two percent loading statewide from point sources. Mercury treatment and even testing is
very expensive and does not make sense to reduce a small part of the already insignificant two percent
overall point source annual loading to State waters.

Catawba River Pollution Control Facility for the City of Morganton
MODEL MUNICIPAL MERCURY MINIMIZATION PLAN
[1/12/2021]
SECTION I - PURPOSE
The purpose of this Mercury Minimization Plan ("MMP") is to describe best management practices
through which City of Morganton will seek to reduce the amount of mercury discharged into its system
and, ultimately, to the environment. The MMP compiles mercury reduction -related efforts to -date and
potential future action items. It is designed to be a working document to help guide City of Morganton in
its efforts to control mercury loadings discharged into its Publicly -Owned Treatment Works (POTW) by
users of the sewer system. Such a reduction in loadings to the sewer system should translate to a
reduction in the amount of mercury which is discharged from the treatment plant. The management
practices summarized below may also help control some of the mercury reaching our storm sewer system
as well.
SECTION II — FACILITY DESCRIPTION
The City of Morganton operates a publicly owned treatment works (POTW), including a collection
system and wastewater treatment plant (WWTP), that serves the city of Morganton, Drexel and Glen
Alpine areas of North Carolina.
The WWTP Facility removes trash and debris from waste stream with bar screens, grit is removed with a
cyclone separator. BOD (Biochemical Oxygen Demand) and TSS (Total Suspended Solids) are removed
with the biological process created through mixing oxygen into an aeration basin to allow microorganisms
to further break down waste. Wastewater is then disinfected with Chlorine. After disinfection, the
Chlorine is removed with Sodium Bi-Sulfate before entering the Catawba River. Sludge accumulated is
dewatered using centrifuges and composted. Finished residuals are classified as Class A Biosolids and is
distributed to the general public.
As with most municipal treatment plants, the City of Morganton's WWTP is not designed to remove
mercury and it is exceedingly expensive to do so to very low levels. Incidental mercury removal occurs
through typical municipal treatment with trace levels of mercury (and other metals) ending up in solids
removed from the raw wastewater.
Mercury is not used in the treatment processes at the WWTP. Mercury may be introduced into the sewer
system through a variety of sources, such as from industrial users, laboratories, and other businesses.
Residual deposits of mercury are also possible in the sewer system from historic practices. Finally, trace
amounts from household products and atmospheric deposition (both wet and dry) contribute to sewer
system mercury loadings.
While there is typically some mercury contributed to public sewer systems statewide, it is usually in
minute quantities and comprises a tiny portion of the already insignificant statewide loading for all point
sources - just two percent of the annual mercury loadings to all State waters.

SECTION HI — PROGRAM PLAN
A. EVALUATION OF POTENTIAL NON -DOMESTIC SOURCES CONTRIBUTING
MERCURY TO THE POTW
Within 24 months from the NPDES required 180-day period for development of an MMP, the City of
Morganton will evaluate available information to assess the potential for non -domestic users of the sewer
system to contribute mercury to the system. The information to be reviewed may include: (1) POTW
influent and effluent mercury data and trends; (2) industrial user permits and associated mercury
monitoring data; (3) Toxics Release Inventory (TRI); (4) state hazardous site registry and the National
Priority List relating to mercury contamination; and (5) historical records of industrial sites which may
have contributed mercury loadings to the sewer system.
The City of Morganton will also survey and evaluate the following common sources of mercury in its
service area: (1) dentist offices; (2) hospitals; (3) laboratories; (4) auto recyclers; and (5) other potential
sources of mercury based on existing information.
The City of Morganton will request that industrial users review mercury concentrations in high -volume
process chemicals and demonstrate that the mercury concentrations are below industry average. The City
of Morganton will request that alternative sources for chemicals be explored if the mercury levels are
determined to be significantly higher than would normally be expected.
The evaluation of potential non -domestic sources of mercury to the sewer system will be updated every
five years, as warranted by prior sampling results and any additional new potentially significant sources to
the system.
B. ADDITIONAL CONTROL MEASURES
This MMP identifies reasonable and cost-effective control measures to minimize mercury being
discharged into the POTW. Below is a listing of initial BMPs for this POTW.
Pollution Prevention
Substances used at the WWTP will be evaluated to determine if they contain mercury or mercury -based
compounds. Any such chemicals will be evaluated for substitution with non -mercury -containing
substances.
Housekeeping, Spill Control and Collection, and Education
The City of Morganton will develop procedures to minimize the possibility of any spill or release at the
WWTP involving mercury containing substances. The City of Morganton will add mercury identification
and proper disposal to ongoing and future operator training procedures.
Public Outreach
The City of Morganton will make available educational information regarding sources of household
mercury and appropriate use/disposal practices. This information may be posted on the City of
Morganton's website. The availability of this information will be highlighted in the coming months of
2021 to outreach the City of Morganton's customers. The City of Morganton will also facilitate public
awareness regarding community collection points for mercury -containing products from

residents/customers for proper disposal. Periodic reminders of such collection programs will be provided
as part of the City of Morganton's ongoing public outreach.
Laboratory Practice
The City of Morganton operates a laboratory for purposes of complying with state and federal monitoring
and sampling requirements. The laboratory is a potential source of small quantities of mercury -
containing compounds. Laboratory employees will be trained in the proper handling and disposal of these
materials. The laboratories have also replaced mercury thermometers with non -mercury thermometers,
whenever practical.
C. TRACKING AND MONITORING
In order to assess the implementation of the control measures, the City of Morganton proposes to
undertake the following evaluations beginning after the first full year that this MMP is implemented:
1. Survey annually at least ten percent (10%) of any non -domestic users identified as
possible significant sources of mercury to the POTW;
2. Track the implementation of the programs outlined above;
3. Monitor influent mercury at least annually. Require significant non -domestic sources of
mercury to monitor periodically, as warranted; and
4. Measure effluent mercury as required by the NPDES permit.
These efforts will allow the City of Morganton to establish a baseline of influent and effluent mercury
levels to assist in identifying any trends in mercury contributions from domestic and non -domestic users
of the sewer system. This baseline will be tracked annually.
SECTION IV — IMPLEMENTATION OF CONTROL MEASURES
The POTW sampled for Low Level Mercury in its effluent each month beginning in September 2019 to
November 2020 to gather a baseline and for the needs of our Headworks Analysis and Long Term
Monitoring program. POTW has continued to sample for Low Level Mercury quarterly. The City of
Morganton in 2020 began sending surveys to dental offices in an effort to identify and monitor mercury
use at their practices. The City of Morganton has also began in 2021 sending out surveys to its Significant
Industry Users (SUI's) in an attempt to identify and reduce the potential mercury discharge from their
facilities. We are in the process of gathering information to send to Hospitals after SUI's.
The City of Morganton will implement the control measures summarized in Section III over the permit
term and will update this MMP as warranted.
SECTION V - REPORTING
A summary of the MMP activities will be submitted as part of the NPDES permit renewal process.

Permit No. NC0026573
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 µg/1 for human health protection; cyanide at 5 µg/L and fluoride at
1.8 mg/L for aquatic life protection).
Table 2. Dissolved Freshwater Standards for Hardness -Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A
NCAC 02B .0211 Subparagraph (11)(d)
Metal
NC Dissolved Standard, µg/I
Cadmium, Acute
WER*{1.1366724ln hardness](0.041838)} - e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters
WER*{1.1366724ln hardness](0.041838)} - e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic
WER*{1.1016724ln hardness](0.041838)} - e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute
WER*0.316 - e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic
WER*0.860 • e^{0.8190[ln hardness]+0.6848}
Copper, Acute
WER*0.960 • e^{0.9422[ln hardness]-1.700}
Copper, Chronic
WER*0.960 • e^{0.8545[ln hardness]-1.702}
Lead, Acute
WER*{1.462034ln hardness](0.145712)} • e^{1.273[ln hardness]-1.460}
Lead, Chronic
WER*{1.462034ln hardness](0.145712)} • e^{1.273[ln 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. NC0026573
Silver, Acute
WER*0.85 • e^{1.72[ln hardness]-6.59}
Silver, Chronic
Not applicable
Zinc, Acute
WER*0.978 • e^{0.8473[ln hardness]+0.884}
Zinc, Chronic
WER*0.986 • e^{0.8473[In 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. NC0026573
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/
(Permitted Flow, cfs + s7Q10, cfs)
The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.
3. The permit writer converts the numeric standard for each metal of concern to a total recoverable
metal, using the EPA Default Partition Coefficients (DPCs) or site -specific translators, if any
have been developed using federally approved methodology.
EPA default partition coefficients or the "Fraction Dissolved" converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in -stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:
Cdiss = 1
Ctotal 1 + { LKPoI �SS(1+a)I [1 0-61
J
Where:
ss = in -stream suspended solids concentration [mg/1], minimum of 10 mg/L used,
and
Kpo and a = constants that express the equilibrium relationship between dissolved
and adsorbed forms of metals. A list of constants used for each hardness -dependent
metal can also be found in the RPA program under a sheet labeled DPCs.
4. The numeric standard for each metal of concern is divided by the default partition coefficient (or
site -specific translator) to obtain a Total Recoverable Metal at ambient conditions.
In some cases, where an EPA default partition coefficient translator does not exist (ie. silver), the
dissolved numeric standard for each metal of concern is divided by the EPA conversion factor to
obtain a Total Recoverable Metal at ambient conditions. This method presumes that the metal is
dissolved to the same extent as it was during EPA's criteria development for metals. For more
information on conversion factors see the June, 1996 EPA Translator Guidance Document.
5. The RPA spreadsheet uses a mass balance equation to determine the total allowable concentration
(permit limits) for each pollutant using the following equation:
Ca = (s7Q10 + Qw) (Cwqs) — (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on -going with EPA on how best to address background concentrations
Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
Page 3 of 4

Permit No. NC0026573
QA = used in the equation to protect human health through the consumption of water,
fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality
6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of concern.
Data entered must have been taken within four and one-half years prior to the date of the permit
application (40 CFR 122.21). The RPA spreadsheet estimates the 95th percentile upper
concentration of each pollutant. The Predicted Max concentrations are compared to the Total
allowable concentrations to determine if a permit limit is necessary. If the predicted max exceeds
the acute or chronic Total allowable concentrations, the discharge is considered to show
reasonable potential to violate the water quality standard, and a permit limit (Total allowable
concentration) is included in the permit in accordance with the U.S. EPA Technical Support
Document for Water Quality -Based Toxics Control published in 1991.
7. When appropriate, permit writers develop facility specific compliance schedules in accordance
with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to Alexis Strauss on
40 CFR 122.47 Compliance Schedule Requirements.
8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium data
results may be used as a conservative surrogate in cases where there are no analytical results
based on chromium III or VI. In these cases, the projected maximum concentration (95th %) for
total chromium will be compared against water quality standards for chromium III and
chromium VI.
9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness -dependent metals to ensure the
accuracy of the permit limits and to build a more robust hardness dataset.
10. Hardness and flow values used in the Reasonable Potential Analysis for this permit included:
Parameter
Value
Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
36.23
Data provided in DMRs
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25.0
Default value
7Q10 summer (cfs)
118.0
NPDES Files
1Q10 (cfs)
118.0
Calculated in RPA
Permitted Flow (MGD)
8.0
NPDES permit application
Date: 9/22/2021
Permit Writer: Diana Yitbarek
Page 4 of 4

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 ICI J 2 IS I 3 I NC0026573 111 121 20/08/13 117
Type
18 [
I I I I I
Inspector Fac Type
19 G I 201
211111 I I I I I I II I I I I I I I I I I I I I I I I I
I II
I I I I I 166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671I 7° I I 711I 72 I N I 73I I 174
L� 1 751
I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Catawba River Pollution Control Facility
1000 Vine Arden Rd
Morganton NC 28680
Entry Time/Date
10:30AM 20/08/13
Permit Effective Date
16/05/01
Exit Time/Date
12:30PM 20/08/13
Permit Expiration Date
20/02/29
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Eli Self,PO Box 3448 Morganton NC 286559850/Superintendent ORC/828-438-5375/
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Operations & Maintenar Records/Reports Facility 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
Linda S Wiggs DWR/ARO WQ/828-296-4500 Ext.4653/
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
NC0026573 111 121 20/08/13
117
Inspection Type
18ILI
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Linda Wiggs met with Eli Self (ORC) and Tim Arney (Pretreatment Coordinator).
Records were reviewed remotely.
No compliance issues were noted. The staff do an exceptional job operating this facility.
Page# 2

Permit: NC0026573
Inspection Date: 08/13/2020
Owner - Facility: Catawba River Pollution Control Facility
Inspection Type: Compliance Evaluation
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: sludge judge, settleability, pH, DO, MLSS, MCRT, microscopic analysis.
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
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?
Yes No NA NE
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Yes No NA NE
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0
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Page# 3

Permit: NC0026573
Inspection Date: 08/13/2020
Owner - Facility: Catawba River Pollution Control Facility
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?
Comment:
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:
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:
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Primary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
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• ❑ • ❑
Yes No NA NE
•
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Yes No NA NE
•
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Yes No NA NE
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Page# 4

Permit: NC0026573
Inspection Date: 08/13/2020
Owner - Facility: Catawba River Pollution Control Facility
Inspection Type: Compliance Evaluation
Primary Clarifier
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 sludge blanket level acceptable?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment. Blanket checked multiple times daily.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Comment: Continuous DO read system.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
Diffused
• ❑ ❑ ❑
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
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• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 5

Permit: NC0026573
Inspection Date: 08/13/2020
Owner - Facility: Catawba River Pollution Control Facility
Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Comment: Blanket checked multiple times daily.
Page# 6

[External] RE: Morgaton_Catawba RPCF_26573_pre- 2nd Public Notice
Self, Eli <[e-mail]>
Tue 5/24/2022 07:59
To: Yitbarek, Diana <[e-mail]>
Cc: Boris, Brad <[e-mail]>;Robert Vinay <[e-mail]>;Mcgee, Keyes
<[e-mail]>;Montebello, Michael J <[e-mail]>;Arney, Tim
<[e-mail]>
1 attachments (18 KB)
Morganton WWTP NPDES Permit;
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
to Report Spam.
Diana,
After discussing the posed question on the cover section with our engineers, we have come to a conclusion. The
answer to your question is yes we would, to confidently meet the proposed 10.5 MGD permit requirements.
Attached is a statement from Engineer Robert Vinay which reads:
Eli,
In their latest draft NPDES permit cover letter (dated May 31, 2022), the NCDEQ Permitting Unit asks the question
of the City to "Please clarify, with the revised limits, whether the Facility needs an Authorization to
Construct/upgrade before moving to the 10.5 MGD flow tier". We are assuming they are asking you if the existing
plant can reliably treat a monthly average of 10.5 MGD, and if Freese and Nichols, as your consultant will provide
an engineering certification stating such. Design of the Process Conversion Project in 2017 was based on influent
flow characteristics from 7 years ago and performance of existing plant components at that time. Based on recent
discussion with the plant's operation staff, and now that several years of performance data is available with the
upgraded plant in operation, we believe that a re-evaluation of plant capacity would be prudent prior to offering a
current engineering opinion regarding the plant's design capacity.
Thanks,
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <[e-mail]>
Sent: Friday, May 6, 2022 1:21 PM
To: Self, Eli <[e-mail]>
Cc: Boris, Brad <[e-mail]>; Robert Vinay <[e-mail]>; Mcgee, Keyes
<[e-mail]>; Montebello, Michael J <[e-mail]>; Arney, Tim
<[e-mail]>
Subject: Morgaton_Catawba RPCF_26573_pre- 2nd Public Notice
© THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
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IRMS @ [e-mail].
Good afternoon, Eli - Hope this message finds you well.
Please find attached the courtesy draft NPDES permit package. Please address the question you will
find in the Cover Letter's comment section, and let me know if you have any comments or questions
by May 24th.
Thank you,
Diana Yitbarek (she/her)
Engineer
T: 919-707-9130
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From: Self, Eli <[e-mail]>
Sent: Wednesday, March 30, 2022 08:50
To: Yitbarek, Diana <diana.yitbarek_@ ncdenr.gov>; Montebello, Michael J <Michael.Montebello_@ ncdenr.gov>
Cc: Boris, Brad <[e-mail]>; Robert Vinay <Robert.Vinayyfreese.com>; Mcgee, Keyes
<keyes.mcgeePncdenr.gov>; Kenneth Bruce <[e-mail]>; Nick Landes
<[e-mail]>; Wiggs, Linda <[e-mail]>; Arney, Tim <TArney_ morgantonnc.gov>;
Annas,Rex <RAnnas_. morgantonnc.gov>
Subject: RE: [External] RE: Morgaton_Catawba RPCF_26573_pre-issuance
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attachment to Report Spam.
Permit writing,
After much discussion, we request to keeping the 13.0 MGD flow tier for the upcoming permit.
If you have any further questions, please let us know.
Thanks,
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Self, Eli [mailto:ESelfj morgantonnc.gov]
Sent: Tuesday, March 8, 2022 12:13 PM
To: Yitbarek, Diana <[e-mail]>; Boris, Brad <[e-mail]>; Robert Vinay

[External] RE: Morganton CRPCF_NC0026573 Permit Questions
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To:Yitbarek, Diana <diana.yitbarek©ncdenr.gov>
Cc: Annas,Rex <[e-mail]>;Arney, Tim <[e-mail]>;Wiggs, Linda <[e-mail]>;Boris, Brad <[e-mail]>
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Anyway, so now we will go back and revise the eDMRs again. I also forgot to update the antimony from 4/11/2018, so the new list of eDMR's corrections and the corresponding paperwork (attached PDF) are as follows:
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We are sorry for the confusion and the incorrect data, I hope we have cleared all the missing/wrong parameters for the permit renewal.
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We have double checked all of our copper results referencing the data sheet draft. The only result that was incorrect was 10/5/2017 — correct result was 0.010 mg/I. Attached is the lab sheet.
I will now begin to update all of the eDMR's incorrect results with the correct results. These will be as follows:
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Look forward to hearing back from you,

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See attachment for signed copy of the chemical addendum. Let me know if you need anything else.
)
\
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Good afternoon, Eli - Thank you. We have an additional request for this submittal:
Since we want to maintain the format and also know who reports the form and when. Could you please pdf the Chemical Addendum form and add a signature block with a date next to your note?
Thank you and please let me know if you have any questions.
Division of Water Resources
$@ƒ
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
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Morganton CRPCF_NC0026573 (pre -public notice)
Yitbarek, Diana <[e-mail]>
Thu 10/21/2021 13:50
To: Wiggs, Linda <[e-mail]>
Cc: Mcgee, Keyes <[e-mail]>
Linda - apologies I forgot to include you in the email below.
From: Yitbarek, Diana <[e-mail]>
Sent: Thursday, October 21, 2021 13:28
To: Self, Eli <[e-mail]>
Cc: Mcgee, Keyes <[e-mail]>
Subject: Morganton CRPCF_NC0026573 (pre -public notice)
Good afternoon, Eli
We are close to sending the permit package for public notice and wanted to update you on a few items:
1. Aluminum - We are interested in assessing the discharge of the effluent based on EPA's 2018 aquatic life criteria - https://www.epa.gov/wqc/2018-
final-aquatic-life-criteria-aluminum-freshwater; however, we need additional information; therefore,
a. The Division will require Aluminum (Al) monitoring in a quarterly basis.
b. To calculate a specific instream target value (ITV) for Al, specific dissolved organic carbon (DOC), hardness, and pH data are needed. We will
add a DOC monitoring requirement on a quarterly basis, as well. The ITV will be assessed in the next permit cycle.
2. Long Term Monitoring Plan (LTMP) update required.
a. The LTMP currently lists Al as an SIU limited pollutant. Since that is not the case anymore, please update the LTMP document to list the Al
monitoring as an NPDES required pollutant.
i. The attachments to the fact sheet will convey that information in the pollutants of concern (POC) review form. Please address any further
comments to the LTMP, and when ready, please submit the updated LTMP to Keyes McGee (cc'd here)
Thanks for all your assistance in this process, and please let me know if you have any questions or if you'd like to have a virtual meeting with us.
Best,
-Diana
Diana Yitbarek (she/her)
Engineer II
T: 919-707-9130
i n .yitbarek(aa ncdenr.gov
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street Raleigh NC 27604
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <[e-mail]>
Sent: Wednesday, September 22, 2021 14:36
To: Yitbarek, Diana <[e-mail]>
Cc: Annas,Rex <[e-mail]>
Subject: [External] RE: Catawba - Morganton RPCF (NC0026573) - NPDES Permit Renewal
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to I sport Spam.
Diana,
Our lab supervisor Rex has checked and all the aluminum results reported are correct.
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <[e-mail]>
Sent: Wednesday, September 22, 2021 7:16 AM
To: Self, Eli <[e-mail]>
Subject: Catawba - Morganton RPCF (NC0026573) - NPDES Permit Renewal
LL THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
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message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Thank you, Eli. I have updated the reasonable potential analysis (RPA) to include the 2018 sample for antimony.

Regarding Aluminum, I'd like you to confirm that the following data reported in the DMR corresponds to what you have on your file.
Date Data, ugll
7/11/2017 1010
1/25/2018 39
7/19/2018 119
1/29/2019 85
7/15/2019 423
9/24/2019 181
1/9/2020 604
7f7/2020 221
1/12/2021 160
7/20/2021 154
Thank you,
-Diana
Diana Yitbarek (she/her)
Engineer II
T: 919-707-9130
diana.yitbarelc@ncdenr guy
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street, Raleigh, NC 27604
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <[e-mail]>
Sent: Thursday, September 16, 2021 07:48
To: Yitbarek, Diana <[e-mail]>
Cc: Annas,Rex <[e-mail]>
Subject: [External] RE: Catawba - Morganton RPCF (NC0026573)
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Diana,
We were able to track down the antimony test from 2018, it was missed by the Blue Ridge Labs in 2018 and we had to have them add parameter afterward that year.
Attached is the results. Sb = <.0.01 mg/I
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <[e-mail]>
Sent: Wednesday, September 15, 2021 3:09 PM
To: Self, Eli <[e-mail]>
Cc: Annas,Rex <[e-mail]>
Subject: Catawba - Morganton RPCF (NC0026573)
® THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY LL
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message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Eli - Thank you so much for addressing my questions. Please sample and test for antimony.
-Diana
Diana Yitbarek (she/her)
Engineer II
T: 919-707-9130
d is na.yitbarekCal ncdenr.goy
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street Raleigh NC 27604

"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <[e-mail]>
Sent: Tuesday, September 14, 2021 11:25
To: Yitbarek, Diana <diana.yitbarek@a ncdncgov>
Cc: Annas,Rex <[e-mail]>
Subject: [External] RE: Catawba - Morganton RPCF (NC0026573)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Hey Diana,
I will do my best to clarify for each. We try to keep everything as mg/I for simplicity.
Copper on 4/11/17 —the correct lab result is 0.013 mg/I
- Lead on 4/19/18 — The correct lab result was <0.01 mg/I
- Lead on 1/12/21 & 7/20/21— Both were correct at <0.001 mg/I & <0.001 mg/I
Selenium on 7/19/18—the correct lab result is <0.01 mg/I
- Temperature on 5/15/17 was a typo — correct result was 16.9 C
Conductivity on 7/10/19 was a typo — correct result was 452
Antimony on PPA 2018 — after investigating, the test was not conducted for 2018 but was for 2017 from the chain of custodies.
Dimethylphthalate on PPA 2017 — results of <0.0103 mg/I (see attachment)
Dimethylphthalate on PPA 2018— results of <0.01 mg/I (see attachment)
Aluminum analytical method is EPA 200.8 — see attachment for info.
Let me know if you need any else. I assume we will need to get another antimony test conducted.
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <[e-mail]>
Sent: Tuesday, September 14, 2021 8:14 AM
To: Self, Eli <ESelf(&morgantonnc.gov>
Subject: Catawba - Morganton RPCF (NC0026573)
® THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
CAUTION: Don't be quick to click! We're counting on you! This email is from an external sender! Don't click on links or open attachments from unknown sources. If you know this is spam delete the message. If you believe this
message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Good morning, Eli - I hope you are well. I just restarted working on the NPDES permit renewal for the Catawba River Pollution Control Facility. I have a few
requests below.
• Please clarify and update the following entry values in the eDMR as needed.
o Copper, 4/11/2017 was 0.013 ug/I. Did the City want to report 13 ug/I?
o Lead, 4/19/2018 was 10 mg/I. Did the City want to report to 10 ug/I? For the lead reported on 1/12/2021 and 7/20/2021, did the City mean to
report <10 ug/I/0.01 mg/I?
o Selenium, 7/19/2018, did the City mean to report <10 ug/I/0.01 mg/I?
o Upstream temperature, 5/15/2017. There may be a typo.
o Effluent conductivity, 7/10/2019. There may be a typo, or please confirm/explain.
• Please provide laboratory reports for the following compounds:
o Antimony - there was no 2018 result for this pollutant in the provided priority pollutant analysis (PPA). Please follow up with your lab.
(Application, Part D. lists 3 sampling results)
o Dimethyl phthalate - there was no 2017 and 2018 result for this pollutant in the provided PPA. Please follow up with your
lab. (Application, Part D. lists 3 sampling results)
• Please clarify what analytical method was used to test for aluminum and its ML/MDL.
Thank you and please let me know if you have any questions,
-Diana
Diana Yitbarek (she/her)
Engineer II
T: 919-707-9130
d is na.yitbarek@ncdencgov
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street Raleigh NC 27604
Q
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Yitbarek, Diana < i n .yitbarekCla ncdenr.go>
Sent: Thursday, June 10, 2021 10:43

To: Self, Eli <ESelfl&morgantonnc.gov>
Subject: Re: 2nd species needed - Fw: [External] RE: NC0026573, Morganton
Good morning, Eli
Thank you for the notification on completing the fourth and final second species test. All four tests passed! I will add the permit renewal to my queue and
let you know once I restart working on it.
Happy Thursday!
-Diana
Diana Yitbarek (she/her)
Engineer II
T: 919-707-9130
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 North Salisbury Street Raleigh NC 27604
E Q�
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
We can also be available via Microsoft Teams or other web -based calling services if requested. Thanks for your patience and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <ESelfl&morgantonnc.gov>
Sent: Thursday, June 10, 202109:03
To: Yitbarek, Diana <[e-mail]>
Cc: Annas,Rex <RAnnas@a morgantonnc.gov>
Subject: RE: 2nd species needed - Fw: [External] RE: NC0026573, Morganton
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Good morning Diana,
We have submitted our 4 second species tests to the appropriate branches. I want to confirm that we are caught up and can continue with our permit renewal. Please let me
know if you need anything.
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <diana.yitbarek(alncdenr.gov>
Sent: Wednesday, January 20, 20218:57 AM
To: Self, Eli <eself ci.morganton.nc.us>
Subject: 2nd species needed - Fw: [External] RE: NC0026573, Morganton
THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
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message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Good morning, Eli
We can put the permit on hold for now. Please go ahead and schedule four (4) 2nd species tests and let me know once you have the results.
Please let me know if you have any questions.
Best,
-Diana
Diana Yitbarek
Engineer II
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh, NC 27604-1170
;trfittps://attachments.office.net/owa/diana.yitbarek%4Oncdenr.goviservice.svc/s/GetAttachmentThumbnail?
id=AAMkADNmOTIxZjdhLTEyMWYtN DEzMS1iOGNiLTkxNmZhYWJmZThI MABGAAAAAAChNtXPy901QhuVQ14DYFU BBwBXZLmYUZH014ikbNYDUx2JAAAAAAEPAABXZLmYUZHO14ikbNYDUx2JAAC9Fej6AAABEgAQADsU Dks
G2-0bDg3pbgZetRwgZeh5s22CYcGDG8P5L4ZPj15-ij-OQFT_KupTpPDrNdTw140_ekyFyLAB9I1B4f3x0Vge0WZBVBo3P0Kmpnn5Xn MAAavVP_Qh6tHY2-EGzHmvcTvmOS9TjyOzfC19YZxh2cf5xV1gmM_K4TjW7Lkg3e3wxSUsDM
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.

Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <eself(Eci.morganton.nc.us>
Sent: Wednesday, January 20, 2021 08:13
To: Yitbarek, Diana <[e-mail]>
Subject: RE: [External] RE: NC0026573, Morganton
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana,
We looked through everything we have in the lab from previous ORC and Lab supervisor then we called our outside lab to determine if a second species test was completed.
Unfortunately we have no information showing the second species test was completed. The outside lab does have a spot open in February, would you like for us to go ahead
and schedule it so you can at least have one test result for 2nd species? It would be fat head minnow.
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana [mailto:diana.yitbarek@ncdencgov
Sent: Thursday, January 14, 2021 11:44 AM
To: Self, Eli
Subject: Re: [External] RE: NC0026573, Morganton
® THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
CAUTION: Don't be quick to click! We're counting on you! This email is from an external sender! Don't click on links or open attachments from unknown sources. If you know this is spam delete the message. If you believe this
message is a phish attack or you are unsure what to do, contact IRMS @ misGaci.morganton.nc.us.
Eli,
Thank you for your message and all the information you have provided so far.
You are correct. The language about that test is on page 9.
Best,
-Diana
Diana Yitbarek
Engineer II
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh, NC 27604-1170
j1ttps://attach ments.office. n et/owa/di a na.yitha rek%4oncd enr.gov/service.svc/s/G etAtta ch mentThu mb nai I?
id=AAMIcADNmOTIxZjdhLTEyMWYtNDEzMS1iOGNILTkxNmZhYWJmZThIMABGAAAAAAChNtXPy901QhuVQADYFUBBwMamYUZHcgaikbNYDUx2JAAAAAAEPAABXZLmYUZHq MMAYDUx2JAAC9Fej6AAABEgAQAIM3Myf
G2-0bDg3pbcgetRwilZeh5s22CYcGM8P5L4ZPj15-ij-OQFT_KupTpPDrNdTw140_ekyFyLAB9I1B4f3x0VgeOWZBVBo3POKmpnn5Xn MAAavVP_Qb6tHY2-EGzHmvcTvm059TjyOzfC19YZxb2cf5xV1gmM_K4TjW7Lkg3e3wx5UsDM
"Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be availabk via Microsoft Teams if requested. Thanks foryourpatience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <eselfC7a ci.morganton.nc.us>
Sent: Thursday, January 14, 2021 11:19
To: Yitbarek, Diana <[e-mail]>
Subject: [External] RE: NC0026573, Morganton
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana,
I am currently looking into the second species request. My Lab Supervisor is out today so I will have to wait to see if we have any results. I am unaware that we needed the 2nd
species test but looking over our permit, it does mention on page 9 of an "Additional Toxicity Testing Requirements". The language in this section of the permit is confusing but I
believe this is what you were asking about.
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana [mailto:diana.yitbarek@ncdencgov
Sent: Thursday, January 14, 2021 9:18 AM
To: Self, Eli
Subject: NC0026573, Morganton

LL THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY LL
CAUTION: Don't be quick to click! We're counting on you! This email is from an external sender! Don't click on links or open attachments from unknown sources. If you know this is spam delete the message. If you believe this
message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Dear Eli,
It was good to talk to you yesterday. Per our conversation about no plans for expansion for this facility, I will remove the 13.0 MGD flow tier page from the
permit. I need your support with the following:
1. I noted that the toxicity testing data results were recorded under section E.4. of the application, however, I can't tell whether a four
2nd/alternate/multiple species test was performed. Could you please double check with your lab results? and send me a scan of the 2nd species
test. Here is additional information on the testing.
2. Please confirm if the City still has 2 SIUs and 3 NSCIUs
Thanks,
-Diana
From: Yitbarek, Diana <diana.yitbarek(alncdenr.gov>
Sent: Tuesday, January 12, 2021 13:02
To: Self, Eli <eself ci.morganton.nc.us>
Subject: NC0026573, Morganton
When: Wednesday, January 13, 2021 9:00 AM-9:30 AM.
Where:
Tomorrow at 9 am works for me. Look forward to talking to you then. I will call you on the phone and I am adding a link to MS Teams in case we need to share
screens.
From: Self, Eli <eself ci.morganton.nc.us>
Sent: Tuesday, January 12, 2021 5:45:57 PM
To: Yitbarek, Diana <[e-mail]>
Subject: Re: [External] RE: Request - NC0026573, Catawba River Pollution Control Facility, City of Morganton, Burke County, ARO
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Unable to do 1 today. Can we try again at 9am tomorrow?
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Yitbarek, Diana <[e-mail]>
Sent: Tuesday, January 12, 2021, 11:04 AM
To: Self, Eli
Subject: Re: [External] RE: Request - NC0026573, Catawba River Pollution Control Facility, City of Morganton, Burke County, ARO
LL THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY LL
CAUTION: Don't be quick to click! We're counting on you! This email is from an external sender! Don't click on links or open attachments from unknown sources. If you know this is spam delete the message. If you believe this
message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Thanks for your message, Eli. I will give you a call at 1 pm. Let me know if that time works or if you prefer another time.
For now, I will attach the current form 2A with the instructions, and here is the link to the 40 CFR 122.21(m) and (n). We will go through it on our call.
Best,
-Diana
Diana Yitbarek
Engineer II
T: [phone]
i n .yitbarekCla ncdenr.guv
NPDES Municipal Permitting Unit
NC Department of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh, NC 27604-1170
G`Jfittps://attach ments.office. n et/owa/di a na.yitba rek%40ncd encgov/service.svc/s/G etAtta ch mentThu mb nai I?
id=AAMkADNmOTIxZjdhLTEyMWYtN DEzM51iOGNiLTkxNmZhYWJmZThI MABGAAAAAACbNtXPy901QbxVQ14DYFU BBwBXZLmYUZHgQ4ikbNYDUx2JAAAAAAEPAABXZLmYUZHgQ4ikbNYDUx2JAAC9Fej6AAABEgAQAIM3Myf
G2-OhDg3phgZetRwgZeh5s22CYcGfxi8P5L4ZPj15-ij-OQFT_KupTpPDrNdTw140_ekyFyLAB911B4f3xOVgeOWZBVBo3POKmpnn5Xn MAAavVP_Qh6tHY2-EGzHmvcTvmOS9TjyOzfC19YZxh2cf5xV1gmM_K4TjW7Lkg3e3wxSUsDM
°Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Self, Eli <eself(alci.morganton.nc.us>
Sent: Tuesday, January 12, 2021 10:35
To: Yitbarek, Diana <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>• Wiggs, Linda <[e-mail]>
Subject: [External] RE: Request - NC0026573, Catawba River Pollution Control Facility, City of Morganton, Burke County, ARO

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Diana,
On EPA Form 2A, what would you want me to check for section 1.6 on page 2, and section 1.5 on page 3?
When you are available, please give me a call as I have other questions.
Thanks,
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
From: Self, Eli
Sent: Tuesday, January 12, 2021 8:18 AM
To: Yitbarek, Diana'
Cc: Montebello, Michael J; Wiggs, Linda
Subject: RE: Request - NC0026573, Catawba River Pollution Control Facility, City of Morganton, Burke County, ARO
Diana,
I have received the email and I will work on gathering the information needed.
Thanks,
Eli Self
Superintendent
Wastewater Treatment Plant
Morganton, NC
828-438-5375
;city-seal-500px
From: Yitbarek, Diana[mailto:diana.yitbarekCancdenr.gp_v]
Sent: Tuesday, January 12, 2021 8:15 AM
To: Self, Eli
Cc: Montebello, Michael J; Wiggs, Linda
Subject: Request - NC0026573, Catawba River Pollution Control Facility, City of Morganton, Burke County, ARO
® THIS EMAIL ORIGINATED FROM OUTSIDE THE CITY
CAUTION: Don't be quick to click! We're counting on you! This email is from an external sender! Don't click on links or open attachments from unknown sources. If you know this is spam delete the message. If you believe this
message is a phish attack or you are unsure what to do, contact IRMS @ [e-mail].
Dear Eli Self,
I hope this message finds you well. As Linda mentioned previously, I am the assigned permit writer for the subject Facility. I recently started reviewing the
NPDES permit application for renewal submitted by the City on September 3, 2019, and have a couple of requests:
1. Please submit the signed Annual Monitoring and Pollutant Scan for 2016 - 2019. Scanned copies with your signature would suffice.
2. Please provide coordinates for upstream and downstream location points.
3. Please submit the mercury minimization plan (MMP).
4. Since the EPA form 2A has been updated, please complete this form. I'll attach it as an addendum to your application.
Thanks for your continued cooperation with the NPDES program and your work protecting public health and the environment. Please confirm the reception
of this email and let me know if you have any questions.
Best,
-Diana
Diana Yitbarek
Engineer II
T: [phone]
[e-mail]
NPDES Municipal Permitting Unit
NC D@pattment of Environmental Quality/ Division of Water Resources
Mailing: 1617 Mail Service Center, Raleigh, NC 27699-1617
Physical: 512 N. Salisbury Street Rm. 925T Raleigh, NC 27604-1170
'Mips://attachments.office.nesJowa/dianayitbarek%40ncdem.gov/service.svc/s/GetAttachmentThumbnail?
id=AAMkADNmOTbaj dhLTEyM W YtNDEzM S 1 iOGNiLlkocNmZhY W JmZTh1MABGAAAAAACbNtXPy901 Qbx V QI4DYFUBBwBXZLmYUZHgQ4ikbNYDUx2JAAAAAAEPAABXZLmYUZHgQ4ikbNYDUx2J.
G2-ObDg3pbgZetRwgZeh5s22CYcGOCi8P5L4ZPj 15-ij-OQFT_KupTpPDINdTw140_ekyFyLAB9I1B4f3xOVgeOWZBVBo3POKmpnn5XnMAAavVP_Qb6tHY2-EGzHmvaymOS9TjyOz1C19YZxb2cf5xV 1gmM_K4Tj5
*Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We can also be available via Microsoft Teams if requested. Thanks for your patience
and stay safe.
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.

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:EPA
Environmental Protection
United States
Agency
Office of Water
EPA 822-F-18-003
December 2018
Fact Sheet: Final 2018 Aquatic Life Ambient Water
Quality Criteria for Aluminum in Freshwaters
Summary
The EPA has published final updated aquatic life
ambient water quality criteria recommendations for
aluminum in freshwater under Section 304(a)(1) of
the Clean Water Act to reflect the latest scientific
knowledge. There are not enough data to support
the development of estuarine/marine aluminum
criteria at this time. Aluminum can inhibit an aquatic
organism's ability to regulate salt concentrations and
clog fish gills, potentially resulting in death or
affecting growth and reproduction.
States and authorized tribes can adopt these criteria
into their water quality standards or can adopt other
aluminum criteria that is scientifically defensible
based on local or site -specific conditions. These final
criteria are not a regulation, nor do they impose a
legally -binding requirement. These criteria provide
information for states to develop science -based
standards that reflect site -specific factors and are
protective against the effects of aluminum on
aquatic life.
Background
The EPA first published criteria for aluminum in
1988. The updated aluminum criteria better reflect
the latest science. Studies have shown that three
water chemistry parameters — pH, total hardness,
and dissolved organic carbon (DOC) —can affect the
toxicity of aluminum by affecting the bioavailability
of aluminum in the water to aquatic species. Unlike
the fixed acute and chronic values found in the 1988
criteria recommendation, these final 2018
recommended criteria provide users the flexibility to
develop site -specific criteria based on local water
chemistry.
The EPA released a draft of this criteria in 2017 for
public comment and has reviewed the comments
and updated the document.
What is Aluminum and How Does It Enter
the Water?
Aluminum is found in most soils and rocks. It is the
third most abundant element and the most common
metal in the earth's crust. Aluminum can enter the
water via natural processes, like weathering of rocks.
Aluminum is also released to water by mining,
industrial processes using aluminum, and in waste
water and drinking water treated with alum, an
aluminum compound.
How Does Aluminum Affect Aquatic Life?
Aluminum is considered a non -essential metal
because fish and other aquatic life do not need it to
function. Elevated levels of aluminum can affect
some species' ability to regulate ions, like salts, and
inhibit respiratory functions, like breathing.
Aluminum can accumulate on the surface of a fish's
gill, leading to respiratory dysfunction, and possibly
death. Aquatic plants are generally less sensitive to
aluminum than fish and other aquatic life.
What is a Water Chemistry Parameter and
Why is it Important?
Bioavailability is the measure of whether a substance
in the environment is available to affect living
organisms, like fish. The bioavailability of aluminum
is dependent on the chemistry of the water. The
more bioavailable the aluminum is, the more likely it
is to cause a toxic effect. The water chemistry
parameters that have the greatest impact on
aluminum's bioavailability are pH, total hardness,
and DOC.
pH: a low pH generally makes it easier for
aluminum to be dissolved, and therefore more
bioavailable. At higher pH, aluminum speciation
changes make it more bioavailable.
Hardness: generally, higher hardness values
mean there are more ions present. These ions

compete with aluminum and make aluminum
less bioavailable.
DOC: higher dissolved organic carbon reduces
bioavailability. Aluminum is bound to DOC,
making the aluminum less bioavailable to aquatic
organisms.
What are the Recommended Criteria for
Aluminum in Freshwater for the Protection
of Aquatic Life?
The recommended aquatic life criteria for aluminum
in freshwater depend on a site's water chemistry
parameters. Unlike the fixed values found in the
1988 criteria document, these criteria use Multiple
Linear Regression (MLR) models to normalize the
toxicity data and provide a range of acceptable
values. The criteria are calculated based on a site's
pH, total hardness, and DOC. See Table 1 for a
comparison of 2018 and 1988 criteria values.
For freshwater criteria, users can enter their site's
water quality parameters into the Aluminum Criteria
Calculator V.2.0.xlsm or use the lookup tables in the
criteria document's appendix. The resulting acute
criterion indicates that freshwater organisms would
be protected if the one -hour average concentration
is not exceeded more than once every three years
on average. The chronic criterion indicates that
freshwater organisms would be protected if the
four -day average concentration is not exceeded
more than once every three years on average.
Where can I find more information?
For more information and to view the aluminum
criteria document and the criteria calculator, please
visit EPA's website at www.epa.gov/wgc/aquatic-
life-criteria-aluminum or email Diana Eignor at
[e-mail].
Table 1: Comparison of the EPA's 2018 and 1988 National Recommended Aquatic Life Criteria for
Aluminum
Version
Freshwater Acute'
(1 hour,
total recoverable aluminum)
Freshwater Chronic'
(4-day,
total recoverable aluminum)
2018 Criteria
(vary as a function of a site's pH, total hardness, and DOC)
1- 4,800 µg/Lb
0.63 - 3,200 µg/Lb
1988 Criteria
(pH 6.5-9.0, across all total hardness and DOC ranges)
750 µg/L
87 µg/L
'Values are recommended not to be exceeded more than once every three years on average.
b Values will be different under differing water chemistry conditions.

Dear Permit Renewal Team,
We at the City of Morganton intend in this letter to appeal the decision to remove 8.0 MGD permit as
well as address potential changes of the permit. Included in this document are the following:
1. Rainfall and I&I challenges
2. Investments into wastewater system
3. Literature from engineer design studies
4. Nutrient removal (N&P) for 10.5 MGD permit
5. Literature from flow rate study in 2017
6. Removal of 13.0 MGD permit
7. PFAS Monitoring requirements
1. Rainfall and I&I Challenges
As spoke about in the meeting on 2/9/2022, we believe the challenges Morganton NC had during the year
2018 and 2019 were not indicative of normal operations and thus feel unwarranted to be moved to the 10.5
MGD permit. We have compiled data points from flow, rain totals and averages over the past several years to
show these challenges.
Below are graphs of the flow and total rain fall for the area of Morganton NC over the last 5/6 years.
7
6
5
2
4
3
0
L.
2
1
0
Wm
I 1
2016
2017
Rain vs Flow
2018
2019
Rain (inches) —•—Flow (MGD)
2020
•
2021
90
80
70
60
50
40
30
20
10
0
Rain Inches
E
0
NC0026573 Average Flow by Month Compared to Average Flow by Year
12.00
10.00
8.00
6.00
4.00
2.00
0.00
Ln Ln Lf1 Lo LD LD N N N CO CO CO 01 rn al 0 0 0
.-i .-i .-i .-i .-i .-i .-i .-i .-i .-i .-i .-i .-i .-i .-i N N N N N N
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N N
ci LA
O1 —1 Lr 6c1 LA O1 c1 LA O1 c1 Lr 6c1 Lr 6c1 Lr 60 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
—Flow (mgd) Average Flow

Referencing the graphs above, one challenge Morganton had was much higher than normal rainfall for the
calendar year of 2018, 2019 and 2020. As mentioned in the meeting, several other cities also had challenges
with the rainfall during this period of years. Morganton struggled with I&I issues. In December 2019, a major 30"
sewer line was repaired. There is a significant difference shown after the line was repaired, when looking at top
graph, 2020 shows higher amounts of rainfall with lower annual flow than in 2019.
2. Investments into wastewater system
Morganton continues to invest in its collection system. Capital projects are ongoing to repair sewer lines and
rehabilitate manhole. Currently there are engineered designs completed and near ready for bidding to construct
a new lift station to replace a major existing station. This is our largest and most extensive lift station, pumping
an estimated average of 1.5-2.0 MGD to the plant. This is estimated to cost around $5 million. Also currently is
an engineer design and planning phase for another lift station overhaul that will cost a significant amount of
money to complete in the coming year.
The WWTP has gone through three major construction projects during and since the previous permit
cycle. Over $20 million has been invested into the plant since 2010. The primary focus of the investments has
been to repair or replace failing infrastructure with some planning to address future regulatory requirements
and potential future expansion.
3. Literature from Engineer design study from 2015
Below are some excerpts from a "Secondary Process Conversion Feasibility Memorandum" provided by
engineering firm Freese and Nichols from year 2015. This study was used to design and construct our current
operating facility. Construction was completed in July 2019. What was constructed is briefly mention from study
proposal as the option #3:
"3. Construct two rectangular aeration basins with dimensions identical to the current EQ basin and
install blowers and fine -pore diffusers to provide aeration in both new basins. Retain the
Interim Aeration Basin and leave its surface aerators in place, allowing it to serve two purposes:
an EQ basin for storage of peak flows (with aeration/mixing), or a backup aeration basin to allow
maintenance of either aeration basin. It would still be advisable to convert Reaction Basin 3 for
peak flow storage in case the plant would receive peak flows while one of the aeration basins
was out of service for maintenance."
Next, using this design above, calculations were conducted and designed to accommodate the 2016 flow
average of 4.5 MGD, 8.0 MGD, and 10.5 MGD. Conclusions are following the chart below in the design used for
the authorization to construct from 2017.

Morganton WWTP Aeration Basin Sizing
Parameter Units
Current Conditions
Permitted Conditions
Min
Weekend
Average
Month
Ann Avg
Dsgn Q
Peaking
Factor
Peak
Month
Peaking
Factor
Peak
Day
Flow Rate MGD
2.3
4.5
8
10.5
Influent BCD mg/L
414
374
350
Primary BOD removal %
43.2
43.2
37.1
Primary effluent BOD mg/L
235
212
220
Primary effluent BOD lb/day
4,511
7,973
14,688
1.4
20,564
2.0
29,377
Influent NH3-IN mg/L
22
22
22
Primary NH3-N removal %
13.6
13.6
13.6
Primary effluent NH3-N mg/L
19
19
19
Primary effluent NH3-N lb/day
365
713
1,268
1.4
1,775
2.0
2,535
Number ABs in service ---
2
2
3
3
3
BOD Organic Loading Ib/1000 ft3-d
12.4
21.9
26.9
37.6
54
Oxygen required (AOR) Ib/hr
234
427
778
1,089
1,556
lb/day
5,627
10,242
18,671
26,139
37,341
lb/day/basin
1,876
3,414
6,224
8,713
12,447
"The following spreadsheet was developed to calculate process organic loadings (lbs BOD per thousand
cubic feet per day) as a function of influent flow rate, primary effluent concentrations, and the number
of aeration basins in service. The goal of the design is to provide enough aeration volume to keep the
permitted peak month BOD organic loading rate below, or just slightly above, 35 lbs BOD / 1000 cu ft -
day, a conservative design criterion for single -stage nitrification. The peak month and peak day organic
loadings are calculated using a typical organic loading peaking factor of 1.4 and 2.0 respectively.
The results indicate that to meet the permitted condition of 10.5 MGD the plant will require three
aeration basins. The existing EQ basin will be converted to an aeration basin. The two proposed basins
will match the existing EQ basin size: 225 ft long by 45 ft wide, with 18 ft SWD, and a volume of 1.363
MG. The design has incorporated flexibility to add a fourth aeration basin all of which can be zoned into
anaerobic and anoxic zones to provide biological nutrient removal if required in the future."
4. Nutrient Removal (nitrogen and phosphorous)
Below is information concerning total effluent nitrogen and total phosphorous for the calendar years of
2019-2020-2021. These years were selected because of the new secondary process that was constructed and
completed in 2019 and how plant is currently operated. Data was collected from eDMR and totals calculated.
2019
N mg/I P mg/I Month MG
N Ibs
P Ibs
Jan
11.2
3.84
278.41
26006
8916
Feb
11.1
2.72
282.99
26198
6420
Mar
10.5
0.376
217.49
19046
682
Apr
12.29
1.87
230.06
23581
3588
May
11.76
4.63
171.35
16806
6617
June
11.2
6.1
239.03
22327
12160
July
11.2
2.3
147.8
13806
2835
Aug
11.11
2.68
137.73
12762
3078
Sep
12.7
0.544
145.69
15431
661
Oct
11.32
9.97
155.33
14665
12916
Nov
12.07
1.91
164.78
16587
2625
Dec
12.37
4.38
183.12
18892
6689
Total
226,105
67,187
10.5 MGD permit limit
146,659
33,200
2020
N mg/I
P mg/I
Month MG
N Ibs
P Ibs
Jan
11.94
4.24
214.43
21353
7583
Feb
14.21
1.23
157.26
25412
2200
Mar
13.21
2.19
139.38
17326
2872
Apr
11.92
10.4
172.22
13856
12089
May
13.24
3.75
149.41
19017
5386
June
12.51
3.45
124.58
15588
4299
July
13.27
2.97
178.71
13787
3086
Aug
13.79
2.15
177.97
20553
3204
Sep
13.74
3.15
186.48
20394
4675
Oct
13.83
2.09
205.65
21509
3250
Nov
12.04
2.45
179.04
20650
4202
Dec
13.49
3.85
166.00
20143
5749
Total
229,589
58,596
10.5 MGD permit limit
146,659
33,200
2021
N mg/I P mg/I
Month MG
N Ibs
P Ibs
Jan
12.76
1.36
184.45
19629
2092
Feb
11.88
1.89
175.34
18275
2907
Mar
11.26
3.9
194.45
16466
5703
Apr
12.48
3.55
150.87
20239
5757
May
11.72
4.87
142.35
14747
6128
June
10.95
3.2
133.13
13000
3799
July
13.85
4.33
138.08
15378
4808
Aug
12.77
2.97
151.76
14706
3420
Sep
11.1
2.48
132.48
14049
3139
Oct
12.3
3.19
160.67
13590
3525
Nov
11.44
3.21
135.03
15329
4301
Dec
12.05
2.74
136.38
13570
3086
Total
188,978
48,665
10.5 MGD permit limit
146,659
33,200

As shown, the total nutrients vs. the 10.5 MGD purposed permit limits would not be met. Further construction
of a dedicated system to remove nutrients would have to be implemented. Below is an excerpt from the same
engineering study referenced above:
"At some point in the future, the state regulatory agencies probably will impose nutrient limits on the
City's treatment plant. Implementation of BNR processes for total nitrogen and phosphorus typically
requires conversion of one-fourth to one-third of the secondary treatment volume to anaerobic and
anoxic zones. At that point, four (4) dedicated aeration basins with internal nutrient removal
infrastructure will be needed to provide the 8.1 MGD permitted plant capacity."
5. Flow Rate Study
Morganton underwent a "Water and Wastewater Master Plan and Rate Study" in 2017 by engineering firm
Freese and Nichols. This study helped show that the city is not anticipating the need for the 10.5 MGD permit
flow in the upcoming years from population growth or projected industry needs.
Table ES.1 Projected Population
Year
Service Area Population
Water
Wastewater
2015
31,965
20,089
2020
32,886
20,833
2025
33,834
21,605
2035
35,812
23,235
Table 6.1
Table ES.2 Projected Wastewater Flows
Year
Projected
Wastewater
Service Area
Population
Average
Annual Dry
Weather Flow
(MGD]
2016
2D,089
5.5
2020
20,833
5.8
2025
21,605
6.0
2035
23,235
6.5
Historical Wastewater Flows
Average Per Capita Annual
Year Population WW1) Flow Flow Rainfall
(MGD} (gpcd) (inches)
2011
2012
2013
2014
2015
20,557
20,455
20,333
20,211
20, D89
4.6
4.7
222
229
36.3
44.0
5.8
283
4.7
230
4.6
231
75.9
47.3
61.3
Average
Maximum
An evaluation summary was taken from the rate study below:
"Wastewater Treatment Plant Capacity Evaluation:
...illustrates the historical average annual daily flow (AADF) from 2011 through 2015, projected
average annual daily flows for each planning year and the permitted AADF and 80% of the permitted AADF
under Part 1 and Part 11 of the NPDES permit.
By the year 2035, the average annual flow to the treatment plant is expected to reach 6.5 MGD. This will
trigger a move to Part II of the current NPDES permit and more stringent discharge limits. The City will
need to begin planning for a treatment plant expansion when the AADF reaches 80% of the Part II
permitted flow, 8.4 MGD. Based on the projected population and 2035 AADF of 6.5 MGD, the City will
not need to begin planning additional treatment capacity until after 2035."

Conclusion of engineering, further study will be required to determine the feasibility of the proposed 10.5 MGD
permit for the plant for the future if required. The greatest challenges would be the N&P removal, the removal
of additional sludge generated and settling capabilities of secondary system to comply with stricter parameters
such as BOD.
6. Removal of 13.0 MGD permit
We also appeal the decision of keeping the 13.0 MGD permit. Referencing the comments mentioned by the
Southern Environmental Law Center, the City agrees with said comments;
"....has no plans to expand. Expansion would require an "Authorization to Construct" from DEQ. We are
aware of no reason why DEQ would provide limits for a flow level that cannot currently be accommodated at
this facility. If expansion to 13 MGD flow becomes necessary, the proper course is to modify the permit active at
that time. DEQ should not attempt to preauthorize the expansion for purposes of Section 402 of the Clean
Water Act in this permit."
7. PFAS Monitoring requirements
In regards with the decision over email to potentially require monitoring for PFAS for industries and
plant effluent, we are not informed with the procedures or requirements needed to meet this proposal. We
request more information associated to these requirements or the monitoring be postponed to future permit
requirements as more solutions are developed for the removal of PFAS in wastewater streams.
Sincerely,
Eli Self — Wastewater Superintendent
Brad Boris — Water Resources Director

SOUTHERN
ENV RONMENTAL
CENTER
Via Electronic Mail and U.S. Mail
NCDEQ/DWR
NPDES Permitting Branch
c/o Diana Yitbarek
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[e-mail]
48 Patton Avenue, Suite 304 Telephone [phone]
Asheville, NC 28801 Facsimile 828-258-2024
November 29, 2021
Re: Draft NPDES Permit NC0026573
Dear Ms. Yitbarek:
Please accept these comments on behalf of the Catawba Riverkeeper Foundation and the
Southern Environmental Law Center concerning the renewal of NPDES Permit NC0026573 for
the Catawba River Pollution Control Facility in Morganton, NC.
The Catawba Riverkeeper Foundation's primary mission is to protect the 8,900 miles of
waterways in the Catawba—Wateree River Basin. The Foundation fulfills its mission through
monitoring, conservation advocacy, and public education and engagement. The Foundation's
members routinely use rivers and streams within the watershed for recreation; some members
rely on the river as a drinking water source, others for educational and business purposes. The
Southern Environmental Law Center works to protect the basic right to clean air, clean water,
and a livable climate; to preserve the South's natural treasures and rich biodiversity; and to
provide a healthy environment for all.
The Catawba River Pollution Control Facility processes domestic sewage from
Morganton and Glen Alpine, as well as industrial effluent from three Significant Industrial
Users.' Effluent is discharged from the facility into the Catawba River just above Lake
Rhodhiss. The wastewater treatments plants for Lenoir and Valdese also discharge into, or
directly upstream of, Lake Rhodhiss. Several municipalities get their drinking water from the
lake.2 The lake has a history of nutrient loading problems.3 The Catawba River Pollution Control
Facility ("the facility") has violated the terms of its existing NPDES permit multiple times in the
last several years.4
' Fact Sheet, Draft NPDES Permit No. NC0026573 (Oct. 26, 2021) at 1-2 (hereafter "Fact Sheet").
2 See Western Piedmont Council of Govemments, Western Piedmont Source Water Protection Plan (2014) at 1,
available at https://files.nc.gov/ncdeq/Water%20Resources/files/swap/SWPP%20Westem%20Piedmont.pdf.
3 See Burke County, 2011 Community Health Assessment at 16, available at
https://www.burkenc.org/ArchiveCenterNiewFile/Item/233.
4 See Environmental Protection Agency, ECHO Detailed Facility Report, available at https://echo.epa.gov/detailed-
facility-report?fid=110027948498.
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

Rather than address the facility's continued violations or ameliorate concerns about
water quality in Lake Rhodhiss, the draft permit fails to protect the Catawba River in violation of
both the Clean Water Act and North Carolina state law.
The draft permit must be withdrawn, substantially revised, and reissued for public
comment. Specifically, DEQ must make the following changes in particular:
• The permit must evaluate and include technology -based effluent limitations for
constituents discharged from the facility, including copper, antimony, zinc,
aluminum, NH3-N, fecal coliform, pH, dissolved oxygen, total residual chlorine,
arsenic, cyanide, lead, molybdenum, nickel, selenium, total phenolic compounds,
dimethyl phthalate, phosphorous, nitrogen, and methyl bromide. The omission of
these effluent limitations is especially egregious for copper, antimony, zinc, and
selenium, which DEQ acknowledges may threaten water quality standards.
• It is unclear if the Reasonable Potential Analysis contemplates discharges from
Unix Packaging LLC, a Significant Industrial User whose contribution to the
facility was not yet active during permit application. If those discharges were not
considered, the Reasonable Potential Analysis must be revised.
• The permit must include water -quality -based effluent limitations for constituents
that have a reasonable potential to affect water quality standards —namely,
copper, antimony, zinc, and selenium.
• The facility must disclose if per- and polyfluoroalkyl substances are present in its
discharge and, if so, DEQ must include appropriate limits in the NDPES permit.
• To comply with anti -backsliding provisions of the Clean Water Act, DEQ must
enforce the more stringent effluent limitations applicable under the 10.5 MGD
flow regime.
• Finally, the permit should rescind DEQ's attempt to pre -approve effluent
limitations for the facility under a 13 MGD flow regime since that rate has not
been requested by the facility, is not anticipated, and would require additional
approvals from DEQ.
To the extent these changes require modification to the facility's treatment process or
pipe network, we encourage Morganton to seek funding newly made available in the North
Carolina state budget and federal Infrastructure Investment and Jobs Act.
I. DEQ must impose technology -based effluent limits
A. The Clean Water Act requires DEQ to evaluate technologies available to treat
pollutants
Congress passed the Clean Water Act in 1972 "to restore and maintain the chemical,
physical, and biological integrity of the Nation's waters." 33 U.S.C. § 1251(a). To that end,
Congress established an "interim goal of [achieving] water quality which provides for the
protection and propagation of fish, shellfish, and wildlife and provides for recreation ... by July
1, 1983" and a longer -term "goal that the discharge of pollutants into the navigable waters be
eliminated by 1985." Id. § 1251(a)(1-2) (emphasis added). To meet those goals, Congress
2

prohibited the discharge of pollutants5 from point sources6 without a permit. See id. § 1311(a).
The Clean Water Act's National Pollutant Discharge Elimination System ("NPDES") permitting
program is structured around progressive improvements in pollution control over time to meet
Congress's "national goal" of eliminating discharges of pollutants. See id. § 1251(a)(1).7
NPDES permits control pollution through two primary mechanisms: first, by setting
limits based on the technology available to treat pollutants ("technology -based effluent limits")
and second, by setting any additional limits necessary to protect water quality ("water quality -
based effluent limits"). 33 U.S.C. §§ 1311(b), 1314(b); 40 C.F.R. § 122.44(a)(1), (d). Every
NPDES permit "shall" contain technology -based effluent limits ("TBELs"), which set the
minimum level of control required in every NPDES permit. 40 C.F.R. § 125.3(a). DEQ may
issue an NPDES permit only if the permit assures compliance with all technology -based and
water quality -based effluent limits. 33 U.S.C. § 1342(a)(1)(A); 40 C.F.R. § 122.43(a).
Stated differently, to comply with the Clean Water Act, a permit writer first imposes
TBELs and subsequently evaluates the need to impose additional water -quality based effluent
limits ("WQBELs") if the TBEL is insufficient to ensure compliance with water quality
standards. TBELs "are developed independently of the potential impact of a discharge on the
receiving water, which is addressed through water quality standards and water quality based
effluent limitations." EPA, NPDES Permit Writers' Manual at 5-1.8 A discharger must
implement technology -based standards, even if doing so goes beyond the level necessary to meet
water quality standards. Id.; see 15A N.C. Admin. Code 2B.0404(a) ("if the discharge is subject
to both technology based and water quality based effluent limitations for a parameter, the more
stringent limit shall apply"). Permit writers run afoul of the Clean Water Act by focusing
exclusively on WQBELs, in part, because this would foreclose the Congressional goal of
eliminating discharges of pollutants to navigable waters —discharges would be maintained, or
even increased, so long as they did not violate water quality standards.
For publicly -owned treatment works ("POTW"), like the Catawba River Pollution
Control Facility, compliance with TBELs is achieved, in part, by meeting secondary treatment
requirements. See 33 U.S.C. § 1311(b); 40 C.F.R. § 125.3(a)(1). Secondary treatment
requirements limit discharges of pollutants commonly associated with POTWs: oxygen
consuming waste (BOD5), suspended solids, and pH. See 40 C.F.R. § 133.102. Permit writers
must clearly present the data used to determine whether secondary treatment standards apply to a
5 "The term `pollutant' means dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge,
munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock,
sand, cellar dirt and industrial, municipal, and agricultural waste discharged into water." 33 U.S.C.§ 1362(6).
6 "The term `point source' means any discemible, confined and discrete conveyance, including but not limited to any
pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding
operation, or vessel or other floating craft, from which pollutants are or may be discharged." 33 U.S.C. § 1362(14).
North Carolina administers the NPDES program within its borders under delegated authority from EPA. See
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM MEMORANDUM OFAGREEMENT
BETWEEN THE STATE OF NORTH CAROLINA AND THE UNITED STATES ENVIRONMENTAL
PROTECTIONAGENCY REGION 4 (2007) available at https://www.epa.gov/sites/default/files/2013-
09/documents/nc-moa-npde s.pdf.
8 Available at https://www.epa.gov/sites/production/files/2015-09/documents/pwm 2010.pdf.
3

permitted facility, and thoroughly describe how these standards are applied in the fact sheet. See
NPDES Permit Writers' Manual at 5.1.3.6. But compliance with secondary treatment standards
is not a substitute for application of TBELs to other contaminants discharged through the POTW.
If other contaminants are discharged, the permit writer must evaluate and apply TBELs to them
as well.
North Carolina law similarly requires TBELs for other contaminants discharged from
POTWs. Secondary treatment requirements apply to "all municipal wastewater treatment
discharges and all discharges consisting primarily of domestic sewage" but "limits applicable to
industrial categories ... shall be applicable to any municipality if influent waste discharges from
industries in any single category account for 10 or more percent of its average daily wastewater
flow or the industrial discharges significantly impact the municipal system or its effluent
discharge." 15A N.C. Admin. Code 2B.0406(a). The Catawba River Pollution Control Facility
passes this threshold. The average daily flow from the facility is 6.4 MGD;9 2 MGD influent
flow is allocated to Case Farms (chicken processing) and 1.5 MGD is allocated to Seiren
industries (textiles).10 Thus, both federal and state law require additional TBELs, as well as the
secondary treatment standards applicable to POTWs, at the Catawba River Pollution Control
Facility. See 15A N.C. Admin. Code 2B.0406(b) (incorporating TBEL requirements from the
Clean Water Act).
Technology -based limits are derived from one of two sources: (1) national effluent
limitation guidelines ("ELGs") issued by EPA for various industries, 33 U.S.C. § 1314(b), or (2)
case -by -case determinations using the "best professional judgment" ("BPJ") of permit writers,
when EPA has not issued an ELG for an industry. See 33 U.S.C. § 1342(a)(1)(B); 40 C.F.R. §
125.3(c)(2). North Carolina rules likewise direct staff to calculate TBELs using "available
information" in the absence of a promulgated ELG. 15A N.C. Admin. Code 02B .0406(b)(3).
Here, where EPA has not issued effluent limitation guidelines for the relevant industries, TBELs
derive from the "best professional judgment" of the permit writer.
To be sure, the city of Morganton is not left alone to meet these requirements for
industrial dischargers using its wastewater treatment plant. The city is required to regulate its
industrial dischargers so that they do not cause the treatment plant to violate its own Clean Water
Act obligations. See 40 C.F.R. § 403.8(f)(1). 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." 11 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 who support municipally -owned treatment
plants. But the first step in this process is for DEQ to apply TBELs in this NPDES permit;
9 See Catawba River Pollution Control Facility, NPDES No. NC0026573 Renewal Application (Sept. 3, 2019) at
Section A.9 (hereafter "Renewal Application").
1° See City of Morganton, Annual Pretreatment Report for 2020 (Feb. 17, 2021), Allocation Table.
11 General Pretreatment Regulations for Existing and New Sources, 52 Fed. Reg. 1586, 1590 (Jan. 14, 1987)
(codified at 40 C.F.R. § 403).
4

Morganton can then require upstream industrial dischargers to reduce pollutant inflow to ensure
compliance with NPDES limits.
B. DWR failed to include TBELS for many constituents in the draft permit
Despite this obligation, DEQ left TBELs out of the draft NDPES permit for the facility,
except for those related to secondary treatment requirements (BOD5 and Total Suspended
Solids).12 The draft fact sheet indicates that DEQ established WQBELs for NH3-N, fecal
coliform, pH, dissolved oxygen, and total residual chlorine, but provides no indication that it
considered technology -based limits.13 The fact sheet states that the permit includes no standards
for "arsenic, cyanide, lead, molybdenum, nickel, selenium, zinc, total phenolic compounds,
dimethyl phthalate, [and] methyl bromide" specifically because "they did not demonstrate
reasonable potential to exceed applicable water quality standards."14 This may justify lack of
WQBELs but it cannot justify failure to evaluate TBELs. The fact sheet notes several other
constituents discharged through the POTW with no indication that DWR evaluated TBELs to
limit their discharge, including antimony, copper, silver, phosphorous, aluminum, and nitrogen.15
This approach does not comply with the Clean Water Act. As explained above, DWR
must evaluate whether there are technologies available to limit the discharges of these
contaminants and, if so, apply TBELs as appropriate. DWR may not skip directly to WQBELs
without evaluating TBELs (as it appears to have done with NH3-N, fecal coliform, pH, dissolved
oxygen, total residual chlorine, arsenic, cyanide, lead, molybdenum, nickel, selenium, zinc, total
phenolic compounds, dimethyl phthalate, phosphorous, nitrogen, and methyl bromide); fail to
evaluate the need for TBELs, or impose WQBELs, for constituents that appear to risk violations
of water quality standards, such as copper and antimony; or fail to evaluate TBELs for
constituents with no water quality standard, such as aluminum.
The failure to include TBELs for copper, antimony, zinc, and selenium is particularly
problematic because, according to the cover letter accompanying the draft permit, discharges of
these constituents risk violating water quality standards.16
Fortunately, technologies are available to limit the discharge of many of these pollutants.
For example, the use of a sand -chemically carbonized rubber wood sawdust column system has
12 Fact Sheet at 14.
13 Fact Sheet at 14-15.
14 Fact Sheet at 9.
15 Fact Sheet at 14-16.
16 See DEQ, Draft Permit No. NC0026573 Cover Letter (Oct. 26, 2021) at 1-2. The Fact Sheet and Cover Letter
appear to take inconsistent positions on whether discharges of these constituents risk water quality standard
violations. Compare Cover Letter at 2 (noting "RPA predicting a maximum effluent zinc concentration that is
greater than the allowable discharge concentration based on state water quality standards") with Fact Sheet at 8
(stating that zinc "did not demonstrate reasonable potential to exceed applicable water quality standards"). See also
Fact Sheet at 15 (stating that for zinc "RP [Reasonable Potential] exists").
5

been shown to reduce copper discharges in municipal wastewater," and several different
technologies have been used to reduce selenium discharges in nonmunicipal wastewater.'$ DEQ
must evaluate the potential for these and other technologies to minimize the discharge of
pollutants from the facility.
The Clean Water Act requires that DEQ evaluate and issue TBELs as appropriate for the
discharged constituents not already covered by secondary treatment standards for this facility.
Since there is no applicable ELG, DEQ must use its best professional judgement to determine
how available technology can effectively limit discharges of numerous constituents including
copper, antimony, aluminum, NH3-N, fecal coliform, pH, dissolved oxygen, total residual
chlorine, arsenic, cyanide, lead, molybdenum, nickel, selenium, zinc, total phenolic compounds,
dimethyl phthalate, phosphorous, nitrogen, and methyl bromide. By omitting this analysis and
neglecting to set appropriate effluent limits, the draft permit violates the Clean Water Act. The
agency cannot bring this permit into compliance without evaluating technologies available to
limit discharges of these pollutants.
IL DEQ must apply WQBELs to pollutants with a reasonable potential to violate
water quality standards
Even when TBELs are applied, the Clean Water Act prohibits DEQ from issuing a
NPDES permit that allows a violation of water quality standards. 33 U.S.C. § 1342(a)(1)(A); 40
C.F.R. § 122.43(a). Accordingly, WQBELs "shall be established for discharges that are found . .
. to have a reasonable potential to cause or contribute to exceedance of applicable water quality
standards." 15A N.C. Admin. Code 2B.0404. The WQBEL must be sufficient to "ensure that a
discharge does not cause or contribute to a contravention of state surface water quality
standards." Id. 2B.0403(15).
To fulfill this requirement, DEQ conducted a reasonable potential analysis ("RPA")
evaluating the potential for specific constituents to violate water quality standards. This RPA is
flawed and incomplete.
As an initial matter, it is unclear if the RPA accounted for pollutants discharged by Unix
Packaging LLC. Unix Packaging appears to have sought permission to discharge to the POTW
as a Significant Industrial User after Morganton submitted its NPDES renewal application.19 As
a result, there is no information about Unix Packaging available in the renewal application,
including no disclosure of pollutants associated with Unix Packaging's industrial processes. If
17 See Swarup Biswas, Treatment of Copper Contaminated Municipal Wastewater by Using UASB Reactor and
Sand -Chemically Carbonized Rubber Wood Sawdust Column, BIOMED RESEARCH INTERNATIONAL (Jan. 20, 2016)
available at https://www.hindawi.com/joumals/bmri/2016/5762781/.
18 See Lea Chua Tan, et al., Selenium: environmental significance, pollution, and biological treatment technologies,
BIOTECHNOLOGY ADVANCES (September -October 2016) available at
https://www. sciencedirect.com/science/article/abs/pii/S0734975016300623.
19 Documents available on DEQ's Laserfiche system indicate that Unix Packaging requested an Industrial User
Pretreatment Permit in early 2021; the NPDES renewal application was submitted to DEQ on Sept. 3, 2019.
6

the RPA does not account for industrial wastewater from Unix Packaging, DEQ must re -run its
RPA to assess the need for additional WQBELs.
More to the point, the cover letter to the draft permit concludes that "based on the
reasonable potential analysis," discharges of copper, antimony, zinc, and selenium may exceed
state water quality standards at various permitted flow levels.20 The accompanying fact sheet
likewise states that "[b]ased on the Reasonable Potential Analysis, RP exists" for those same
constituents except selenium, which is not discussed.21 Nevertheless, the draft permit includes
no limits on discharges of antimony, zinc, and selenium; only a requirement to monitor
discharges. Monitoring alone will not "ensure that a discharge does not cause or contribute to a
contravention of state surface water quality standards." 15A N.C. Admin. Code 2B.0403(15).
DEQ must revise the draft permit to add WQBELs for those constituents with a reasonable
potential to violate state water quality standards.
For copper, DEQ has proposed a new limit, but it gives the permittee one year from
permit issuance to develop a strategy for arresting copper discharges and three years from permit
issuance to comply with the limit. We are sympathetic to the need for the permittee to identify
the sources of the copper in its wastewater and make appropriate changes, but this time table is
too long. To be clear, if discharges of copper from the facility are currently causing or
contributing to water quality standard exceedances, then the facility is in violation of its existing
permit and the Clean Water Act. There is no need to delay the process of identifying the source
of the copper in the facility's wastewater until a new NPDES permit issues —that process should
start now. The Clean Water Act requires compliance schedules, such as the one proposed for
copper, to achieve water quality standards "as soon as possible." 40 C.F.R. § 122.47(a), see also
40 C.F.R. § 123.25 (requiring permitting authorities to administer delegated state programs in
conformance with this and other specified regulatory provisions). EPA's guidance to permit
writers elucidates the minimum criteria applicable to schedules of compliance for state water
quality standards. See NPDES Writers' Manual at 9.1.3. Echoing the regulatory requirements,
EPA directs permit writers to "[j]ustify and demonstrate that compliance with the final WQBEL
is required as soon as possible." See id. Furthermore, EPA guidance to regulators provides
eleven principles to assess whether a compliance schedule is consistent with the CWA and its
implementing regulations.22 This guidance reinforces the responsibility of state regulators to
ensure that the schedule is justified and requires compliance "as soon as possible."
The proposed copper compliance schedule does not meet these requirements. DEQ has
not explained why three years is necessary to identify sources of copper discharges and bring
them into compliance with water quality standards. The permit also appears to impose no
limitation on copper discharges in the intervening three-year period. This will allow unlimited
copper discharges for the next three years, despite the fact that these discharges risk violating
water quality standards now. DEQ should require the permittee to begin the process of
20 Cover Letter at 1-2.
21 Fact Sheet at 15-16.
22 See Memorandum from James Hanlon to Alexis Strauss, "Compliance Schedules for Water Quality -Based
Effluent Limitations in NPDES Permit" (May 10, 2007) available at
https://www3.epa.gov/npdes/pubs/memo complianceschedules may07.pdf.
7

identifying the sources of copper discharges now and to come into compliance within one year.
At the very least, DEQ should establish interim limits to progressively reduce copper discharges
as quickly as possible.
III. DEQ must require disclosure of any PFAS discharges and include appropriate
limits in the draft and final permit
The Clean Water Act's strategy of applying TBELs and WQBELs to reduce or eliminate
discharges of pollutants into navigable waters only works if permittees and permit writers know
what contaminants are discharged from a facility. Accordingly, a core requirement of the Clean
Water Act is that permittees assess and disclose the pollutants in their effluent. The Renewal
Application for the facility's NPDES permit is silent on whether per- and polyfluoroalkyl
substances ("PFAS") are discharged. DEQ must require the facility to disclose whether PFAS are
being discharged and, if so, apply appropriate limits.
The human health and environmental problems associated with PFAS exposure are now
widely known. EPA recently recognized PFAS as "an urgent public health and environmental
issue facing communities across the United States."23 EPA has called on "[e]very level of
government —federal, Tribal, state, and local—[ ] to exercise increased and sustained leadership
to accelerate progress to clean up PFAS contamination [and] prevent new contamination,"
specifically calling on states to "[1]everage NPDES permitting to reduce PFAS discharges to
waterways."24 Increasingly aware of the health problems associated with PFAS exposure,
several states have acted to reduce PFAS in drinking water. Just this month, Pennsylvania's
environmental agency proposed drinking water standards for two PFAS compounds of 14 and 18
parts per trillion, respectively.25
DEQ has acknowledged that disclosure of toxic pollutants, including PFAS, is required
by the Clean Water Act and state law. 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,
23 EPA, PFA Strategic Roadmap: EPA's Commitments to Action 2021-2024 at 1, available at
https://www.epa.gov/system/files/documents/2021-10/pfas-roadmap_final-508.pdf .
24 Id.
25 Frank Kummer, Pennsylvania DEP proposes strict limits for `forever chemicals' in drinking water, T
PHILADELPHIA INQUIRER (Nov. 16, 2021), available at https://www.inquirer.com/science/climate/pennsylvania-dep-
pfo s-pfo a-standards-20211116.html.
8

including but not limited to those contained in a priority pollutant analysis." 15A
N.C.A.C. 2H .0105(j) (emphasis added).26
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."27
DEQ's position in the Chemours enforcement case was correct. The Clean Water Act
generally prohibits discharges to streams and rivers. See 33 U.S.C. § 1311(a). The NPDES
permitting program is a limited exception to that prohibition, see Nat'l Ass'n of Home Builders v.
Def. of Wildlife, 551 U.S. 644, 650 (2007), and discharges under the program cannot be approved
unless they are disclosed, 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). EPA has
also 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.28
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. 40 C.F.R. § 403.8(f)(2)(ii).
Based on information included in the NPDES permit renewal application, there is the
potential that PFAS are discharged through the Catawba River Pollution Control Facility. The
textile industry has been recognized as a common source of PFAS.29 Seiren North America is a
textile facility which discharges through the POTW.30 Seiren uses "polyester yarn, dye stuffs,
surfactants, and finishing agents" to produce fabrics for automobiles.31 It is known that
"[f]inishing agents based on [PFAS] are widely used in textiles in order to achieve water, oil and
26 Amended Complaint, N C Dept. of Environmental Quality v. Chemours, 17 CVS 580, 6-7 (N.C. Super. 2018)
(hereinafter "N.C. DEQ Amended Complaint") (citing 33 U.S.C. § 1342(k), Piney Run Pres. Ass 'n v. Cty. Comm'rs
of Carroll Cty., MD, 268 F.3d 255, 265 (4th Cir. 2001)).
27 Id. at 33.
28 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33,526-31 (May 19, 1980).
29 See EPA, Multi -Industry Per- and Polyfluoroalkyl Substances (PFAS) Study — 2021 Preliminary Report at 8-1 —
8-4, available at https://www.epa.gov/system/files/documents/2021-09/multi-industry-pfas-study jreliminary-2021-
report 508 2021.09.08.pdf.
3° No information is provided in the application regarding Unix Packaging LLC so it is unclear if its processes also
potentially involved PFAS.
31 Renewal Application at 20.
9

dirt repellency of the material."32 PFAS have also been recognized as effective surfactants.33
Because PFAS are used in a broad array of industries, it is also possible that PFAS are used and
discharged by other facilities using the POTW as well, including non -significant industrial
facilities that are not listed in the POTW's permit application.
Given the potential for PFAS discharges by Seiren North America and other facilities
through the POTW, Morganton must assess and disclose whether PFAS are in fact being
discharged. As explained above, if a permit holder is discharging a pollutant that it did not
disclose in its NPDES permit application, it is in violation of the permit and the Clean Water
Act. Piney Run, 268 F.3d. at 268. DEQ, in turn, may not issue a permit that does not ensure
compliance with the Clean Water Act.
If PFAS are present in the effluent, DEQ must include appropriate limits in the NDPES
permit, starting with TBELs. Effective technologies, such as granular activated carbon, are
available to limit PFAS discharges. Recently, DEQ included TBELS for PFAS in its NPDES
permit for Chemours, noting that it was exercising its "professional judgement and experience in
establishing Technology Based Effluent Limits for [PFAS]" at the facility.34 DEQ must do the
same here.
If TBELs are insufficient to protect water quality, then DEQ must develop PFAS
WQBELS to ensure water quality standards are met. 33 U.S.C. § 1342(a)(1)(A); 40 C.F.R. §
122.43(a). This includes compliance with North Carolina's toxic substances standard, which
requires that "the concentration of toxic substances, either alone or in combination with other
wastes, in surface waters shall not render waters injurious to aquatic life or wildlife, recreational
activities, public health, or impair the waters for any designated uses." 15A N.C. Admin. Code
2B.0208(a). DEQ has recognized that PFAS "meet the definition of `toxic substance' under
North Carolina law.35 Finally, DEQ must also reasonably ensure compliance with North
Carolina's prohibition against allowing "[o]ils, deleterious substances, colored, or other wastes"
in waters classified as Class C waters —which include the section of the Catawba River that
would receive Morganton's discharge36—"to render the waters injurious to public health,
secondary recreation, or to aquatic life and wildlife, or adversely affect the palatability of fish,
aesthetic quality, or impair the waters for any designated uses." Id. 02B .0211(12).
32 See Danish Ministry of the Environment, Alternatives to perfluoroalkyl and polyfluoro-alkyl substances (PFAS)
in textiles (2015) at 7, available at https://www.enviro.wiki/images/f/f4/DEPA2015.pdf.
33 See supra note 29.
34 See NCDEQ, Responses to the Comments, Chemours Permit NC0089915 (Sept. 11, 2020), at 1, available at
https://deq.nc.gov/media/17001 /download.
35 N.C. DEQ Amended Complaint at 32 (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).
36 Morganton's treatment plant discharges to Water Supply IV waters, which are also protected as Class C waters.
Draft Permit at 2; 15A N.C. Admin Code 02B .0218.
10

As explained above, once appropriate limits are included in the NPDES permit,
Morganton can put the burden of cleaning up toxic PFAS pollution on the industries that create it
by regulating upstream users to limit their PFAS discharges.
IV. The draft permit violates the Clean Water Act's anti -backsliding provision
As recognized in the draft permit fact sheet, the Clean Water Act requires that "when a
permit is renewed or reissued, interim effluent limitations, standards or conditions must be at
least as stringent as the final effluent limitations, standards, or conditions in the previous permit."
Fact sheet at 13 (citing 40 C.F.R. § 122.44(1)); see 33 U.S.C. 1342(o) (statutory anti -backsliding
provision); 15A N.C. Admin. Code 02B .0408(25) (incorporating § 122.44 by reference). The
draft permit violates this condition on two fronts.
First, the active permit includes a weekly average BOD5 limit of 27.8 mg/L under the
10.5 MGD flow regime.37 The draft permit replaces this with a weekly average limit of 45 mg/L
under the same flow regime.38 DEQ must reinstate the 27.8 mg/L limit or explain why the
increase to 45 mg/L meets one of the limited exceptions to the anti -backsliding provision.
Second, both the current and draft permit explain that the facility is authorized to
discharge 8 MGD as a monthly average until "this facility reaches an annual average daily flow
equal to or greater than 6 4 MGD."39 Once that happens, the facility is authorized to discharge up
to 10.5 MGD under different, more stringent effluent limits.40 The NPDES permit application
indicates that "last year" annual average daily flow was 6.494 MGD and "this year" annual
average daily flow was 7.43 MGD.41 As a result, the facility is now subject to the more stringent
limits under the 10.5 MGD flow regime. Nevertheless, the draft permit appears to reset the clock
on this requirement, allowing the facility to apply the less stringent limits under the 8 MGD flow
regime for at least a year or until it "reaches an annual average daily flow equal to or greater than
6.4 MGD"—even though that has already happened. This is backsliding, which is explicitly
foreclosed by the Clean Water Act. DEQ cannot revert to the less stringent standard each time
this NPDES permit is renewed. Once the more stringent 10.5 MGD limits kick in —as they have
here —they must be carried forward to the next permit renewal.
V. DEQ should remove the effluent limits under the 13 MGD flow regime
The draft NPDES permit also purports to provide effluent limits in the event that the
facility is expanded to accommodate 13 MGD in flow.42 These effluent limits should be
removed. The facility is only designed to accommodate up to 10.5 MGD in flow and "has no
37 Final NPDES Permit No. NC0026573 (March 28, 20176) at 4.
38 Draft Permit at 5.
39 Final NPDES Permit No. NC0026573 (March 28, 20176) at 4; Draft Permit at 5.
49 Final NPDES Permit No. NC0026573 (March 28, 20176) at 4; Draft Permit at 5.
41 Renewal Application at 3.
42 Draft Permit at 7.
11

plans to expand."43 Expansion would require an "Authorization to Construct" from DEQ.44 We
are aware of no reason why DEQ would provide limits for a flow level that cannot currently be
accommodated at this facility. If expansion to 13 MGD flow becomes necessary, the proper
course is to modify the permit active at that time. DEQ should not attempt to preauthorize the
expansion for purposes of Section 402 of the Clean Water Act in this permit.
VI. Conclusion
We appreciate the opportunity to comment on this draft permit. As explained above, the
draft permit must be revised to ensure compliance with state and federal law. Revisions must
include application of TBELs for multiple constituents and application of WQBELs for
pollutants with a reasonable potential to impact water quality standards. Additionally, disclosure
of toxic pollutants such as PFAS should be mandated, and any applicable effluent limitations
must be issued. Finally, the permit must comply with the Clean Water Act's anti -backsliding
provisions by enforcing the more stringent effluent limitations already applicable to the facility
under a 10.5 MGD flow rate, and DEQ must not attempt to circumvent a proper Clean Water Act
Section 402 analysis by pre -approving effluent limitations at a flow rate not yet possible or
anticipated by the facility.
Please contact Patrick Hunter at [phone] or [e-mail] if you have any
questions regarding our concerns.
43 Fact Sheet at 1
44 Draft Perinit at 2.
12
Sincerely,
Patrick Hunter
Managing Attorney
Alyson Merlin
Associate Attorney

SOUTHERN
ENV RONMENTAL
CENTER
Via Electronic Mail and US. Mail
NCDEQ/DWR
NPDES Permitting Branch
c/o Diana Yitbarek
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[e-mail]
48 Patton Avenue, Suite 304 Telephone [phone]
Asheville, NC 28801 Facsimile 828-258-2024
July 22, 2022
Re: 2'd Draft NPDES Permit NC0026573
Dear Ms. Yitbarek:
Please accept these comments on behalf of the Catawba Riverkeeper Foundation and the
Southern Environmental Law Center concerning the 2nd Draft National Pollutant Discharge
Elimination System ("NPDES") Permit NC0026573 for the Catawba River Pollution Control
Facility in Morganton, NC. Our previously filed comments on the 1st Draft Permit for the
facility are also attached.
North Carolina Department of Environmental Quality ("DEQ") must implement more
stringent requirements for several constituents of concern to public health which were only
addressed through monitoring provisions.
First, the Clean Water Act ("CWA") requires that per- and polyfluoroalkyl substances
("PFAS") discharges, like all constituent discharges, be made only with proper disclosure to
DEQ and with appropriate effluent limitations.
It appears that the permittee has not disclosed any discharges of PFAS to DEQ.
Disclosure' must be made in the permit application_ Discharges not disclosed in a permit
application are not covered by an NPDES permit, and therefore violate the CWA.2 The purpose
of disclosure is two -fold: to make DEQ aware of the full scope of discharge from the applicant's
facility, and to allow the public to be fully informed during the public comment period. This is
because "permit writers need to know what pollutants are present in an effluent to determine
appropriate permit limits.i3 Additionally, public notice must be given about permitting decisions,
1 The Fourth Circuit has defined "disclosure" to require more than a "general description of the plant's operation" or
a "general[] aware[ness]" by the agency that a pollutant discharge is possible. S. Appalachian Mtn. Stewards V. A&G
Coal Corp., 758 F.3d 560, 568 (4th Cir. 2014). In other words, descriptions of an industrial process known by an
agency to be associated with or produce particular pollutant(s), like PFAS, does not satisfy the requirement that an
applicant disclose the pollutant(s) in its NPDES permit application. See id.
2 Piney Run Preservation Ass'n v. Civ Comm'rs, 268 F.3d 255, 268 (4th Cir. 2001) ("To the extent that a permit
holder discharges a pollutant that it did not disclose, it violates the NPDES permit and the CWA.")
3 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33516, 33526 (May 19, 1980).
Charlottesville Chapel Hill Atlanta Asheville Birmingham Charleston Nashville Richmond Washington, DC

including "a summary of each applicant's activities or operations that result in the discharge
described in the NPDES application." 15A NCAC 02H .0109(a)(3)(C). Such a summary would
be ineffective if all discharges were not included in the permit application.
In the new draft permit, DEQ has ordered twice annual monitoring for PFAS "[b]ased on
the categories of significant industrial users" which discharge through the Catawba River
Pollution Control Facility. Monitoring is not a substitute for required disclosure. Moreover,
because the Catawba River Pollution Control Facility handles discharges from industries
suspected to discharge PFAS, DEQ should make clear in final permitting documents that any
undisclosed pollutants, including PFAS, are not permitted and therefore violate the CWA.4 The
Tennessee Department of Environment and Conservation has made clear that undisclosed
discharges of PFAS are unpermitted for at least one permit for a facility that manufactures coated
paper products:
The facility's application did not report any forms of PFAS as chemicals that there
was the potential to discharge. The permittee has no permit shield for the discharge
of PFAS compounds because no such chemicals were disclosed in the permit
application or otherwise...5
DEQ should do the same here.
Once PFAS discharges are properly disclosed, DEQ must include technology -based
effluent limitations ("TBELs") for PFAS in the permit. The CWA requires TBELs be assessed
first, to be followed by water -quality based effluent limitations ("WQBELS") where necessary to
ensure compliance with water quality standards. 33 U.S.C. §§ 1311(b), 1314(b); 40 C.F.R. §
122.44(a)(1), (d).6 North Carolina law similarly requires TBELs. See 15A N.C. Admin. Code
2B.0406(b) (incorporating TBEL requirements from the Clean Water Act). Publicly Owned
Treatment Works ("POTW") permit limits must take into account whether the POTWs treat
industrial discharges: "Limits applicable to industrial categories ... shall be applicable to any
municipality if influent waste discharges from industries in any single category account for 10 or
more percent of its average daily wastewater flow or the industrial discharges significantly
impact the municipal system or its effluent discharge." 15A N.C. Admin. Code 2B.0406(a). The
Catawba River Pollution Control Facility passes this threshold. The average daily flow from the
facility is 6.4 MGD'; 2 MGD influent flow is allocated to Case Farms (chicken processing) and
1.5 MGD is allocated to Seiren North America (textiles), representing 31.3% and 23.4% of daily
4 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (EPA) (1998); Piney Run Pres. Ass 'n v. CO;. 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).
5 TDEC, NPDES Permit NO. TN0002330 (2020), Holliston Holdings, LLC, Addendum to Rationale,
https://perma.cc/4RKY-PKFG (emphasis added).
6 Assessing TBELs for constituents of concern is necessary even where analytical methods for pollution detection
are not yet perfected. "Nonetheless, even at levels where the accuracy of the data may be somewhat uncertain,
analytical information is useful to the permitting authority as a screening technique to identify the presence of a
pollutant and supply an estimate of its concentration." 49 Fed Reg. 37908, 38002 (Sept. 26, 1984). Thus, DEQ is not
absolved of its obligation to regulate PFAS if more effective technology is being developed.
See Catawba River Pollution Control Facility, NPDES No. NC0026573 Renewal Application (Sept. 3, 2019) at
Section A.9.
2

flow, respectively.89 As the draft permit notes,10 these SIUs represent industry categories likely
to discharge PFAS. As a textile facility representing over 20% of daily flow, Seiren North
America's discharge of PFAS is especially probable," and DEQ's failure to assess TBELs
associated with this effluent is concerning.
Finally, the new draft permit represents that the Reasonable Potential Analysis ("RPA")
found both silver and antimony have a likelihood of exceeding the maximum effluent
concentration allowable by state water quality standards. However, DEQ assigned only quarterly
monitoring requirements for these constituents. As detailed extensively in our original comments
and reiterated above, DEQ has an obligation under the CWA to issue both TBELs and WQBELs
for constituents covered by an NPDES permit which have the potential to cause or contribute to
water quality violations. The failure to set these limitations is even more egregious where, by
DEQ's own analysis, these constituents pose a threat to public health and environmental welfare
according to state water quality standards. We hope to see this error corrected in the final permit
for the Catawba River Pollution Control Facility.
Thank you for considering these comments. Please contact me if you have any questions
about the information contained in this letter.
Sincerely,
Alyson Merlin
Associate Attorney
[e-mail]
8 See City of Morganton, Annual Pretreatment Report for 2020 (Feb. 17, 2021), Allocation Table.
9 An unknown amount of the Catawba River Pollution Control Facility's daily flow is allocated to Unix Packaging,
LLC (beverage packaging). If this SIU represents 10% or more of the Catawba River Pollution Control Facility's
daily flow, the above arguments apply to this facility as well.
10 Draft Permit at 2 ("Based on the categories of significant industrial users (SIUs) discharges, there is a need to
assess PFAS compounds."); Draft Fact Sheet at 12 ("A PFAS monitoring Special
Condition is added based on the significant industrial users (SIUs) discharges.").
" See Multi -Industry Per- and Polyfluoroalkyl Substances (PFAS) Study — 2021 Preliminary Report,
ENVIRONMENTAL PROTECTION AGENCY, EPA-82 1 -R-2 1-004 (Sept. 2021).
3

The Division received comments for the City of Morganton/Catawba River Pollution Control Facility
draft NPDES permit NC0026573 (See full comments in fact sheet attachments) and provides the
following responses:
Comments from the Southern Environmental Law Center (SELC) and the Catawba Riverkeeper
Foundation on July 22, 2022, by Alyson Merlin
I. Comments suggesting stringent requirements for silver and antimony, constituents of concern to
public health which were only addressed thorough monitoring provisions
Response:
NC DEQ DWR applies WQBELs to pollutants with a reasonable potential (RP) to violate water quality
standards, for which there is a representative data set (e.g., typically 8 to 12 samples). Additional
representative data needs to be collected by the Permittee at the correct PQL. For comments and
calculation results for each pollutant, please see the reasonable potential analysis (RPA) results attached
to the Fact Sheet. NC DEQ evaluates up to the last 4.5 years of data to be used in the RPA per 40 CFR 122.
• Since there is not a representative data set for antimony, DEQ will maintain quarterly monitoring
for antimony.
• Upon review of the most recent silver monitoring data, all the values were less than detect after
September 2019; however, to collect additional representative data, DEQ is increasing monitoring
frequency to monthly with the requirement to use the most sensitive PQL. A review of the silver
data will be made in the permit renewal.
II. Comment on PFAS Discharges
a. DEQ must require disclosure of any PFAS discharges and include appropriate limits in the
draft and final permit
Response:
The Facility has reported that has not conducted any sampling for PFAS. Upon consideration that the
Facility discharges to WS-IV waters, has an active Pretreatment Program, and the categories of significant
industrial users (Sills) discharges prompt a need to assess PFAS compounds, the Division has revised the
PFAS monitoring requirement for this NPDES permit from 2/year to quarterly.
Since, to this date, no published final 40 CFR 136 wastewater sampling Method is available for PFAS
compounds, the PFAS requirement was added as a Special Condition which will take effect six months
after the Method is published in the final form in the Federal Register.

The Division received comments for the City of Morganton/Catawba River Pollution Control Facility
draft NPDES permit NC0026573 (See full comments in fact sheet attachments) and provides the
following responses:
Comments from the Southern Environmental Law Center (SELC) on November 29, 2021, by Patrick
Hunter and Alyson Merlin
I. Comments on technology -based effluent limitations (TBELs) and water -quality based effluent
limits (WQBELs)
a. The Clean Water Act requires DEQ to evaluate technologies available to treat pollutants
b. DWR failed to include TBELS for many constituents in the draft permit
a. DEQ must apply WQBELs to pollutants with a reasonable potential to violate water quality
standards
Response:
EPA establishes TBELs for POTWs that set minimum technology -based limits. This permit includes limits
that comply with minimum secondary technology -based limits for BOD5, TSS, pH, and percent pollutant
removal for BOD and TSS. In addition, water quality limits have also been applied as described in the
Factsheet.
15A N.C. Admin. Code 2B.0406(a) applies to categorical industries with pretreatment standards. For NC
DEQ DWR, categorical industries are industries with pretreatment standards. Seiren industries (textiles)
do not have pretreatment standards per current regulations. Case Farms (chicken processing) and Unix
Packaging are being currently regulated by the POTW under current Pretreatment requirements.
NC DEQ DWR applies WQBELs to pollutants with a reasonable potential (RP) to violate water quality
standards, for which there is a representative data set (e.g., typically 8 to 12 samples). Additional
representative data needs to be collected by the Permittee at the correct PQL. For comments and
calculation results for each pollutant, please see the reasonable potential analysis (RPA) results attached
to the Fact Sheet. NC DEQ evaluates up to the last 4.5 years of data to be used in the RPA per 40 CFR 122.
Lastly, DEQ has decided to maintain the Copper Compliance Schedule in the NPDES permit. The Facility
has identified the potential industrial sources for copper in October 2017. Within one (1) year of the
permit effective date, the Permittee shall submit to DEQ a Corrective Action Plan (CAP) for Division
approval (which could include a pretreatment local limit assessment), summarizing the strategy or actions
to be taken to achieve compliance with the copper limitations listed in Section A. (1.). This plan will include
specific dates for the completion or implementation of each action. The Permittee may request the final
limit be placed in effect and remove the Compliance Schedule.
III. Comment on PFAS Discharges
a. DEQ must require disclosure of any PFAS discharges and include appropriate limits in the
draft and final permit

Response:
Upon consideration and review of the industrial activity in the City and the status of upcoming PFAS 40
CFR 136 Methods and regulations, the Division has added a PFAS-related requirement to this NPDES
permit.
Since, to this date, no approved 40 CFR 136 sampling Method exists for PFAS compounds in the
wastewater matrix, the PFAS requirement was added as a Special Condition which will take effect six
months after the Method is published in the final form in the Federal Register.
IV. Comment on anti -backsliding
a. The draft permit violates the Clean Water Act's anti -backsliding provision
Response:
Based on the information provided by the POTW, the existing wastewater Facility cannot currently meet
all the limits at 10.5 MGD. The permit will require an Authorization to Construct (ATC) and engineering
certification before moving to the 10.5 MGD flow tier. Therefore, the 8.0 MGD effluent limitation page
will remain in place with the ATC condition.
V. Comment on expanded flow tier, 13.0 MGD
b. DEQ should remove the effluent limits under the 13 MGD flow regime
Response:
DEQ is maintaining the authorized 13.0 MGD flow tier limitation page at the request of the Permittee.
Comments from the City of Morganton WWTP's team on November 29, 2021, by Eli Self and Brad Boris
I. Rainfall and I&I challenges
II. Investments into wastewater system
III. Literature from engineer design studies
IV. Nutrient removal (N&P) for 10.5 MGD permit
V. Literature from flow rate study in 2017
VI. Removal of 13.0 MGD permit
VII. PFAS Monitoring requirements
Response:
The Division has revised the status for nutrients in the Lake Rhodhiss area and based on the available
information has decided to remove the proposed nutrients limits for the 10.5 MGD flow tier.
The Division acknowledges that the Facility is not ready to transition to the 10.5 MGD flow tier; therefore,
permit authorization requirements have been updated to facilitate the transition to the higher flow tier.
Per Facility's email received on March 30, 2022, the 13.0 MGD flow tier will be maintained in the permit.
Due to the timeframe projected before these limits become effective, the nutrient limitations in the
existing permit have been maintained. If you wish to remove this limits page, this can be addressed
sometime in the future.

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
MEMORANDUM
To:
NORTH CAROLINA
Environmental Quality
October 26, 2021
Kimberly Barnett and Nicole Hairston
NC DEQ / DWR / Public Water Supply
Asheville Regional Office
From: Diana Yitbarek
NC DEQ / DWR / Municipal Permitting Unit
Subject: Review of Draft NPDES Permit NC0026573
Catawba River Pollution Control Facility
Outfall 001/ Catawba River
Burke County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
November 26 , 2021. If you have any questions on the draft permit, please contact me at 919-707-9130
or via e-mail [[e-mail]].
RESPONSE: (Check one)
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
Concur with the issuance of this permit provided the facility is operated and maintained properly,
the stated effluent limits are met prior to discharge, and the discharge does not contravene the
designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signature: ��tet- Date: 1 1 /01 /2021
D_E
NORTH CAROLINA
Department of Environmental tluali�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

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NC0026573 City of Morganton
O O O O.- N M V O O O O O O.- N M V OO 0000000000 0000000000
N N N N N N N N N N N N N N N N N N N N
NC0041696 Town of Valdese

Morganton News Herald
Advertising Affidavit
PO Box 968
Hickory, NC 28603
NC DENRIDWQ
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
Account Number
3142720
Date
October 28, 2021
Date
Category Description
Ad Number Ad Size
10/28/2021
Legal Notices
Public Notice North Carolina Environmental Management Comi 0000750084
Publisher of
Morganton News Herald
Burke County
Before the undersigned, a Notary Public duly commissioned, qualified.
and authorized by law to administer oaths, personally appeared the
Publisher's Representative who by being duly sworn deposes and says:
that he/she is authorized to make this affidavit and sworn statement: that
the notice or other legal advertisement_ a copy of which is attached hereto,
t+'as published in the News Herald on the following dates:
1012812021
2x31 L
and that the said newspaper in which such notice, paper document, or
legal advertisement was published. was at the time of each and every such
publication, a newspaper meeting all the requirements and qualifications
of Section 1-597 of the General Statutes of North Carolina.
Billing Representative
Newspaper reference: 0000750084
Sworn to and subscribed before me, this 28th day of October, 2021.
Notaii Public
State of Virginia
County of Hanover
My commission expires:
Kimberly Kay Harris
NOTARY PUBLIC
Commonwealth of Virginia
Reg. No. 356753
Commission Exp. Jan. 31, 2025
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

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 NC0026573 Cata-
wba River Pollution Control Facility The North Carolina Environmental
Management Commission proposes to issue a NPDES wastewater dis-
charge permit to the person(s) listed below. Written comments regarding
the proposed permit will be accepted until 30 days after the publish date
of this notice. The Director of the NC Division of Water Resources (DWR)
may hold a public hearing should there be a significant degree of public in-
terest. Please mail comments and/or information requests to DWR at the
above address. Interested persons may visit the DWR at 512 N. Salisbury
Street, Raleigh. NC 27604 to review information on file. Additional infor-
mation on NPDES permits and this notice may be found on our website: ht
tp://deq.ncgov/about/divisions/water-resources/water-resources-
permits/wastewater-branch/npdes-wastewater/public-notices, or by call-
ing [phone]. The City of Morganton (P.O. Box 3448 Morganton, NC
28655) has requested renewal of the NPDES Permit NC0026573 for its
Wastewater Treatment Plant in Burke County. This permitted facility dis-
charges treated domestic and industrial wastewater to the Catawba River
in the Catawba River Basin. Ammonia, biochemical oxygen demand, dis-
solved oxygen, fecal coliform, pH, total copper, total residual chlorine, to-
tal nitrogen, total phosphorous, and total suspended solids are water quali-
ty limited parameters in both permits. These discharges may affect fu-
ture allocations in these segments of the Catawba River.
Publish: October 28, 2021.

Morganton News Herald
Advertising Affidavit
PO Box 968
Hickory, NC 28603
NC DENR/DWQ
ATTN: WREN THEDFORD
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
Account Number
3142720
Date
June 16, 2022
Date
Category Description
Ad Number Ad Size
06/16/2022 Legal Notices Public Notice North Carolina Environmental Management Comi 0000788673 2 x 31 L
Publisher of
Morganton News Herald
Burke County
Before the undersigned, a Notary Public duly commissioned, qualified,
and authorized by law to administer oaths, personally appeared the
Publisher's Representative who by being duly sworn deposes and says:
that he/she is authorized to make this affidavit and sworn statement; that
the notice or other legal advertisement, a copy of which is attached hereto,
was published in the News Herald on the following dates:
06/16/2022
and that the said newspaper in which such notice, paper document, or
legal advertisement was published, was at the time of each and every such
publication, a newspaper meeting all the requirements and qualifications
of Section 1-597 of the General Statutes of North Catolina.
Billing Representative
Newspaper reference: 0000788673
Sworn to and subscribed before me, this 16th day of June, 2022.
2I
Notary Public
State of Virginia
County of Hanover
My commission expires:
rco220
Kimberly Kay Harris
NOTARY PUBLIC
Commonwealth of Virginia
Reg. No. 356753
Commission Exp. Jan. 31, 2025
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

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 NC0026573 City of
Morganton The North Carolina Environmental Management Commission
proposes to issue a NPDES wastewater discharge permit to the person(s)
listed below. Written comments regarding the proposed permit will be ac-
cepted until 30 days after the publish date of this notice. The Director of
the NC Division of Water Resources (DWR) may hold a public hearing
should there be a significant degree of public interest. Please mail com-
ments and/or information requests to DWR at the above address. Interest-
ed persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC
27604 to review information on file. Additional information on NPDES per-
mits and this notice may be found on our website: http://deq.nc.gov/abou
t/divisions/water-resources/water-resources-permits/wastewater-
branch/nodes-wastewater/public-notices or by calling [phone].
The City of Morganton (P.O. Box 3448 Morganton, NC 28655) has request-
ed renewal of the NPDES Permit NC0026573 for its Wastewater Treat-
ment Plant in Burke County. This permitted facility discharges treated do-
mestic and industrial wastewater to the Catawba River in the Catawba
River Basin. Ammonia, biochemical oxygen demand, dissolved oxygen, fe-
cal coliform, pH, total copper, total residual chlorine, and total suspended
solids are water quality limited parameters. This discharge may affect fu-
ture allocations in this segment of the Catawba River.
Publish: lune 16, 2022.