NC0049867_Fact Sheet_20221114

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Fact Sheet
NPDES Permit No. NC0049867

Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: August 10, 2021
Division/Branch: NC Division of Water Resources/NPDES Municipal Permitting
Fact Sheet Template: Version 09Jan2017

Permitting Action:
☒ Renewal
☐ Renewal with Expansion
☐ New Discharge
☐ Modification (Fact Sheet should be tailored to mod request)

Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.

Complete applicable sections below. If not applicable, enter NA.

1. Basic Facility Information
Facility Information
Applicant/Facility Name: Town of Cleveland/Cleveland Wastewater Treatment Plant (WWTP)
Applicant Address: PO Box 429, Cleveland, NC 27013
Facility Address: 625 Third Creek Church Road, Cleveland, NC 27013
Permitted Flow: 0.27 MGD
Facility Type/Waste: MAJOR Municipal; 35% domestic, 65% industrial
Facility Class: Grade II Biological Water Pollution Control System
Treatment Units: Rotary bar screen, Manual bar screen, Flow splitter box, Two oxidation
ditches, Two final clarifiers, Chlorination / dechlorination basin,
Ultrasonic flow measurement station, Aerobic digester with diffused
aeration and mixing system, Standby power
Pretreatment Program (Y/N) Y; STMP
County: Rowan
Region Mooresville
Briefly describe the proposed permitting action and facility background: The Town of Cleveland has
applied for an NPDES permit renewal at 0.27 MGD for the Cleveland WWTP. This facility serves a
population of approximately 820 residents as well as 1 significant industrial user (SIU) via an approved
pretreatment program. Treated domestic and industrial wastewater is discharged into Third Creek, a class
C water in the Yadkin Pee Dee River Basin. The facility has a primary Outfall 001. Speculative limits
were requested by the Permittee on September 22, 2017 for 0.4 MGD and 0.5 MGD flow tiers and
provided by the Division on March 9, 2018. The renewal application does not include request for
expansion and no expanded flow tiers are proposed for this facility at this time.

The sludge generated by the WWTP is disposed of by either land application or incineration.

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2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s): Outfall 001 – Third Creek
Stream Index: 12-108-20-4b
Stream Classification: C
Drainage Area (mi2): 87.4
Summer 7Q10 (cfs) 14.0
Winter 7Q10 (cfs): 24.1
30Q2 (cfs): -
Average Flow (cfs): 89.1
IWC (% effluent): 3.2
2022 303(d) listed/parameter: No
Subject to TMDL/parameter: Yes- State wide Mercury TMDL implementation.
Subbasin/HUC: 03-07-06/03040102
USGS Topo Quad: E16NW Granite Falls, NC
While not listed in the 2022 303(d) list, segment 12-108-20-4b (from SR 2359 to SR 1970) of Third
Creek is listed as exceeding criteria for Turbidity and Total Suspended Solids in the 2022 Integrated
Report. In 2011, the Division of Water Resources developed a turbidity TMDL for Third Creek. Turbidity
is addressed for POTWs by regulating total suspended solids. The waste load allocation for the Cleveland
WWTP is the existing total suspended solids limits.
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of January 2018 through June 2022.
Table 1. Effluent Data Summary Outfall 001
Parameter Units Average Max Min Permit Limit
Flow MGD 0.13 0.72 0.014 MA 0.27
BOD (summer) mg/l 7.7 56.2 2 WA 22.5
MA 15.0
BOD (winter) mg/l 12.3 492 2.5 WA 45.0
MA 30.0
TSS mg/l 8.9 492 2.5 WA 45.0
MA 30.0
NH3N (summer) mg/l 0.4 9.55 0.1 WA 18.0
MA 6.0
NH3N (winter) mg/l 0.8 11 0.04 WA 35.0
MA 12.0
DO mg/l 6.9 12.5 5.02 Monitor & Report
Fecal Coliform #/100 ml (geomean)
16.2
> 12000 < 1
(geometric)
WA 400
MA 200
Temperature ° C 17.8 26 4.5 Monitor & Report
pH SU 6.6 8.1 5.82 6.0 ≤ pH ≤ 9.0
Oil and Grease mg/l 5.4 60.6 < 1 Monitor & Report
Total Residual Chlorine µg/l 14 30 < 1 DM 28
TN mg/l 33.1 54.7 8.06 Monitor & Report
TP mg/l 4.0 9.38 0.877 Monitor & Report
MA-Monthly Average, WA-Weekly Average, DM-Daily Maximum, DA-Daily Average, QA-
Quarterly Average
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4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: The current permit requires instream monitoring for dissolved oxygen, fecal coliform,
conductivity and temperature upstream at least 100 feet from the discharge point and downstream at
NCSR 1003. The Town is a member of the Yadkin Pee Dee River Basin Association (YPDRBA) and
their instream requirements are provisionally waived as long as they maintain membership. There are no
nearby upstream or downstream YPDRBA monitoring stations. However, the Division’s Ambient
Monitoring System has a monitoring station Q3934500, located just downstream of the facility. Data
from this station reported from January 2017 through February 2020 have been summarized below in
Table 2.
Table 2. Instream Data Summary AMS Q3934500
Parameter Units Average Max Min
DO mg/l 9.4 15.4 6.2
Fecal Coliform #/100 ml (geomean)
583 8900 70
Temperature ° C 15.4 25.4 0.1
Conductivity µmhos/cm 110 151 10
Turbidity NTU 43.5 450 6.8
The downstream temperature did not exceed 29 degrees Celsius [per 15A NCAC 02B .0211 (18)] during
the period reviewed.
Downstream DO did not drop below 5 mg/L during the period reviewed [per 15A NCAC 02B .0211 (6)].
The geometric mean for fecal coliform exceeded 200/100mL downstream of the facility [per 15A NCAC
02B .0211 (7)] and was reported at levels greater than 400/100ml in more than 20% of samples taken
downstream of the facility during the period reviewed. While the Cleveland WWTP has reported limit
violations for fecal coliform, the geomean of the data during the period reviewed was considerably lower
than that of downstream fecal coliform. Permitted cattle Animal Feeding Operations (AFOs) are in
the watersheds which may be contributing to the fecal coliform exceedances.
Downstream turbidity exceeded 50 NTUs on 6 occasions during the period reviewed. [per 15A NCAC
02B .0211 (21)].
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): Y
Name of Monitoring Coalition: Yadkin Pee Dee River Basin Association

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5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): In 2018, the facility reported
one BOD limit violation and one fecal coliform limit violation. In 2019, the facility reported 21 BOD
limit violations. The facility reported 4 fecal coliform limit violations, 2 pH limit violations and 3 TSS
limit violations in 2020. In 2021, the facility reported 6 fecal coliform limit violations resulting in
enforcement.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 16 of 16 quarterly chronic toxicity tests as well as 4 of 4 second species
toxicity tests from March 2017 to December 2020.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in September 2020 reported that the facility was out of compliance with NPDES permit NC0049867. The
Regional Officer reported that, “Review of compliance history indicates facility has numerous limit
violations for BOD, TSS, pH, and Fecal Coliform. Review of violations indicate that WWTP cannot
properly treat waste loads from industry during peak operation.”
Due to the Town’s history of non-compliance, Special Condition A.(5.) Wastewater Management Plan
has been added to the permit. This special condition requires the Town to have a North Carolina licensed
Professional Engineer evaluate the structural integrity and operational efficiency of the Cleveland WWTP
to ensure the integrity of the treatment. Based on this evaluation, the Engineer and Town shall submit to
the Division a wastewater management plan that includes an assessment of facilities and an optimization
plan. Additionally, the Town shall submit annual reports summarizing actions taken towards achieving
and maintaining compliance with permit limitations.

6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows 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

Oxygen-Consuming Waste Limitations
Limitations for oxygen-consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
If permit limits are more stringent than TBELs, describe how limits were developed: The existing
limitations for BOD are based on the results of a 1994 Level B model. No changes are proposed.

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Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non-Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/l) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: TRC limits have
been reviewed in the attached WLA and have been found to be protective. No changes are proposed.
The existing limitations for BOD are based on the results of a 1994 Level B model. The ammonia limits
have been reviewed in the attached WLA for toxicity and have been found to be protective. No changes
are proposed.

Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of ½ detection limit for “less than” values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between September
2016 through May 2018 Pollutants of concern included toxicants with positive detections and associated
water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for
this permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality-based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: NA
• 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: NA
• 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: NA
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern. (PPAs from 2016 and 2017, as well as 2018 sampling)
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: N/A
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: N/A
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o 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: Total
Arsenic, Total Beryllium, Total Cadmium, Total Chromium, Total Phenolic Compounds,
Total Cyanide, Total Lead, Total Nickel, Total Selenium, Total Silver, Total Zinc, Total
Copper, Chlorodibromomethane, Bromoform

If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.

Toxicity Testing Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging “complex” wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: The permit requires quarterly chronic toxicity testing at
3.0% effluent concentration. No changes are proposed.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA’s mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (~2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/l) will
receive an MMP requirement. Industrials are evaluated on a case-by-case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/l) and/or if any individual value exceeds a TBEL
value of 47 ng/l.
Table 3. Mercury Effluent Data Summary (0.27 MGD)
2018
# of Samples 1
Annual Average Conc. ng/L 6.35
Maximum Conc., ng/L 6.35
TBEL, ng/L 47
WQBEL, ng/L 413.4

Note: an insufficiently sensitive test method was used during the Town’s 3 priority pollutant scans.
Describe proposed permit actions based on mercury evaluation: Since no annual average mercury
concentration exceeded the WQBEL, and no individual mercury sample exceeded the TBEL, no mercury
limit is required. Since the facility is < 2 MGD in design capacity, no mercury minimization plan (MMP)
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is required. Monitoring for mercury via effluent pollutant scans will continue. The Town shall use EPA
test method 1631E for low level total mercury when conducting mercury testing, including when
conducting priority pollutant scans.

Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: A TMDL to address nutrient loading to High Rock Lake is currently in progress
which may affect this facility’s discharge. As such, Special Condition A.(6.) Nutrient Reopener for High
Rock Lake has been added to the permit, indicating that the permit may be reopened and modified to
implement requirements in accordance with any future TMDL and/or nutrient management strategy for
High Rock Lake.

Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
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: NA
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, Overall BOD and TSS
removal was greater than 85%.
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

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9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(l) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
10. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti-
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
Per 15A NCAC 02B .0508., a 0.27 MGD WWTP should monitor for TN and TP at a quarterly frequency.
During the 2000 renewal of the NPDES permit, the TN and TP monitoring frequencies were increased to
monthly to provide additional data for the development of a nutrient strategy for the Yadkin Pee-Dee
River Basin. Monthly monitoring for TN and TP has been maintained to support future modeling. Based
on discussion with the DWR Basin Planning Branch, to support planning efforts, and as the two
parameters are used in calculating TN, monthly monitoring and reporting for TKN and NO2+NO3 has
been added to the permit.
To identify PFAS contamination in waters classified as Water Supply (WS) waters, monitoring
requirements are to be implemented in permits with pretreatment programs that discharge to WS waters.
As the Cleveland WWTP has a pretreatment program and discharges treated wastewater upstream of
waters designated as WS-V, monitoring of PFAS chemicals will be added to the permit at a frequency of
2/year. Since an EPA method for sampling and analyzing PFAS in wastewater is not currently available,
the PFAS sampling requirement in the Permit includes a compliance schedule which delays the effective
date of this requirement until the first full calendar quarter beginning 6 months after EPA has a final
wastewater method in 40 CFR136 published in the Federal Register. This date may be extended upon
request and if there are no NC-certified labs.

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.
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12.Summary of Proposed Permitting Actions:
Table 4. Current Permit Conditions and Proposed Changes 0.27 MGD
Parameter Current Permit Proposed Change Basis for Condition/Change
Flow MA 0.27 MGD No change 15A NCAC 2B .0505
BOD5 Summer:
MA 15.0 mg/l
WA 22.5 mg/l
Winter:
MA 30.0 mg/l
WA 45.0 mg/l
Monitor and report
weekly
No change WQBEL. 1994 Level B Model;
15A NCAC 2B; 15A NCAC 02B
.0500
NH3-N Summer:
MA 6.0 mg/l
WA 18.0 mg/l
Winter:
MA 12.0 mg/l
WA 35.0 mg/l
Monitor and report
weekly
No change WQBEL. 1994 Level B Model;
2022 WLA review. 15A NCAC
2B; 15A NCAC 02B .0500
TSS MA 30 mg/l
WA 45 mg/l
Monitor and report
weekly
No change TBEL. Secondary treatment
standards/40 CFR 133 / 15A
NCAC 2B .0406; 1994 Level B
Model; 15A NCAC 2B; 15A
NCAC 02B .0500
Fecal Coliform MA 200/100ml
WA 400/100ml
Monitor and report
weekly
No change WQBEL. State WQ standard, 15A
NCAC 2B ; DWR Guidance
Regarding the Reduction of
Monitoring Frequencies in NPDES
Permits for Exceptionally
Performing Facilities
DO DA ≥ 5 mg/l
Monitor and report
weekly
No change WQBEL. State WQ standard, 15A
NCAC 2B .0200; 15A NCAC 02B
.0500
Temperature Monitor and
Report Daily
No change Surface Water Monitoring, 15A
NCAC 2B. 0500
pH 6.0 –9.0 SU
Monitor and report
weekly
No change WQBEL. State WQ standard, 15A
NCAC 2B .0200; 15A NCAC 02B
.0500
Total Residual Chlorine DM 28 ug/L
Monitor and report
2/week
No change WQBEL. 2021 WLA. Surface
Water Monitoring, 15A NCAC 2B.
0500
Oil and Grease Monitor and report
weekly
No change Surface Water Monitoring; based
on industry
Total Nitrogen

Monitor and
Report Monthly
No change

Surface Water Monitoring, aid in
development of Yadkin Pee-Dee
River Basin Nutrient Strategy
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TKN No requirement Monitor and Report
Monthly
Surface Water Monitoring; For
calculation of Total Nitrogen – per
Basin Planning request
NO2+NO3 No requirement Monitor and Report
Monthly
Surface Water Monitoring; For
calculation of Total Nitrogen – per
Basin Planning request
Total Phosphorous Monitor and
Report Monthly
No change Surface Water Monitoring, aid in
development of Yadkin Pee-Dee
River Basin Nutrient Strategy
Total Hardness No requirement Quarterly monitoring
Upstream and in
Effluent
Hardness-dependent dissolved
metals water quality standards
approved in 2016; facility with
pretreatment
Chronic Toxicity Chronic limit,
3.0% effluent
No change WQBEL. No toxics in toxic
amounts. 15A NCAC 2B
Effluent Pollutant Scan Three times per
permit cycle
No change; to be
conducted in 2024,
2025, 2026
40 CFR 122
Electronic Reporting Electronic
Reporting Special
Condition
No change In accordance with EPA Electronic
Reporting Rule 2015.
PFAS No requirement
Add 2/year monitoring
with delayed
implementation
Evaluation of PFAS contribution:
pretreatment facility;
Implementation delayed until after
EPA certified method becomes
available.
Special Condition A.(4.)
Instream Monitoring
Requirements
Provisional
waiving of
instream
requirements based
on participation in
YPDRBA
Condition removed;
language added to
footnote of effluent
limitations table
Footnote added to A.(1.) noting
provisional waiver of instream
monitoring
Special Condition A.(6.)
Nutrient Reopener for
High Rock Lake
No requirement Add Condition A.(6.) TMDL/nutrient management
strategy development for High
Rock Lake
Special Condition A.(5.)
Wastewater
Management Plan
No requirement Add Condition A.(5.) Addressing history of non-
compliance.
MGD – Million gallons per day, MA - Monthly Average, WA – Weekly Average, DM – Daily Max, QA
– Quarterly Average, DA – Daily Average, AA – Annual Average

13. Public Notice Schedule:

Permit to Public Notice: August 16, 2022

Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
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14. NPDES Division Contact

If you have any questions regarding any of the above information or on the attached permit, please
contact Nick Coco at [phone] or via email at [e-mail].

15. Fact Sheet Addendum (if applicable):

The draft was submitted to the Town of Cleveland, EPA Region IV, and the Division’s Mooresville
Regional Office, Aquatic Toxicology Branch, and Operator Certification Program for review. The Town
of Cleveland submitted a comment on October 19, 2022 to update the Division that they have begun
working with McGill to address concerns at the plant and begin satisfying Special Condition A.(5.)
Wastewater Management Plan.

On September 14, 2022, the Division received comment from the Southern Environmental Law Center
(SELC) requesting the disclosure of any known discharges of PFAS by the Cleveland WWTP and that
NCDEQ incorporate PFAS limits in the permit. In their chemical addendum, the Town noted that no
sampling for additional parameters had been conducted and therefore no additional parameters had been
identified. By adding a monitoring requirement for PFAS, effective 6 months after the development of an
appropriate EPA-approved method to provide time for laboratories to become certified, the Town will
begin to characterize their waste stream with regard to PFAS and provide the Division valuable data. At
this time, no limits have been added for PFAS compounds. The Town remains responsible for ensuring
their indirect dischargers (whomever they may be) do not cause pass through and interference at the
wastewater treatment plant.

On September 21, 2022, the DWR Basin Planning Branch provided comments requesting the addition of
effluent TKN and NO2+NO3 monitoring and reporting to accompany TN requirements.

The Town’s, Basin Planning Branch’s and SELC’s comments have been attached to this fact sheet. No
comments were received from any other party.

Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• Based on discussion with the DWR Basin Planning Branch, to support planning efforts, and as
the two parameters are used in calculating TN, monthly monitoring and reporting for TKN and
NO2+NO3 has been added to the permit.

16. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• BOD and TSS Removal
• Dissolved Metals Implementation/Freshwater
• Waste Load Allocation Spreadsheet
• Mercury TMDL Spreadsheet
• Pretreatment Form
• Toxicity Summary
• Renewal Application Addendum
• Chemical Addendum
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4B • TUESDAY, AUGUST 16, 2022 SALISBURY POST
Motorcycles &Homes For Sale Y, Public Notices Public Notices Public Notices Public Notices
1991 Honda Nighthawk 750 to sell the Property and to deliver To]
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indebted to said estate No.1485499
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have a commissioner appointed a i
are notified to make immediate payment. Na.1493987 NOTICE TO CREDITORS
g Today's date 08/16/2022.William E.Love NOTICE TO CREDITORS Having qualified as Executor for the EstatetothepurchaseradeedtosaidasExecutorfortheestateofWilliamC. Having qualified as Collector for the Es- of Linda Sue Hughes, 108 School Street,
real estate in fee simple,free and Love,Jr.,deceased,Estate File 22E1027, fate of Ronald Howard Burridge Sr..6320 Cleveland,NC 27013,late of Rowan Coun-
jr-1'REALTY clear of all encumbrances, and 127 Fisher Farm Court,China Grove,NC South Main Street, Salisbury NC 28147 ty, NC.This is to notify all persons,firms
ii! 28023.Publish 8/16/22,8/23/22,8/30/22, late of Rowan County, NC.This is to no- and corporations having claims against thethattheinterestsandequitiesof9/6/22 tify all persons, firms and corporations said decedent to exhibit them to the un-
redemption of the Defendants in having claims against the said decedent dersigned on or before October 31,2022.No.148SoakupthepropertybeforeverbarredandNOTICE TO CREDITORS to exhibit them to the undersigned on or This notice will be pleaded in bar of their
foreclosed.Having qualified as Executor for the Es-
before November 14.2022.This notice will recovery.All persons, firms and corpora-
be pleaded in bar of their recovery.All per- tions indebted to said estate are notifiedtateofDonaldNelsonSpillman,Sr., 1540thesunWeaverRoad, China Grove, NC 28023, sons,firms and corporations indebted to to make immediate payment. Today's date
said estate are notified to make immediate 07/26/2022.Elsie Barntt Bennett as Exec-
miles, $2,000 OBO, in Solis- You are required to make defense late of Rowan County,NC.This is to notify payment. Today's date 08/09/2022.John utor for the estate of Linda Sue Hughes,n your all persons,sfitets and corporationse having T.Hudson as Collector for the estate of deceased,Estate File 22E946, 11575 NC
1
bury.973-879-7273 to such pleading not later than claims against the said decedent to exhibit Ronald Howard Burridge, Sr., deceased, Hwy 801, Mt. Ulla, NC 28125. PublishnewSeptember19, 2022 and upon them to the undersigned on or before No-P PEstate File ,122
tt
North Lee Street, 7/26/22,8/2 22,8/9/22,8/16/22
your failure to do SO the party
v
bar of heir recovery.
This noticeAll willbeo pls,firms Salisbury,NC 28144.Attorney at Law:JohnhomePublicNoticesinbartheirAllpersons,firms T. Hudson, 122 North Lee Street, Salis-seeking service against you will and corporations indebted to said estate No.1485608
Dale is ready to help you with all apply to the court for the relief are notified to make immediate payment. bury, NC 28144. Publish 8/9/22, 8 16/22, NOTICE TO CREDITORS
8/23/22,8/30/22 Havingqualified as Admninstrator CTA for
sought. Hill ass date
Executor for the
Rhonda Elaine
your real estate needs! Hill for the estate of Donald the Estate of William Clarence Phelps,Jr.,
Nelson Spillman, Sr., deceased, Estate 360 Longbow Road,Salisbury,NC 28144,Dale is someone you can trust with No.1493475 ate of Rowan Count NC.This is to Holt
p
File
NC .
1540 Weaver Road, China NOTICE TO CREDITORS
y fgsuccessfulhomesellingexperiencePublicNoticesThisdayofJuly28,2022. Grove,NC 28023.Attorney at Law:Carole Havingqualified as Co-Executors for the all pe sons,firms and corporations havingandapassionforrealestate! Carlton Brooke,PO Box 903,China Grove, claims against the said decedent to exhibit
NC 28023.Publish 8/2/22,8/9/22,8/16/22, Estate of James William Pitzer, 6220 them to the undersigned on or before Oc-
CallSarah E.G.Pilon 8/23/22 Southern Lane,Salisbury,NC 28147,late tober 31,2022.This notice will be pleaded
Dale TODAY at 704 202- No.1488347 of Rowan County,NC.This is to notify all in bar of their recovery.All persons,firms
3663 or email dale.realtor Attorney for Plaintiff No.1457131 persons, firms and corporations having and corporations indebted to said estate
NOTICE OF SERVICE BY PROCESS NOTICE TO CREDITORS claims against the said decedent to ex- are notified to make immediate [e-mail] BY PUBLICATION Capital Center Having qualified as Administrator CTA for hibit them to the undersigned on or before Today's date 07/26/2022 Rebecca Boyd
82 Patton Avenue,Suite 500 the Estate of Donald Ray Tilley,485 Hall- November 14, 2022. This notice will be Phelps as Administrator CTA for the
IN THE GENERAL COURT OF mark Circle, Salisbury, NC 28147 late of pleaded in bar of their recovery.All per- estate of William Clarence Phelps, Jr.,
JUSTICE Asheville,North Carolina 28801 Rowan County,NC.This is to notify all per- sons, firms and corporations indebted to deceased, Estate File 21 E746, 510 Bell-
sons,firms and corporations having claims said estate are notified to make immediate ingham Drive NE, Cleveland,TN 37312.
Land For Sale SUPERIOR COURT DIVISION [phone] against the said decedent to exhibit them payment.Today's date 08/09/2022.Jeffrey Resident Process Agent:Andrea Anders,
to the undersigned on or before November William Pitzer,545 Deerfield Drive,Mount 118 East Council Street, Salisbury, NC
FILE NO.22 CvS 1218 21,2022.This notice will be pleaded in bar Holly, NC 28120 and Melinda Jo Pend- 28144.Attorney at Law:Andrea Anders,
Publish 8/9/22,8/16/22,8/23/22 of their recovery.All persons,firms and cor- ergrass, 742 Rich Creek Valley Road Lot 118 East Council Street, Salisbury, NC
NORTH CAROLINA porations indebted to said estate are noti- 2M, Peterstown.West Virginia, 24963 as 28144. Publish 7/26/22, 8/2/22. 8/9/22,
12 Acres For Sale Pied to make immediate payment. Today's Co-Executors for the estate of James Wil- 8/16/22.
Starnes Road in East Rowan.Call ROWAN COUNTY No.1485581 date 08/16/2022.David Alexander Tilley as liam Pitzer,deceased,Estate File 22E998.
Administrator CTA for the estate of Donald Attorney at Law: Sean B. Sandison. 113
980-432-0676 for details.
Having qualifNfiied as ExecutorCREDITORSurf r the Estate Ray Tilley,deceased,Estate File 22E990, East Council Street,Salisbury.NC 28144. No.1497112
Rowan County,A Body Politic and of Doris Anne Roberts. 103 Tanglewood 2020 Stirewalt Road, China Grove. NC Publish 8/9/22.8/16/22,8/23/22,8/30/22 Public Notice
Corporate vs. Unknown Heirs at Drive,Kannapolis,NC 28081,late of Row- 28023. Attorney at Law: Carole Carlton
Wanted: Real Law of Albert H. an County,NC.This is to notify all persons, Brooke, P.O. Box 903, China Grove, NC North Carolina Environmental
firms and corporations having claims 28023.Publish 8/16/22,8/23/22,8/30/22, No.1488575 Management Commission/NPDES
Estate Watson, a/k/a Albert Holly Wat- against the said decedent to exhibit them 9/6/22.
Son, Dawanna Smith Watson, to the undersigned on or before October NO 14I12330
Unit
31,
f
2022.This notice will be pleaded in bar NOTICE TO CREDITORS COMPLAINT FOR ABSOLUTE 1617 Mail Service Centera/k/a Dawanna Watson, of their recovery All persons,firms and cor-
HavingALLCASHDEALSa/k/a Dawanna S. Watson, a/k/a porations indebted to said estate are noti-
the Estate ofqualified as Co-AdministratorslnKepley, Sr.,
or DIVORCE Raleigh,NC 27699-1617
fladt to make/ immediate
in R. C.
Today'sera7255BringleFerryRoad, Salisbury, NC Notice of Intent to Issue a NPDESWeBuyLand&Houses" Dewanna Smith Watson date
Executor the of R. Cramer as ry
Cash in 7 days or less Executor for the estate of Doris Anne Rob- 28146,late of Rowan County,NC.This is
to notify all persons,firms and corporations IN THE GENERAL COURT OF JUS Wastewater Permit NC0049867
Facing or In Foreclosure arts, deceased, Estate File 22E864, 103
havingclaims against the said decedent Cleveland WWTP The North Car-
TO: Unknown Heirs at Law of Tanglewood Drive,Kannapolis,NC 28081 g TICE-DISTRICT COURT DIVISION
NoProperties in any condition Publish 7/26/22,8/2/22.8/9/22.8/16/22. to exhibit them to the undersigned on or olina Environmental Management
property too small/large Albert H. Watson, a/Wa Albert before October 2022.This notice will NORTH CAROLINA 22-CVD-766 Commission proposes to issue
Call 24 hrs,7 days 704-202 2530' Holly Watson, Dawanna Smith No.1497141 pleaded in bar of their recovery.All p p
Y NOTICE TO CREDITORS persons.firms and corporations indebted STATE OF NORTH CAROLINA, a NPDES wastewater discharge
Watson, a/k/a Dawanna Watson,
Having qualified as Executor for the Estate to said estate are notified to make imme-
a/k/a Dawanna S. Watson, a/k/a of Betty Mauney Crayton,405 Mitchell As- diate payment. Today's date 07/21/2022. COUNTY OF ROWAN permit to the person(s) listed be-
Dewanna enue,Salisbury,NC 28144,late of Rowan Jack S. Kepley. Jr., 7275 Bringle Ferry low. Written comments regarding
County, NC.This is to notify all persons, Road. Salisbury, NC 28146 and William the proposed permit will be accept-
Smith Watson firms and corporations having claims K.Kepley.7265 Bringle Ferry Road,Solis- IN THE MATTER OF LAURIE D.
Rentals against the said decedent to exhibit them bury,NC 28146 as Co-Administrators for BLACK, Plaintiff, vs. MICHAEL date of this notice.The Director of
to the undersigned on or before November the estate of Jack Simpson Kepley, Sr., DALE BLACK,
ed until 30 days after the publish
Take notice that a pleading seek- 21,2022.This notice will be pleaded in bar deceased, Estate File 22E922. Publish the NC Division of Water Resourc-
ing relief against you has been of their recovery.All persons,firms and cor- 7/21/22,7/28/22,8/4/22,8/11/22. Defendant 22-CVD-766 es(DWR)may hold a public hear-
porations indebted to said estate are noti-filed in the above-entitled action- fied to make immediate payment. Today's
No.1493740 ing should there be a significant
Apartments The nature of the relief beingdate 08/16/2022.BennyMitchell Crayton NOTICE TO CREDITORS degree of public interest. PleaseasExecutorfortheestaeofBettyMauneyHavingqualifiedasAdministratorfortheThePlaintiffhavingfiledaCom-plaint
mall commnts and/or
interest..
p sought is as follows:
Crayton, deceased, Estate File 2E1024, Estate of John Lindsay Blackwell,508 Mor-and Summons,on or about
412 Mitchell Avenue,Salisbury,NC 28144. Ian Park Road,Salisbury,NC 28146,late of May 3, 2022, the Plaintiff, Laurie tion requests to DWR at the above
A+ Apartments, Salisbury. Foreclosure sale to satisfyunpaid Attorney at Law: John T. Hudson, 122 Rosa firmn s andNC.Thlcorporationsisohaviin claims D. Black, hereby notifies, Michael address. Interested persons mayPYPNorthLeeStreet, Salisbury, NC 28144. against the said decedent to exhibit them Dale Black, that she will seek an visit the DWR at 512 N.Salisburymaintained, responsible landlord- property taxes owing to Rowan Publish 8/16/22,8/23/22,8/30/22,9/6/22
to the undersigned on or before Novem- Street, Ralei h, NC 27604 to re-
750&up.Nopets.Countyon
Absolute Divorce from the De- 9
your interest in the No.1490593 ber 14,2022.This notice will be pleaded fondant and that the Defendant view information on file. Addition-Enkay Properties,704 642 1955 property described as follows: NOTICE TO t in bar of their recovery.All persons,firms al information on NPDES permitsHavingqualifiedasExecuxecutororfortheEstateandcorporationsindebtedtosaidestatemayAnswersaidComplaintby
of Jimmie Alexander Karriker,650 Corriher are
notifiedyy
to make immediate payment. filing such Answer with the Clerk and this notice may be found on
t Lying and Being in Litaker Town-
of Rowanan County,oNC.This is
28115,late ToToday'sdAdministratore / 9/2022.
for imbestaerlyofBishoP of Superior Court, Rowan County our website: http://deq.nc.gov/
abouA+Apartments&Houses Like new! ship, Rowan County, North Car-
persons, firms and corporations having LindsayE8 Blackwell,deceased,
lce
Estate File located at 210 N Main St, Salis
water-resources-permits/waste-
da
olina, with a small portion also claims against the said decedent to exhibit g bury, NC 28144 and copying the495anduppermonth. 1 Free
being located in Number Five (5) them to the undersigned on or before No- 27616.Attorney in Fact:Floyd B.Messick.
Plaintiff, Laurie D. Black at the water-branch/npdes-wastewater/
Month's Rent.704-234-7777 vember 9,2022.This notice will be pleaded III.,McKissick&McKissick,835 North Ma-
P49
Township,Cabarrus County,North in bar of their recovery.All person ,firms nun Street, Durham, NC 27701.Publish S. Milford Drive, Salisbury, North public-notices,or by calling (919)
Carolina, and being located East and corporations indebted to said estate 819r22,8/16/22.8/23/22,8/30/22 Carolina 28144 on or before Sep-
Moreland
The Town of Cleveland
Moreland Park Area 2BR all of the Roy Cline Road(SR 2570), are notified to make immediate payment. No 1484968 tember 1, 2022, or this Notice of [P.O. Box 429, Cleveland, NC
appliances furnished. $515- and being more particularly de- worth asdaa 08o vo ne slat eof Jimmie
NOTICE TO CREDITORS Publication will be pled in bar to 27013] has requested renewal of
650/mo.Dep.negotiable.Sec- scribed as follows: Alexander Karriker,deceased,Estate File Having qualified as Executor for the Estate
of Maceo Cook, 1070 Legion Club Road, any Defenses of said Defendant. NPDES permit NC0049867 for its
tion 8 welcome.336-669-7660 22E966, 2726 Brantley Road,
Richard
o-
Salisbu y NC 2atas,late of Rowan Coun- Michael Dale Black shall immedi- Cleveland Wastewater Treatment
lid,NC 28083.Attorney at Law:Richard D. ty,NC.This is to notify all persons,firmsPlant, located in Rowan County.BEGINNING at an established Locklear,P.O.Box 56,Landis,NC 28088. atelyAnswer said Complaint to the
Publish 8/2/22,8/9/22,8/16/22,8/23/22 and corporations having claims against the undersigned. This permitted facility discharges
Movingto Town? iron pin common to George H. said decedent to exhibit them to the un- treated municipal and industrial
Stirwalt,Max L.Taylor(Deed Book No.1489418 dersigned on or before October 31,2022.
Need a home or Apart- 585,Page 381),and Melvin Darius NOTICE TO CREDITORS This notice will be pleaded in bar of their wastewater to Third Creek,a class
Having qualified as Administrator for the recovery.All persons,firms and corpora- This 2nd day of August,2022. C water in the Yadkin-Pee Dee
ment?We manage rental Spry(Deed Book 564, Page 295) Estate of Rita Sherman,410 North Maple lions indebted to said estate are notified River Basin. BOD5, ammonia,
homes& apartments. and runs along the line common ES Street, Salisbury NC 28144, late of to
07/26/
e immediate pachael ment.
Cook aka
Today'schaste fecal coliform, dissolved oxygen,
Call and let us help you.
to George H. Stirwalt and Melvin Rowan
osoli msuandcorporations
NC.Ihis is o nothavingcall r-laimsel Laurie D.Black
p qualitySaffordasExecutorfortheestateofMa- TRC and Hare water ualit
Darius Spry South 07-1400 West against the said decedent to exhibit them ceo Cook,deceased,Estate File 22E940. 149 S.Milford Drive limited.This discharge may affectWaggonerRealtyCo. 599.96 feet to an established iron to the undersigned on or before November 701 Honeysuckle Way, Desoto,TX 75115. Salisbur ,NC 28144
704-633-0462 pin in the line of Charles E. Fun- 7 2022.This notice will be pleaded in bar Attorney at Law: Carl M. Short, Jr., 225 Y future allocations in this segment
of their recovery.All persons.firms and cor- North Main Street, Suite 200, P.O. Box of Third Creek.
www.waggonerrealty.com
derburk (Deed Book 296, Page porations indebted to said estate are nob- /26/Salisbury,
2 8/9/22,88 6 2229. Publish
Publish 8/2/22,8/9/22,8/16/22 Publish 8/16/22
16).said estahlished iron nirteine fled to make immediate payment. Today's
SALISBURY POST TUESDAY, AUGUST 16, 2022 • 3B
c1 ass e s Place an ad online 24 hours a day, rzE.:-.....,:,..-.,,,••
SALISBURYPOST.COM/PLACE AN AD
1v1cirketIcice 131 W Innes St, Salisbury, NC 28144 I [e-mail] I [phone]
Employment Job Opportunities Deals & Bargains Domestic Pets Homes For Sale ' Homes For Sale
CDs & Cassettes, Albums & 8 Track 511 Saint Paul Church Road,
Tapes.A rare collection of 5os/60s R&R, Dachshund Minnie Puppy Salisbur 9+Acres in Rockwell
County,Doo-Wop,Beach,R&B,Oldies, r;r+
Soul&Motown.$5.336 766 5096
Job Opportunities u
ALL-SCAPE Console Cabinet Floor Model Stereo 17
Beautiful cabinet.All works except
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automatic turn table,can be worked •
CONSTRUCTION Now Hiring! manually.$75 OBO 704-636-1382
HELP NEEDED Hourly Positions
Epoxy Table Tops Located right outside of the small
town of Faith! This 3BR, 2BA
Full-time/Part-time. Full Time& Part time! 704-232-0881 text for a pic $500 8 weeks old male,piebald, beau- beautiful home is a MUST SEE! Very nice plot of land that has a
704-636-9569 or 704-433-9700 Experience preferred FREE Piano
tiful marked, shots & wormed. This two-story farmhouse is full lot of possibilities! Apartments,
500 Call 352-304-4649 of character & charm & sits on fairly new subdivision,and approx.Rockwell•704-785-6726 704-857-3399 almost 3 acres. Fully remodeled 330 new housing development
Email: Frigidaire Refrigerator from top to bottom with fresh- down the road.So a very desirable
PallieraIISCa erockwellCurben
IIC@ mail.com Runs Good.$200 OBO.704-633 Notices
fresh-
ly painted walls & new laminate piece of property.Check with ETJ
p g flooring.
details!
t
MLS#3865205 of Rockwell for proposed uses.
e5486459,900 MLS# 3851317 DaleDaleYontzRealty,704-202-3663,
Old Kitchen Table call for details! foYr details!
Realty,704-202-3663,call
COMPANIES, LLC lrslnn From 1960s. Includes 4 chairs. AUTOS
Marketing Coordinator e • ,, $200.704-298-4089
Rockwell,618 Lake Dr.
ExcitingMarketingopportunity 701-BJA Quart/Pints//Half Pints/Jelly
CommunityEvents MERCHANDISE
with Power Curbers Compa-
Canning Jars GARAGE SALES
nies, an established Salisbury Office Manager
NC-based equipment manufac- 7/dozen.704-298 4089 ANGEL WALK/RUN 5K REAL ESTATE FOR SALE
turer. Duties include direct mail Needed Each participant
campaigns, event coordination, Small business in need of Miscellaneous receives a t-shirt. REAL ESTATE FOR RENT r
trade show support, company
an office manager to handle Top three finish- 4BR, 3BA, A veryinvitinghome 1newsletter, ad design and man- g For Sale 1
ers in each cate-
ANNOUNCEMENTS
agement, sales team support, bookeeping payroll, and ac with a front porch and very nice
gory will receive BUSINESSES&SERVICES covered patio in the back. Thisandoccasionalvideo/photog- counting as well as related a prize. Proceeds
raphy. Adobe Creative Suite home offers 3 nice size bedrooms
and Microsoft Office Products
service dispatch program. go towards Mount MISCELLANEOUS and a bath and a half with an ad
Please contact J. Newton Tabor Presbyteri- dition that has a large family room,experience preferred. Reports
an Church's summer camp and SOBS
full bath with a fourth bedroom. IttocompanyPresident. Com- Cohen by phone at 704-
couldpetitivecompensationpackage636-0003 byore-mail at:
Michelle's Butterfly Foundation, be used as a in-law suite,of-
including 401K, health &dental
Inc. $20.00 https://runsignup. Find it in the five,or an older adult child.There
profittcohen@ newtoncohen.com Harmer L ft win Awa
com/Race/NC/Cleveland/Angel-
WalkRun5K
an 20 x 20 buildingin the back.insurance, sharing, Send 1 9 Y WalkRun5K SalisburyPost This home is veryneat and clean.resume to sbullock@power- or
curbers.com
Harmar lift swing away for van, A must see! $321,500 MLS# 1
[e-mail] car, truck. Great for power chairs CLASSIFIEDS 3862252 DaleYontz Realty,704-or wheelchairs. Model AL105R1.202-3663,call for details!
phone [phone] $1,200.00 Lost Found
in e ll Rand Merchandise METAL:Angle,Channel,Pipe,SheetqPlateShearFab. & Welding PUBLIC AUCTION OF PARTIAL ESTATES
FAB DESIGNS
Found Female Puppy
Now Hiring! approx. 1yr old. Black, brown & CONSIGNMENTS
2231 Old Wilkesboro Road white.Westcliff area,no collar.CallAvailablePositions: Open Mon-Fri 7-5 704-223-1370 Thursday, August 18th •3.30 mWarehouse
Cemetery &
704-636-2349 g p
Machining Like Us On Facebook, help re 1560 Julian Road, Salisbury, 28146
Supply Chain Monument Lots Want to Buy unite Lost&Found Pets Located at the Rowan County Fairgrounds,1/2 mile off of1-85 exit74)
Assembly Merchandise www.facebook.com/ Come join us for our first auction at the New Warehouse!Several
Rowancountylostandfound partial estates including more from Dr.Crawford and some great
Engineering 2-Side by Side Burial Crypts items from the Hart estate plus two more partial estates.
BUYING JUNK CARS$100 EACH
FREE TOWING CALL 704-253-2095 LOST-SMALL MEDAL(OR Some of the great items to be auctioned:Guitars,
Competitive Pay PLEASE RECYCLE
MEDALION)w/inscription"ALL Banjo,Vintage Fender Deluxe Amp,Vintage ste-
sajelINAROUND BOY".Lost in vicinity of reo equipment, 1962 Barbie/Midge dolls w/boxes
Benefits First Day Buying old items, Furniture, Old Food Lion at 2825 Cannon Blvd., &clothes,Singer Featherweight sewing machine,
Climate Controlled Lighters,Records,Cast Iron Pans, Kannapolis. Hand tools,Shelving,Old fire alarm box,Albums/
Com an Ownership eaa Tools, Old Watches, Bottles, Old
00 Reward! LP's,HS/College annuals,20 Tom Clark Gnomes,Vin-P Y Jewelry.704-467-5261 tags toys to include:Lunch boxes,Transformers, Pez I
Matching 401 k in the beautiful `Tower of Light' at
Timber wanted - Pine or hard-
Please call 704-798-5127
dispensers,Metal cars&trucks,Thomas the Tank,
Grove
Westlawn Memorial Park in China
wood.5 acres or more select or ChattyCathy&Cabbage Patch dolls,Glassware,Chi-Grove. Located on midlevel 3, the g
Apply Now at: crypt numbers are 16 and 17 Name clear cut. Shaver Wood Prod- na sets,Christmas decor,Antique&Used Furniture
https://careers.irco.com
plate and vase are included. For ucts, Inc.Call 704-278-9291. Real Estate to include:Chests of drawers,Music Cabinet, Drop
more information call 704-298-3279.side tables,Blanket Chest,Victorian cradle,Queen
l ets & Livest IOC
Anne server, Lots of wrought iron patio furniture,
Open Interviews: Slant front desk,Wood settee, Bookcases, Beautiful
August 30th 2 pm—7 pm Deals & Bargains lamps,Antique clocks,Oriental carpets,Modern rugs
Homes For Sale including shag, Lots of mahogany furniture,Bed-
501 Sanford Avenue room suite,Several curio/display cabinets,2 Newer
TOWN OF CLEVELAND
302 East Main St
Cleveland,NC 27013
704-278-4777
Fax: [phone]
REEOCCEIVT192022
D
September 28,2022 NCDEQ/DWR/NpDES
To: Nick Coco,PE,NPDES Municipal Permit Unit
Subject: Draft NPDES Permit Renewal
Permit NC0049867
Cleveland WWTP
Rowan County
Grade II Biological WPCS
SIC Code 4952
Dear Mr. Coco:
In response to the renewal permit, special condition A(5)waste water management plan. The
following action is currently proceeding:
The Town is in a planning stage with McGill Engineering Firm to develop an expansion plan for
the wastewater treatment plant.Due to anticipated BOD,population in years and potential industrial
possibilities.
Our fecal colloform problem was due to a valve error at the chlorine treatment tank. This valve is
no longer in service, and McGill is designing an additional chlorine treatment tank.
Our BOD problem in 2019 was caused by a bug kill resulting in a bacteria rebuild.
Sincerely,
Pat Phifer
Mayor

September 14, 2022
VIA E-MAIL
Nick Coco
NCDEQ/DWR/NPDES
Municipal Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
[e-mail]

Re: Southern Environmental Law Center Comments on NPDES Wastewater
Draft Permit NC0049867 Cleveland WWTP
Dear Mr. Coco:
The Southern Environmental Law Center offers the following comments on the draft
renewal permit for National Pollutant Discharge Elimination System (“NPDES”) Permit
NC0049867, issued by the North Carolina Department of Environmental Quality (“DEQ”) to the
Town of Cleveland, North Carolina.1
The draft permit allows the Town of Cleveland to discharge wastewater likely
contaminated with per- and polyfluoroalkyl substance, or PFAS, from its wastewater treatment
plant (“WWTP”) into downstream drinking water supplies in the Yadkin Pee-Dee River Basin.
Cleveland discharges into Third Creek, a class C water less than 20 river miles upstream of the
Salisbury-Rowan surface water intake, which provides drinking water for nearly 50,000
residents. Cleveland receives wastewater from Daimler Truck North America, LLC, a significant
industrial user that likely used PFAS in its manufacturing process.
The Town of Cleveland did not disclose its PFAS discharges2 and DEQ did not evaluate
limits for the chemicals in the draft permit.3 Instead, DEQ incorporated a monitoring requirement
to become effective six months after the U.S. Environmental Protection Agency (“EPA”)
publishes a final method for analyzing PFAS concentrations in wastewater.4 Because Cleveland
did not disclose discharges of PFAS, and DEQ did not evaluate limits for the chemicals in its
draft permit, as required by the Clean Water Act and state laws, any permit issued by the agency
will necessarily prohibit all discharges of the chemicals. While it’s true that DEQ has the
authority to issue a permit that allows PFAS discharges, it cannot do so by ignoring what
pollutants are in the discharge and simply executing a monitoring condition.

1 N.C. Dep’t of Env’t Quality, Draft NPDES Permit NC0049867 (Aug. 10, 2022) [hereinafter “Cleveland Draft
Permit”].
2 Town of Cleveland, NPDES Permit Renewal Application No. NC0049867 (Sept. 26, 2018) [hereinafter
“Cleveland Permit Application”].
3 N.C. Dep’t of Env’t Quality, Fact Sheet NPDES Permit No. NC0049867 (Aug. 10, 2021), at 8.
4 Cleveland Draft Permit, supra note 1 at 8.
2

EPA’s PFAS Strategic Roadmap recently affirmed that “existing NPDES authorities” can
be used to “reduce discharges of PFAS at the source.”5 EPA’s plan further confirms that the
Clean Water Act pretreatment program can be used to control sources of PFAS, and the agency
plans to “require pretreatment programs to include source control.”6 In fact, EPA has emphasized
that regulatory bodies need not wait for final analytical methods before requiring sampling as
evidenced by EPA’s NPDES Guidance for EPA issued permits that encourages the use of Draft
Analytical Method 1633 to determine if PFAS are in a facility’s effluent.7 DEQ, therefore, must
require Cleveland test for and disclose PFAS and, if present, include limits in the town’s permit.
North Carolina has already faced a PFAS drinking water crisis. Because communities
continue to suffer from exposure to these chemicals, DEQ must act now to stop PFAS from
entering our rivers, streams, and drinking water supplies. For each permit issued for facilities that
discharge PFAS, DEQ must use its existing authority under the Clean Water Act to require
disclosure and, if PFAS are in the effluent, implement limits and mandate that municipalities use
their pretreatment authority to ensure PFAS are kept out of our state’s waterways.
I. PFAS are harmful to human health and the environment.
PFAS are a group of man-made chemicals manufactured and used broadly by industry
since the 1940s.8 PFAS pose a significant threat to human health at extremely low
concentrations. Two of the most studied PFAS––perfluorooctanoic acid (“PFOA”) and
perfluorooctane sulfonate (“PFOS”)––are bioaccumulative and highly persistent in humans.9
PFOA and PFOS have been shown to cause developmental effects to fetuses and infants, kidney
and testicular cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis,
obesity, decreased immune response to vaccines, reduced hormone levels, delayed puberty, and
lower birth weight and size.10 Because of its impacts on the immune system, PFAS can also
exacerbate the effects of Covid-19.11 Studies show that exposure to mixtures of different PFAS

5 U.S. Env’t Prot. Agency, PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024, at 14, (Oct. 2021),
https://perma.cc/LK4U-RLBH [hereinafter “EPA PFAS Roadmap”].
6 Id.
7 Memorandum from Radhika Fox, U.S. Env’t Prot. Agency to Water Division Directors EPA Regions 1-10,
Addressing PFAS Discharges in EPA-Issued NPDES Permits and Expectations Where EPA in the Pretreatment
Control Authority (Apr. 28, 2022), https://perma.cc/5NMB-ME3L[hereinafter “EPA NPDES PFAS Guidance”].
8 Lifetime Drinking Water Health Advisories for Four Perfluoroalkyl Substances, 87 Fed. Reg. 36,848, 36,849 (June
21, 2022); Our Current Understanding of the Human Health and Environmental Risks of PFAS , U.S. ENV’T PROT.
AGENCY, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (last
visited Sept. 12, 2022).
9 87 Fed. Reg. at 36,849; U.S. Env’t Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctanoic Acid
(PFOA) CASRN 335-67-1 (June 2022), at 3–4, available at https://www.epa.gov/system/files/documents/2022-
06/interim-pfoa-2022.pdf; U.S. Env’t Prot. Agency, Interim Drinking Water Health Advisory: Perfluorooctane
Sulfonic Acid (PFOS) CASRN 1763-23-1 (June 2022), at 3–4, available at
https://www.epa.gov/system/files/documents/2022-06/interim-pfos-2022.pdf.
10 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENV’T. HEALTH
PERSP. 5, A 107 (May 2015); U.S. Env’t Prot. Agency, Drinking Water Health Advisories for PFAS: Fact Sheet for
Communities, at 1–2 (June 2022), available at https://www.epa.gov/system/files/documents/2022-06/drinking-
water-ha-pfas-factsheet-communities.pdf.
11 See Lauren Brown, Insight: PFAS, Covid-19, and Immune Response–Connecting the Dots, BLOOMBERG LAW
(July 13, 2020, 4:00 AM), https://news.bloomberglaw.com/environment-and-energy/insight-pfas-covid-19-and-
immune-response-connecting-the-dots?context=article-related.
3

can worsen these health effects.12 Given these harms, EPA in June 2022 established interim
updated lifetime health advisories for PFOA and PFOS in drinking water of 0.004 and 0.02 parts
per trillion (“ppt”), respectively.13
Other PFAS are similarly harmful. This June, EPA set final lifetime health advisories for
GenX in drinking water of 10 ppt.14 Numerous states have acknowledged the dangers of other
PFAS compounds and proposed or finalized drinking water standards for various PFAS at 20 ppt
and lower.15
PFAS are also harmful to wildlife and the environment. The chemicals have been shown
to cause damaging effects in fish,16 amphibians,17 mollusks,18 and other aquatic invertebrates19—
resulting in developmental and reproductive impacts, behavioral changes, adverse effects to

12 Emma V. Preston et al., Prenatal Exposure to Per- and Polyfluoroalkyl Substances and Maternal and Neonatal
Thyroid Function in the Project Viva Cohort: A Mixtures Approach , 139 ENV’T INT’L 1 (2020),
https://perma.cc/DJK3-87SN.
13 87 Fed. Reg. at 36,848–49.
14 Id.
15 See Per- and Polyfluoroalkyl Substances (PFAS), INTEGRAL CORP., https://www.integral-corp.com/pfas/ (last
visited Sept. 12, 2022).
16 Chen et al., Perfluorobutanesulfonate Exposure Causes Durable and Transgenerational Dysbiosis of Gut
Microbiota in Marine Medaka, 5 ENV’T SCI. & TECH LETTERS 731–38 (2018); Chen et al., Accumulation
of Perfluorobutane Sulfonate (PFBS) and Impairment of Visual Function in the Eyes of Marine Medaka After
a LifeCycle Exposure, 201 AQUATIC TOXICOLOGY 1–10 (2018); Du et al., Chronic Effects of Water-Borne PFOS
Exposure on Growth, Survival and Hepatotoxicity in Zebrafish: A Partial Life-Cycle Test, 74 CHEMOSPHERE 723–29
(2009); Hagenaars et al., Structure–Activity Relationship Assessment of Four Perfluorinated Chemicals Using a
Prolonged Zebrafish Early Life Stage Test, 82 CHEMOSPHERE 764–72 (2011); Huang et al., Toxicity, Uptake
Kinetics and Behavior Assessment in Zebrafish Embryos Following Exposure
to Perfluorooctanesulphonicacid (PFOS), 98 AQUATIC TOXICOLOGY 139–47 (2010); Jantzen et al., PFOS, PFNA,
and PFOA Sub-Lethal Exposure to Embryonic Zebrafish Have Different Toxicity Profiles in terms of
Morphometrics, Behavior and Gene Expression, 175 AQUATIC TOXICOLOGY 160–70 (2016); Liu et al., The Thyroid-
Disrupting Effects of Long-Term Perfluorononanoate Exposure on Zebrafish (Danio rerio),
20 ECOTOXICOLOGY 47–55 (2011); Chen et al., Multigenerational Disruption of the Thyroid Endocrine System in
Marine Medaka after a Life-Cycle Exposure to Perfluorobutanesulfonate, 52 ENV’T SCI. & TECH. 4432–39
(2018); Rotondo et al., Environmental Doses of Perfluorooctanoic Acid Change the Expression of Genes in Target
Tissues of Common Carp, 37 ENV’T TOXICOLOGY & CHEM. 942–48 (2018).
17 Ankley et al., Partial Life-Cycle Toxicity and Bioconcentration Modeling of Perfluorooctanesulfonate in the
Northern Leopard Frog (Rana Pipiens), 23 ENV’T TOXICOLOGY & CHEM. 2745 (2004); Cheng et al., Thyroid
Disruption Effects of Environmental Level Perfluorooctane Sulfonates (PFOS) in Xenopus Laevis,
20 ECOTOXICOLOGY 2069–78 (2011); Lou et al., Effects
of Perfluorooctanesulfonate and Perfluorobutanesulfonate on the Growth and Sexual Development of
Xenopus Laevis, 22 ECOTOXICOLOGY 1133–44 (2013).
18 Liu et al., Oxidative Toxicity of Perfluorinated Chemicals in Green Mussel and Bioaccumulation Factor
Dependent Quantitative Structure-Activity Relationship, 33 ENV’T TOXICOLOGY & CHEM. 2323–32 (2014); Liu et
al., Immunotoxicity in Green Mussels under Perfluoroalkyl Substance (PFAS) Exposure: Reversible Response and
Response Model Development, 37 ENV’T TOXICOLOGY & CHEM. 1138–45 (2018).
19 Houde et al., Endocrine-Disruption Potential of Perfluoroethylcyclohexane Sulfonate (PFECHS) in Chronically
Exposed Daphnia Magna, 218 ENV’T POLLUTION 950–56 (2016); Liang et al., Effects of Perfluorooctane Sulfonate
on Immobilization, Heartbeat, Reproductive and Biochemical Performance of Daphnia Magna ,
168 CHEMOSPHERE 1613–18 (2017); Ji et al., Oxicity of Perfluorooctane Sulfonic Acid and Perfluorooctanoic Acid
on Freshwater Macroinvertebrates (Daphnia Magna and Moina Macrocopa) and Fish (Oryzias Latipes), 27 ENV’T
TOXICOLOGY & CHEM. 2159 (2008); MacDonald et al., Toxicity of Perfluorooctane Sulfonic Acid and
Perfluorooctanoic Acid to Chironomus Tentans, 23 ENV’T TOXICOLOGY & CHEM. 2116 (2004).
4

livers, disruption to endocrine systems, and weakened immune systems.20 Moreover, PFAS are
extremely resistant to breaking down in the environment, can travel long distances, and bio-
accumulate in organisms.21 PFAS have been found in fish tissue, and communities that rely
heavily on fishing have been found to have elevated PFAS levels in their blood.22 Due to these
harms, EPA has published draft recommended freshwater aquatic life criteria for PFOA and
PFOS.23
II. Daimler Truck, Cleveland’s only significant industrial user, is a type of industry
that uses and discharges PFAS.
Daimler Truck North America is freightliner truck manufacturer whose industrial
processes include metal finishing.24 In Cleveland’s permit application, the town notes that
Daimler Truck’s principal raw materials include aluminum, steel, plastics, paints, solvents,
adhesives, petroleum products, and commodity chemicals and that the town receives continuous
process water flow from the truck manufacturer.25 PFAS are widely used in the metal finishing
industry, and many metal finishing facilities have been found to be sources of PFAS
contamination into groundwater and surface waters.
The term “metal finishing” refers to different types of finishing operations including
electroplating, electroless plating, anodizing, coating, chemical etchings and milling, and printed
circuit board manufacturing.26 EPA has confirmed that “PFAS have been, and continue to be,
used by metal finishing facilities in the United States” to reduce mechanical wear as well as
reduce corrosion or enhance aesthetic appearance.27 For example, plating, a type of metal
finishing that involves covering a surface with a thin layer of metal, is used “for corrosion
inhibition and radiation shielding; to harden, reduce friction, alter conductivity, and decorate
objects; and to improve wearability, paint adhesion, infrared (IR) reflectivity, and solderability”28
The plating industry uses PFAS for “corrosion prevention, mechanical wear reduction, aesthetic

20 See supra notes 16–19.
21What are PFAS?, Agency for Toxic Substances and Disease Registry, https://www.atsdr.cdc.gov/pfas/health-
effects/overview html (last visited Sept. 12, 2022); see also Our Current Understanding of the Human Health and
Environmental Risks of PFAS, supra note 8.
22 Patricia A. Fair et al., Perfluoralkyl Substances (PFASs) in Edible Fish Species from Charleston Harbor and
Tributaries, South Carolina, United States: Exposure and Risk Assessment , 171 ENV’T. RES. 266 (April
2019); Chloe Johnson, Industrial chemicals in Charleston Harbor taint fish – and those who eat them, POST &
COURIER (June 4, 2022), https://www.postandcourier.com/environment/industrial-chemicals-in-charleston-harbor-
taint-fish-and-those-who-eat-them/article b2b14506-bc19-11ec-83e5-7f2a8322d624 html.
23Draft Recommended Aquatic Life Ambient Water Quality Criteria for Perfluorooctanoic Acid (PFOA) and
Perfluorooctane Sulfonic Acid (PFOS), 85 Fed. Reg. 26,199, 26,200 (May 3, 2022).
24 Cleveland Permit Application, supra note 2 at PDF 19.
25 Id.
26 U.S. Env’t Prot. Agency, Multi-Industry Per- and Polyfluoroalkyl Substances (PFAS) Study -2021 Preliminary
Report, at 6-1 (Sept. 2021), available at https://www.epa.gov/system/files/documents/2021-09/multi-industry-pfas-
study preliminary-2021-report 508 2021.09.08.pdf [hereinafter “EPA PFAS Industry Preliminary Report”].
27 Id. at 6-4.
28 Hayley & Aldrich, PFAS Technical Update (2020), available at
https://www.haleyaldrich.com/Portals/0/Downloads/HA-Technical-Update-PFAS-in-the-plating-industry.pdf.
5

enhancement,” and as a “surfactant, wetting agent/fume suppressant for chrome, copper, nickel
and tin electroplating, and postplating cleaner.”29
As a result of the metal finishing industry’s broad use of PFAS, PFAS contamination of
surface water is often found near plating facilities.30 For instance, Michigan, which has done
extensive PFAS sampling throughout the state, has linked PFAS pollution to plating facilities in
several instances.31 The state found one type of PFAS—perfluorooctane sulfonate (“PFOS”)—at
levels of 19,000 parts per trillion (“ppt”) in the wastewater from Lapeer Plating & Plastics, a
chrome finishing company.32 Similarly, the state has found elevated levels of PFAS in or around:
• the Washetenaw Industrial Facility in Saline, a former plating site;
• the Ford Motor Company Saline Plant, which formerly did chrome plating;
• a former General Motors Plant 3 plating facility in Lansing;
• the Adams Plating Superfund site in Lansing;
• the Michner Plating shop in Jackson;
• the Diamond Chrome Plating facility i n Howell;
• an old Lacks Enterprises plating shop in Cascade Township;
• Electro Chemical Finishing in Wyoming, which discharged plating wastewater;
• a former Lacks Enterprises plating shop in Saranac;
• the former Production Plated Plastics site in Richland;
• the MAHLE Engine Components USA former Harvey Street plant in
Muskegon, which previously used plating in the production of engine parts;
• the Peerless Plating facility in Muskegon Heights; and
• the fo rmer Manistee Plating shop.33

It is likely, therefore, that Cleveland is receiving wastewater that contains PFAS from
Daimler Truck’s metal finishing waste .34

29 Interstate Technology Regulatory Council, History and Use of Per- and Polyfluoroalkyl Substances (PFAS)
(2020), at 5, available at https://pfas-
1.itrcweb.org/fact sheets page/PFAS Fact Sheet History and Use April2020.pdf; Fath, et al., Electrochemical
decomposition of fluorinated wetting agents in plating industry waste water, 73 WATER SCI TECH. 7, 1659–66
(2016), available at https://iwaponline.com/wst/article-lookup/doi/10.2166/wst.2015.650.
30 See EPA PFAS Industry Preliminary Report, supra note 26 at 6-4 to 6-5.
31 Garret Ellison, All Known PFAS Sites in Michigan, MLIVE (Jun. 11, 2019), https://www mlive.com/news/erry-
2018/07/00699c24a57658/michigan pfas sites html.
32 Id.
33 Id.
34 It’s also possible that Daimler’s metal finishing waste contains 1,4-dioxane—a harmful chemical used as a solvent
stabilizer. See U.S. Env’t Prot. Agency, Technical Fact Sheet-1,4-Dioxane (Nov. 2017), available at
https://www.epa.gov/sites/default/files/2014-03/documents/ffrro factsheet contaminant 14-
dioxane january2014 final.pdf. 1,4-dioxane is a clear, man-made chemical that is a byproduct of many industrial
processes. The chemical is toxic to humans, causing liver and kidney damage. Id. As a result of the harms caused by
1,4-dioxane, EPA established a drinking water health advisory with an associated lifetime cancer risk of one -in-a-
million at a concentration of 0.35 parts per billion (“ppb”). Id. DEQ currently regulates 1,4-dioxane through the
narrative water quality standard, 15A N.C. Admin. Code 2B .0208, whic h sets a water quality standard for 1,4-
dioxane at 0.35 ppb in water supply waters. 15A N.C. Admin Code 2B .0208; see also Managing Emerging

6

III. DEQ must require Cleveland to disclose any PFAS that the town is discharging
from its treatment plant.
The Clean Water Act prohibits the discharge of any pollutant without a NPDES permit.
The discharge of a specific pollutant (or group of pollutants) cannot be permitted if it is not
disclosed in a NPDES permit application. Therefore, Cleveland is required to disclose any
discharges of PFAS in its permit application.
If a NPDES permit applicant does not adequately disclose its release of a pollutant, the
applicant does not have approval to discharge the pollutant.35 Disclosure is considered adequate
when the applicant provides enough information for a permitting agency to “be[] able to judge
whether the discharge of a particular pollutant constitutes a significant threat to the
environment.”36 To meet this burden, an applicant must include all relevant information,
including the concentration, volume, and frequency of the discharge.37 The Clean Water Act
places the burden of disclosure on the permit applicant because they are in the best position to
know what is in their discharge.38
The EPA has stressed the need for disclosure of pollutants during the permitting process:
[D]ischargers have a duty to be aware of any significant pollutant levels in their
discharge. […] Most important, [the disclosure requirements] provide the
information which the permit writers need to determine what pollutants are likely
to be discharged in significant amounts and to set appropriate permit limits. […]
[P]ermit writers need to know what pollutants are present in an effluent to
determine approval permit limits in the absence of applicable effluent
guidelines.39
The EPA Environmental Appeals Board’s decision in In re: Ketchikan Pulp Company further
emphasized the importance of disclosure,40 and this decision has been adopted by the Fourth

Compounds in Water, N.C. DEP’T OF ENV’T QUALITY, https://deq nc.gov/news/key-issues/emerging-
compounds/managing-emerging-compounds-water#groundwater-and-surface-water-quality-standards-actions (last
visited Sept. 12, 2022). DEQ should at the minimum, require Cleveland to sample and disclose (in the manner
discussed throughout this letter) whether its discharges contain 1,4-dioxane and if the effluent does, set a limit that
achieves compliance with the narrative water quality standard.
35 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).
36 Piney Run, 268 F.3d at 268 (“Because the permitting scheme is dependent on the permitting authority being able
to judge whether the discharge of a particular pollutant constitutes a significant threat to the environment, discharges
not within the reasonable contemplation of the permitting authority during the permit application process, whether
spills or otherwise, do not come within the protection of the permit shield.”).
37 See In re Ketchikan Pulp Co., 7 E.A.D. 605 (“In explaining the provisions of 40 C.F.R. § 122.53(d)(7)(iii ), which
required dischargers to submit quantitative data relating to certain conventional and nonconventional pollutants that
dischargers know or have reason to believe are present in their effluent, the [EPA] stated: ‘permit writers need to
know what pollutants are present in an effluent to determine appropriate limits in the absence of effluent
guidelines.’”).
38 S. Appalachian Mountain Stewards, 758 F.3d at 566 (“The statute and regulations purposefully place the burden
of disclosure on the permit applicant.”).
39 Consolidated Permit Application Forms for EPA Programs, 45 Fed. Reg. 33,526 –31 (May 19, 1980).
40 See In re Ketchikan Pulp Co., 7 E.A.D. 605.
7

Circuit. For example, in Piney Run Pres. Ass’n v. Cty. Comm’rs of Carroll Cty., Maryland, the
Fourth Circuit stated:
The Ketchikan decision therefore made clear that a permit holder is in compliance
with the [Clean Water Act] even if it discharges pollutants that are not listed in its
permit, as long as it only discharges pollutants that have been adequately
disclosed to the permitting authority. […] To the extent that a permit holder
discharges a pollutant that it did not disclose, it violates the NPDES permit
and the [Clean Water Act].41
Moreover, as discussed in more detail in Section V, 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.42
DEQ has acknowledged that disclosure of toxic pollutants, including PFAS, is required
by the Clean Water Act and state water quality laws. In its enforcement action against The
Chemours Company, LLC for the company’s discharge of GenX and other PFAS into the Cape
Fear River, the agency stated:
Part of the permit applicant’s burden in this regard is to disclose all relevant
information, such as the presence of known constituents in a discharge that pose a
potential risk to human health. The permit applicant is required to disclose “all
known toxic components that can be reasonably expected to be in the discharge,
including but not limited to those contained in a priority pollutant analysis.” 15A
N.C.A.C. 2H .0105(j) (emphasis added). […] These disclosure obligations are
critical, in part, because they define the scope of the Clean Water Act’s “permit
shield.” While compliance with the express terms of an NPDES permit generally
“shields” the permittee from liability for violations of 33 U.S.C. § 1311, the
permit does not shield the permittee from liability where the pollutant being
discharged was not within the “reasonable contemplation” of the permitting
agency when it issued the permit due to nondisclosure by the permittee.43
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.”44
DEQ’s position in the Chemours enforcement case was correct and should be applied to
Cleveland in this permit renewal. If Cleveland discharges PFAS, then the town was required to
disclose the pollutant in its permit application so that DEQ can “judge whether the discharge”

41 Piney Run, 268 F.3d. at 268 (emphasis added).
42 40 C.F.R. § 403.8(f)(1)(vi)(B).
43 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, ¶¶ 21–24 (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)).
44 Id. at ¶ 156.
8

“constitutes a significant threat to the environment.”45 Because Cleveland failed to do so,46 DEQ
does not have the information it needs to make an informed decision on the town’s application.47
Importantly, if Cleveland were to discharge PFAS after failing to disclose such
chemical(s) in its NPDES permit application, it would violate the Clean Water Act and would
not be covered by a permit shield. The Tennessee Department of Environment and Conservation
has made clear in at least one NPDES permit that undisclosed discharges of PFAS are
unpermitted:
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…48
DEQ must require Cleveland to disclose any discharge of PFAS in the town’s permit
application before moving forward with the draft NPDES permit. DEQ should direct Cleveland
to analyze its effluent using EPA recommended draft method 1633 and draft method 1621 and
disclose any PFAS found through this sampling.49 Draft method 1633 tests for 40 PFAS
compounds in a variety of media, while draft method 1621 is a screening method that can
identify the presence of thousands of known PFAS but does not identify the specific PFAS that
are present.50 DEQ must do require disclosure to ensure regulated parties know of their
obligations with respect to PFAS and are aware of the potential liability if they fail to do so.
IV. DEQ must analyze appropriate effluent limits for PFAS in Cleveland’s NPDES
permit.
If Cleveland is discharging PFAS, DEQ must consider appropriate permit limits for the
town’s renewal NPDES permit. The Clean Water Act requires permitting agencies to, at the very
least, incorporate, technology-based effluent limitations on the discharge of pollutants.51 North
Carolina water quality laws further state that municipalities must be treated like an industrial
discharger if an industrial user “significantly impact[s]” a municipal treatment system.52 In this
situation, the agency must consider technology-based effluent limits for the municipality, even if
effluent limits and guidelines have not been published and adopted.53

45 Piney Run, 268 F.3d at 268.
46 Cleveland Permit Application, supra note Error! Bookmark not defined. at PDF 4–8.
47 See S. Appalachian Mountain Stewards, 758 F.3d at 566 (“[T]he CWA and its implementing regulations focus on
the information that the permit applicant must gather and provide to the permitting agency, so that it can make a
fully informed decision to issue the requested permit.”).
48 TDEC, NPDES Permit NO. TN0002330 (2020), Holliston Holdings, LLC, Addendum to Rationale,
https://perma.cc/4RKY-PKFG (emphasis added).
49 EPA recommends the use these methods for EPA-issued NPDES permits. See EPA NPDES PFAS Guidance,
supra note 7 at 2.
50 CWA Analytical Methods for Per- and Polyfluorinated Alkyl Substances (PFAS), U.S. ENV’T PROT. AGENCY,
https://www.epa.gov/cwa-methods/cwa-analytical-methods-and-polyfluorinated-alkyl-substances-pfas (last visited
Sept. 12, 2022).
51 40 C.F.R. § 125.3(a); see also 33 U.S.C. § 1311.
52 15A N.C. Admin. Code 2B .0406(a).
53 Id.
9

Effective treatment technologies for PFAS are available. Granular activated carbon is a
cost effective and efficient technology that is capable of reducing PFAS concentrations to
virtually nondetectable levels. A granular activated carbon treatment system at the Chemours’
facility, for example, has reduced PFAS concentrations as high as 345,000 ppt from a creek
contaminated by groundwater beneath the facility to nearly nondetectable concentrations.54 DEQ
must consider the feasibility of Cleveland installing this technology or similarly effective
technologies as well as its industrial user.
If these limits are not enough to ensure compliance with water quality standards, then
water quality-based effluent limits must be included.55 PFAS are known to harm human health,
and their discharge threatens to violate multiple water quality standards, including the state toxic
substances standard.56 DEQ itself has stated in its lawsuit against Chemours that PFAS “meet the
definition of ‘toxic substance’” under North Carolina rules.57 In order to comply with the Clean
Water Act, therefore, if Cleveland discharges PFAS, DEQ must limit its discharge so that it will
not “cause, or contribute” to concentrations of PFAS in excess of levels protective of human
health. To determine this concentration, DEQ should utilize EPA’s interim health advisories and
other data that shows the harmful effects of PFAS.
V. DEQ should require Cleveland to update its industrial user inventory.
By setting PFAS limits and conditions in Cleveland’s permit, DEQ can ensure that
Cleveland properly regulates its industrial users so that they do not release uncontrolled PFAS
waste into the environment and downstream drinking water supplies.58
The Clean Water Act pretreatment program requires a municipality to know what it is
receiving from its industries, and EPA has confirmed that this requirement extends to pollutants
that are not conventional or listed as toxic, like PFAS.59 Municipal wastewater treatment plants,
like Cleveland, must instruct their industries to identify their pollutants in an industrial waste
survey60 and, when applying for a pretreatment permit, to disclose “effluent data,” including on
internal waste streams when necessary to evaluate pollution controls.61 Significant industrial

54 See Parsons, Engineering Report – Old Outfall 002 GAC Pilot Study Results (Sept. 2019), available at
https://www.chemours.com/ja/-/media/files/corporate/12e-old-outfall-2-gac-pilot-report-2019-09-
30.pdf?rev=6e1242091aa846f888afa895eff80e2e&hash=040CAA7522E3D64B9E5445ED6F96B0FB ; see also
Chemours Outfall 003, NPDES No. NC0089915 Discharge Monitoring Reports (2020–2022), available at
https://perma.cc/8YND-XT5M.
55 15A N.C. Admin. Code 2H .0112(c) (stating that DWR must “reasonably ensure compliance with applicable
water quality standards and regulations.”); see 33 U.S.C. § 1311(b)(1)(c) (requiring that permit limits be established
as necessary to comply with water quality standards).
56 15A N.C. Admin. Code 2B .0208(a).
57 N.C. DEQ Amended Complaint, supra note 43 at ¶ 152 (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).
58 40 C.F.R. § 403.8(f)(1).
59 See EPA PFAS Roadmap, supra note 5 at 14.
60 40 C.F.R. § 403.8(f)(2)(ii); U.S. Env’t Prot. Agency, Introduction to the National Pretreatment Program, at 4 -3
(Jun. 2011), available at https://www.evansvillegov.org/egov/documents/1499266949 62063.pdf .
61 U.S. Env’t Prot. Agency, Industrial User Permitting Guidance Manual (2012), at 4 -2 to 4-3, available at
https://www.epa.gov/sites/default/files/2015-10/documents/industrial user permitting manual full.pdf.
10

users are further required to provide information “[p]rincipal products and raw materials . . . that
affect or contribute to the [significant industrial user’s] discharge.”62 To ensure that
municipalities use their existing pretreatment authority, EPA’s NPDES PFAS Guidance
recommends that permits issued to municipal wastewater treatment plants include a permit
requirement to identify industrial users in industry categories “expected or suspected of PFAS
discharges.”63 Because Cleveland’s only significant industrial user engages in metal finishing,
DEQ should follow EPA’s guidance and include a condition in Cleveland’s permit that requires
it to update its industrial user survey and determine the volume of PFAS, if any, being sent to the
wastewater treatment plant.
If after survey, Cleveland learns that Daimler Truck discharges PFAS, the Clean Water
Act gives the town the tools it needs to control the discharges and ensure the industry does not
cause the treatment plant to violate its own NPDES permit.64 Cleveland can establish local limits
for PFAS,65 or can go beyond pretreatment permit limits and incorporate permit conditions
including “[r]equirements for the installation of pretreatment technology, pollution control, or
construction of appropriate containment devices, designed to reduce, eliminate, or prevent the
introduction of pollutants into the treatment works.”66 Regulating municipal WWTPs this way 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 [WWTPs] rather than directly to
receiving waters.”67
VI. Conclusion.
In summary, DEQ must require Cleveland to disclose any discharges of PFAS in its
permit application so that DEQ and the public have adequate information to evaluate the
discharge. If Cleveland does not make that disclosure, any discharge of PFAS is illegal and
subject to agency or citizen enforcement. If Cleveland makes that disclosure, DEQ must then
evaluate available treatment technologies and impose limits that ensure compliance with water
quality standards. Additionally, DEQ should require Cleveland to update its industrial user

62 40 CFR § 122.21(j)(6)(ii)(C).
63 EPA NPDES PFAS Guidance, supra note 7 at 3.
64 40 C.F.R. § 403.8(f)(1).
65 See U.S. Env’t Prot. Agency, Local Limits Development Guidance (July 2004), at 5-11 to 5-21, available at
https://www3.epa.gov/npdes/pubs/final local limits guidance.pdf. Municipal wastewater treatment plants, like
Cleveland, also have discretion to set permit limits for industrial u sers through a case-by-case analysis “based on the
discharger’s current loading, its need for a continued loading allocation, its ability to apply pretreatment to achieve
certain discharge pollutant levels (i.e. treatability), or any other factor that the [municipal WWTP] determines is
relevant.” Id. at 6-12.
66 U.S. Env’t Prot. Agency, EPA Model Pretreatment Ordinance, at 24 (Jan. 2007), available at
https://www3.epa.gov/npdes/pubs/pretreatment model suo.pdf.
67 General Pretreatment Regulations for Existing and New Sources, 52 Fed. Reg. 1586, 1590 (Jan. 14, 1987)
(codified at 40 C.F.R. § 403).
11

survey to include PFAS. Because the draft permit fails to meet these requirements, it should be
withdrawn.
Thank you for considering these comments. Please contact me at 919-967-1450 or
[e-mail] if you have any questions regarding this letter.

Sincerely,

Hannah M. Nelson
SOUTHERN ENVIRONMENTAL LAW CENTER
601 W. Rosemary Street, Suite 220
Chapel Hill, NC 27516

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Permit No. NC0049867
Page 1 of 4

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/l
(Dissolved)
Chronic FW, µg/l
(Dissolved)
Acute SW, µg/l
(Dissolved)
Chronic SW, µg/l
(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/l 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/l
Cadmium, Acute WER*{1.136672-[ln hardness](0.041838)} ∙ e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters WER*{1.136672-[ln hardness](0.041838)} ∙ e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic WER*{1.101672-[ln hardness](0.041838)} ∙ e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute WER*0.316 ∙ e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic WER*0.860 ∙ e^{0.8190[ln hardness]+0.6848}
Copper, Acute WER*0.960 ∙ e^{0.9422[ln hardness]-1.700}
Copper, Chronic WER*0.960 ∙ e^{0.8545[ln hardness]-1.702}
Lead, Acute WER*{1.46203-[ln hardness](0.145712)} ∙ e^{1.273[ln hardness]-1.460}
Lead, Chronic WER*{1.46203-[ln 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}
Permit No. NC0049867
Page 2 of 4

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[ln hardness]+0.884}

General Information on the Reasonable Potential Analysis (RPA)
The RPA process itself did not change as the result of the new metals standards. However, application of
the dissolved and hardness-dependent standards requires additional consideration in order to establish the
numeric standard for each metal of concern of each individual discharge.
The hardness-based standards require some knowledge of the effluent and instream (upstream) hardness
and so must be calculated case-by-case for each discharge.
Metals limits must be expressed as ‘total recoverable’ metals in accordance with 40 CFR 122.45(c). The
discharge-specific standards must be converted to the equivalent total values for use in the RPA
calculations. We will generally rely on default translator values developed for each metal (more on that
below), but it is also possible to consider case-specific translators developed in accordance with
established methodology.

RPA Permitting Guidance/WQBELs for Hardness-Dependent Metals - Freshwater
The RPA is designed to predict the maximum likely effluent concentrations for each metal of concern,
based on recent effluent data, and calculate the allowable effluent concentrations, based on applicable
standards and the critical low-flow values for the receiving stream.
If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most cases. If
monitoring for a particular pollutant indicates that the pollutant is not present (i.e. consistently below
detection level), then the Division may remove the monitoring requirement in the reissued permit.
1. To perform a RPA on the Freshwater hardness-dependent metals the Permit Writer compiles the
following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically calculates
the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification

2. In order to establish the numeric standard for each hardness-dependent metal of concern and for
each individual discharge, the Permit Writer must first determine what effluent and instream
(upstream) hardness values to use in the equations.

The permit writer reviews DMR’s, Effluent Pollutant Scans, and Toxicity Test results for any
hardness data and contacts the Permittee to see if any additional data is available for instream
hardness values, upstream of the discharge.

If no hardness data is available, the permit writer may choose to do an initial evaluation using a
default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum limits on the
hardness value used for water quality calculations are 25 mg/L and 400 mg/L, respectively.

If the use of a default hardness value results in a hardness-dependent metal showing reasonable
potential, the permit writer contacts the Permittee and requests 5 site-specific effluent and
upstream hardness samples over a period of one week. The RPA is rerun using the new data.

Permit No. NC0049867
Page 3 of 4

The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) + (s7Q10, cfs *Avg. Upstream Hardness, mg/L)
(Permitted Flow, cfs + 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.

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
EPA default partition coefficients or the “Fraction Dissolved” converts the value for
dissolved metal at laboratory conditions to total recoverable metal at in-stream
ambient conditions. This factor is calculated using the linear partition coefficients
found in The Metals Translator: Guidance for Calculating a Total Recoverable
Permit Limit from a Dissolved Criterion (EPA 823-B-96-007, June 1996) and the
equation:

_Cdiss__ = _______1_______________
Ctotal 1 + { [Kpo] [ss(1+a)] [10-6] }

Where:
ss = in-stream suspended solids concentration [mg/l], 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.

Permit No. NC0049867
Page 4 of 4

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)]
162.67 Average from 2016 and two 2017
PPAs
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)]
25 Default value
7Q10 summer (cfs) 14.0 USGS 1994 Low Flow Report
1Q10 (cfs) 11.59 Calculated in RPA
Permitted Flow (MGD) 0.27 NPDES Files

Date: _____8/10/2022________________________

Permit Writer: ______Nick Coco________________
REQUIRED DATA ENTRY
Name WQS Type Chronic Modifier Acute PQL Units
Facility Name Cleveland WWTP Par01 Arsenic Aquactic Life C 150 FW 340 ug/L
WWTP/WTP Class II Par02 Arsenic Human Health
Water Supply C 10 HH/WS N/A ug/L
NPDES Permit NC0049867 Par03 Beryllium Aquatic Life NC 6.5 FW 65 ug/L
Outfall 001 Par04 Cadmium Aquatic Life NC 0.6599 FW 3.7763 ug/L
Flow, Qw (MGD)0.270 Par05 Chlorides Aquatic Life NC 230 FW mg/L
Receiving Stream Third Creek Par06 Chlorinated Phenolic Compounds Water Supply NC 1 A ug/L
HUC Number 03040102 Par07 Total Phenolic Compounds Aquatic Life NC 300 A ug/L
Stream Class Par08 Chromium III Aquatic Life NC 132.9340 FW 1045.0353 ug/L
Par09 Chromium VI Aquatic Life NC 11 FW 16 µg/L
7Q10s (cfs)14.000 Par10 Chromium, Total Aquatic Life NC N/A FW N/A µg/L
7Q10w (cfs)24.10 Par11 Copper Aquatic Life NC 8.9451 FW 12.3557 ug/L
30Q2 (cfs)14.00 Par12 Cyanide Aquatic Life NC 5 FW 22 10 ug/L
QA (cfs)89.10 Par13 Fluoride Aquatic Life NC 1,800 FW ug/L
1Q10s (cfs)11.59 Par14 Lead Aquatic Life NC 3.4754 FW 91.9593 ug/L
Effluent Hardness 162.67 mg/L (Avg)Par15 Mercury Aquatic Life NC 12 FW 0.5 ng/L
Upstream Hardness 25 mg/L (Avg)Par16 Molybdenum Human Health NC 2000 HH ug/L
Combined Hardness Chronic 29 mg/L Par17 Nickel Aquatic Life NC 42.2072 FW 388.8812 µg/L
Combined Hardness Acute 29.8 mg/L Par18 Nickel Water Supply NC 25.0000 WS N/A µg/L
Data Source(s)Par19 Selenium Aquatic Life NC 5 FW 56 ug/L
Par20 Silver Aquatic Life NC 0.06 FW 0.4009 ug/L
Par21 Zinc Aquatic Life NC 143.6989 FW 145.8660 ug/L
Par22 Chlorodibromomethane Human Health C 21 HH µg/L
Par23 Bromoform Human Health C 120 HH µg/L
Par24
Follow directions for data entry. In some cases a
comment menu list the available choices or a
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
To appy a Model IWC %: Once the
"Flow, Qw (MGD)" and and the
"CHRONIC DILUTION FACTOR =
" values are entered, the 7Q10s
(cfs) flow is calculated and
displayed. Enter the calculated
"7Q10s (cfs)" flow value in Table 1.
Table 1. Project Information Table 2. Parameters of Concern
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
C
CHECK IF HQW OR ORW WQS
CHECK TO APPLY MODEL
Apply WS Hardness WQC
49867 RPA, input
8/2/2022
REASONABLE POTENTIAL ANALYSIS
H1 H2
Effluent Hardness Upstream Hardness
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 9/6/2016 140 140 Std Dev.32.5781 1 Default 25 25 Std Dev.N/A
2 12/11/2017 148 148 Mean 162.6667 2 Mean 25.0000
3 3/15/2017 200 200 C.V. (default)0.6000 3 C.V.0.0000
4 n 3 4 n 1
5 10th Per value 141.60 mg/L 5 10th Per value 25.00 mg/L
6 Average Value =162.67 mg/L 6 Average Value =25.00 mg/L
7 Max. Value 200.00 mg/L 7 Max. Value 25.00 mg/L
8 8
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 1 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
Arsenic
Date Data BDL=1/2DL Results
1 6/27/2018 <5 2.5 Std Dev.1.4434
2 9/13/2016 <10 5 Mean 3.7500
3 12/5/2017 <5 2.5 C.V. (default)0.6000
4 3/15/2017 <10 5 n 4
5
6 Mult Factor =2.59
7 Max. Value 5.0 ug/L
8 Max. Pred Cw 13.0 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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 2 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par03 Par04
Beryllium Cadmium
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 9/13/2016 <1 0.5 Std Dev.0.0000 1 5/15/2018 <5 2.5 Std Dev.0.8660
2 12/5/2017 <1 0.5 Mean 0.5000 2 6/27/2018 <2 1 Mean 1.0000
3 3/15/2017 <1 0.5 C.V. (default)0.6000 3 9/13/2016 <1 0.5 C.V. (default)0.6000
4 n 3 4 12/5/2017 <1 0.5 n 5
5 5 3/15/2017 <1 0.5
6 Mult Factor =3.00 6 Mult Factor =2.32
7 Max. Value 0.50 ug/L 7 Max. Value 2.500 ug/L
8 Max. Pred Cw 1.50 ug/L 8 Max. Pred Cw 5.800 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 3 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par07 Par10
Total Phenolic Compounds Chromium, Total
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 9/13/2016 <50 25 Std Dev.0.0000 1 6/27/2018 9 9 Std Dev.2.6887
2 3/15/2017 <50 25 Mean 25.0000 2 9/13/2016 <10 5 Mean 5.3750
3 C.V. (default)0.6000 3 12/5/2017 <5 2.5 C.V. (default)0.6000
4 n 2 4 3/15/2017 <10 5 n 4
5 5
6 Mult Factor =3.79 6 Mult Factor =2.59
7 Max. Value 25.0 ug/L 7 Max. Value 9.0 µg/L
8 Max. Pred Cw 94.8 ug/L 8 Max. Pred Cw 23.3 µg/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 4 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Pa11 Par12
Copper Cyanide
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 6/27/2018 10 10 Std Dev.6.8071 1 6/27/2018 <5 5 Std Dev.0.0000
2 9/13/2016 23.1 23.1 Mean 16.3500 2 9/13/2016 <5 5 Mean 5.00
3 12/5/2017 11 11 C.V. (default)0.6000 3 12/5/2017 <5 5 C.V. (default)0.6000
4 3/15/2017 21.3 21.3 n 4 4 3/15/2017 <5 5 n 4
5 5
6 Mult Factor =2.59 6 Mult Factor =2.59
7 Max. Value 23.10 ug/L 7 Max. Value 5.0 ug/L
8 Max. Pred Cw 59.83 ug/L 8 Max. Pred Cw 13.0 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 5 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par14 Par16
Lead Molybdenum
Date BDL=1/2DL Results Date Data BDL=1/2DL Results
1 6/27/2018 <2 1 Std Dev.1.9738 1 5/15/2018 <5 2.5 Std Dev.0.0000
2 9/13/2016 <10 5 Mean 3.3750 2 5/16/2018 <5 2.5 Mean 2.5000
3 12/5/2017 <5 2.5 C.V. (default)0.6000 3 6/27/2018 <5 2.5 C.V. (default)0.6000
4 3/15/2017 <10 5 n 4 4 n 3
5 5
6 Mult Factor =2.59 6 Mult Factor =3.00
7 Max. Value 5.000 ug/L 7 Max. Value 2.5 ug/L
8 Max. Pred Cw 12.950 ug/L 8 Max. Pred Cw 7.5 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 6 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par17 & Par18 Par19
Nickel Selenium
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/15/2018 <5 2.5 Std Dev.1.0945 1 6/27/2018 <5 2.5 Std Dev.1.2500
2 5/16/2018 <5 2.5 Mean 2.8017 2 9/13/2016 <10 5 Mean 4.3750
3 6/27/2018 2 2 C.V. (default)0.6000 3 12/5/2017 <10 5 C.V. (default)0.6000
4 9/13/2016 2.31 2.31 n 6 4 3/15/2017 <10 5 n 4
5 12/5/2017 <10 5 5
6 3/15/2017 2.5 2.5 Mult Factor =2.14 6 Mult Factor =2.59
7 Max. Value 5.0 µg/L 7 Max. Value 5.0 ug/L
8 Max. Pred Cw 10.7 µg/L 8 Max. Pred Cw 13.0 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE
SPECIAL-Values"
then "COPY" .
Maximum data
points = 58
Use "PASTE
SPECIAL-Values"
then "COPY" .
Maximum data
points = 58
- 7 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par20 Par21
Silver Zinc
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 5/15/2018 <5 2.5 Std Dev.1.5943 1 6/27/2018 53 53 Std Dev.3.5331
2 5/16/2018 <5 2.5 Mean 3.0833 2 9/13/2016 46.1 46.1 Mean 51.2250
3 6/27/2018 <2 1 C.V. (default)0.6000 3 12/5/2017 54 54 C.V. (default)0.6000
4 9/13/2016 <10 5 n 6 4 3/15/2017 51.8 51.8 n 4
5 12/5/2017 <5 2.5 5
6 3/15/2017 <10 5 Mult Factor =2.14 6 Mult Factor =2.59
7 Max. Value 5.000 ug/L 7 Max. Value 54.0 ug/L
8 Max. Pred Cw 10.700 ug/L 8 Max. Pred Cw 139.9 ug/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE SPECIAL-
Values" then "COPY" .
Maximum data points =
58
Use "PASTE SPECIAL-
Values" then "COPY"
. Maximum data
points = 58
- 8 -
49867 RPA, data
8/2/2022
REASONABLE POTENTIAL ANALYSIS
Par22 Par23
Chlorodibromomethane Bromoform
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 9/12/2016 18 18 Std Dev.5.9181 1 9/12/2016 78 78 Std Dev.35.5349
2 12/12/2017 7.7 7.7 Mean 11.1667 2 12/12/2017 8.7 8.7 Mean 47.9000
3 3/11/2017 7.8 7.8 C.V. (default)0.6000 3 3/11/2017 57 57 C.V. (default)0.6000
4 n 3 4 n 3
5 5
6 Mult Factor =3.00 6 Mult Factor =3.00
7 Max. Value 18.000000 µg/L 7 Max. Value 78.000000 µg/L
8 Max. Pred Cw 54.000000 µg/L 8 Max. Pred Cw 234.00000 µg/L
9 9
10 10
11 11
12 12
13 13
14 14
15 15
16 16
17 17
18 18
19 19
20 20
21 21
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
Use "PASTE
SPECIAL-Values"
then "COPY" .
Maximum data points
= 58
Use "PASTE
SPECIAL-Values"
then "COPY" .
Maximum data
points = 58
- 9 -
49867 RPA, data
8/2/2022
Cleveland WWTP ≥Outfall 001
NC0049867 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 0.27 MGD
MAXIMUM DATA POINTS = 58
Qw (MGD) = 0.2700 WWTP/WTP Class:II COMBINED HARDNESS (mg/L)
1Q10S (cfs) = 11.59 IWC% @ 1Q10S = 3.485031436 Acute = 29.8 mg/L
7Q10S (cfs) = 14.00 IWC% @ 7Q10S = 2.902521067 Chronic = 29 mg/L
7Q10W (cfs) = 24.10 IWC% @ 7Q10W = 1.706874401
30Q2 (cfs) = 14.00 IWC% @ 30Q2 = 2.902521067
Avg. Stream Flow, QA (cfs) = 89.10 IW%C @ QA = 0.467501131
Receiving Stream:Stream Class:C
PARAMETER RECOMMENDED ACTION
Chronic Applied
Standard Acute n # Det.Max Pred Cw
Acute (FW):9,756.0
Arsenic C 150 FW(7Q10s)340 ug/L
4 0 13.0 Chronic (FW):5,167.9
C.V. (default)Max MDL = 10
Arsenic C 10 HH/WS(Qavg)ug/L Note: n ≤ 9 NO DETECTS Chronic (HH):2,139.0
Limited data set Max MDL = 10
Acute:1,865.12
Beryllium NC 6.5 FW(7Q10s)65 ug/L 3 0 1.50
Note: n ≤ 9 C.V. (default)Chronic:223.94
Limited data set NO DETECTS Max MDL = 1
Acute:108.358
Cadmium NC 0.6599 FW(7Q10s)3.7763 ug/L 5 0 5.800
Note: n ≤ 9 C.V. (default)Chronic:22.735
Limited data set NO DETECTS Max MDL = 5
Acute:NO WQS
Total Phenolic Compounds NC 300 A(30Q2)ug/L 2 0 94.8
Note: n ≤ 9 C.V. (default)Chronic:10,335.8
Limited data set NO DETECTS Max MDL = 50
Acute:29,986.4
Chromium III NC 132.9340 FW(7Q10s)1045.0353 µg/L 0 0 N/A
Chronic:4,580.0
Acute:459.1
Chromium VI NC 11 FW(7Q10s)16 µg/L 0 0 N/A
Chronic:379.0
Tot Cr value(s) ≥ 5 but < Cr VI Allowable Cw
Chromium, Total NC µg/L 4 1 23.3
Note: n ≤ 9 C.V. (default)
Limited data set
Acute:354.53
Copper NC 8.9451 FW(7Q10s)12.3557 ug/L 4 4 59.83
Note: n ≤ 9 C.V. (default)Chronic:308.19
Limited data set No value > Allowable Cw
Acute:631.3
Cyanide NC 5 FW(7Q10s)22 10 ug/L 4 0 13.0
Note: n ≤ 9 C.V. (default)Chronic:172.3
Limited data set NO DETECTS Max MDL = 10PQLUNITSTYPE
Allowable Cw
REASONABLE POTENTIAL RESULTSNC STANDARDS OR EPA CRITERIA
Third Creek HUC 03040102
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Max reported value = 9
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
a: No monitoring required if all Total Chromium
samples are < 5 µg/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Page 1 of 2
49867 RPA, rpa
8/2/2022
Cleveland WWTP ≥Outfall 001
NC0049867 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw = 0.27 MGD
Acute:2,638.694
Lead NC 3.4754 FW(7Q10s)91.9593 ug/L 4 0 12.950
Note: n ≤ 9 C.V. (default)Chronic:119.738
Limited data set NO DETECTS Max MDL = 10
Acute (FW):11,158.6
Nickel NC 42.2072 FW(7Q10s)388.8812 µg/L
6 3 10.7 Chronic (FW):1,454.2
Note: n ≤ 9 C.V. (default)No value > Allowable Cw
Nickel NC 25.0000 WS(7Q10s)µg/L Limited data set Chronic (WS):861.3
No value > Allowable Cw
Acute:1,606.9
Selenium NC 5 FW(7Q10s)56 ug/L 4 0 13.0
Note: n ≤ 9 C.V. (default)Chronic:172.3
Limited data set NO DETECTS Max MDL = 10
Acute:11.503
Silver NC 0.06 FW(7Q10s)0.4009 ug/L 6 0 10.700
Note: n ≤ 9 C.V. (default)Chronic:2.067
Limited data set NO DETECTS Max MDL = 10
Acute:4,185.5
Zinc NC 143.6989 FW(7Q10s)145.8660 ug/L 4 4 139.9
Note: n ≤ 9 C.V. (default)Chronic:4,950.8
Limited data set No value > Allowable Cw
Acute:NO WQS
Chlorodibromomethane C 21 HH(Qavg)µg/L 3 3 54.00000
Note: n ≤ 9 C.V. (default)Chronic:4491.968
Limited data set No value > Allowable Cw
Acute:NO WQS
Bromoform C 120 HH(Qavg)µg/L 3 3 234.00000
Note: n ≤ 9 C.V. (default)Chronic:25668.38710
Limited data set No value > Allowable Cw
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
All values reported non-detect < 10 ug/L, < 5 ug/L or
< 2 ug/L - No monitoring required. Permittee shall
report to PQL of 1 ug/L.
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
Page 2 of 2
49867 RPA, rpa
8/2/2022
NC0049867 Cleveland WWTP 8/2/2022
Month RR (%)Month RR (%)Month RR (%)Month RR (%)
January-18 97.35 July-20 98.38 January-18 98.56 July-20 98.42
February-18 98.04 August-20 99.13 February-18 99.45 August-20 97.56
March-18 95.85 September-20 98.89 March-18 99.40 September-20 98.32
April-18 95.31 October-20 99.12 April-18 98.34 October-20 97.82
May-18 96.90 November-20 98.34 May-18 99.09 November-20 92.71
June-18 96.64 December-20 99.26 June-18 97.77 December-20 99.41
July-18 96.88 January-21 99.14 July-18 98.94 January-21 99.57
August-18 95.22 February-21 97.12 August-18 97.52 February-21 92.50
September-18 96.32 March-21 97.30 September-18 96.42 March-21 98.44
October-18 96.61 April-21 97.30 October-18 98.36 April-21 99.28
November-18 96.89 May-21 98.92 November-18 99.41 May-21 99.74
December-18 89.00 June-21 98.18 December-18 99.46 June-21 99.65
January-19 68.18 July-21 99.47 January-19 99.70 July-21 99.66
February-19 87.76 August-21 98.84 February-19 99.05 August-21 99.52
March-19 85.13 September-21 98.94 March-19 99.36 September-21 97.12
April-19 86.21 October-21 97.84 April-19 98.02 October-21 95.72
May-19 89.64 November-21 98.53 May-19 99.41 November-21 97.46
June-19 92.45 December-21 97.46 June-19 99.49 December-21 98.03
July-19 94.78 January-22 98.38 July-19 99.47 January-22 98.60
August-19 92.86 February-22 98.49 August-19 99.04 February-22 97.61
September-19 97.40 March-22 98.49 September-19 99.64 March-22 99.43
October-19 97.53 April-22 97.97 October-19 99.32 April-22 99.59
November-19 98.66 May-22 99.28 November-19 99.87 May-22 99.70
December-19 97.94 June-22 99.63 December-19 99.68 June-22 99.83
January-20 97.71 July-22 January-20 99.37 July-22
February-20 97.17 August-22 February-20 99.34 August-22
March-20 96.02 September-22 March-20 89.41 September-22
April-20 98.37 October-22 April-20 97.04 October-22
May-20 97.09 November-22 May-20 96.62 November-22
June-20 97.96 December-22 June-20 98.57 December-22
Overall BOD removal rate 96.08 Overall TSSD removal rate 98.35
BOD monthly removal rate TSS monthly removal rate
8/2/22 WQS = 12 ng/L V:2013-6
Facility Name
/Permit No. :
Total Mercury 1631E PQL = 0.5 ng/L 7Q10s = 14.000 cfs WQBEL = 413.43 ng/L
Date Modifier Data Entry Value Permitted Flow = 0.270 47 ng/L
6/27/18 6.35 6.35 6.4 ng/L - Annual Average for 2018
Cleveland WWTP/NC0049867 No Limit Required
MERCURY WQBEL/TBEL EVALUATION
No MMP Required
Cleveland WWTP/NC0049867
Mercury Data Statistics (Method 1631E)
2018
# of Samples 1
Annual Average, ng/L 6.4
Maximum Value, ng/L 6.35
TBEL, ng/L
WQBEL, ng/L 413.4
47

NH3/TRC WLA Calculations
Facility: Cleveland WWTP
PermitNo. NC0049867
Prepared By: Nick Coco
Enter Design Flow (MGD):0.27
Enter s7Q10 (cfs):14
Enter w7Q10 (cfs):24.1
Total Residual Chlorine (TRC)Ammonia (Summer)
Daily Maximum Limit (ug/l)Monthly Average Limit (mg NH3-N/l)
s7Q10 (CFS)14 s7Q10 (CFS)14
DESIGN FLOW (MGD)0.27 DESIGN FLOW (MGD)0.27
DESIGN FLOW (CFS)0.4185 DESIGN FLOW (CFS)0.4185
STREAM STD (UG/L)17.0 STREAM STD (MG/L)1.0
Upstream Bkgd (ug/l)0 Upstream Bkgd (mg/l)0.22
IWC (%)2.90 IWC (%)2.90
Allowable Conc. (ug/l)586 Allowable Conc. (mg/l)27.1
Cap at 28 ug/L. Same as current permit limit. Maintain limit.Less stringent than current permit limit. Maintain limit.
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/l)
Fecal Coliform w7Q10 (CFS)24.1
Monthly Average Limit:200/100ml DESIGN FLOW (MGD)0.27
(If DF >331; Monitor)DESIGN FLOW (CFS)0.4185
(If DF<331; Limit)STREAM STD (MG/L)1.8
Dilution Factor (DF)34.45 Upstream Bkgd (mg/l)0.22
IWC (%)1.71
Allowable Conc. (mg/l)92.8
Less stringent than current permit limit. Maintain limit.
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/l 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
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non-Muni)
MRs Between and Violation Category:Program Category:
Param Name County:Subbasin:%Violation Action:
Major Minor:%
Permit:
Facility Name:
Region:--NC0049867
%%
%
%
Limit Violation %
%
8 2017 8 2022
MONITORING REPORT(MR) VIOLATIONS for:08/01/22Report Date:1Page:of 3
PERMIT:NC0049867 FACILITY:Town of Cleveland - Cleveland WWTP COUNTY:Rowan REGION:Mooresville
%
Over
UNIT OF
MEASURE VIOLATION ACTIONVIOLATION TYPECALCULATED
VALUELIMITFREQUENCYVIOLATION
DATEPARAMETERLOCATIONMONITORING
REPORT
Limit Violation
OUTFALL
04 - 2018 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
04/28/18 Weekly Weekly Average
Exceeded
Proceed to NOV27.922.5mg/l 24
01 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
01/12/19 Weekly Weekly Average
Exceeded
Proceed to NOV15645mg/l 246.7
01 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
01/19/19 Weekly Weekly Average
Exceeded
Proceed to NOV8345mg/l 84.4
01 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
01/26/19 Weekly Weekly Average
Exceeded
Proceed to NOV55.545mg/l 23.3
01 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
01/31/19 Weekly Monthly Average
Exceeded
Proceed to NOV82.630mg/l 175.3
02 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
02/02/19 Weekly Weekly Average
Exceeded
Proceed to NOV77.845mg/l 72.9
02 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
02/09/19 Weekly Weekly Average
Exceeded
Proceed to NOV62.145mg/l 38
02 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
02/28/19 Weekly Monthly Average
Exceeded
Proceed to NOV34.330mg/l 14.3
03 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
03/16/19 Weekly Weekly Average
Exceeded
Proceed to NOV64.845mg/l 44
03 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
03/31/19 Weekly Monthly Average
Exceeded
Proceed to NOV37.130mg/l 23.7
04 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
04/06/19 Weekly Weekly Average
Exceeded
Proceed to NOV56.222.5mg/l 149.8
04 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
04/13/19 Weekly Weekly Average
Exceeded
Proceed to NOV27.822.5mg/l 23.6
04 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
04/27/19 Weekly Weekly Average
Exceeded
Proceed to NOV36.222.5mg/l 60.9
04 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
04/30/19 Weekly Monthly Average
Exceeded
Proceed to NOV34.6515mg/l 131
05 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
05/25/19 Weekly Weekly Average
Exceeded
Proceed to NOV32.122.5mg/l 42.7
MRs Between and Violation Category:Program Category:
Param Name County:Subbasin:%Violation Action:
Major Minor:%
Permit:
Facility Name:
Region:--NC0049867
%%
%
%
Limit Violation %
%
8 2017 8 2022
MONITORING REPORT(MR) VIOLATIONS for:08/01/22Report Date:2Page:of 3
PERMIT:NC0049867 FACILITY:Town of Cleveland - Cleveland WWTP COUNTY:Rowan REGION:Mooresville
%
Over
UNIT OF
MEASURE VIOLATION ACTIONVIOLATION TYPECALCULATED
VALUELIMITFREQUENCYVIOLATION
DATEPARAMETERLOCATIONMONITORING
REPORT
Limit Violation
OUTFALL
05 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
05/31/19 Weekly Monthly Average
Exceeded
Proceed to NOV25.215mg/l 68
06 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
06/01/19 Weekly Weekly Average
Exceeded
Proceed to NOV36.722.5mg/l 63.1
06 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
06/08/19 Weekly Weekly Average
Exceeded
Proceed to NOV23.822.5mg/l 5.8
06 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
06/30/19 Weekly Monthly Average
Exceeded
Proceed to NOV16.1515mg/l 7.7
07 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
07/27/19 Weekly Weekly Average
Exceeded
Proceed to NOV35.122.5mg/l 56
08 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
08/31/19 Weekly Weekly Average
Exceeded
Proceed to NOV23.222.5mg/l 3.1
08 - 2019 001 Effluent BOD, 5-Day (20 Deg. C) -
Concentration
08/31/19 Weekly Monthly Average
Exceeded
Proceed to NOV15.2815mg/l 1.8
03 - 2020 001 Effluent Chlorine, Total Residual 03/18/20 2 X week Daily Maximum
Exceeded
No Action, BPJ3028ug/l 7.1
04 - 2020 001 Effluent Chlorine, Total Residual 04/01/20 2 X week Daily Maximum
Exceeded
No Action, BPJ3028ug/l 7.1
04 - 2020 001 Effluent Chlorine, Total Residual 04/13/20 2 X week Daily Maximum
Exceeded
No Action, BPJ3028ug/l 7.1
09 - 2018 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
09/22/18 Weekly Weekly Geometric Mean
Exceeded
No Action, BPJ415.13400#/100ml 3.8
07 - 2020 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
07/31/20 Weekly Monthly Geometric Mean
Exceeded
Proceed to NOD202.2200#/100ml 1.1
08 - 2020 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
08/01/20 Weekly Weekly Geometric Mean
Exceeded
Proceed to NOV742.79400#/100ml 85.7
09 - 2020 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
09/05/20 Weekly Weekly Geometric Mean
Exceeded
Proceed to NOV2,420400#/100ml 505
11 - 2020 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
11/14/20 Weekly Weekly Geometric Mean
Exceeded
Proceed to NOV4,200400#/100ml 950
01 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
01/09/21 Weekly Weekly Geometric Mean
Exceeded
Proceed to
Enforcement Case
2,000400#/100ml 400
MRs Between and Violation Category:Program Category:
Param Name County:Subbasin:%Violation Action:
Major Minor:%
Permit:
Facility Name:
Region:--NC0049867
%%
%
%
Limit Violation %
%
8 2017 8 2022
MONITORING REPORT(MR) VIOLATIONS for:08/01/22Report Date:3Page:of 3
PERMIT:NC0049867 FACILITY:Town of Cleveland - Cleveland WWTP COUNTY:Rowan REGION:Mooresville
%
Over
UNIT OF
MEASURE VIOLATION ACTIONVIOLATION TYPECALCULATED
VALUELIMITFREQUENCYVIOLATION
DATEPARAMETERLOCATIONMONITORING
REPORT
Limit Violation
OUTFALL
01 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
01/23/21 Weekly Weekly Geometric Mean
Exceeded
Proceed to
Enforcement Case
7,070.05400#/100ml 1,667.5
01 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
01/30/21 Weekly Weekly Geometric Mean
Exceeded
Proceed to
Enforcement Case
5,800400#/100ml 1,350
01 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
01/31/21 Weekly Monthly Geometric Mean
Exceeded
Proceed to
Enforcement Case
3,291.15200#/100ml 1,545.6
02 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
02/06/21 Weekly Weekly Geometric Mean
Exceeded
Proceed to
Enforcement Case
12,000400#/100ml 2,900
02 - 2021 001 Effluent Coliform, Fecal MF, MFC
Broth, 44.5 C
02/13/21 Weekly Weekly Geometric Mean
Exceeded
Proceed to
Enforcement Case
5,400400#/100ml 1,250
03 - 2020 001 Effluent pH 03/17/20 Weekly Daily Minimum Not
Reached
Proceed to
Enforcement Case
5.826su 3.0
03 - 2020 001 Effluent pH 03/30/20 Weekly Daily Minimum Not
Reached
Proceed to
Enforcement Case
5.876su 2.2
03 - 2020 001 Effluent Solids, Total Suspended -
Concentration
03/14/20 Weekly Weekly Average
Exceeded
Proceed to
Enforcement Case
47.845mg/l 6.2
03 - 2020 001 Effluent Solids, Total Suspended -
Concentration
03/21/20 Weekly Weekly Average
Exceeded
Proceed to
Enforcement Case
49245mg/l 993.3
03 - 2020 001 Effluent Solids, Total Suspended -
Concentration
03/31/20 Weekly Monthly Average
Exceeded
Proceed to
Enforcement Case
142.6230mg/l 375.4
EPA
United States Environmental Protection Agency
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 Type Inspector Fac Type
1 N 52 NC0049867 20/09/10 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
3 N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Cleveland WWTP
625 Third Creek Church Rd
Cleveland NC 27013
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 20/09/10 14/08/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Troy Gene Cassidy/ORC/704-278-4669/
Other Facility Data
12:12PM 20/09/10 19/03/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Patrick Phifer,302 E Main St Cleveland NC 270138414/Mayor/704-278-4777/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
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
Roberto Scheller DWR/MRO WQ/707-235-2204/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger DWR/Division of Water Quality/704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
NPDES yr/mo/day
20/09/10
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Review of compliance history indicates facility has numerous limit violations for BOD, TSS, pH, and
Fecal Coliform. Review of violations indicate that WWTP can not properly treat waste loads from
industries during peak operation.
NC0049867 17
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Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Permit Yes No NA NE
(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?
Permit is for continued operation of 0.27 MGD wastewater treatment plant with influent
rotary screen, 2-oxidation ditches, 2- secandary clarifiers, gas Cl2 and dechlorination,
flow measurement, aerobic digester, drying beds, and standby power.
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
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Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
pH meter calibration sheet should have serial # or ID# of meter on sheet to identify
meter being calibrated.
Review of compliance history for subject facility indicates that facility has received
numerous limit violations for BOD, TSS, and Fecal Coliform. Review of violations
appear to indicate that WWTP can not handle waste loads from industries during peak
operations. It is therefore required that a writen responce be submitted to this Office
indicating what steps the Town plans to take or have taken to correct this issue.
Please note that this responce does not alleviate the Town of any enforcement actions
by the State.
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Review of process control indicate that MLSS appeared to be under general design
parameters for oxidation ditch operation.
Enclosed with inspection report is copy of "EPA Wastewater Technology Fact Sheet
Oxidation Ditches" with general design parameters for MLSS concertration, Solids
Rentention Time (SRT), BOD Loading, and other general parameters for operation.
It is recommended that the orignal facility Operations and Maintenance Manual for
WWTP operation be found to find design set parameters for facility.
Comment:
Bar Screens Yes No NA NE
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?
Influent structure is equiped with rotary screen and has a manual bar screen bypass.Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is sampling performed according to the permit?
Page#4
Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Influent Sampling Yes No NA NE
At time of inspection influent sampler was recorded at 7 degrees Celsius.Comment:
Oxidation Ditches Yes No NA NE
Are the aerators operational?
Are the aerators free of excessive solids build up?
# 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?
Are settleometer results acceptable (> 30 minutes)?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes)
30 minute settelometer had been ran for oxidation ditch #1 & 2 and had sat for 2
hours before inspection. Settelometers had settled to 350ml/l and 375 ml/L
respectively.
Comment:
Secondary Clarifier Yes No NA NE
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 ¼ of the sidewall depth)
At time of inspection effluent was clear with what appeared to be small grease particles
going over weirs. FOG program should be enforced and grease traps inspected.
Comment:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
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Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Comment:
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No.
7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
When tested during inspection chlorine and sulfur dioxide leak alarms did not operate.
Leak detection alarms should be in working order at all times.
Comment:
De-chlorination Yes No NA NE
Type of system ?Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de-chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
When tested during inspection sulfur dioxide and chlorine leak detection did not
operate. Leak detection alarms should be in working order at all times.
Comment:
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Page#6
Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Effluent Sampling Yes No NA NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
At time of inspection effluent sampler was recorded at 2 degrees Celsius.Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Danny Kruchkaw of Carolina Technical Services calibrated flow meter on August 21,
2020.
Comment:
Aerobic Digester Yes No NA NE
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Drying Beds Yes No NA NE
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
# Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
# Is the sludge disposed of through county landfill?
# Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Drying beds were grown up in vegetation. It is recommended that drying beds be
maintained for a back up during winter months when land application is not possible.
Comment:
Page#7
Permit:NC0049867
Inspection Date:09/10/2020
Owner - Facility:
Inspection Type:
Cleveland WWTP
Compliance Evaluation
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Town maintains generator and checks fuel levels.Comment:
Page#8
Whole Effluent Toxicity Testing and Self Monitoring Summary Cleveland County WTPNC0051918/001Acu Monit:  90% annFthd24PFBegin:2/1/2015Freq:AJan Apr Jul OctNonComp:County:ClevelandRegion:MROBasin:BRD047Q10:IWC:SOC_JOC:PF:0.485JFMAMJJASOND2017 H‐‐H‐‐H‐‐‐‐‐2018‐‐‐‐‐‐‐‐‐Pass‐‐2019‐‐‐‐‐‐‐‐‐Pass‐‐Cleveland WWTPNC0049867/001chr lim: 3.0%Ceri7dPFBegin:4/1/2009Freq:QMar Jun Sep DecNonComp:SingleCounty:RowanRegion:MROBasin:YAD067Q10:14.0IWC:3.0SOC_JOC:PF:0.27JFMAMJJASOND2017‐‐Pass‐‐Pass‐‐Pass >12(P)‐‐>12(P) Pass2018‐‐Pass >6(P)‐‐Pass>6(P)‐Pass‐‐Pass2019‐‐Pass‐‐Pass‐‐Pass‐‐Pass2020‐‐Pass‐‐Pass‐‐Pass‐‐PassCliffside Sanitary District WWTPNC0004405/001Ceri chr lim: 1.2%Ceri7dPFBegin:12/1/2014Freq:QJan Apr Jul OctNonComp:SingleCounty:RutherfordRegion:AROBasin:BRD027Q10:62.10IWC:4.19SOC_JOC:PF:1.75JFMAMJJASOND2017 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2018 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2019 Fail 1.7>4.8Pass‐‐Pass‐‐Pass‐‐2020 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2021 Pass‐‐‐‐‐‐‐‐‐‐‐Clinton‐Norman Larkins WPCFNC0020117/001chr lim: 90%Ceri7dPFBegin:2/1/2012Freq:QMar Jun Sep DecNonComp:SingleCounty:SampsonRegion:FROBasin:CPF197Q10:0.0IWC:100SOC_JOC:PF:5.0JFMAMJJASOND2017‐‐Pass‐‐Pass‐‐Pass‐‐Pass2018‐‐Pass‐‐Pass‐‐HPass‐Pass2019‐‐Pass‐‐Pass‐‐Pass‐‐Pass2020‐‐Pass‐‐Pass‐‐Pass‐‐PassCMUD‐Irwin Creek WWTPNC0024945/001chr lim: 83%Ceri7dPFBegin:10/1/2017Freq:QJan Apr Jul OctNonComp:SingleCounty:MecklenburgRegion:MROBasin:CTB347Q10:4.9IWC:83.0SOC_JOC:PF:15.0JFMAMJJASOND2017 >100 >100(P)‐‐95.7(s)‐‐>100(s)‐‐>100(s) >100(P)‐‐2018 >100(s) 87.1(s) Pass‐‐>100(s)‐‐>100(s)‐‐>100(s)‐‐2019 >100(s)‐‐>100 >100(P)‐‐>100(s)‐‐>100(s)‐‐2020 >100(s)‐‐>100(s)‐‐100% >100% >100%‐‐>100 (P) >100 (P)‐‐2021 >100 (P)‐‐‐‐‐‐‐‐‐‐‐CMUD‐Mallard Cr. WWTPNC0030210/001chr lim: 90%Ceri7dPFBegin:1/1/2014Freq:QFeb May Aug NovNonComp:ChV AvgCounty:MecklenburgRegion:MROBasin:YAD117Q10:0.64IWC:94.0SOC_JOC:PF:12.0JFMAMJJASOND2017‐Pass(s)‐‐Pass(s)‐‐Pass(s)‐‐Pass(s) >100(P)‐2018‐Pass(s) >100(P)‐‐Pass(s)‐‐Pass‐‐Pass‐2019‐Pass(s)‐‐>100(P) Pass(s)‐‐Pass(s)‐‐Pass(s)‐2020‐Pass(s)‐‐Pass(s)‐‐Pass ChV >100% Pass‐‐Pass‐Page 20 of 114Legend:  P= Fathead minnow (Pimphales promelas), H=No Flow (facility is active), s = Split test between Certified Labs
Whole Effluent Toxicity Testing and Self Monitoring Summary Cleveland WWTPNC0049867/001chr lim: 3.0%Ceri7dPFBegin:4/1/2009Freq:QMar Jun Sep DecNonComp:SingleCounty:RowanRegion:MROBasin:YAD067Q10:14.0IWC:3.0SOC_JOC:PF:0.27JFMAMJJASOND2018‐‐Pass >6(P)‐‐Pass>6(P)‐Pass‐‐Pass2019‐‐Pass‐‐Pass‐‐Pass‐‐Pass2020‐‐Pass‐‐Pass‐‐Pass‐‐Pass2021‐‐Pass‐‐Pass‐‐Pass‐‐Pass2022‐‐Pass‐‐Pass‐‐‐‐‐‐Cliffside Sanitary District WWTPNC0004405/001Ceri chr lim: 1.2%Ceri7dPFBegin:12/1/2014Freq:QJan Apr Jul OctNonComp:SingleCounty:RutherfordRegion:AROBasin:BRD027Q10:62.10IWC:4.19SOC_JOC:PF:1.75JFMAMJJASOND2018 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2019 Fail 1.7>4.8Pass‐‐Pass‐‐Pass‐‐2020 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2021 Pass‐‐Pass‐‐Pass‐‐Pass‐‐2022 Pass‐‐Pass‐‐‐‐‐‐‐‐Clinton‐Norman Larkins WPCFNC0020117/001chr lim: 90%Ceri7dPFBegin:2/1/2012Freq:QMar Jun Sep DecNonComp:SingleCounty:SampsonRegion:FROBasin:CPF197Q10:0.0IWC:100SOC_JOC:PF:5.0JFMAMJJASOND2018‐‐Pass‐‐Pass‐‐HPass‐Pass2019‐‐Pass‐‐Pass‐‐Pass‐‐Pass2020‐‐Pass‐‐Pass‐‐Pass‐‐Pass2021‐‐Pass‐‐Pass‐‐Pass‐‐Pass2022‐‐Pass‐‐Pass‐‐‐‐‐‐CMUD‐Irwin Creek WWTPNC0024945/001chr lim: 83%Ceri7dPFBegin:10/1/2017Freq:QJan Apr Jul OctNonComp:SingleCounty:MecklenburgRegion:MROBasin:CTB347Q10:4.9IWC:83.0SOC_JOC:PF:15.0JFMAMJJASOND2018 >100(s) 87.1(s) Pass‐‐>100(s)‐‐>100(s)‐‐>100(s)‐‐2019 >100(s)‐‐>100 >100(P)‐‐>100(s)‐‐>100(s)‐‐2020 >100(s)‐‐>100(s)‐‐100 (P) >100% >100%‐‐>100 (S) >100 (S)‐‐2021 >100‐‐>100 (S) >100 (S)‐‐>100 (S) >100 (S)‐‐>100 (S) >100 (S) >100 (P‐‐202287.1 (S) >100 (S) >100 (P)‐‐>100 (S) >100 (S)‐‐‐‐‐‐‐‐CMUD‐Mallard Cr. WWTPNC0030210/001chr lim: 90%Ceri7dPFBegin:1/1/2014Freq:QFeb May Aug NovNonComp:ChV AvgCounty:MecklenburgRegion:MROBasin:YAD117Q10:0.64IWC:94.0SOC_JOC:PF:12.0JFMAMJJASOND2018‐Pass(s) >100(P)‐‐Pass(s)‐‐Pass‐‐Pass‐2019‐Pass(s)‐‐>100(P) Pass(s)‐‐Pass(s)‐‐Pass(s)‐2020‐Pass(s)‐‐Pass(s)‐‐Pass ChV >100% Pass‐‐Pass‐2021‐Pass‐‐Pass (S) Pass (S)‐‐Fail>100 Pass>100 (S) >100 (S)>100 (P) Pass (S) Pass (S)‐2022‐Pass >100 (P)‐‐Pass (S) Pass (S)‐‐‐‐‐‐‐Page 23 of 117Legend:  P= Fathead minnow (Pimphales promelas), H=No Flow (facility is active), s = Split test between Certified Labs
Town of Cleveland
PO Box 429
Cleveland, NC 27013
Receive Date:12/05/2017
Reported:05/07/2021
For:
Comments:
Sample Number Parameter Sample ID Result Unit Method Analyzed Analyst
171205-34-01 PPA Eff See Attached As Noted 12/28/2017 EV1
Respectfully submitted,
Melissa Myers
NC Cert #440,
NCDW Cert #37755,
EPA #NC00909
Analytical Results
PO Box 228 • Statesville, NC 28687 • 704/872/4697
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PO Box 228 • Statesville, NC 28687 • 704/872/4697
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PO Box 228 • Statesville, NC 28687 • 704/872/4697
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