NC0081256_Draft Permit_20220906

ROY COOPER
Governor \lig}
ELIZABETH S.BISER
Secretary
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
September 09, 2022
Mr. Robby Stone
City of High Point PO Box 230
High Point,NC,
27261-0230
Subject: DRAFT NPDES PERMIT NC0081256
Frank L Ward WTP
Grade I PC WPCS
[15A NCAC 08G .0306]
Guilford County
Dear Mr. Stone
In October of 2021,the Division noticed a draft NPDES permit for your facility. This draft included a
proposed addition of monthly monitoring for 1,4 Dioxane. After this notice process the Division has
worked to update its strategy for addressing 1,4 Dioxane. The updated strategy will not require
monitoring of 1,4 Dioxane for Water Treatment Plants, it instead focuses on areas that are more likely
potential sources of this pollutant. With this change,the Division is also moving to update your draft
permit to remove the proposed 1,4 Dioxane monitoring and re-notice your permit . All other change
proposed in the previous draft remain in place.Enclosed with this letter is a copy of the new draft permit
for your facility. Please review the draft very carefully to ensure thorough understanding of the conditions
and requirements it contains.
This draft contains the following changes from the existing permit:
• Updated discharge description language on the Supplement to Permit Cover Sheet
• Added description of treatment components to Supplement to Permit Cover Sheet
• Added facility classification above effluent table(A.1).
• Iron monitoring requirements have been removed from the permit. There are no longer action
level standards for this parameter.
• Turbidity monitoring was reduced to 2/month as there is no limit present(per current WTP
guidance)
• Copper Monitoring has been removed from the permit.Review of data from the past permit cycle
demonstrated no reasonable potential for the discharge of copper from this facility to exceed
water quality standards.
• Instream and effluent hardness monitoring requirements were removed. Copper was previously
the only hardness-dependent metal being sampled. As of this renewal, copper monitoring
requirements are removed, so hardness monitoring is no longer needed.
• The limit for Fluoride has been removed,and monitoring has been reduced from monthly to
quarterly. Review of data from the past permit cycle demonstrated no reasonable potential for the
discharge of fluoride from this facility to exceed water quality standards,however monitoring
will remain since fluoride is used in the water treatment process.
• The requirement to conduct sampling concurrent with WET testing is no longer part of the
Division's permitting strategy. The footnote requiring concurrent sampling with WET testing has
been removed from A(1).
• Section A. (2)has been updated to include language for electronic submittal of toxicity results
D_� North Carolina Departtr ent of EnviMail Service Center I Raleigh.North Carolina 27699-1611
i�.rar ___ e./ 919.707.9000

• The language of Section A.(4)Electronic Reporting of Monitoring Reports has been updated to
be consistent with current federal requirements for electronic reporting.
Please note that the receiving stream is listed as an impaired waterbody on the North Carolina 303(d)
Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream data
will continue to be evaluated. If there is noncompliance with permitted effluent limits and stream
impairment can be attributed to your facility, then mitigative measures may be required.
The NPDES standard conditions(Parts II,III, and IV)that are a part of the permit are not included in this
draft document (cover, map, and Part I). The conditions are the same as in your current permit. The latest
version is available at https://bit.ly/2BZ4xxx and can be viewed online or downloaded as a PDF file.
With this notification, the Division will solicit public comment on this draft permit by publishing a notice
in newspapers having circulation in the general Guilford County area,per EPA requirements. Please
provide your comments, if any,to me no later than 30 days after receiving this draft permit.
Following the 30-day public comment period,the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft,please
contact me via email at [[e-mail]].
Sincerely,
Emily Richards
Environmental Specialist II
NPDES Permitting Program
ec: NPDES files
Winston Salem Regional Office
DWR Public Water Supply—Eric Hudson Aquatic Toxicity Branch
D_E Q North Cazolini Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I l61 I Mail Service Center I Raleigh.North Carolina 2 7699-1 61 1
oiira..M r \ �/ 919.707.9000

Permit NC0081256
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of High Point
is hereby authorized to discharge wastewater from a facility located at the
Frank L. Ward WTP
121 North Pendleton Street
High Point
Guilford County
to receiving waters designated as an unnamed tributary to Richland Creek in the Cape Fear River Basin
in accordance with effluent limitations,monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on August 31, 2026.
Signed this day
Richard E. Rogers, Jr.
Director, Division of Water Resources
By Authority of the Environmental Management Commission
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Permit NC0081256
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility,whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore,the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
The City of High Point
is hereby authorized to:
1. Continue to operate a conventional Water Treatment Plant with a discharge for filter-backwash
wastewater. This water treatment plant currently has a design potable flowrate of 24 MGD and a
current maximum,monthly average wastewater discharge of 1.01 MGD. This facility is located at
the Frank L. Ward WTP at 121 North Pendleton Street, in High Point, in Guilford County. Water
and wastewater treatment consists of:
• Super Pulsator with 2 treatment trains capable of treating 12 MGD each
• Chemical additions:
- Fluoride addition
- Aluminum sulfate
- Clarifloc A 3310 (polymer)
- Sodium Hydroxide
- Sodium Hypochlorite
- DC 22-L Corrosion Inhibitor(blended silicate-phosphate compound)
• Two (2) settling lagoons
2. Discharge from the South Lagoon via outfall 001 at the location specified on the attached map into
an unnamed tributary to Richland Creek [HUC: 030300030103; Stream Segment:17-7-(0.5)],
classified WS-IV* waters in the Cape Fear River Basin.
3. Discharge from the North Lagoon on an as-needed basis via outfall 002 (approximately 400 feet
upstream of outfall 001)into an unnamed tributary to Richland Creek [HUC:030300030103; Stream
Segment:17-7-(0.5)],classified WS-IV* waters in the Cape Fear River Basin.
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Permit NC0081256
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -FINAL
[15A NCAC 02B .0400 et seq., 15A NCAC 02B.0500 et seq.]
Grade I Physical Chemical WPCS [15A NCAC 08G .0306]
During the period beginning on the effective date of this permit and lasting until expiration,the Permittee is
authorized to discharge from outfall 001 or outfall 002. Simultaneous discharge from both outfalls is prohibited.
Such discharges shall be limited and monitored' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Monthly Daily Measurement Sample Type Sample
Parameter Code Average Maximum Frequency Location
Flow 50050 Continuous Recording Effluent
Total Suspended Solids C0530 30.0 mg/L 45.0 mg/L Weekly Grab Effluent
pH 00400 >_6.0 s.u.and<_9.0 s.u. Weekly Grab Effluent
Total Residual Chlorine2 50060 17 pg/L Weekly Grab Effluent
Turbidity 00070 2/Month Grab Effluent
Aluminum 01105 Quarterly Grab Effluent
Manganese 01055 Quarterly Grab Effluent
Fluoride4 00951 Quarterly Grab Effluent
Ammonia Nitrogen5 C0610 Quarterly Grab Effluent
Total Phosphorous(TP) C0665 Quarterly Grab Effluent
Total Nitrogen(TN) C0600 Quarterly Grab Effluent
Whole Effluent Toxicity Monitoring6 TGP3B Quarterly Grab Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the Division's eDMR system. See
Condition A.(4.).
2. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit.
However,the Permittee shall continue to record and submit all values reported by a North Carolina certified
laboratory(including field certified),even if these values fall below 50 µg/L.
3. Monitoring After a minimum of 12 samples have been taken over a 12-month period,the permittee may request the
Division reevaluate the monitoring frequency for 1,4-dioxane.
4. Fluoride monitoring requirements apply only if the Permittee backwashes with fluoridated finished water.
5. Ammonia Nitrogen should be monitored if the Permittee uses chloramines(adds ammonia to chlorinated water)or
secondary disinfection prior to backwashing.
6. Ceriodaphnia dubia 7-day pass/fail test @ 90%concentration. See Condition A. (2.)for toxicity testing
requirements.Toxicity testing should be performed during the months of January,April,July and October,and
sampling should coincide with sampling for parameters covered by footnote 3.
All samples must be collected from a typical discharge event.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 9

Permit NC0081256
A. (2.) CHRONIC TOXICITY MONITORING (QUARTERLY)
[15A NCAC 02B .0500 et seq.]
The permittee shall conduct quarterly chronic toxicity tests using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised December 2010, or subsequent
versions.
The effluent concentration defined as treatment two in the procedure document is 90 %. The testing
shall be performed as a Ceriodaphnia dubia 7-day pass/fail test. The tests will be performed during the
months of January,April,July and October. These months signify the first month of each three
month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be
obtained during representative effluent discharge and shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered electronically using
the Divisions eDMR system for the months in which tests were performed, using the parameter code
TGP3B. Additionally, DWR Form AT-1 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh,NC 27699-1621
Or, results can be sent to the email, [e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity(AT) test
form indicating the facility name,permit number, pipe number,county, and the month/year of the report
with the notation of"No Flow"in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately. Upon submission of a valid test, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re-opened and
modified to include alternate monitoring requirements or limits.
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Permit NC0081256
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A. (3.) PERMIT RE-OPENER: NUTRIENT MONITORING
[G.S. 143-215.1(b)]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the North
Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114(a) and Part II sections B-12
and B-13 of this permit,the Director may reopen this permit to require supplemental nutrient monitoring
of the discharge. The purpose of the additional monitoring will be to support water quality modeling
efforts within the Cape Fear River Basin and shall be consistent with a monitoring plan developed
jointly by the Division and affected stakeholders. In addition, the results of water quality modeling may
require that limits for Total Nitrogen and Total Phosphorus be imposed in this permit upon renewal.
A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements (Supersedes Section D. (2.) and Section E. (5.) (a)l
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. The eDMR system may be
accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
Page 5 of 9

Permit NC0081256
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
following address:
NC DEQ/Division of Water Resources/Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
See "How to Request a Waiver from Electronic Reporting" section below.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported via the eDMR system no later than the last calendar day of the month following the
completed reporting period. Regardless of the submission method, the first DMR is due on the last
day of the month following the issuance of the permit or in the case of a new facility, on the last day
of the month following the commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act(CWA) Section 316(b)Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program)that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at: https://www.federalregister.gov/documents/2015/10/22/2015-
24954/national-pollutant-discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the"Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
Page 6 of 9

Permit NC0081256
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to
the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data
and reports shall be submitted electronically to the Division unless the permittee re-applies for and is
granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting
waivers are not transferrable. Only permittees with an approved reporting waiver request may
submit monitoring data and reports on paper to the Division for the period that the approved
reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
1'I
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system,registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"1 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 fines and imprisonment for knowing violations."
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Permit NC0081256
5. Records Retention ISunniements Section D. (6.11
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. Thisperiod maybe extended byrequest of the Director at anytime [40 CFR
p q
122.41].
Page 8 of 9

Permit NC0081256
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Page 9 of 9