NC0078115_Fact Sheet_20221014

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO078115
2022 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/Facility Name:
Aqua North Carolina, Inc. Gre stone Subdivision WWTP
Applicant Address:
202 Mackenan Court; Cary, NC 27511
Facility Address:
1549 Creek Bed Road; Kernersville, NC 27284
Facility Class/Permit Status:
Grade II Biological WPCS / Renewal
Permitted Flow (as
built)
0.185 MGD (0.032
MGD)
Type of Waste
98.5% Domestic
1.5% WTP backwash
Receiving Stream
UT Right Fork of Belews
Creek Dean Creek
Stream Class / ID
C / 22-27-3
River Basin
Roanoke
Subbasin
03-02-01
HUC
030101030303
USGS Too
C18NE Belews Ceek
7 10 Sum Win cfs
0 0.08 as built
30 2 cfs
0.09 as built
Avg. Stream Flow cfs
0.44 as built
IWC % sum/win
100 as built
County
Forsyth
Regional Office
WSRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / August 3, 2022 updated Oct 14, 2022
Does permit need daily max NH3 limits?
Yes - Already in permit
Does permit need TRC limits/language?
Yes - Already in permit
Does permit have toxicity testing?
Yes - In permit
Does permit have Special Conditions?
Yes - Chronic Tox and Reo ener
Does permit have instream monitoring?
Yes - Temp, DO and Hardness
Stream on 303 d List? For w arameter?
No - Mercury statewide issue only
Any compliance concerns?
No Enforcements or Violations
Any modifications since lastpermit?
None in the application
New expiration date:
I February 28, 2027
FACILITY OVERVIEW:
This facility treats domestic waste from a subdivision serving a population of 323 people and also accepts
uranium -filter generated backwash from ion -exchange treatment of well water from three adjacent community
well treatment systems. The facility has a permitted flow of 0.185 MGD and as built flow rate of 0.032.
Expansion to 0.185 MGD will require an Authorization to Construct (ATC) from the Division, construction of the
expanded system in compliance with the ATC and relocation of the discharge point to outfall 002 as shown on
the site map. The current treatment system includes the following wastewater treatment components:
• influent pump station
• flow splitter
• bar screen
• flow -equalization basin
• dual (2) extended aeration basins
• dual (2) clarifiers
• sludge holding tank
• chlorination [tablet]
• dechlorinator [tablet]
• v-notch weir
• effluent -flow recording meter and sample
port

• Filter backwash from uranium filtration systems at community well treatment systems (Nantucket
Village, River Run and Willard Oaks) is transferred to the Greystone WWTP and introduced into the
influent at a rate less than 1GPM not to exceed 500 GPD.
The facility also holds collection system permit WQCSD0201. The last inspection under the collection system
permit was May 19, 2 02 2, and there were no violations. System noted as well operated and maintained.
APPLICATION
The application does not indicate any changes in the facility or treatment since the last renewal of the permit.
The treatment system is operated byAqua North Carolina, Inc. The annual average daily flow is indicated as
0.013 MGD over the last two years, so the facility is operating at well below its designed and permitted capacity.
The application and last permit noted a facility location address of Pine Creek Road but this road name is not
found on Google maps. After map review and verification with the permittee it appears that the street location
of Creek Bed Road in previous versions of the permit was correct. The facility address is 1549 Creek Bed Road,
Kernersville, NC and the permit has been changed to reflect this location.
The 2021 application does not discuss the previously permitted future expansion or the addition of well water
backwash into the treatment system from the last permit renewal/modification. This uranium filter backwash
has been noted in the components list in the draft permit along with the wells where the wastewater originates
- Nantucket Village, River Run and Willard Oaks WTPs.
INSPECTION
The most recent inspections occurred on May 19, 2022. No issues were found and the inspection indicates the
facility is well operated and maintained.
COMPLIANCE:
During the permit cycle this facility has not had any violation actions or enforcement actions. The only issues
shown in the data are TRC values over the limit, but none of these were over the compliance level.
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 — August 3, 2022, updated October 14, 2022
Page 2

MONITORING DATA REVIEW. -
Parameter (Units)
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.001
0.241
0.013
0.032 MA
Flow well below permit limit
BOD (mg/L)
2
19.1
2.91
23 MA
34.5 DM
No Exceedances
TSS (mg/L)
2.5
21.3
2.5
30 MA
45 DM
No Exceedances
Temp (C) - Effluent
0
29
16.2
-
Temp (C) - Upstream
-2
25
13.6
-
Temp (C) - Downstream
-2
27
13.7
-
NH3-N (mg/L) - Summer
< 0.2
3.03
0.23
2 MA 10 DM
No Exceedances
NH3-N (mg/L) - Winter
< 0.2
4.15
0.3
20 DM
No Exceedances
DO (mg/L) - Effluent
6.2
16.2
9.66
>-5 DA
No Exceedances
DO (mg/L) - Upstream
6.7
19.9
10.37
-
DO (mg/L) - Downstream
7
19.2
10AS
-
Fecal Coliform (#/ml)
< 1
250
3.5
200 MA
400 DM
No Exceedances
TRC (µg/L)
9
48
11.84
28 DM
No values > compliance level of 50
Total Nitrogen (mg/L)
33.28
33.28
33.28
-
Total Phosphorus (mg/L)
6.88
6.88
6.88
-
pH (su)
6.7
8.4
N/A
>-6 and <-9
No Exceedances
Total Cu (µg/L)
6
55.8
14.9
Total Zn (µg/L)
53
730
120.9
Total Lead (µg/L)
5
5
2.62
Hardness - Effluent (mg/L)
65
165
100.1
Hardness - Upstream (mg/L)
35
70
51.4
Total Chloride (mg/L)
29.5
183
54.8
Radium 226 & 228 (pCi/L)
0.05
1.79
0.78
5 An Avg
No value > 1.8
Alpha Emitters (pCi/L)
0.25
14
2.26
15 An Avg
No value > 14
Beta Emitters (pCi/L)
5.4
19.5
9.8
50 An Avg
No value > 19.5
Strontium (pCi/L)
0.009
4.1
0.79
30 8 WA
No value > 4
Tritium (pCi/L)
< 1
178
34.4
20,000
An Avg
No value > 178
Uranium (µg/L)
< 0.2
13.1
2.5
30 WA
No Exceedances
MA- Monthly Average DM - Daily Max QA- Quarterly Average DA - Daily Average An Avg- Annual Avg Summer -April -Oct Winter - Nov - March
The data reviewed for the renewal is from July 2017 through April 2022.
REVIEW OF PERMIT LIMITS AND PARAMETERS OF INTEREST:
Flow - The facility is operating on average at around 40% of the as -built flow allowed by the permit. Around
20% of the 59 monthly average flow values were above half of the as -built flow of 0.032 MGD.
BOD / TSS / Fecal/ DO / NH3-N I pH - No limit violations occurred for any of these limited parameters over
the permit cycle.
TRC- The facility reported 66 values of TRC that were over the 28µg/L limit but none of these values exceeded
the compliance threshold of 50.
Radiological Parameters of Concern - These six parameters were added in the 2017 permit renewal in response
to the addition of backwash water from the community well water treatment systems. No limit violations
occurred for any of these parameters over the permit term. Only one parameter (Alpha Emitters) has a single
data value that was more that 50% of the annual average limit. All these components did have monitoring
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 - August 3, 2022, updated October 14, 2022
Page 3

results that were above the detection limit. With the continued concern for radiological parameters and the
small data set from one permit cycle, the Division does not propose to change the monitoring or limits for these
parameters in this permit renewal.
The previous permit allowed grab sampling for these parameters. However, in accordance with rule 15A N CAC
2B .0505, since this facility has an as -built flow of above 30,000 GPD the sampling should be conducted as
composite sampling and this change has been made in the draft permit. One other change in the permit is the
correction of the appropriate discharge limit for Strontium. The previous permit set this at an average annual
limit of 30 µg/L. Based on the Division's December 5, 2006 memo on Disposal of Wastewater from Private
Water Supply Wells and 15A NCAC 2B .0211, the Strontium limit has been corrected to 8 pCi/L annual average.
Reasonable Potential Analysis (RPA) - An RPA analysis was conducted for Copper, Lead, Zinc, Chloride and
Uranium. These parameters were all added in the 2017 permit renewal in response to the addition of the well
water treatment system filter backwash to the Greystone Treatment System. Data has now been collected
through the last permit term so that the RPA can be considered for these parameters. Results of this
spreadsheet analysis are included later in this Fact Sheet and results are summarized below. The RPA analaysis
was preformed using the RPA spreadsheet and was run for the current outfall (001) and future outfall 002. The
flow numbers used for each were:
Fow
Outfall
7Q10 s
7Q10 w
30Q2
Avg Stream Flow
0.032 MGD
001
0
0.08
0.09
0.44
0.185 MGD
002
0.34
0.66
0.795
2.65
For 0.032 MGD permitted flow at Outfall 001
- Copper - The copper data showed reasonable potential. The draft permit includes copper limits
based on the RPA results with a daily max of 38.7 µg/L and a monthly average of 25.8 µg /L.
Monitoring frequency has also been changed to monthly.
- Lead - Lead data did not show reasonable potential and none of the values was greater than 50% of
the predicted maximum. With this evaluation, monitoring for Lead has been removed from the draft
permit.
- Zinc - The zinc data showed reasonable potential. The draft permit includes zinc limits based on the
RPA results with a daily max of 407.4 µg /L and a monthly average of 410.7 µg /L. Monitoring
frequency has also been changed to monthly.
- Chloride - Chlorides did not exhibit reasonable potential, but the predicted maximum value is
greater than 50% of the allowable maximum. So, quarterly monitoring will remain in the permit.
- Uranium - Uranium did not exhibit reasonable potential, but the predicted maximum value is greater
than 50% of the allowable maximum and the predicted max is two-thirds of the allowable maximum.
Based on the data results in this cycle and the continued concerns for radiological parameters the
Division does not propose to change the required monitoring at his time and the uranium limit will
remain in place.
For 0.185 MGD permitted flow at Outfall 002
- Copper - The copper data showed reasonable potential. The draft permit establishes copper limits
based on the RPA results with a daily max of 59.8 µg/L and a monthly average of 43.6 µg /L.
- Lead - Lead data did not show reasonable potential and none of the values was greater than 50% of
the predicted maximum. With this evaluation, monitoring for Lead has been removed from the draft
permit.
- Zinc - The zinc data showed reasonable potential. The draft permit establishes zinc limits based on
the RPA results with a daily max of 646.1 µg /L and a monthly average of 695.7 µg /L.
- Chloride - Chlorides did not exhibit reasonable potential, and none of the values was greater than
50% of the predicted maximum. With this evaluation, monitoring for Chloride has been removed
from the draft permit.
- Uranium - Uranium did not exhibit reasonable potential, and none of the values was greater than
50% of the predicted maximum. Given the continued concerns for radiological parameters the
Division does not propose to change the required monitoring at his time and the uranium limit will
remain in place.
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 — August 3, 2022, updated October 14, 2022
Page 4

Whole Effluent Toxicity (WETS - All WET test results passed during the permit cycle and did not exhibit
potential toxicity impacts. Toxicity requirements will remain in the permit to continue to assess the potential
impacts of the filter backwash wastewater addition. There is one change in the WET monitoring requirements
for the 0.032 MGD effluent discharge. WET toxicity limitations and monitoring requirements are based on the
instream waste concentration (IWC). The IWC is calculated based on the upstream stream flow during 7Q10
conditions and the permitted wasteflow. In the 2017 permit an incorrect 7Q10 flow was utilized in establishing
these requirements. The summer 7Q10 flow for this stream segment is zero (0) and the IWC is 100%. By
Division policy with an IWC of 100 the WET test should be conducted at an effluent concentration of 90% rather
than the 38% that the previous permit include. This change has been made in the draft permit.
FILE HISTORY REVIEW SUMMARY
• February 6, 2002 - Preliminary Engineering Report - Proposal to replace the activated sludge plant that
was nearing end of life. Replace with a 0.04 MGD extended aeration dual train package plant serving 72
homes. Current permit limits - BOD 23; TSS - 30; NH3-N - 2 & 4; Fecal - 200.
• May 31, 2002 -Permit Renewal -Reduced flow as requested by the permittee to 0.032 MGD
Flow (MGD)
BOD
(mg/L)
TSS
(mg/L)
DO
(mg/L)
Fecal per
100 mL
pH
NH3-N
(mg/L)
0.032
23/34.5
30/45
>_5
200/400
6 to 9
2(s) & 4(w)
• November 1, 2002 - Authorization to Construct (ATC) approved to construct influent pump station with
duplex feed pumps, equalization tank, dual -train extended aeration package plant with flow splitter and
integrated clarifiers, sludge treatment and holding tank and related equipment. System designed at 0.032
MGD.
• July 1, 2003 - Engineers Certification on completion of construction from 2002 ATC.
• November 18, 2004 - Owner name change to Aqua NC, Inc.
• February 28, 2007 Permit Renewal - Added NH3-N Daily Max limits of 10(s) and 20(w). Added TRC limit of
17 µg /L with an effective date of October 1, 2008.
• September 24, 2007 Permit Issuance - Response to a request from the permittee for expansion of flow and
relocation of discharge point. A level B model was done for this requested change on 6/25/2007 and the
Engineering Alternative Analysis (EAA) approved on 2/27/2007. This permit added an expanded flow to
0.185 MGD with a future ATC, Engineers Certification and relocation to Outfall 002. Stream flow at the new
discharge point is given as - 7g10 (s) - 0.344; 7Q10(w) - 0.66; 30Q2 - 0.795; avg flow - 2.65. Limits for the
expansion shown under effluent page #2
Flow (MGD)
BOD
(mg/L)
TSS
(mg/L)
DO
(mg/L)
Fecal per
100 mL
pH
NH3-N
(mg/L)
TRC
(µg/L)
0.185
5/7.5
30/45
>_5
200/400
6 to 9
2/10(s) & 4/20(w)
17
This application includes detailed maps of the locations of the new treatment facility, outfall 001and
proposed outfall 002
• January 8, 2008 - ATC to install dichlorination system utilizing sodium sulfate.
• April 25, 2008 - Engineers Certification for the January ATC.
• March 27, 2008 Permit Renewal - This permit did not include information about expansion on the
Supplement to Cover Sheet (added back in 2017 renewal).
• May 10, 2017 - Permit Renewal. This permit was issued with a modification to added in, as requested by
the permittee, flow from uranium filter backwash from surrounding community well water treatment
systems. This wastewater addition is trucked in and introduced at the influent. Not to exceed 500 GPD and
introduced at around 1 GPM. New limits were added to the permit in accordance with the Division's Water
Treatment Plant permitting policy and the Division's 2006 policy for Disposal of Wastewater Associated
with Private Water Supply Wells (Radiological POCs). Monitoring for Cu, Zn, Pb, Hardness, Chlorides and
WET were added to the permit and limits added for six radiological POCs. These parameters and limits
were added for both effluent monitoring pages.
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 — August 3, 2022, updated October 14, 2022
Page 5

PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added regulatory citations throughout permit as needed.
• Added information to treatment system components to note the well water treatment filter backwash that
is now part of the system.
• Corrected street address of the facility to 1549 Creek Bed Road
• Corrected Radiological POC sampling type to composite
• Corrected Strontium limit to 8 pCi/L.
0 0.032 MGD Effluent - Based on RPA analysis, added limits for Cu and Zn, removed Pb monitoring. For this
flow the WET monitoring and limit have been corrected to be evaluated at an effluent concentration of
90%.
0 0.185 MGD Effluent - Based on RPA analysis, added limits for Cu and Zn, removed Pb and Chloride.
• For the Copper and Zinc limits added in each effluent page the draft permit also includes a new footnote
indicating the while monitoring is required on the effective date of the permit, the limits themselves have
a compliance schedule that will be effective two (2) years after the effective date of the permit. These
parameters will also now have monthly monitoring instead of quarterly.
• Permit map information updated including location coordinates of outfalls.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: August 9, 2022
Permit Scheduled Effective Date: December 1, 2022
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
bradley.bennettOncdenr.gov. .
SUPPLEMENT TO FACT SHEET
During the process to finalize the permit Division staff noticed that there was an oversight in the review of the
DMR data. Evaluations of Chlorides data showed that there was reasonable potential for the Chlorides values to
impact water quality. As such, the draft permit should have included effluent limits for Total Chlorides. The
final permit addresses this issue by including the necessary limits for Chlorides of 230 mg/L as a Daily Max and a
Monthly Average limit. During this permit cycle monitoring will be required and the limits will be postponed
until the next permit cycle.
The permittee submitted comments on the draft permit in an email and attachment that we received from Joe
Pearce on September 9, 2022. In the comments Aqua questioned whether they had been able to view the
complete permit file. Hard copy information was reviewed by Mr. Pearce Division offices and the draft permit
and Fact Sheet were emailed to the permittee. These represented the complete permit file. Aqua also requested a
native version of the Reasonable Potential Analysis Spreadsheet. The Division does not provide this spreadsheet
in a native excel format outside our agency. In the fact sheet, the data used in the analysis and the results of the
RPA have been provided.
Aqua comments outlined concerns with meeting the Cu and Zn limits in the two-year compliance timeframe
allowed in the draft permit and requested additional time to review potential sources, make potential adjustments
and monitor the results of actions taken. In the comments Aqua requested that the Division either postpone
implementation of the limits until the next permit cycle or include the proposed schedule of actions spelled out in
their comment letter. The Division appreciates these comments and the permittees efforts to comply with the
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 — August 3, 2022, updated October 14, 2022
Page 6

permit conditions and agrees with the request to postpone the permit limit implementation until the next permit
cycle. The permit still includes the limits as an indication of the expectations for the next renewal. The permit
also includes general requirements for Aqua to provide annual reports on actions taken in review, assessment, and
implementation toward meeting these limits down the road. These reports should address actions taken related to
all three parameters scheduled for limits in the future (Cu, Zn and Chlorides).
A few additional minor changes of note relate to changes to monitoring frequency, effluent table footnote changes
and schedule of compliance are summarized below.
• The monitoring frequency for Total Hardness has been changed to monthly to be consistent with
monitoring frequency for metals.
• The monitoring frequency for Total Chlorides has been changed to monthly to be consistent with the
requirements associated with the addition of Total Chlorides limits.
• Footnote 10 has been updated to reflect limits not imposed during this permit cycle and to reference added
Special Conditions in Section A. (6).
• Since metals are now monitored monthly Footnote 7 has now been duplicated as Footnote 12 to reflect the
same condition on a quarterly basis for radiological parameters.
• Section A. (6) has been added to address a schedule of compliance for Cu, Zn and Chlorides.
Greystone Subdivision WWTP Fact Sheet
NPDES Renewal 2022 — August 3, 2022, updated October 14, 2022
Page 7

Bennett, Bradley
From: Bennett, Bradley
Sent: Tuesday, October 4, 2022 7:34 AM
To: Pearce, Joseph R
Cc: Berger, Amanda A; Hennessy, John
Subject: RE: [EXTERNAL] Greystone Permit Renewal Update - NCO078115
Joe,
It doesn't appear that there is anything in the Non -Discharge rules that is specifically for individual properties like you
seemed to be talking about. As you look more into those details for sources from individual homeowner systems (if you
could separate them) or from the community wells or other areas you might want to talk directly with the non -discharge
staff about any alternatives that might be available for you.
m
Bradley Bennett
Compliance and Expedited Permitting
Division of Water Quality
NC Department of Environmental Quality
brad ley. ben [e-mail]
0�E ��
p,:....I I :,:1 H-i 1L I`.I
0E02rtf itnt 61 E41y06nMENISI 0u81ity
Email correspondence to and from this address rs subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Pearce, Joseph R <[e-mail]>
Sent: Monday, October 3, 2022 10:54 AM
To: Bennett, Bradley <[e-mail]>
Subject: RE: [EXTERNAL] Greystone Permit Renewal Update - NCO078115
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Thanks. I will have 5 years to figure it out. Barring RO, chloride treatment is not reasonable. I guess I&I could fix it
AOUAII
Joseph Pearce PE CFIVI

Director of Operations
Aqua North Carolina, Inc.
202 MacKenan Court
Cary, North Carolina 27511
0:919.653.6964 F:919.460.1788
From: Bennett, Bradley <bradley. [e-mail]>
Sent: Monday, October 3, 2022 10:01 AM
To: Pearce, Joseph R <[e-mail]>; Berger, Amanda A <[e-mail]>
Cc: Hennessy, John <[e-mail]>
Subject: RE: [EXTERNAL] Greystone Permit Renewal Update - NCO078115
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Joe,
I'm checking into this with our Non -Discharge staff. It may be an issue that you will have to have further discussion with
them on, but I'll let you know.
W.
Bradley Bennett
Compliance and Expedited Permitting
Division of Water Quality
NC Department of Environmental Quality
brad ley. ben nett()ncdenr.gov
E -�>
I I C:AROLINA
QEOrkrtMeol Of ElirifMlMEOIbI Rualil•r
Email correspondence to and from this address rs subject to the Noah
Carolina Public Records Law and may be disclosed to third parties.
From: Pearce, Joseph R <[e-mail]>
Sent: Friday, September 30, 2022 9:54 AM
To: Bennett, Bradley <bradley. ben [e-mail]>; Berger, Amanda A <[e-mail]>
Cc: Hennessy, John <[e-mail]>
Subject: RE: [EXTERNAL] Greystone Permit Renewal Update - NCO078115
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Report Spam.
Bradley and John,
Can you remind me are discharges from individual home water system allowed on the ground? I suspect water
softening from home systems may be contributes to WWTP loads...

Joe
*,I fe,
AL
#tertr"0610
Joseph Pearce PE CFM
Director of Operations
Aqua North Carolina, Inc.
202 MacKenan Court
Cary, North Carolina 27511
0:919.653.6964 F:919.460.1788
ANXf
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Friday, September 30, 2022 9:47 AM
To: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>
Cc: Hennessy, John <[e-mail]>
Subject: [EXTERNAL] Greystone Permit Renewal Update - NCO078115
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Amanda, Joe
I just wanted to touch base on this renewal with one issue we have noticed and in response to your comments.
First of all, in review of our RPA analysis we realized that Chlorides data also exhibited Reasonable Potential for water
quality impacts. You will note in the Fact Sheet you received that the maximum predicted Chlorides value was higher
than the allowed value which leads to application of a limit. Sorry that I overlooked that previously. In this case the
Chlorides limit will beset at 230 mg/L as a Daily Max and a Monthly Average. We plan to handle this limit like the limits
for Cu and Zn so the limit will not be effective during this permit cycle but monitoring will be required.
In your comments and in our previous discussion we had looked at the possibilities of delaying the Cu and Zn limits to
allow Aqua to review sources, do additional monitoring and evaluate the process for compliance with the limits. The
Division is in agreement with your proposal to postpone the limits until the next permit cycle. Our plan at this point is to
move forward with very general language in the permit that does note the limits, but only requires monitoring at this
time. The permit would also require annual reports from Aqua on your findings as you look at issues toward meeting
the limits in the future. This will allow you more flexibility than spelling out the specific actions and timeframes as you
had included as a second potential option in your comments.
m
Bradley Bennett
Compliance and Expedited Permitting
Division of Water Quality
NC Department of Environmental Quality
brad ley. ben nett at7.ncdenr.gov

DBE
r:,.,r; I, I c:.aHOUN;'k
Department al Enviro"menlal Guality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.

Bennett, Bradley
From:
Pearce, Joseph R <[e-mail]>
Sent:
Friday, September 9, 2022 2:47 PM
To:
Bennett, Bradley
Cc:
Berger, Amanda A
Subject:
[External] Comments on Draft NPDES permit
Attachments:
Graystone Draft NPDES Comments 220909.pdf
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Report Spam.
Good Afternoon Bradley,
Attached please find an electronic copy of Aqua's response to the Draft Graystone NPDES permit. A hardcopy should be
delivered by USPS in the very near future.
Have a Good Weekend,
Joe
r
Joseph Pearce PE CFM
Director of Operations
Aqua North Carolina, Inc.
202 MacKenan Court
Cary, North Carolina 27511
0:919.653.6964 F:919.460.1788
V w {�
1

..r
A,.
A., '� Essential t}c
I os C onwany
September 9, 2022
Certified Mail
Return Receipt Requested
Mr. Bradley Bennett
NCDEQ-DWR-Compliance and Expedited Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699
Re: Comments on Draft NPDES Permit NCO078115
Greystone Subdivision WWTP
Forsyth County
Dear Mr. Bennett:
On behalf of Aqua North Carolina (Aqua) I appreciate the opportunity to provide comment
on the above -referenced draft permit for the Greystone Wastewater Treatment Plant
(WWTP) and raise concerns about the proposed imposition of new limits for copper and
zinc, and the reduced dilution allowance for Whole Effluent Toxicity. As you know, Aqua
requested a complete file review and a copy of the Reasonable Potential Analysis in its
native format. As of this date, it does not appear we have received access to the complete
file or the Reasonable Potential Analysis in its native format (Excel). As such, we cannot
verify that the 7Q10 was reduced based upon new or appropriate information, or that
errors in the calculation of the reasonable potential analysis do not exist.
Aside from questions regarding validation of the reasonable potential analysis, Aqua also
has concerns regarding the feasibility to meet the proposed copper and zinc limits. the
Greystone WWTP is designed for the treatment of conventional pollutants (BOD5, TSS,
and Ammonia -Nitrogen) and is not designed for the removal of metals. The proposed two-
year timeframe to complete improvements prior to the effective date of the limits is
insufficient. During a recent discussion with you and John Hennessey, neither of you
provided any insight regarding treatment technologies used for removing metals from
similar small wastewater treatment plants. Large wastewater treatment plants are
required to evaluate and/or reduce their metal discharge concentrations through the
control of discharges from significant and categorical industrial users. However, typical of
small wastewater treatment plants, Greystone WWTP primarily receives domestic
wastewater and the periods of higher copper and zinc concentrations in the effluent may
not correlate with the discharge of the hauled backwash water, nor may be effectively
reduced by eliminating that waste stream.
202 MacKenan Court, Cary, INC 27511 ® O: 919.467.8712 ® F: 919.460.1788 ® AquaAmerica.com

Aqua strives for one -hundred percent compliance and has shown significant improvement
in our wastewater treatment plant compliance in the last four years. I trust that NCDEQ/
DWR appreciates Aqua's efforts and does not wish to create a non-compliance situation
for Aqua without sufficient opportunity to study the issue and to implement a solution.
Aqua proposes to undertake the following:
1. Characterize each of the hauled wastewater sources to determine if those are
significant sources of the pollutants of concern (within three months of permit
issuance).
2. Review the corrosion control technology used for the water supply and determine
if a better alternative exists (within six months of permit issuance).
3. Based upon mass balances for the pollutants of concern, Aqua will determine if
source control for the pollutants of concern will reliably meet the proposed limits.
Examples of source control would be cessation of the hauled backwash water
contribution, or implementation of an improved corrosion control strategy (within
18 months of permit issuance). Source control is the preferred solution, but
dependent upon the source being controlled it may be many months before the
results are witnessed. Specifically, the formation of corrosion -protecting scale in
home plumbing is not instantaneous.
4. Aqua would monitor the concentrations of the pollutants of concern monthly as
prescribed by the permit and would statistically evaluate the data for changes
between the original condition and after source control. If the data is statistically
different, Aqua will submit the data to NCDEQ in support of a permit modification
to remove the subject permit limits. (within 48 months of permit issuance).
5. Concurrent with Item 4 above, Aqua will complete treatability evaluations for the
removal of the pollutants of concern. If these pollutants of concern are in a soluble
chelate form, treatment will be challenging and may require a process separate
from the existing wastewater treatment plant process. To Aqua's knowledge, there
is no domestic wastewater treatment facility in North Carolina operating a
wastewater treatment plant of this type and concerns would exist for Aqua
operating one of our facilities with this level of treatment. If needed to meet the
proposed permit limits, Aqua would complete treatability study, design, permitting,
and construction (within 60 months of permit issuance).
Aqua requests that you consider the option of either: (i) postponement of the
implementation of the new and revised limits until the next permit cycle with the known
expectation that these limits will be implemented; or (ii) incorporation of the proposal
above as a schedule within the permit.
Lastly, please be aware that our submission of these comments does not preclude the
right of permit appeal for the above stated reasons, or other reasons yet to be announced

or discovered. We are available to discuss these comments, and please feel free to
contact me at [phone].
Sincerely,
os h Pearce PE
Director of Operations
cc: Shannon Becker
Amanda Berger

Winston-Salem Journal
Advertising Affidavit
P.O Box 3159
Winston-Salem, NC 27102
NCDEQ-DIVISION OF WATER RESOURCES
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
PO Number Order Category Description
Account Number
4019534
Date
August 16, 2022
0000797810 Legal Notices Public Notice North Carolina Environmental Management Commission / NPDES U
Publisher of the
Winston-Salem Journal
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 Winston-Salem Journal on the following dates:
08/16/2022
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 Carolina.
C�,4) I X_�,
(signature of p o making affidavit)
Sworn to and subscribed before me the 16th day of A 2
(Notary Pub
State of Virginia Richard A. Hundley
County of Hanover Notary Public
M commission expires: Commonwealth of Virginia
y p No. 7904041
Commission Exp. Jan 31, 2024
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 17699.1617
Notice of Intent to Issue a NPDES
Wastewater Permit NCO078115
Greystone Subdivision WWTP The
North Carolina Environmental Man-
agement Commission proposes to is-
sue a NPDES wastewater discharge
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 pub-
lic interest. Please mail comments
and/or information requests to DWR
at the above address. Interested per-
sons may visit the DWR at 512 N.
Salisbury Street, Raleigh, NC 27604
to review information on file. Addi-
tional information on NPDES permits
and this notice may be found on our
website: http://deq.nc.gov/abouVdi
visions/water-resources/water-
resources-permits/wastewater-
branch/npdes-wastewater/public-
notices,or by calling [phone].
AQUA North Carolina, Inc. (202
MacKenan Court; Cary, NC 27511]
has requested renewal of NPDES
permit NCO078115 for the Greystone
Subdivision WWTP, located in For-
syth County. This permitted facility
discharges treated wastewater to a
UT to Right Fork of Belews Creek, a
class C; water in the Roanoke River
Basin. Some of the parameters in
the permit are water quality limited.
This discharge may affect future al-
locations in this segment of the
Right Fork of Belews Creek.
WSJ: August 16, 2022.

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Proiect Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
Greystone Subdivision WWTP
WWTP/WTP Class
Class II
NPDES Permit
NCO078115
Outtall
002
Flow, Qw (MGD)
0.185
Receiving Stream
UT to Right Fork of Belews Creek
HUC Number
030101030303
Stream Class
❑ Apply WS Hardness WQC
Class C
7Q10s (cfs)
0.34
0.66
7Q10w (cfs)
0.80
30Q2 (cfs)
2.65
QA (cfs)
0.29
1Q10s (cfs)
Effluent Hardness
100.14 mg/L (Avg)
Hardness
51.43 mg/L (Avg)
_Upstream
Combined Hardness Chronic
I _ _ _ _ _ _ _ 73.57 mg/L
Combined Hardness Acute
75.65 mg/L
Data Source(s)
❑ CHECK TO APPLY MODEL
Par01
Par02
Par03
Par04
Par05
Par0M
Par07
Par08
Par09
Parl0
Parl I
Parl 2
Parl 3
Parl4
Parl 5
Parl 6
Parl 7
Parl8
Parl9
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name wQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
1.3333
FW
8.5108
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
lllChlorinated Phenolic Compounds
Water supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
284.9938
FW
2241.3632
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
19.8218
FW
29.7232
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
9.7829
FW
258.8253
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
92.7908
FW
855.3087
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
1.9905
ug/L
Zinc
Aquatic Life
NC
316.2984
FW
321.2078
ug/L
Uranium
Human Health
NC
30
FW
ug/L
NC0078115_Final FW RPA for 185 ug_20220726, input
8/3/2022

H1
1
2
3
4
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
REASONABLE POTENTIAL ANALYSIS
H2
Use "PASTE SPECIAL
Effluent Hardness Values" then "COPY". Upstream Hardness
Maximum data points
= 58
Date Data
BDL=1/2DL
6/21 /2017
89
89
9/20/2017
118
118
12/13/2017
90
90
3/14/2018
94
94
6/13/2018
112
112
9/12/2018
99
99
10/3/2018
109
109
1/16/2019
75
75
4/24/2019
120
120
7/3/2019
81
81
10/2/2019
85
85
1 /8/2020
68
68
4/1/2020
96
96
7/1/2020
95
95
10/7/2020
120
120
1 /6/2021
65
65
4/7/2021
138
138
7/14/2021
104
104
10/6/2021
92
92
1 /5/2022
88
88
4/6/2022
165
165
Results
Std Dev.
23.4527
Mean
100.1429
C.V.
0.2342
n
21
10th Per value
75.00 mg/L
Average Value
100.14 mg/L
Max. Value
165.00 mg/L
Use "PASTE SPECIAL
Values" then "COPY".
Maximum data points
= 58
Date Data
BDL=1/2DL
Results
1 6/21/2017
45
45
Std Dev.
11.7114
2 9/20/2017
54
54
Mean
51.4286
3 12/14/2017
40
40
C.V.
0.2277
4 3/14/2018
35
35
n
21
5 6/13/2018
60
60
10th Per value
38.00 mg/L
6 9/12/2018
42
42
Average Value
51.43 mg/L
7 10/3/2018
69
69
Max. Value
70.00 mg/L
8 1/16/2019
40
40
9 4/24/2019
50
50
10 7/3/2019
64
64
11 10/2/2019
55
55
12 1 /8/2020
37
37
13 4/1/2020
43
43
14 7/1/2020
46
46
15 10/7/2020
54
54
16 1 /6/2021
42
42
17 4/7/2021
64
64
18 7/14/2021
70
70
19 10/6/2021
64
64
20 1 /5/2022
38
38
21 4/6/2022
68
68
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
-1-
NC0078115_Final FW RPA for 032ug_20220726, data
8/3/2022

REASONABLE POTENTIAL ANALYSIS
Par05
Chlorides
Date Data
BDL=1/2DL
Results
1
6/21/2017
59
59
Std Dev.
2
9/20/2017
60
60
Mean
3
12/13/2017
47
47
C.V.
4
3/14/2018
34.5
34.5
n
5
6/13/2018
46.5
46.5
6
9/12/2018
30.5
30.5
Mult Factor =
7
10/3/2018
47
47
Max. Value
8
1/16/2019
29.5
29.5
Max. Pred Cw
9
4/24/2019
47
47
10
7/3/2019
74
74
11
10/2/2019
63
63
12
1/8/2020
38
38
13
4/1/2020
41
41
14
7/1/2020
57
57
15
10/7/2020
44
44
16
1/6/2021
38
38
17
4/7/2021
39
39
18
7/14/2021
60
60
19
10/6/2021
65
65
20
1/5/2022
48.2
48.2
21
4/6/2022
183
183
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
Pal
Use "PASTE SPECIAL- Use "PASTE SF
Values" then "COPY, . Copper Values" then' C
Maximum data points = Maximum data
58 = 58
54.8
0.5784
21
1.3
183.0 mg/L
243.4 mg/L
Date
Data
BDL=1/2DL
Results
1
6/21/2017
0.006
6.0000
Std Dev.
2
9/20/2017
16
16.000
Mean
3
12/13/2017
10
10.000
C.V.
4
3/14/2018
8
8.000
n
5
6/13/2018
22
22.000
6
9/12/2018
29
29.000
Mult Factor =
7
10/3/2018
25
25.000
Max. Value
8
1/16/2019
7
7.000
Max. Fred Cw
9
4/24/2019
11
11.0000
10
7/3/2019
13.8
13.800
11
10/2/2019
14.4
14.400
12
1 /8/2020
55.8
55.800
13
4/1/2020
12.9
12.9000
14
7/1/2020
14.6
14.600
15
10/7/2020
12.5
12.500
16
1 /6/2021
8.8
8.800
17
4/7/2021
7.9
7.9
18
7/14/2021
0.0098
9.8
19
10/20/2021
0.0104
10.4
20
1 /5/2022
0.0074
7.4
21
4/6/2022
0.0115
11.5
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
14.9429
0.7430
21
1.42
55.80
79.24
NC0078115_Final FW RPA for 032ug_20220726, data
-2- 8/3/2022

REASONABLE POTENTIAL ANALYSIS
Par14
Par21
IECIAL
Use "PASTE SPECIAL
Use "PASTE SF
Zinc
Values" then "C
Maximum data
:OPY" .
points
Lead
Values" then "COPY".
Maximum data points
= 58
= 58
1
Date
6/21/2017
< 5
BDL=1/2DL
2.5
Results
Std Dev.
0.5455
1
Date
6/21/2017
Data
36
BDL=1/2DL
36
Results
Std Dev.
146.2317
2
9/20/2017
< 5
2.5
Mean
2.6190
2
9/20/2017
59
59
Mean
105.2286
3
12/13/2017
< 5
2.5
C.V.
0.2083
3
12/13/2017
87
87
C.V.
1.3897
4
3/14/2018
< 5
2.5
n
21
4
3/14/2018
54
54
n
21
5
6/13/2018
< 5
2.5
5
6/13/2018
60
60
6
9/12/2018
< 5
2.5
Mult Factor =
1.12
6
9/12/2018
165
165
Mult Factor =
1.74
ug/L
7
10/3/2018
< 5
2.5
Max. Value
5.000 ug/L
7
10/3/2018
112
112
Max. Value
730.0
ug/L
8
1/16/2019
< 5
2.5
Max. Pred Cw
5.600 ug/L
8
1/16/2019
730
730
Max. Pred Cw
1270.2
9
4/24/2019
< 5
2.5
9
4/24/2019
127
127
10
7/3/2019
< 5
2.5
10
7/3/2019
71.5
71.5
11
10/2/2019
< 5
2.5
11
10/2/2019
74.6
74.6
12
1/8/2020
< 5
2.5
12
1/8/2020
65.1
65.1
13
4/1/2020
< 5
2.5
13
4/1/2020
71.1
71.1
14
7/1/2020
< 5
2.5
14
7/1/2020
95.1
95.1
15
10/7/2020
< 5
2.5
15
10/7/2020
53.6
53.6
16
1/6/2021
< 5
2.5
16
1/6/2021
53
53
17
4/7/2021
< 5
2.5
17
4/7/2021
56.6
56.6
18
7/14/2021
< 5
2.5
18
7/14/2021
63
63
19
10/6/2021
< 5
2.5
19
10/20/2021
61
61
20
1/5/2022
5
5
20
1/5/2022
44.9
44.9
21
4/6/2022
< 5
2.5
21
4/6/2022
70.3
70.3
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
NC0078115_Final FW RPA for 032ug_20220726, data
-3- 8/3/2022

REASONABLE POTENTIAL ANALYSIS
:OPY"
points
ug/L
ug/L
Par22
1
2
3
4
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
Uranium
Date Data
BDL=1/2DL
6/21 /2017
2.18
2.18
9/20/2017 <
0.199
0.0995
12/13/2017
4
4
3/14/2018
0.981
0.981
6/13/2018
2.46
2.46
9/12/2018
0.888
0.888
10/3/2018
13.1
13.1
1/16/2019
0.829
0.829
6/12/2019
5.2
5.2
7/3/2019
3.15
3.15
10/2/2019
2.69
2.69
1 /8/2020
1.67
1.67
4/1/2020
0.773
0.773
7/1/2020
0.995
0.995
10/7/2020
3.88
3.88
1/13/2021
1.84
1.84
4/7/2021
0.933
0.933
7/14/2021
1.17
1.17
10/20/2021
2.22388
2.22388
1 /5/2022
1.86567
1.86567
2/25/2022
0.993
0.993
4/6/2022
2.67164
2.67164
Use "PASTE SPECIAL
Values" then "COPY".
Maximum data points
= 58
Results
Std Dev.
2.6832
Mean
2.4815
C.V.
1.0813
n
22
Mult Factor = 1.56
Max. Value 13.100000 ug/L
Max. Pred Cw 20.436000 ug/L
-4-
NC0078115_Final FW RPA for 032ug_20220726, data
8/3/2022

Greystone Subdivision VVMP >
NCO078115 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) =
0.03
WWTP/WTP Class: Class II
1Q10S (cfs) =
0.00
IWC% @ 1Q10S =
100
7Q10S (cfs) =
0.00
IWC% @ 7Q10S =
100
7Q10W (cfs) =
0.08
IWC% @ 7Q10W =
38.27160494
30Q2 (cfs) =
0.09
IWC% @ 30Q2 =
35.53008596
Avg. Stream Flow, QA (cfs) =
0.44
IW%C @ QA =
10.13071895
Receiving Stream:
UT to Right Fork of Belews Creek HUC 030101030303
Stream Class:
Class II
Outfall 001
Qw = 0.032 MGD
COMBINED HARDNESS (mg/L)
Acute = 100.14 mg/L
Chronic = 100.14 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
Applied
Chronic Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute: NO WQS
No RP , Predicted Max >_ 50% of Allowable Cw -
Chlorides
NC
230 FW
mg/L
21 21
243.4
apply Quarterly Monitoring
---------------------------------------------
Chronic: 230.0
No RP , Predicted Max > 50% of Allowable Cw
No value > Allowable Cw
apply Quarterly Monitoring
Acute: 38.71
RP shown - apply Monthly Monitoring with Limit
Copper
NC
25.7959 FW 38.7146
ug/L
21 21
79.24
__ _ _______ _____
_ _ _ _ _ _ _ _ _ _ ___
Chronic: 25.80
RP shown - apply Monthly Monitoring with Limit
2 values > Allowable Cw
Acute: 351.720
No RP, Predicted Max < 50% of Allowable Cw - No
Lead
NC
13.7060 FW 351.7205
ug/L
21 1
5.600
Monitoring required
-----------------------------
Chronic: 13.706
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 407.4
RP shown - apply Monthly Monitoring with Limit
Zinc
NC
410.7164 FW 407.3841
ug/L
21 21
1,270.2
__ _ _______ _____
Chronic: 410.7
_ _ _ _ _ _ _ _ _ _ ___
RP shown - apply Monthly Monitoring with Limit
1 values > Allowable Cw
Acute: NO WQS
No RP , Predicted Max > 50% of Allowable Cw -
Uranium
NC
30 FW
ug/L
22 21
20.43600
apply Quarterly Monitoring
Chronic: 30.00000
No RP , Predicted Max > 50% of Allowable Cw
No value > Allowable Cw
apply Quarterly Monitoring
Acute:
0 0
N/A
Acute:
0 0
N/A
Chronic:
Acute:
0 0
N/A
Chronic:
NC0078115_Final FW RPA for 032ug_20220726, rpa
Page 1 of 1 8/3/2022

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Proiect Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
Greystone Subdivision WWTP
WWTP/WTP Class
Class II
NPDES Permit
NCO078115
Outtall
002
Flow, Qw (MGD)
0.185
Receiving Stream
UT to Right Fork of Belews Creek
HUC Number
030101030303
Stream Class
❑ Apply WS Hardness WQC
Class C
7Q10s (cfs)
0.34
0.66
7Q10w (cfs)
0.80
30Q2 (cfs)
2.65
QA (cfs)
0.29
1Q10s (cfs)
Effluent Hardness
100.14 mg/L (Avg)
Hardness
51.43 mg/L (Avg)
_Upstream
Combined Hardness Chronic
I _ _ _ _ _ _ _ 73.57 mg/L
Combined Hardness Acute
75.65 mg/L
Data Source(s)
❑ CHECK TO APPLY MODEL
Par01
Par02
Par03
Par04
Par05
Par0M
Par07
Par08
Par09
Parl0
Parl I
Parl 2
Parl 3
Parl4
Parl 5
Parl 6
Parl 7
Parl8
Parl9
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name wQs Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
1.3333
FW
8.5108
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
lllChlorinated Phenolic Compounds
Water supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
284.9938
FW
2241.3632
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
19.8218
FW
29.7232
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
9.7829
FW
258.8253
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
ng/L
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
92.7908
FW
855.3087
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
1.9905
ug/L
Zinc
Aquatic Life
NC
316.2984
FW
321.2078
ug/L
Uranium
Human Health
NC
30
FW
ug/L
NC0078115_Final FW RPA for 185 ug_20220726, input
8/3/2022

H1
1
2
3
4
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
REASONABLE POTENTIAL ANALYSIS
H2
Use "PASTE SPECIAL
Effluent Hardness Values" then "COPY". Upstream Hardness
Maximum data points
= 58
Date Data
BDL=1/2DL
6/21 /2017
89
89
9/20/2017
118
118
12/13/2017
90
90
3/14/2018
94
94
6/13/2018
112
112
9/12/2018
99
99
10/3/2018
109
109
1/16/2019
75
75
4/24/2019
120
120
7/3/2019
81
81
10/2/2019
85
85
1 /8/2020
68
68
4/1/2020
96
96
7/1/2020
95
95
10/7/2020
120
120
1 /6/2021
65
65
4/7/2021
138
138
7/14/2021
104
104
10/6/2021
92
92
1 /5/2022
88
88
4/6/2022
165
165
Results
Std Dev.
23.4527
Mean
100.1429
C.V.
0.2342
n
21
10th Per value
75.00 mg/L
Average Value
100.14 mg/L
Max. Value
165.00 mg/L
Use "PASTE SPECIAL
Values" then "COPY".
Maximum data points
= 58
Date Data
BDL=1/2DL
Results
1 6/21/2017
45
45
Std Dev.
11.7114
2 9/20/2017
54
54
Mean
51.4286
3 12/14/2017
40
40
C.V.
0.2277
4 3/14/2018
35
35
n
21
5 6/13/2018
60
60
10th Per value
38.00 mg/L
6 9/12/2018
42
42
Average Value
51.43 mg/L
7 10/3/2018
69
69
Max. Value
70.00 mg/L
8 1/16/2019
40
40
9 4/24/2019
50
50
10 7/3/2019
64
64
11 10/2/2019
55
55
12 1 /8/2020
37
37
13 4/1/2020
43
43
14 7/1/2020
46
46
15 10/7/2020
54
54
16 1 /6/2021
42
42
17 4/7/2021
64
64
18 7/14/2021
70
70
19 10/6/2021
64
64
20 1 /5/2022
38
38
21 4/6/2022
68
68
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
-1-
NC0078115_Final FW RPA for 185 ug_20220726, data
8/3/2022

REASONABLE POTENTIAL ANALYSIS
Par05
Use "PASTE SPECIAL -
Chlorides
Values" then "COPY".
Maximum data points =
58
Date Data
BDL=1/2DL
Results
1
6/21/2017
59
59
Std Dev.
31.7101
2
9/20/2017
60
60
Mean
54.8
3
12/13/2017
47
47
C.V.
0.5784
4
3/14/2018
34.5
34.5
n
21
5
6/13/2018
46.5
46.5
6
9/12/2018
30.5
30.5
Mull Factor =
1.3
7
10/3/2018
47
47
Max. Value
183.0 mg/L
8
1/16/2019
29.5
29.5
Max. Pred Cw
243.4 mg/L
9
4/24/2019
47
47
10
7/3/2019
74
74
11
10/2/2019
63
63
12
1/8/2020
38
38
13
4/1/2020
41
41
14
7/1/2020
57
57
15
10/7/2020
44
44
16
1/6/2021
38
38
17
4/7/2021
39
39
18
7/14/2021
60
60
19
10/6/2021
65
65
20
1/5/2022
48.2
48.2
21
4/6/2022
183
183
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
Pal
Copper
Date
Data
BDL=1/2DL
Results
1
6/21/2017
6.0000
6
Std Dev.
2
9/20/2017
16.000
16
Mean
3
12/13/2017
10.000
10
C.V.
4
3/14/2018
8.000
8
n
5
6/13/2018
22.000
22
6
9/12/2018
29.000
29
Mull Factor =
7
10/3/2018
25.000
25
Max. Value
8
1/16/2019
7.000
7
Max. Pred Cw
9
4/24/2019
11.0000
11
10
7/3/2019
13.800
13.8
11
10/2/2019
14.400
14.4
12
1/8/2020
55.800
55.8
13
4/1/2020
12.9000
12.9
14
7/1/2020
14.600
14.6
15
10/7/2020
12.500
12.5
16
1 /6/2021
8.800
8.8
17
4/7/2021
7.9
7.9
18
7/14/2021
9.8
9.8
19
10/20/2021
10.4
10.4
20
1 /5/2022
7.4
7.4
21
4/6/2022
11.5
11.5
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
NC0078115_Final FW RPA for 185 ug_20220726, data
-2- 8/3/2022

REASONABLE POTENTIAL ANALYSIS
Par14
Use "PASTE SPECIAL
Values" then "COPY" .
Maximum data points
= 58
14.9429
0.7430
21
1.42
55.80 ug/L
79.24 ug/L
Date
1 6/21 /2017 <
2 9/20/2017 <
3 12/13/2017 <
4 3/14/2018 <
5 6/13/2018 <
6 9/12/2018 <
7 10/3/2018 <
8 1/16/2019 <
9 4/24/2019 <
10 7/3/2019 <
11 10/2/2019 <
12 1 /8/2020 <
13 4/1/2020 <
14 7/1/2020 <
15 10/7/2020 <
16 1 /6/2021 <
17 4/7/2021 <
18 7/14/2021 <
19 10/6/2021 <
20 1 /5/2022
21 4/6/2022 <
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
Lead
BDL=1/2DL
Results
5 2.5
Std Dev.
5 2.5
Mean
5 2.5
C.V.
5 2.5
n
5 2.5
5 2.5
Mult Factor =
5 2.5
Max. Value
5 2.5
Max. Pred Cw
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
5 5
5 2.5
Use "PASTE SPECIAL
Values" then "COPY".
Maximum data points
= 58 r
2.6190
0.2083
21
1.12
5.000 ug/L
5.600 ug/L
Zinc
Date
Data
BDL=1/2DL
Results
1
6/21/2017
36.0000
36
Std Dev.
2
9/20/2017
59.000
59
Mean
3
12/13/2017
87.000
87
C.V.
4
3/14/2018
54.000
54
n
5
6/13/2018
60.000
60
6
9/12/2018
165.000
165
Mult Factor =
7
10/3/2018
112.000
112
Max. Value
8
1/16/2019
730.000
730
Max. Pred Cw
9
4/24/2019
127.0000
127
10
7/3/2019
71.500
71.5
11
10/2/2019
74.600
74.6
12
1/8/2020
65.1000
65.1
13
4/1/2020
71.1000
71.1
14
7/1/2020
95.100
95.1
15
10/7/2020
53.600
53.6
16
1 /6/2021
53.000
53
17
4/7/2021
56.6
56.6
18
7/14/2021
63
63
19
10/20/2021
61
61
20
1 /5/2022
44.9
44.9
21
4/6/2022
70.3
70.3
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
-3-
NC0078115_Final FW RPA for 185 ug_20220726, data
8/3/2022

REASONABLE POTENTIAL ANALYSIS
Use"PASTE SPECIAL
Values" then "COPY"
Maximum data points
= 58
146.2317
105.2286
1.3897
21
1.74
730.0 ug/L
1270.2 ug/L
Par22
1
2
3
4
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
Uranium
Date Data
BDL=1/2DL
6/21 /2017
2.18
2.18
9/20/2017 <
0.199
0.0995
12/13/2017
4
4
3/14/2018
0.981
0.981
6/13/2018
2.46
2.46
9/12/2018
0.888
0.888
10/3/2018
13.1
13.1
1/16/2019
0.829
0.829
6/12/2019
5.2
5.2
7/3/2019
3.15
3.15
10/2/2019
2.69
2.69
1 /8/2020
1.67
1.67
4/1/2020
0.773
0.773
7/1/2020
0.995
0.995
10/7/2020
3.88
3.88
1 / 13/2021
1.84
1.84
4/7/2021
0.933
0.933
7/14/2021
1.17
1.17
10/20/2021
2.22388
2.22388
1 /5/2022
1.86567
1.86567
2/25/2022
0.993
0.993
4/6/2022
2.67164
2.67164
Use 'PASTE SPECIAL
Values" then "COPY"
Maximum data points
= 58
Results
i
Std Dev.
2.6832
Mean
2.4815
C.V.
1.0813
n
22
Mull Factor = 1.56
Max. Value 13.100000 ug/L
Max. Pred Cw 20.436000 ug/L
-4-
NC0078115_Final FW RPA for 185 ug_20220726, data
8/3/2022

Greystone Subdivision VVMP >
NCO078115 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) =
0.19
WWTP/WTP Class: Class II
1Q10S (cfs) =
0.29
IWC% @ 1Q10S =
49.71824881
7Q10S (cfs) =
0.34
IWC% @ 7Q10S =
45.46175188
7Q10W (cfs) =
0.66
IWC% @ 7Q10W =
30.28782678
30Q2 (cfs) =
0.80
IWC% @ 30Q2 =
26.50797319
Avg. Stream Flow, QA (cfs) =
2.65
IW%C @ QA =
9.764195114
Receiving Stream:
UT to Right Fork of Belews Creek HUC 030101030303
Stream Class:
Class II
Outfall 002
Qw = 0.185 MGD
COMBINED HARDNESS (mg/L)
Acute = 75.65 mg/L
Chronic = 73.57 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
a
Applied
Chronic Acute
ri # Det. Max Pred Cw Allowable Cw
Standard
Acute: NO WQS
Chlorides
NC
230 FW(7Q10s)
mg/L
21 21
243.4
Chronic: 505.9
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 59.78
RP shown - apply Monthly Monitoring with Limit
Copper
NC
19.8218 FW(7Q10s) 29.7232
u� L
21 21
79.24
__ _ _______ _____
Chronic: 43.60
_ _ _ _ _ _ _ _ _ _ ___
RP shown - apply Monthly Monitoring with Limit
1 values > Allowable Cw
Acute: 520.584
No RP, Predicted Max < 50% of Allowable Cw - No
Lead
NC
9.7829 FW(7Q10s) 258.8253
ug/L
21 1
5.600
Monitoring required
-----------------------------
Chronic: 21.519
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 646.1
RP shown - apply Monthly Monitoring with Limit
Zinc
NC
316.2984 FW(7Q10s) 321.2078
ugL
21 21
1,270.2
__ _ _______ _____
Chronic: 695.7
_ _ _ _ _ _ _ _ _ _ ___
RP shown - apply Monthly Monitoring with Limit
1 values > Allowable Cw
Acute: NO WQS
No RP, Predicted Max < 50% of Allowable Cw - No
Uranium
NC
30 FW(7Q10s)
ug/L
22 21
20.43600
Monitoring required
Chronic: 65.98954
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute:
0 0
N/A
Acute:
0 0
N/A
Chronic:
Acute:
0 0
N/A
Chronic:
NC0078115_Final FW RPA for 185 ug_20220726, rpa
Page 1 of 1 8/3/2022

NH3/TRC WLA Calculations
Facility: AQUA - Greystone Subdivision WWTP
Permit No. NC0078115
Prepared By: Bradley Bennett
Enter Design Flow (MGD): 0.032 0.19 <= Permitted Flow if Different from Design
Enter s7Q10 (cfs): 0 0.3445
Enter w7Q10 (cfs): 0.08 0.66
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/1)
IWC (%)
Allowable Conc. (ug/1)
Max Limit of 28
Fecal Coliform
Monthly Average Limit
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
Design
Permitted
Design
Permitted
0
0.3445
s7Q10 (CFS)
0
0.3445
0.032
0.185
DESIGN FLOW (MGD)
0.032
0.185
0.0496
0.28675
DESIGN FLOW (CFS)
0.0496
0.28675
17.0
17
STREAM STD (MG/L)
1.0
1.0
0
0
Upstream Bkgd (mg/1)
0.22
0.22
100.00
45.43
IWC (%)
100.00
45.43
17
37
Allowable Conc. (mg/1)
1.0
1.9
*28
< 1 MGD Policy Applies
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Design Permitted
Design
Permitted
w7Q10 (CFS)
0.08
0.66
200/100m1 200/100m1 DESIGN FLOW (MGD)
0.032
0.185
DESIGN FLOW (CFS)
0.0496
0.28675
STREAM STD (MG/L)
1.8
1.8
1.00 2.20 Upstream Bkgd (mg/1)
0.22
0.22
IWC (%)
38.27
30.29
Allowable Conc. (mg/1)
4.3
5.4
*2B .0404 (c) Applies
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/l, 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
• By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT
* From 2B .0404(c) - Winter Limits can be no less stringent than 2 times the summer limits
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Whole Effluent Toxicity Testing and Self Monitoring Summary
Greenville WWTP
NCO023931/001
County: Pitt
Region:
WARO
Basin:
TAR05
Mar Jun Sep Dec
Ceri7dPF
Begin:
3/1/2021
chr lim: 20%
NonComp:
Single
7Q10:
109
PF: 17.5
IWC:
20 Freq: Q
J
F M
A
M
J
J
A
S
O
2018
-
- >80(P) Pass
-
-
>80
-
-
H
>80
2019
-
- >80
-
-
>80
-
-
>80(P) Pass
-
2020
-
- >80(P) Pass
-
-
Pass
-
-
>80
-
2021
-
- >80
-
-
>80(P)>80
-
-
>80
-
2022
-
- >80
-
-
>80
-
-
-
-
Greystone Forest Subdivision
NCO078115/001
County: Forsyth
Region:
WSRO
Basin:
ROA01
Jan Apr Jul Oct
Ceri7dPF
Begin:
6/1/2017
Cerio Chr Lim PF: 38
T NonComp:
7Q10:
0.0
PF: 0.032
IWC:
100.0 Freq: Q
J
F M
A
M
J
J
A
S
O
2018
Pass
- -
Pass
-
-
Pass
-
-
Pass
2019
Pass
- -
Pass
-
-
Pass
-
-
-
2020
Pass
- -
Pass
-
-
Pass
-
-
Pass
2021
Pass
- -
Pass
-
-
Pass
-
-
Pass
2022
Pass
- -
Pass
-
-
-
-
-
-
Hamby Creek WWTP (Thomasville)
NCO024112/001
County: Davidson
Region:
WSRO
Basin:
YAD07
Feb May Aug Nov
Ceri7dPF
Begin:
4/1/2022
Chr lim: 90%
NonComp:
SINGLE
7Q10:
0.43
PF: 6.0
IWC:
94 Freq: Q
J
F M
A
M
J
J
A
S
O
2018
-
Pass >100(P) -
-
Pass
-
-
Pass
-
-
2019
>100
Pass -
-
Pass>100(P)
-
-
Pass
Pass
Pass
2020
Pass
Pass Pass
Pass
Pass
Pass
Pass
Pass
-
-
2021
-
Pass -
-
Pass >100(P)
-
-
Pass
-
-
2022
-
Pass -
-
Pass
-
-
-
-
-
Hamilton WWTP
NCO044776/001
County: Martin
Region:
WARO
Basin:
ROA09
Jan Apr Jul Oct
Fthd24PF
Begin:
6/1/2021
Ac P/F Lim: 90%Fthd
NonComp:
70.10:
PF: 0.08
IWC:
Freq: Q
J
F M
A
M
J
J
A
S
O
2018
Pass
- -
H
H
Pass
Pass
-
-
Pass
2019
Pass
- -
Pass
-
-
Pass
-
-
Pass
2020
Pass
- -
Pass>100
-
-
Pass
-
-
Pass
2021
Pass
- -
Pass
-
-
Pass
-
-
Pass
2022
Pass
- -
Pass
-
-
-
-
-
-
Hamlet WWTP
NCO047562/001
County: Richmond
Region:
FRO
Basin:
YAD16
Jan Apr Jul Oct
Ceri7dPF
Begin:
10/1/2015 chr lim: 38%
NonComp:
Single
7Q10:
2.5
PF: 1.0
IWC:
38.27 Freq: Q
J
F M
A
M
J
J
A
S
O
2018
Invalid(P) Pass
- -
>100(P) Pass
-
-
Pass >100(P)
-
- >100(P)
2019
Pass
- -
Pass
-
-
Pass
-
-
Pass
2020
Pass
- -
Pass
-
-
Pass
-
-
Pass
2021
Pass
- -
Pass
-
-
Pass
-
-
Pass
2022
Pass
- -
Pass
-
-
-
-
-
-
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
Fail
Pass
Pass
Pass
SOC JOC:
N
SOC JOC:
N
D
>80
Pass
>80
>80
C
D
>100
Pass
C
C
Legend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active), s = Split test between Certified Labs Page 48 of 117

Bennett, Bradley
From: Berger, Amanda A <[e-mail]>
Sent: Monday, August 1, 2022 9:05 AM
To: Bennett, Bradley
Cc: Pearce, Joseph R; Simmons, Randy L; Ison, Laurie T
Subject: RE: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
Attachments: NC0078115 Data for Review 20220727.xlsx
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Report Spam.
Hi Bradley —
Apologies on the delayed response. This required some investigation.
In early 2021, Aqua migrated to a new compliance software. The constituent library for zinc, lead, and copper was
updated to reflect drinking water limits which has been converting the lab data to mg/L. I have spoken to our developer
and they are making the necessary adjustments to update our existing data and ensure correct reporting limits in the
future. This impacts all Aqua's utilities, even other states.
Attached is your updated file with the correct values reported in ug/L. Note, I updated lead to reflect < 5ug/L. All
samples were reported as ND.
Once again, apologies on this oversite. Please let me know if you discover any other permit applications that were
effected by this software error.
Thank you,
Amanda
AQUA
Amanda Berger
Director, Environmental Compliance
Aqua North Carolina
0C
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, July 27, 2022 1:26 PM
To: Ison, Laurie T <[e-mail]>
Cc: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>; Simmons,
Randy L <[e-mail]>
Subject: RE: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.

Hey Laurie,
I have another question from my review for Greystone. Looking at the data that has been submitted it appears that for
a few parameters you have been reporting mg/L instead of µg/L. I have attached a spreadsheet showing the values that
are in question for Copper, Lead and Zinc. The ones highlighted in green may be ones that you indicated µg/L but may
have actually reported the value in mg/L. For the others in yellow, since these values are lower than other values over
time, can you verify that they are actually reported in mg/L? I need to be assured of the values as I am running the
Reasonable Potential Analysis.
These values should be reported consistently as µg/L.
Thanks for looking at this.
L3.3
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nettCaMcdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Ison, Laurie T <[e-mail]>
Sent: Monday, July 25, 2022 3:00 PM
To: Bennett, Bradley <[e-mail]>
Cc: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>; Simmons,
Randy L <[e-mail]>
Subject: RE: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
That's my fingers going their own way! 1549 Creek Bed
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Monday, July 25, 2022 2:48 PM
To: Ison, Laurie T <[e-mail]>
Cc: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>; Simmons,
Randy L <[e-mail]>
Subject: RE: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Hi Laurie,
Just wanted to check on the address for the location of the treatment plant. You indicated 1519 Creek Bed Road. See
the screen shots from Google below. These may not be accurate, but if they are then should the address be 1549? The

Thanks
fi:3
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Ison, Laurie T <[e-mail]>
Sent: Friday, July 22, 2022 2:41 PM
To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>; Simmons,
Randy L <[e-mail]>
Subject: FW: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Bradley,
The location of the WWTP is 1519 Creek Bed Road.
The backwash water is coming from Nantucket Village, River Run & Willard Oaks WTPs. The
systems filter for radium or uranium.
Please let me know if I can provide any additional information.
AQUA.
Laurie Ison
Area Manager
Aqua NC
0: 704-489-9404, Avaya Ext. 57234
M: 704-507-5381
000
From: Berger, Amanda A <[e-mail]>
Sent: Thursday, July 21, 2022 10:55 AM
To: Ison, Laurie T <[e-mail]>; Simmons, Randy L <[e-mail]>
Cc: Pearce, Joseph R <[e-mail]>; Ison, Laurie T <[e-mail]>
Subject: FW: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
Laurie and/or Randy — Can you assist in the response to these questions?
Thanks,
Amanda
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Wednesday, July 20, 2022 5:12 PM
To: Berger, Amanda A <[e-mail]>; Pearce, Joseph R <[e-mail]>; Lambeth,
Robyn E <[e-mail]>
Subject: [EXTERNAL] Questions on Greystone Subdivision WWTP (NC0078115)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Hey Guys,
I am working on the draft permit for Greystone Subdivision now. I had a couple of quick questions for you on it.
• The permit, application, etc. reference a location of Pine Creek Road for this one, but I'm wondering if that is
correct. I can't actually find a Pine Creek Road in Kernersville and from some maps it looks like this may actually
be on Creek Bed Road?

• In the last permit renewal you guys added some backwash water from water treatment systems for community
wells to discharge this facility discharge. I didn't see anything in our files that identified the well systems that
this wastewater is coming from. I'd like to add information about the treatment systems at these wells as part
of the treatment system components in the permit if you could pass along brief info along?
Also, as an update, we have the Briarwood Subdivision WWTP draft permit ready and it should go to public notice next
week.
Thanks
fi:3
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett&ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

AQUA -NC DMR/NDMR Permittee Signatory Authority Delegation
October 5, 2020
Permit Number
NC0028746
Facility Name
BRIARWOOD
Facility Address
331 Weatherford Drive, King
Area Manager/Submitter
Laurie Ison
Area Supervisor/Submitter
Randy Simmons
NC0034452
WILLOW CREEK
515 Dorado Drive, High Point
Laurie Ison
Randy Simmons
NC0050792
MELBILLE HEIGHTS
5760 Stony Creek Drive, High Point
Laurie Ison
Randy Simmons
NC0055191
PENMAN HEIGHTS
3498 Hilltop Drive, High Point
Laurie Ison
Randy Simmons
NC0063720
FOREST RIDGE
6931 August Drive, Clemmons
Laurie Ison
Randy Simmons
NC0065587
FRYE BRIDGE
6001 Stone Bluff Drive, Clemmons
Laurie Ison
Randy Simmons
NC0067091
MIKKOLA DOWNS
2777 Stable Hill Trail, Kernersville
Laurie Ison
Randy Simmons
NC0078115
GRAYSTONE
1552 Creekbed Road, Kernersville
Laurie Ison
Randy Simmons
NC0078158
OLDE BEAU
County Downs Ave, Roaring Gap
Laurie Ison
Randy Simmons
NC0083925
SALEM GLEN
1070 Keswick Lane, Clemmons
Laurie Ison
Randy Simmons
NC0083933
SALEM QUARTERS
6960 Rangecrest Road, Belews Creek
Laurie Ison
Randy Simmons
NC0083941
SPRING CREEK
650 Twin Valley Drive, Clemmons
Laurie Ison
Randy Simmons
NC0084409
WELLESLEY PLACE
1010 Laurel Cheek Lane, Lewisville
Laurie Ison
Randy Simmons
NC0088501
STONINGTON
Stonington Way Court
Laurie Ison
Randy Simmons
NC0088528
HILLCREST
Crosswinds Drive, Mount Airy
Laurie Ison
Randy Simmons
NC0088536
BANNERTOWN HILLS
Town Lane, Mount Airy
Laurie Ison
Randy Simmons
NC0088552
COLONIAL WOODS
Adkins Lane, Dobson
Laurie Ison
Randy Simmons
NC0088609
WINDGATE
Simpson Mills road, Dobson
Laurie Ison
Randy Simmons
NC0088617
SNOW HILL
Snow hill Drive, Dobson
Laurie Ison
Randy Simmons
NC0088625
THE HOLLOWS
Lois Lane, Mount Airy
Laurie Ison
Randy Simmons
NC0088633
REEVES WOODS
Reeves Mills Road, Mount Airy
Laurie Ison
Randy Simmons
NC0088854
PINE LAKES
Gloria Drive, Mount Airy
Laurie Ison
Randy Simmons
NC0088927
MEADOW RIDGE
7626 Anthony Road, Stokesdale
Laurie Ison
Randy Simmons

Bennett, Bradley
From: Bennett, Bradley
Sent: Tuesday, May 31, 2022 11:26 AM
To: Graznak, Jenny
Subject: Aqua Renewals up for review next on my list
Hey Jenny,
Hope you are doing well. I just wanted to get in touch with you and let you know that the next permit renewals that I
will be working on are a group of Aqua Facilities that are all in the W-SRO. The list is below. If you guys have any input
on these as I'm getting started, please let me know. Forward these on to the right contacts in your region if others
might have comments or concerns with these. Here is the list:
Permit Owner Facility County
NCO067091
Aqua North Carolina, Inc.
Mikkola Downs Subdivision WWTP
Forsyth
NCO028746
Aqua North Carolina, Inc.
Briarwood Subdivision WWTP
Stokes
NCO078115
Aqua North Carolina, Inc.
Gre stone Subdivision WWTP
Forsyth
NCO083933
Aqua North Carolina, Inc.
Salem Quarters WWTP
Forsyth
Thanks
1*-1V
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett()ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws