NC0026123_Fact Sheet_20230821

Review Fact Sheet
NPDES Permit No. NCO026123
Permit Writer/Email Contact: Nick Coco, [e-mail]
Date Initiated: August 29, 2022; initial draft submitted for public comment 5/9/2018 (see Section 14. Fact
Sheet Addendum for more information)
Division/Branch: NC Division of Water Resources/NPDES Municipal Permitting Unit
Fact Sheet Template: Version 09Jan2017
Permitting Action:
❑X 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:
City of Asheboro/Asheboro WWTP
Applicant Address:
P.O. Box 1106, 146 N Church Street, Asheboro, NC 27204
Facility Address:
1032 Bonkemeyer Drive, Asheboro, NC 27203
Permitted Flow:
9.0 MGD
Facility Type/Waste:
MAJOR Municipal; 92.1% domestic, 7.9% industrial'
Facility Class:
Grade IV
Treatment Units:
Bar screen, Grit removal, Parshall flume, Primary clarifiers, Trickling
filters, Secondary clarifiers, Nitrification with aeration, Final clarifiers,
Tertiary sand filters, Chlorination, De -chlorination, Cascade aeration,
Sludge thickening, Digesters, Dewatering.
Pretreatment Program (Y/N)
Yes
County:
Randolph
Region
Winston-Salem
Footnote.
1. Permitted industrial flow is 0.712 MGD.
Page 1 of 24

Briefly describe the proposed permitting action and facility background: The City of Asheboro has applied
for NPDES permit renewal, received by DWR on 3/21/2016. A draft permit was public noticed in May
2018; comments were received, and the permit was modified for a second public notice (see Sect 13 and
14 below). This facility serves a population of —25,676 residents and operates a pretreatment program with
15 Significant Industrial Users (SIUs), 7 of which are Categorical Industrial Users (CIUs). In addition, the
Asheboro WWTP is receiving 1,400 gpd wastewater from the Randolph County School Bus Maintenance
Garage groundwater remediation project. However, this is not considered a SIU.
CIUs include: Energizer Manufacturing, Inc. Plant 2 (CIU 461: battery manufacturing), Garco, Inc.
(renamed Covanta Environmental Services, CIU 437: centralized waste management), Matlab, Inc. Plant 4
(CIU 433: metal finishing, not yet constructed), Matlab Plant 5 (CIU 433: metal finishing), Matlab Plant 8
(CIU 433: metal finishing), Premier Powder Coating (CIU 433: metal finishing), and Starpet, Inc. (CIU
414: organic chemical, synthetic fibers and plastics).
Non -categorical SIUs include: Acme McCrary (renamed MAS US Holdings, textiles), Bossong Hosiery
(textiles), Energizer Manufacturing, Inc. Plant 1 (battery parts manufacturing), Georgia Pacific (corrugated
paper products), Kayser Roth (textiles), MOM Brands (food processing), Randolph Packing (meat
processing), Wells Hosiery (textiles), and Waste Management of the Carolinas Great Oak Landfill (landfill
leachate).
The average industrial flow rate was 0.386 MGD from January 2021 through January 2022. The
uncontrollable flow was 3.56 MGD for that same period. The facility has a DWR-approved Full
Pretreatment Program with a Long -Term Monitoring Program (LTMP) for its SIUs.
Solids management is handled via land application, permitted under WQ0001684.
2. Receiving Waterbody Information
Receiving Waterbody Information i
Outfalls/Receiving Stream(s):
Outfall 001/Hasketts Creek
Stream Segment:
17-12
Stream Classification:
C
Drainage Area (mi2):
11.6
Summer 7Q 10 (cfs)
0
Winter 7Q10 (cfs):
-
30Q2 (cfs):
0.2
Average Flow (cfs):
12
IWC (% effluent):
90
2022 303(d) listed/parameter:
This stream segment is impaired for Copper and Benthos.
The 2022 Integrated Report also notes data inconclusive for
1,4-Dioxane and Fecal Coliform
Subject to TMDL/parameter:
Statewide TMDL for Mercury
Subbasin/HUC:
03-06-09 / 03030003
USGS Topo Quad:
D19SE Randleman, NC
Page 2 of 24

The Haskett Creek Watershed Action Plan notes that water quality data collected at ambient monitoring
stations above and below the Asheboro WWTP over the past ten years suggests that stormwater runoff and
other nonpoint sources of pollution are contributing to water quality impacts above the Asheboro WWTP.
The two parameters of utmost concern are fecal coliform (a form of bacteria) and turbidity (water clarity),
although high turbidity is likely leading to greater biological impacts. High turbidity and sedimentation can
kill algae, which are a major food source for benthic macroinvertebrates, and smother benthic organisms
and fish eggs. Potential sources of fecal coliform include stormwater runoff, pet or animal waste, or leaking
sewage or septic systems, while high turbidity is most likely caused by stormwater runoff, soil erosion, and
a lack of riparian vegetation. While point source pollution is not a major concern for the watershed, it is
likely that this facility is contributing to some of the water quality impacts downstream. Water quality data
collected below the Asheboro WWTP typically shows higher levels of conductivity and copper than those
collected above the plant. Biological assessment samples also indicated a noticeable decline of benthic
macroinvertebrates below the WWTP (See Instream Data Summary for additional data analysis).
3. Effluent Data Summary
Effluent data is summarized below for the period January 2018 through August 2022 for Outfall 001.
Table 1. Effluent Data Summary
Parameter
Units
Average
Max
Min
Permit Limit 1
Flow 2
MGD
4.05
15.488
1.655
MA = 9.0
BOD summer
mg/L
2.4
9.3
< 2.0
MA = 5.0
WA = 7.5
BOD winter
mg/L
3.4
16.9
< 2.0
MA = 10.0
WA = 15.0
BOD Removal
%
99.0
99.7
97.8
> 85
Total Suspended Solids
mg/L
5.1
72.7
< 2.0
MA = 30.0
(TSS)
WA = 45.0
TSS Removal
`Yo
98.4
99.7
96.4
> 85
Ammonia (NH3-N)
mg/L
0.15
2.03
0.1
MA = 2.0
summer
WA = 6.0
Ammonia (NH3-N)
mg/L
0.4
9.12
< 0.10
MA = 4.0
winter
WA = 12.0
Dissolved Oxygen
mg/L
8.2
10.71
6
DA > 6.0
(DO)
pH
SU
7.0
7.63
6.0
Between 6.0 and 9.0
Fecal Coliform
#/100 mL
18
> 4839
< 1
MA = 200
(geometric mean)
WA = 400
Total Residual
µg/L
15.6
48.7
< 15.0
DM = 17 3
Chlorine (TRC)
Temperature
°C
20.6
28.7
" I
Monitor & report
Conductivity
µmhos/cm
957
1760
238
Monitor & report
Page 3 of 24

Total Chromium
µg/L
5.3
10.7
< 5.0
MA = 50
DM = 1033
Total Mercury
ng/L
1.7
4.6
< 1.0
MA = 12
DM=36
Total Nitrogen (TN)
mg/L
14.0
28.16
0.53
Monitor & report
Total Kjeldahl
mg/L
1.65
5.16
< ]
Monitor & report
Nitrogen (TKN)
Nitrate/Nitrite Nitrogen
mg/L
i2.6
25.00
0.53
Monitor & repot
(NO2 + NO3)
Total Phosphorus (TP)
mg/L
0.35
1.11,
0.05
Monitor & report
Dibromochloromethane
µg/L
8.4
17.2
< 5.0
Monitor & report
Bromodichloromethane
µg/L
17.5
36
< 5.0
Monitor & report
Chloride
mg/L
159
247
71.5
Monitor & report
Total Copper
µg/L
6.6
11.8
3.5
Monitor & report
Total Zinc
µg/L
23.2
100
< 10
Monitor & report
1,4-Dioxane 4
µg/L
116
1011
< 1
Monitor & report
Footnotes.
1. MA = monthly average, WA = weekly average, DA = daily average, DM = daily maximum.
2. Average flow for CY2020 = 4.218 MGD, 47% of permitted flow.
3. Concentrations < 50 µg/L are considered compliant.
4. Monthly monitoring required beginning December 2017 per Division letter sent in October 2017
with increased monitoring beginning December 2020. Data are inclusive from January 2018 -
September 2022.
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 beproposedfor this permit
action: The current permit requires instream monitoring for Temperature and Dissolved Oxygen (DO)
from three locations: one upstream approximately 800 feet above the outfall in Hasketts Creek (U), one
downstream at NCSR 2128, located in Hasketts Creek (D1) and one additional downstream at NCSR 2261,
located in the Deep River (D2).
Instream monitoring is provisionally waived so long as the Permittee maintains membership in the Upper
Cape Fear River Basin Association (UCFRBA). The permit instream monitoring locations correspond to
the ambient monitoring stations B4870000 (U), B4890000 (D1), and B4920000 (132) [station locations
displayed in Figure 1, shown below]. Data from U and D2 were obtained from the Monitoring Coalition
Coordinator and span from June 2017- June 2022; data from D 1 were provided by the Ambient Monitoring
System (AMS) Coordinator for the same period. While sampling at both UCFRBA stations were conducted
Page 4 of 24

on corresponding dates, AMS station data was typically collected within the same week as the UCFRBA
samples. The data has been summarized in Table 2 below.
Table 2. Instream data summary
Parameter
Units
Upstream
Downstream 1
Downstream 2
Average
Max
Min
Average
Max
Min
Average
Max
Min
Temperature
° C
16.5
29.4
1
18.3
28.7
8.7
18.4
30.4
2.8
DO
mg/1
9.1
13.1
4.8
9.2
11.97
6.4
9.4
13.8
6.4
Conductivity
µmhos/cm
115
219
60
594
1095
267
170
350
96
Fecal
Coliform
#/100mL
(geomean)
465
12000
9
(geomean)
333
10000
35
(geomean)
176
11000
4
*Data from June 2017 — June 2022
Students t-tests were run at a 95% confidence interval to analyze relationships between instream
samples. A statistically significant difference is determined when the t-test p-value result is < 0.05
Dissolved Oxygen (DO): DO did not drop below the instantaneous stream standard of 4 mg/L [per 15A
NCAC 02B .0211 (6)] during the period reviewed at either downstream location. The daily average
downstream DO was greater than 5 mg/L for the period reviewed at both locations. It was concluded that
no statistically significant difference between upstream DO and DO at both downstream monitoring stations
exists. Additionally, no statistically significant difference was observed between DO at both downstream
sample locations. Instream DO monitoring has been maintained.
Temperature: The standard maximum of 32°C for lower piedmont and coastal plain waters as defined in
15A NCAC 02B .02011 (18) was maintained at all stations. Instream temperatures were not collected
synchronously among the three sites, therefore assessing for compliance with the 2.8°C increase from up -
to downstream standard (15A NCAC 2B .0211) is not practical. It was concluded that no statistically
significant difference between upstream temperature and temperature at both downstream monitoring
stations exists. Additionally, no statistically significant difference was observed between temperatures at
both downstream sample locations. Instream temperature monitoring has been maintained.
Conductivity is a parameter of concern because of industrial discharges. The permit does not currently
require instream monitoring, but the facility has an active pretreatment program with multiple SIUs, and
instream data are available from the three stations. The data analyzed indicate that a statistically significant
difference exists between upstream and downstream conductivity. Concurrent effluent conductivity was
observed as consistently greater than that of the upstream. As effluent conductivity appears to increase
conductivity in the stream, effluent conductivity monitoring has been added to the permit.
Fecal Coliform: The permit does not currently require instream monitoring, but the 2022 Integrated Report
notes fecal coliform as inconclusive with regard to determination of impairment, and instream data are
available from the three stations. It was concluded that no statistically significant difference between
upstream fecal coliform and fecal coliform at both downstream monitoring stations exists. Additionally, no
statistically significant difference was observed between fecal coliform levels at both downstream sample
locations. As such, instream fecal coliform monitoring has not been added.
Total Copper: Hasketts Creek downstream of Asheboro is impaired for Total Copper (7 µg/L standard for
aquatic life in freshwater) per the 2022 NC Integrated Report. Instream copper monitoring is not required
in the permit, but data are available from D1 as monitored by the DWR Ambient Monitoring System
(AMS). Review of data from January 2020 — September 2022 found the average total copper concentration
Page 5 of 24

(4.3 µg/L) to be below the calculated hardness -dependent chronic standard of 5.12 µg/L and the maximum
total copper concentration (6.0 µg/L) to be below the acute standard of 7.25 µg/L. Instream total copper
monitoring has not been added to the permit at this time but will continue to be monitored at the AMS
station.
MutriPY1%C
The Deep River stream segment 17-(10.5)dl from Hasketts Creek to Gabriels Creek is impaired for
Chlorophyll a (exceeding 40 mg/L standard for aquatic life), but the immediate stream segment upstream
in the Deep River [17-(10.5)c] is not impaired according to the 2022 NC Integrated Report. This pattern of
impairment suggests that sources in Hasketts Creek are contributing to the impairment in the Deep River
(Fig. 1). Due to this downstream impairment, additional instream analysis was conducted for Inorganic
Nitrogen (NO2+NO3), Total Kjeldahl Nitrogen (TKN), Total Nitrogen (TN) and Total Phosphorous (TP)
from data collected by the UCFRBA and AMS at the three instream locations.
Figure 1. Map of Asheboro W WTP with instream sampling locations and impairment designations.
Instream and effluent nutrient data have been summarized below in Table 3. While no statistically
significant difference was observed between upstream TKN concentrations and TKN concentrations at
either downstream location, the same cannot be said for NO3+NO2, TN, or TP. Instream patterns of nutrient
concentrations were largely consistent among parameters: nutrient concentrations are lowest upstream,
increase substantially just downstream of the discharge and decrease further downstream but still appear
consistently elevated at D2 compared to upstream. These patterns indicate effluent impact on the instream.
Page 6 of 24

Table 3. Instream and effluent nutrient concentration averages and ranges (in parentheses) from
June 2017 - June 2022. Values are in mg/L.
Parameter
Upstream (U)
Effluent
Downstream (D1) lir
Downstream (D2)
Nitrate -Nitrite
0.24
12.6
7.5
0.87
(NO3+NO2)
(0.02-1.63)
(0.53-25.0)
(0.53-19.0)
(0.06-4.23)
Total Kjeldahl Nitrogen
0.72
1.66
1.1
0.85
(TKN)
(0.20-4.74)
(<1-5.16)
(0.7-2.2)
(0.20-2.88)
Total Nitrogen (TN)
0.98
14
8.6
1.76
(0.022-6.37)
(0.53-28.16)
(1.42-20.3)
(0.62-4.62)
Ammonia
0.10
0.25
0.05
0.05
(0.02 3.51)
(0.1 9.12)
(0.02-0.33)
(0.02 0.31)
Total Phosphorus (TP)
0.05
0.35
0.24
0.09
(0.02-0.425)
(< 0.05-1.610)
(0.03-2.0)
(0.038-0.179)
Based on this information, which includes monitoring coalition data, instream monitoring for TN, TP, TKN,
NO2+NO3, and ammonia has been added at a frequency of 1/month.
1.4-Dioxane
1,4-Dioxane is an emerging contaminant of concern, identified as a likely human carcinogen. Elevated
concentrations of 1,4-Dioxane were found in the Cape Fear River Basin during the EPA Third Unregulated
Contaminant Monitoring Rule sampling program from 2013-2015. In response to this finding, the Division
conducted an initial stream survey of the Cape Fear River Basin (NCDWR 2016: 1,4-Dioxane in the Cape
Fear River Basin of North Carolina: An Initial Screening and Source Identification Study), which found
multiple sites with elevated concentrations. Among the highest concentrations detected were in Hasketts
Creek downstream of the Asheboro WWTP discharge with an average of 291 µg/L (range: 147-478 µg/L)
from samples collected June 2015-May 2016. Subsequent sampling within Hasketts Creek and the Deep
River by AMS found continued elevated concentrations downstream of Asheboro WWTP discharge and
detectable concentrations in upstream locations of both waterbodies (Table 4). Instream samples were
collected at Hasketts Creek locations U and D1, and at Deep River locations up- and downstream of the
confluence with Hasketts Creek. The Deep River upstream location is at AMS station B4800000, 2.62 miles
upstream of the confluence. The Deep River downstream location is located at AMS station B5100000,
13.7 miles downstream of the confluence and below the discharges of two other WWTPs.
Table 4. Instream and effluent 1,4-Dioxane concentrations in Hasketts Creek and the Deep River,
2018-2022.
Location .
Samples
Dates Sampled
Average
Minimum
Maximum
Hasketts Creek - upstream
9
Jun 2018 - Apr 2019
1.3
0.54
2.2
Hasketts Creek - downstream
27
Jan 2020 - Sep 2022
102.2
900
1.9
Deep River - upstream
3
Jul - Aug 2018
2.6
2.3
3.0
Deep River - downstream
3
Jul - Aug 2018
12.8
3.4
23
Effluent
29
Jan 2018 - Sep 2022
213
< 1
1011
Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess
background concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for 1,4-
Dioxane has been added to the permit. Instream 1,4-dioxane monitoring is to be conducted at a Monthly
frequency and shall be conducted at previously established instream locations upstream and at D1 and D2.
Instream 1,4-dioxane sampling shall be conducted in concurrence with effluent 1,4-doxane sampling.
Page 7 of 24

Sampling for instream 1,4-dioxane may be waived as long as the Monitoring Coalition samples 1,4-dioxane
at the nearest upstream and downstream locations, at a minimum frequency of monthly, and the City has
obtained approval from DWR - NPDES Permitting Unit that the upstream and downstream stations being
monitored by the Coalition are representative of the receiving stream for this discharge. If the Coalition
terminates instream 1,4-dioxane sampling at either of the approved stations, the City will immediately
notify the Division and resume sampling for instream 1,4-dioxane.
In addition to the instream sampling conducted by the City of Asheboro, the Division will conduct instream
sampling at the nearest downstream WS-V boundary.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): YES
Name of Monitoring Coalition: Upper Cape Fear River Basin Association
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): From August 2017 through
August 2022 the facility reported no limit violations.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): The facility passed 18 of 18 quarterly chronic toxicity tests from March 2018 through June 2022,
as well as all most recent four (4) required second species chronic toxicity tests, sampled September 2018,
December 2019, March 2020 and June 2021.
Summarize the results from the most recent compliance inspection: The most recent compliance evaluation
inspection, conducted on January 27, 2022, found the facility to be well -operated and maintained. The
inspection report has been attached. The most recent pretreatment inspection was conducted on May 10,
2022, also found the facility's pretreatment program in compliance.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixin Zones
ones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 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: Limitations for BOD
are based on a 1994 wasteload allocation model for oxygen -consuming waste, which determined limitations
based on zero flow streams. No changes are proposed.
Page 8 of 24

Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/L (summer) and 1.8 mg/L (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 µg/L) and capped at 28 µg/L (acute impacts). Due to analytical issues, all TRC values
reported below 50 µg/L are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: The current
Ammonia -Nitrogen limits (2.0/6.0 mg/L monthly/weekly averages for summer; 4.0/12.0 mg/L
monthly/weekly averages for winter) in the permit are based on a 1994 wasteload allocation model for
oxygen -consuming waste, which determined limitations based on zero flow streams. Toxicity -based
Ammonia was reviewed in the attached Wasteload Allocation (WLA) sheet using the flow design of 9.0
MGD and receiving stream 7Q10 low flow of 0.0 cfs for both the summer and winter values. The resulting
allowable concentrations were 1.0/3.0 mg/L monthly average/weekly average for summer, and 1.8/5.4
mg/L monthly average/weekly average for winter. Because the toxicity -based limits are more stringent,
they were placed in the permit.
Review of DMR data from January 2018 through August 2022 revealed that the facility has not
demonstrated an exceedance of the proposed monthly and weekly winter average limits since January 2018
(Fig. 2). As such, it appears that the City can consistently meet the new limits and a compliance schedule
is not necessary.
Proposed Ammonia-N (NH3-N)
Wk Avg ♦ Mo Avg MA Limit WA Limit
6 —
4 —
J
w 3
E
2
•• r •
0 MAN
1/10/2018 2/14/2019 3/20/2020 4/24/2021 5/29/2022
Figure 2. Asheboro WWTP effluent monthly average (MA) and weekly average (WA) Ammonia-N
concentrations (mg/L) with their respective proposed limits for potential compliance evaluation.
The current TRC limit of 17 µg/L was reviewed via the attached WLA spreadsheet and was found to be
protective. The current TRC limit is maintained in the permit.
Page 9 of 24

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 '/z 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 January 2018
and September 2022. 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: Bromodichloromethane (MA 31.6 pg/L), Silver (MA 0.06 pg/L, DM2.4
,ug/L), 1,4-Dioxane (MA 21.58 pg/L — See Other WQBEL Considerations section for more
information)
• 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: Chloride,
Selenium, Dibromochloromethane, Copper
o Chloride — Reasonable Potential (RP) was found. Rule 15A NCAC 02B .0211 (22) states
that if chloride is determined by the waste load allocation to be exceeded in a receiving
water by a discharge under the specified 7Q 10 criterion for toxic substances, the discharger
shall monitor the chemical or biological effects of the discharge. Monitoring is maintained
in conjunction with toxicity tests.
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards /
criteria and the maximum predicted concentration was < 50% of the allowable concentration:
Arsenic, Cadmium, Total Chromium, Cyanide, Lead, Molybdenum, Nickel, Zinc.
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA
o The following parameters will not receive a limit or monitoring, since as part of a limited
data set, they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: Chloroform, Total Phenolic Compounds, Beryllium
Total Selenium and Total Silver had been sampled at PQLs of 10 µg/L and 5 µg/L, respectively, up until
July 2019, after which the City achieved PQLs of 1 µg/L for both parameters. Data using the less sensitive
test methods were not incorporated in the RPA, as sufficient samples were available using the lower PQL
Page 10 of 24

methods. The City shall continue to test for total silver and total selenium using the lower, sufficiently
sensitive test methods.
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 facility is a Major POTW, and a chronic WET limit at
90% effluent will continue on a quarterly frequency.
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 5. Mercury Effluent Data Summary
2018
2019
2020
2021
2022
Number of Samples
12
13
12
12
8
Annual Average Cone. ng/L
1.7
2.4
1.5
1.3
1
Maximum Cone., ng/L
3.50
2.90
3.30
3.60
4.60
TBEL, ng/L
47
WQBEL, ng/L
12.0
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 (Table 5). Because the facility is > 2 MGD and has reported quantifiable levels of mercury
(> 1 ng/L), a mercury minimization plan (MMP) will be added to the permit.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: The receiving water lies in the Deep River section of the central portion of the Cape Fear River
Page 11 of 24

Basin, an area identified for nutrient criteria development in the North Carolina Nutrient Criteria
Development Plan, Version 2.0 (NCDWR 2014). The current permit has monthly monitoring requirements
for Total Nitrogen (TN), Nitrite -Nitrate Nitrogen (NO2-N + NO3-N), and Total Kjeldahl Nitrogen (TKN)
in recognition of a nutrient strategy for the Upper Cape Fear River in addition to surface water monitoring
and reporting requirements under 15A NCAC 02B .0500. The current permit also has a nutrient re -opener
Special Condition, which has been maintained. No changes were made regarding effluent limitations at this
time.
Other WQBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: The emerging
contaminants 1,4-Dioxane and PFAS family of compounds were evaluated for potential WQBELs.
1,4-Dioxane
1,4-Dioxane (CASRN 123-91-1) is a synthetic industrial chemical that is completely miscible in water.
Synonyms include dioxane, dioxan, p-dioxane, diethylene dioxide, diethylene oxide, diethylene ether and
glycol ethylene ether (EPA 2014). 1,4-Dioxane is an emerging contaminant considered to be a likely human
carcinogen that is highly mobile and does not readily biodegrade in the environment. It is found in
groundwater and surface water sites throughout the United States. EPA risk assessments indicate that the
drinking water concentration representing a 1 X 10-4 cancer risk level for 1,4-Dioxane is 35 µg/L and 1 X 10-6
risk level for 1,4-Dioxane is 0.35 µg/L (EPA 2013, EPA IRIS 2013).
References:
• EPA (U.S. Environmental Protection Agency). 2014. EPA Technical Fact Sheet- 1,4-Dioxane,
January 2014, SDMS Doc ID 575107.
• EPA. 2013. Toxicological Review of 1,4-Dioxane (with Inhalation Update) in Support of Summary
Information on the Integrated Risk Information System (IRIS). EPA 635-R-11-003F.
• EPA IRIS. 2013. 1,4-Dioxane (CASRN 123-91-1). www.epa.gov/iris/subst/0326.htm.
An initial stream survey of the Cape Fear River Basin (NCDWR 2016: 1,4-Dioxane in the Cape Fear River
Basin of North Carolina: An Initial Screening and Source Identification Study) found multiple sites with
elevated concentrations. Among the highest concentrations in that survey were found at Study Site NCSU24
in Hasketts Creek just downstream of the Asheboro WWTP discharge with an average of 291 µg/L (range:
147-478 µg/L) from data collected June 2015—May 2016. DWR issued a letter, dated October 31, 2017,
requiring monthly effluent monitoring beginning December 2017 with samples analyzed using the recently
approved EPA Method 624. L From January 2018 through September 2022, a total of 123 effluent data
points were submitted, with an average of 116 µg/L (range: < 1-1011 µg/L).
The Division issued a letter to Asheboro requesting the City develop and submit a corrective action plan
for 1,4-Dioxane reduction by September 23, 2019. The requested plan was submitted in a timely manner,
received on August 1, 2018, outlining the City's aim to continue monitoring and coordinating with
industrial users toward reduction of 1,4-Dioxane entering the WWTP. The SIU Starpet has been identified
as a significant source of 1,4-Dioxane. In 2019 Starpet had requested an Authorization to Construct from
the City to install a prebuilt KOCH Modular System consisting of a 72-foot long stripper column along
with a reboiler, shell, and a tube condenser & heat exchanger. The treatment system was installed and
implemented in November 2020 according to Asheboro's 2020 Pretreatment Annual Report.
Division regulations applicable to 1,4-Dioxane limitations:
• 15A NCAC 02B .0203 identifies that water quality -based effluent limits for direct dischargers
"shall be developed by the Division such that the water quality standards and best usage of receiving
waters and all downstream waters will not be impaired."
Page 12 of 24

15A NCAC 02B .0206(a)(4)(B) identifies that for the flow design criteria for effluent limitations,
the average annual flow for toxic substances shall be used to protect human health.
15A NCAC 02B .0208(a)(2)(B) identifies for carcinogens, an unacceptable exposed risk level is
1 X 10-6 or greater.
15A NCAC 02B .0216(4)(d) Fresh Surface Water Quality Standards for Class WS-IV Waters
identifies that no discharge of sewage "...shall be allowed that have an adverse effect on human
health or that are not treated in accordance with the permit or other requirements established by the
Division..."
1,4-dioxane is completely miscible in water and resistant to biodegradation. The mass loading of 1,4-
dioxane identified in the facility discharge to Hasketts Creek, a class C waterbody, is expected to persist
downstream to the nearest water supply (WS-V) boundary, located in the Deep River 1.0 mile upstream of
Tysons Creek and 43.5 miles downstream of the outfall. As such, allowable discharge concentrations were
calculated for both the direct discharge to Class C Hasketts Creek and for the nearest downstream water
supply (WS-V) boundary, and the more restrictive concentration was selected for protection of downstream
uses. The water supply boundary is for the Deep River (Gulf- Goldston) water supply watershed. Each
allowable discharge concentration was calculated considering the applicable receiving stream's Average
Annual Flow (AAF), appropriate Instream Target Value (ITV), and the facility's permitted design flow.
Note that the river segment at the WS-V boundary is also classified as High -Quality Waters (HQW). As
the facility is neither new nor expanding, 15A NCAC 02B .0224(c)(G) has not been applied. However,
should the facility pursue expansion, toxic substances shall be limited at 1/2 the normal standard at design
conditions.
For the direct discharge to Class C Hasketts Creek, an ITV of 80 µg/L for non -water supply waters at an
AAF of 12 cfs and a permitted design flow of 9.0 MGD (13.95 cfs) was considered. This calculation yielded
a chronic allowable discharge concentration of 149 µg/L. When considering the downstream WS-V waters,
a 1 X 10-6 risk level ITV of 0.35 µg/L for water supply waters at an AAF of 846 cfs (calculation estimated
by USGS for the WS-V boundary of the Gulf-Goldston WS watershed) and a permitted design flow of 9.0
MGD (13.95 cfs) was considered. This calculation yielded a chronic allowable concentration of 21.58 µg/L.
The discharge determination based on direct discharge to Class C Hasketts Creek is insufficiently protective
of downstream water supply uses. As such, the chronic allowable discharge concentration of 21.58 µg/L
has been used in determination of permitting actions.
Based on a review of the effluent data, the WWTP demonstrates a reasonable potential to exceed the state
water supply (WS) ITV of 0.35 µg/L for 1,4-Dioxane at the nearest downstream water supply boundary.
Given the facility's effluent data, weekly monitoring and limits have been added to the permit. Recognizing
that 1,4-Dioxane is an emerging contaminant and industrial users are in the process of adjusting to its impact
and use in materials, a phased implementation compliance schedule has been included in the permit. In
Asheboro's case, the future phase 1,4-Dioxane target must not cause violation of the ITV for 1,4-Dioxane
at the water supply boundary.
Considering the existing effluent concentrations experienced at the facility, the first phased limit was
calculated to be the 50t1i percentile value of the effluent data submitted from January 2018 through
September 2022. This initial phased limit was calculated after removing detection values identified as
outliers (Z score > 3 or < -3), resulting in a limit of 55.7 µg/L. The second phase is set at the EPA Health
Advisory Level (HAL) of 35 µg/L. The third and final phased limitation is set at 21.58 µg/L based on the
ITV for 1,4-dioxane calculated at the water supply boundary.
Daily maxima limitations have been calculated for each phase from the chronic monthly average limitations
using EPA guidance. Derivation of the maximum daily limit is based on EPA's Technical Support
Document (TSD, USEPA 1991) recommendations.
Page 13 of 24

According to the TSD, developing final permit limits for pollutants affecting human health is somewhat
different from setting limits for other pollutants because the exposure period is generally longer than 1
month. Therefore, the EPA -recommended approach for setting water quality -based limits for human health
protection with statistical procedures is as follows:
• Set the AML (Average Monthly Limit) equal to the WLA (to meet the instream target value of 0.35
µg/L)
• Calculate the MDL (Maximum Daily Limit) based on effluent variability and the number of
samples per month using the multipliers provided in TSD Table 5-3.
This approach ensures that the instream criteria will be met over the long-term and provides a defensible
method for calculating an MDL.
The daily maximum final limit was developed using the recommended approach in TSD Section 5.4.4, for
human health protection. Input variables for the multiplier table consulted (TSD Table 5-3) included:
• A coefficient of variation (CV) of 0.8 based on the most recent 58 data points (July 2021 —
September 2022) and after removing Z-score-identified outlier values,
• AML exceedance probability of 95th percentile,
• MDL exceedance probability of 99th percentile,
• A weekly sampling frequency (n = 4/month).
The table yielded a multiplier of 2.29, which was applied to the average monthly limits of 55.7 µg/L, 35.0
µg/L, and 21.58 µg/L to obtain the maximum daily limits of 127.6 µg/L, 80.2 µg/L, and 49.4 µg/L,
respectively.
Monthly averages for effluent data reported from January 2018 through September 2022 have been
calculated and compared to the proposed monthly average phased limitations below in Figure 3.
Proposed 1,4-Dioxane MA
10000
J
bio
7
C
O
1000 ••
• •
o • • •• : • • be
•• • •
• •
U 100 •• 9 •
55.7 µg/L
0 35 µg/L
0 21.58 µg/L
� 10
ri
v •
an
a 1
11/11/2017 12/16/2018 1/20/2020 2/23/2021 3/30/2022
c
Date
• 1,4-dioxane Effluent Data Phased Target I MA Phased Target II MA Final Phased Target III MA
Figure 3. Asheboro WWTP effluent Monthly Average 1,4-dioxane data versus three proposed phased
Monthly Average limitations
Page 14 of 24

Effluent data from January 2018 through September 2022 has been compared to the proposed daily
maximum phased limitations below in Figure 4.
Proposed 1,4-Dioxane DM
10000
—
J
tao
1000 as•
• •
.
• •
•
•
• • • • • • •
100 0
127.6 µg/L
u
80.2 µg/L
a)
• •
• • • • • 49.4 µg/L
•
�•4%
•
0
o
10
•
M •
•
1
11/11/2017 12/16/2018 1/20/2020
2/23/2021
3/30/2022
Date
• 1,4-dioxane Effluent Data Phased Target I DM
Phased Target II DM
Final Phased Target III DM
Figure 4. Asheboro WWTP effluent 1,4-dioxane data versus three proposed phased Daily Maximum
limitations
Effluent data has been submitted for both the Asheboro WWTP and Starpet ranging from December 2020
through September 2022. A visual representation of this data is provided in Figure 5, below. Please note
that the 1,4-dioxane concentration axis was reduced in range for clarity of the graph. Four (4) Sampling
events occurred during this review period where 1,4-dioxane concentrations greater than 1,000 ug/L were
observed in the atarpet ettluent.
Asheboro WWTP vs Starpet Comparison
100000
J
UO
10000
O
ro
1000 •
C 100 • • f • • • + •••
0 10 fu
• •hiio�r ^0, 0-
1• • • • •
ri •
1 � —
9/26/2020 4/14/2021 10/31/2021 5/19/2022 12/5/2022
Date
*Asheboro WWTP Effluent •Starpet Effluent
Figure 5. Comparison of Asheboro WWTP and Starpet Effluent 1,4-dioxane Concentrations
Page 15 of 24

Review of the data demonstrates instances where 1,4-dioxane was detected at a higher concentration in the
Asheboro effluent than in the Starpet effluent. While some of these instances followed a large spike in
Starpet effluent 1,4-dioxane, others do not appear to follow a spiked event. Based on this review, it has
been concluded that either 1,4-dioxane is somehow being trapped in the components Asheboro WWTP's
treatment works and released over time, leading to varying degrees of effluent spikes, or there exists another
industrial user that is contributing to the 1,4-dioxane loading entering the Asheboro WWTP. The City has
noted that an additional contribution of 1,4-dioxane to the plant's influent is coming from the Waste
Management of the Carolinas Great Oak Landfill. Data provided from the landfill demonstrated 1,4-dioxane
levels ranging from 26,000 ug/L to 66,300 ug/L (sampling conducted from April to July 2021). To better
understand the influent 1.4-dioxane levels entering the facility, a requirement has been added that the City
conduct an investigation into all potential sources of 1,4-dioxane and provide a report to the Division within
2 years of the effective date of the permit.
See the three-phase compliance schedule incorporating the various phased limitations below:
NPDES Permit limits have been calculated for a three-phase compliance schedule:
Phase I — Initial Limit:
o Effluent MA limit of 55.7 µg/L and DM limit of 127.6 µg/L, based on the 50"' percentile
of reported effluent concentrations from January 2018 through September 2022, becomes
effective 1 year after the effective date of the permit.
o Within 1 year of the permit's effective date, the Permittee shall submit to DWR an Action
Plan for Division approval, summarizing the strategy or actions to be taken to achieve
compliance with the nitrate limitations. This Action Plan shall include an assessment of
identified 1,4-dioxane sources. Action Plan updates regarding actions taken to come into
compliance with Phase 11 and III limitations shall be submitted to the Division annually.
o Within 2 years of the permit's effective date, the Permittee shall submit to DWR a report
of actions taken with regard to identified sources in order to achieve compliance with
permit limits. Updates on actions taken shall be submitted to the Division annually.
• Phase II — Interim Limit:
o Effluent MA limit of 35 µg/L and DM limit of 80.2 µg/L, based on the EPA Drinking
Water HAL value, becomes effective beginning three (3) years after the effective date of
the permit.
o Action Plan updates regarding actions taken to come into compliance with Phase III
limitations shall be submitted to the Division annually.
• Phase III — Final Limit:
o Effluent MA limit of 21.58 µg/L and DM limit 49.4 µg/L, based on 1 X 10-6 risk level at
the water supply boundary, becomes effective beginning five (5) years after the effective
date of the permit.
Implementing this phased Compliance Schedule, Monthly Average and Daily Maximum limits along with
weekly monitoring, reporting and notification requirements have been added to the permit. Additionally,
requirements for modification and reissuance of Industrial User Permits to ensure compliance with the
interim and final 1,4-dioxane limits as well as for the notification of downstream drinking water utilities
when effluent 1,4-dioxane concentrations exceed the current interim limit have been added to the permit.
PFAS
Asheboro WWTP had participated in a basin -wide survey for the emerging contaminants PFAS chemical
group in 2019. Three rounds of influent sampling were conducted in July, August and September 2019. In
June 2022, EPA issued interim updated drinking water health advisories for PFOA and PFOS, and final
drinking water health advisories for PFBS and GenX. EPA's Health Advisory Levels (HALs) for PFAS are
Page 16 of 24

non -enforceable and non -regulatory, and only provide technical information to state agencies and other
public health officials on health effects, analytical methods, and treatment technologies associated with
drinking water contamination.
The 2019 influent data collected at the Asheboro WWTP has been summarized below for PFOA, PFOS,
PFBS and GenX and compared to the June 2022 interim updated drinking water health advisories (See
Table 7.).
Table 7. 2019 Investigative Monitoring Influent PFAS Summary
Parameter
Average
Influent (ng/L)
Maximum
Influent (ng/L)
Minimum
Influent (ng/L)
2022 Updated Drinking Water
Health Advisory (ng/L)
PFOS
19.3
19.8
18.8
interim'
PFOA
10.6
11.7
9.47
interim'
PFBS
Non -detect
Non -detect
Non -detect
2,000
GenX2
Non -detect
Non -detect
Non -detect
10
'Interim PFOS and PFOA values can be found https://www.epa.gov/sdwa/drinking-water-health-advisories-pfoa-
and-pfos#:-:text=2022%20Interim%20Updated%20PFOA%20and,those%20EPA%20issued%20in%202016.
2During the 2019 investigation, GenX analysis was only conducted in one of the three events.
On March 14, 2023, EPA proposed Maximum Contaminant Levels (MCLs) for drinking water for PFOA,
PFOS, PFNA, PFHxS, PFBS and GenX.
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.
While not immediately downstream, WS-V classified waters exist approximately 43.5 miles downstream
of the discharge. As the Asheboro WWTP has a pretreatment program and has demonstrated influent PFAS
levels greater than the interim updated drinking water health advisories, monitoring of PFAS chemicals
will be added to the permit at a frequency of quarterly. 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 CFR 136 published in the Federal
Register. This date may be extended upon request and if there are no NC -certified labs.
If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A three-phase 5-year compliance
schedule is proposed for 1,4-Dioxane limit followed by a final limit. Per Permittee request, a 3-year
compliance schedule for total silver with a Water -Effect Ratio (WER) option has been added to the permit.
The City informed the Division in an 11/29/2022 email that they do not require a compliance schedule for
bromodichloromethane.
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
Page 17 of 24

7. Technology -Based Effluent Limitations (TBELs)
Municipals
Are concentration limits in the permit at least as stringent as secondary treatment requirements (30 mg/L
BOD51TSS for Monthly Average, and 45 mg/L for BOD51TSS for Weekly Average). YES
If NO, provide a justification for alternative limitations (e.g., waste stabilization pond). NA
Are 85% removal requirements for BOD51TSS included in the permit? YES
If NO, provide a justification (e.g., waste stabilization pond). NA
8. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
9. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): YES
If YES, confirm that antibacksliding provisions are not violated: Based on the reasonable potential analysis
(RPA) showing no reasonable potential to violate state water quality standards, the limits and monitoring
requirements for total chromium and total zinc have been removed from the permit. Based on the Mercury
TMDL evaluation showing no annual average mercury concentration exceeded the WQBEL, and no
individual mercury sample exceeded the TBEL, the limits and monitoring requirement for total mercury
have been removed from the permit.
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 213.0500; 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.
The City of Asheboro requested 2/week monitoring for BOD, ammonia, TSS and fecal coliform based on
2012 DWR Guidance Regarding the Reduction of Monitoring Frequencies in NPDES Permits for
Exceptionally Performing Facilities on November 18, 2022. The last three years of the facility's data for
these parameters have been reviewed in accordance with the criteria outlined in the guidance. Based on this
Page 18 of 24

review, 2/week monitoring frequency has been added for BOD, ammonia, TSS and fecal coliform. Please
note that the proposed ammonia limitations were used when assessing ammonia criteria.
For instream monitoring, refer to Section 4.
11. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit
additional NPDES reports electronically. This permit contains the requirements for electronic reporting,
consistent with Federal requirements.
12. Summary of Proposed Permitting Actions
Table 4. Current Permit Conditions 1 and Pro osed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 9.0 MGD
No change
15A NCAC 2B .0505
Summer:
MA 5.0 mg/L
WQBEL. Determined via WLA
WA .5 mg/L
conducted in 1995, and for protection
Winter:
No change to limits Monitor and
of DO standard (15A NCAC 2B .0200).
BODS
MA 10 mg/L
Report 2/Week
2012 DWR Guidance Regarding the
WA 15 mg/L
Reduction of Monitoring Frequencies in
Monitor and
NPDES Permits for Exceptionally
Report Daily
Performing Facilities
TBEL. Secondary treatment standards /
MA 30 mg/L
40 CFR 133 / 15A NCAC 2B .0406.
TSS
WA 45 mg/L
No change to limits; Monitor and
2012 DWR Guidance Regarding the
Monitor and
Report 2/Week
Reduction of Monitoring Frequencies in
Report Daily
NPDES Permits for Exceptionally
Performing Facilities
WQBEL. Based on protection of State
Summer:
Summer:
WQ criteria. 15A NCAC 2B.0200;
MA 2.0 mg/L
MA 1.0 mg/L
2022 WLA review; 2012 DWR
WA 6.0 mg/L
WA 3.0 mg/L
Guidance Regarding the Reduction of
NH3-N
Winter:
Winter:
Monitoring Frequencies in NPDES
MA 4.0 mg/L
MA 1.8 mg/L
Permits for Exceptionally Performing
WA 12.0 mg/L
WA 5.4 mg/L
Facilities; No compliance schedule —
Monitor and
Monitor and Report 2/Week
facility meets revised limits
Report Daily
Add instream monitoring 1/Month
consistently. Based on Instream Data
Summary
DO
> 6 mg/L
No change
WQBEL. For protection of the DO
—
standard. 15A NCAC 2B .0200.
pH
6.0 — 9.0 SU
No change
WQBEL. WQ standard, 15A NCAC 2B
.0200.
Page 19 of 24

MA 200 /100 mL
WQBEL. WQ standard, 15A NCAC 2B
Fecal
WA 400 /100 mL
No change to limits; Monitor and
.0200.2012 DWR Guidance Regarding
Coliform
Monitor and
Report 2/Week
the Reduction of Monitoring
Report Daily
Frequencies in NPDES Permits for
Exceptionally Performing Facilities
Total
WQBEL. Based on protection of State
Residual
DM 17 µg/L
No change
WQ criteria. 15A NCAC 2B.0200;
Chlorine
2022 WLA review
Surface Water Monitoring, 15A NCAC
Temperature
Monitor daily
No change
02B .0500
No change to effluent.
15A NCAC 2B.0500, added based on
Conductivity
Monitor effluent
Add instream monitoring upstream
instream conductivity review
daily
(U) and downstream (D 1 and D2)
demonstrating effluent impact on
receiving stream.
Monitor
Surface Water Monitoring, Based on
quarterly in
RPA and 15A NCAC 213.0211 (22). RP
Chloride
conjunction with
No change
shown; apply quarterly monitoring in
Chronic Toxicity
conjunction with toxicity tests, per 15A
test
NCAC 02B .0211(22)
Surface Water Monitoring, Hardness -
Total
dependent dissolved metals water
Hardness
No requirement
Add quarterly effluent monitoring
quality standards, approved in 2016;
upstream hardness not required due to
0 cfs 7Q 10.
Total
MA = 50 µg/L
No reasonable potential was found,
Chromium
DM = 1033 µg/L
Remove from permit
maximum predicted value < Cr-VI
allowable concentration.
Surface Water Monitoring, Based on
RPA, 2022 303(d) listing and Integrated
Total Copper
Monitor
No change
Report: Receiving water is impaired
quarterly
due to copper. No RP , Predicted Max
> 50% of Allowable Cw - apply
Quarterly Monitoring
Total
MA = 12 ng/L
Remove limits from permit.
Consistent with 2012 Statewide
Mercury
DM = 36 ng/L
(MMP Mercury Minimization Plan
Mercury TMDL Implementation.
MA = 0.06 ug/L
DM = 2.4 ug/L
Total Silver
No requirement
Monitor and report Monthly at
WQBEL. Based on RPA. RP shown
lower reporting level of procedure
apply Monthly Monitoring with Limit
3-year compliance schedule with
WER option
Total
No requirement
Quarterly monitoring at lower
Q Y g
Surface Water Monitoring, Based on
g�
Selenium
reporting level of procedure
RPA. No RP, Predicted Max > 50% of
Page 20 of 24

Allowable Cw - apply Quarterly
Monitoring
Based on RPA. No reasonable potential
Total Zinc
Monitor
Remove from permit
found in RPA, but maximum predicted
quarterly
value < 50 /o of the allowable
concentration.
Surface Water Monitoring, Based on
Dibromochlo
Monitor
No change
RPA. No reasonable potential found in
romethane
quarterly
RPA, but maximum predicted value >
50% of the allowable concentration.
Bromodichlo
Monitor
MA = 31.6 µg/L
WQBEL. Based on RPA for NC
romethane
quarterly
Monitor and report Monthly
Instream Target Value. RP shown -
apply Monthly Monitoring with Limit
Surface Water Monitoring, 15A NCAC
Total
Monitor monthly
No change to effluent; Add
2B.0500; nutrient criteria development
Nitrogen
instream monitoring 1/Month
in the Upper Cape Fear River Basin.
Based on Instream Data Summary
Total
Surface Water Monitoring, 15A NCAC
Kjeldahl
Monitor monthly
No change to effluent; Add
213.0500; nutrient criteria development
Nitrogen
instream monitoring 1/Month
in the Upper Cape Fear River Basin.
Based on Instream Data Summary
Nitrate +
Surface Water Monitoring, 15A NCAC
Nitrite
Monitor monthly
No change to effluent; Add
213.0500; nutrient criteria development
Nitrogen
instream monitoring 1/Month
in the Upper Cape Fear River Basin.
Based on Instream Data Summary
Surface Water Monitoring, 15A NCAC
Total
Monitor monthly
No change to effluent; Add
2B.0500; nutrient criteria development
Phosphorus
instream monitoring 1/Month
in the Upper Cape Fear River Basin.
Based on Instream Data Summary
WQBEL. 15A NCAC 02B and
Add 3-phase compliance schedule
protection of downstream water usage:
Monitor monthly
Monitor 1/week grab
Phased limitations based on 501h
1,4-Dioxane
per letter sent in
percentile of effluent levels, EPA
October 2017
Add monthly instream
drinking water HAL of 35 µg/L and NC
monitoring.
human health criterion of 0.35 µg/L at
downstream water supply water.
Evaluation of PFAS contribution:
Add quarterly monitoring with
pretreatment facility with downstream
PFAS
No requirement
delayed implementation
WS; Implementation delayed until after
EPA certified method becomes
available.
Chronic
Quarterly
Ceriodaph nia
aphniail
WQBEL. No toxics in toxic amounts.
Toxicity
dubia at
No change
15A NCAC 213.0200 and 15A NCAC
90% effluent
2B.0500
Page 21 of 24

Effluent
Pollutant
Three times per
Update sampling years to 2025
40 CFR 122
Scan
permit cycle
2026, 2027.
Electronic
Add Electronic Reporting Special
In accordance with EPA Electronic
Reporting
No requirement
Condition
Reporting Rule 2015 and Phase II 2020
update.
Nutrient
Reopener for
Special
No change
Upper Cape Fear River nutrient strategy
TN and TP
Condition
requirement.
1 MGD = Million Gallons per Day, MA = Monthly Average, WA = Weekly Average, DM = Daily Max.
13. Public Notice Schedule
Permit to Public Notice: 05/09/2018
Permit to Second Public Notice: 12/6/2022
Public Hearing: 05/23/2023 (Hearing Officer's Report attached)
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons
why a hearing is warranted.
14. Fact Sheet Addendum (if applicable)
Were there any changes made since the First Draft Permit was public noticed (Yes/No): Yes. Comments
were received from the City of Asheboro (Permittee), dated 5/31/2018. These include:
• Why were mass -based NH3 limits not inserted as requested as an alternative to concentration -based
limits? If mass -based limits not allowed, then requested 3 yr compliance schedule.
• Explain Chloride RPA factors and results.
• Cyanide limits appeared to be based on lab data that were found to be resulting from instrument
interference; requested removal of limits and monitoring
• Requested 2-yr compliance schedule for bromodichloromethane (The City submitted a follow-up
on 11/29/2022 informing the Division that this schedule is not necessary)
• Explain legal basis and calculation of 1,4-dioxane limits
• Explain discrepancy between Asheboro's limits and DAK America's monitoring only requirements
for 1,4-dioxane
• Explain shortened permit term (4 not 5 yrs)
Comments were also received electronically on 6/8/2018 from multiple municipalities expressing water
supply 1,4-Dioxane concerns, the need to consider downstream water supply waters and any additional
sources in developing permit limits, and to reduce the 1,4-Dioxane compliance schedule. Comments were
provided by the Fayetteville Public Works Commission, Cape Fear Public Utility Authority, City of
Sanford, and Town of Cary.
Comments and DWR responses are attached.
Page 22 of 24

If Yes, list changes (from previous public notice) and their basis below:
Note: This is not a comprehensive list of all changes from the current permit.
• Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state
water quality standards, total cyanide limits and monitoring requirements have not been added to
the permit.
• 1,4-dioxane limitations have been revised based on calculations pertaining to downstream WS
water uses. See Other WQBEL Considerations section above.
• A three-phase five-year 1,4-Dioxane compliance schedule has been added. See Other WQBEL
Considerations section above.
• Chromium monitoring requirement was removed, based on an RPA with updated Total Chromium
data not showing a reasonable potential to exceed the Chromium -VI water quality standard.
• Copper monitoring will be maintained based on the reasonable potential analysis (RPA) predicting
a maximum effluent total copper concentration that is greater than half of the allowable discharge
concentration based on state water quality standards.
• Based on the reasonable potential analysis (RPA) predicting a maximum effluent total selenium
concentration that is greater than half of the allowable discharge concentration based on state water
quality standards, quarterly monitoring for total selenium has been added to the permit.
• Based on the reasonable potential analysis (RPA) showing reasonable potential to violate state
water quality standards, total silver limits and monitoring requirements have been added to the
permit.
• To provide an opportunity for the City to develop a plan to assess sources of total silver in order to
come in compliance with the proposed limits, schedules of compliance have been added to the
permit. See Other WQBEL Considerations section above.
• Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess
background concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for
1,4-Dioxane has been added to the permit.
• Based on review of instream data, instream conductivity, TN, TKN, NO2+NO3, ammonia, and TP
monitoring has been added to the permit
• Based on NPDES guidance regarding the reduction of monitoring frequencies in NPDES permits
for exceptionally performing facilities, monitoring requirements for BOD5, NH3-N, Total
Suspended Solids and Fecal Coliform have been reduced to twice per week.
Were there any changes made since the Second Draft Permit was public noticed (Yes/No): Yes.
Comments were received from the following parties regarding the December 2022 draft permit:
• Cranfill Sumner, LLP, attorney on behalf of the City of Reidsville, dated 1/5/2023
• City of Asheboro (Asheboro), dated 1/9/2023
• Cape Fear Public Utility Authority (CFPUA) on 1/13/2023
• Fayetteville Public Works Commission (PWC) on 1/25/2023
• Brooks Pierce, attorney on behalf of the Cities of Greensboro and Asheboro, on 1/26/2023
• Southern Environmental Law Center on 1/27/2023
A request for public hearing was made by Fayetteville PWC and Cranfill Sumner, LLP. All sets of
comments and Division responses have been attached. Division responses to comments can be found in the
attached Hearing Officer's Report. Changes made as a result of the comments received have been
summarized below.
A technical proposal for the development of a silver WER, submitted by BT Solutions, LLC on behalf of
the City of Asheboro, was received by the Division on May 16, 2023. Revisions to the technical proposal
were received on June 30, 2023. The Division approved the revised technical proposal on July 3, 2023.
Page 23 of 24

If Yes, list changes (from previous public notice) and their basis below:
• Per request from downstream utilities and for the sake of redundancy in the event of staff turnover,
the Utility List has been updated to include a secondary contact for each utility downstream of the
Asheboro WWTP discharge.
• As the expiration date has been changed to September 30, 2028, Special Condition A.(3.) has been
modified to include the specific three years in which the Effluent Pollutant Scan shall be
performed (2025, 2026, and 2027).
• Special Condition A.(7.) PFAS Monitoring Requirements has been updated to include reference to
the most recent 4th Draft of EPA Method 1633, released in July 2023.
• Instream monitoring of 1,4-dioxane has been revised to occur monthly [See Special Condition A.
(2.)]. Additionally, the Division is activating a monitoring station downstream at the WS-V
boundary for sampling.
15. Fact Sheet Attachments (if applicable)
RPA Spreadsheet Summary
• NPDES Implementation of Instream Dissolved Metals Standards — Freshwater Standards
• NH3/TRC WLA Calculations
• BOD & TSS Removal Rate Calculations
• Mercury TMDL Calculations
• Pretreatment Information Form
• Monitoring Frequency Reduction Assessment
• WET Testing and Self -Monitoring Summary
• Compliance Inspection Report
• Chemical Addendum
• Application Addendum
• 2022 NC Integrated Report (Hasketts Creek Listing)
• USGS Flow Estimation for WS boundary
• City of Asheboro 2020 Pretreatment Annual Report, page 7
• Public Comments
• Hearing Officer's Report
• Total Silver WER Study Proposal and Approval
Page 24 of 24

Public Notice
AFFP North Carolina Environmental
Public Notice North Carolina Management Commission/
NPDES Unit
1617 Mail Service Center
Affidavit of Publication Raleigh, NC 27699-1617
Notice of Intent to Issue a NP-
DES Wastewater Permit
STATE OF NC} SS
NCO026123 Asheboro WWTP
COUNTY OF }
The North Carolina, Environment-
jkandoj Ph
al Management Commission pro-
poses to issue a NPDES
Brenda Poole, being duly sworn, says:
wastewater discharge permit to
the person(s) listed below. Writ -
That she is Classified Rep of the The Courier -Tribune, a
ten comments regarding the pro -
daily newspaper of general circulation, printed and
posed permit will be accepted un-
published in Asheboro, County, NC; that the publication, a
til aft days after the publish date
copy of which is attached hereto, was published in the
of this notice. The Director of the
said newspaper on the following dates:
NC Division of Water Resources
December 09, 2022
(DWR) may hold a public hearing
should there be a significant de-
gree of public interest. Please
mail comments and/or informa-
tion requests to DWR at the
above address. Interested per-
sons may visit the DWR at 512 N.
That said newspaper was regularly issued and circulated
Salisbury Street, Raleigh, NC
on those dates.
27604 to review the information
SIGNED:
on file. Additional information on
NPDES permits and this notice
may be found on our website: ht-
Classified Rep
tp://deq.nc.gov/aboutldwvlsionslwa
ter -resources. water- resources -
Subscribed to and sworn to me this 9th day of December
permits/wastewater-branch/np-
2022.
des-wastewater/{public-notices,or
by calling [phone]. The
City of Asheboro [P.O. Box 1106,
Asheboro, NC 27204] has re-
,u„u.
quested renewal of NPDES per -
Barbara M Daniels, Notary Guilford, County, NC
mit N00026123 for its Asheboro
Wastewater Treatment Plant. loc-
My commission expires: March 06, 202'7' --'
ated in Randolph County. This
©"►AR�
permitted facility discharges
treated municipal and industrial
wastewater to Hasketts Creek., a.
?,
class C water in the Cape Fear
,;�U:
70083249 70540195 ' �- _
�PYDCo'
River Basin. Currently, BCD, am-
WREN THEDFORD
monla, dissolved oxygen, pH,
fecal coliform, total residual chlor-
NCDEQ-DWR-NPDES (ASH)
lne, total silver, brornodichloro-
1617 MAIL SERVICE CENTER
methane and 1,4-dloxane are wa-
RALEIGH, NC 27699-1617
ter quality limited. This discharge
may affect future allocations in
this segment of Hasketts Creek.
1 t: 1219/22

Notice of Public Hearing
AFFP
PUBLIC NOTICE is hereby giv-
en that the North Carolina De
Public Notice State of North
partment of Environmental
Quality's Division of Water Re-
sources will hold a public hear-
ing from 6 p.m. to 8 p.m. on
Affidavit
of Publication
May 23, 2023, for National Pol.
lulion Discharge Elimination
System (NPDES) Wastewater
Discharge Permit NC0026123.
The purpose of the hearing is to
give the opportunity to com-
ment on the draft NPDES per-
STATE OF NC) SS
mit.
COUNTY OF )
The City of Asheboro has ap-
plied for a renewal of its NP-
Qands[ph
DES wastewater permit
Asheboro
(NC0026123) for the
Wastewater Treatment Plant,
Brenda Poole, being duly sworn, says:
1032 Bonkemeyer Drive.
Asheboro. INC. Randolph
County. The facility will dis-
charge treated municipal and
That she is Classified Rep of the The Courier -Tribune, a
industrial wastewater to Has,
daily newspaper of general circulation, printed and
kelts Creek in the Cape Fear
River Basin (Class C). The
published in Asheboro, County, NC; that the publication, a
nearest downstream water sup -
copy of which is attached hereto, was published in the
ply (WS-V) boundary, located in
the Deep River 43.5 miles
said newspaper on the following dates:
downstream of the curial, was
considered during the develop-
ment of this permit. This dis-
April 20, 2023
charge may affect future alloca-
tions in this portion of the Cape
Fear River Basin. The location
of the Outfall is: Latitude.
35.46.00 N: Longitude
79-47'06".
The draft wastewater permit
and related documents are
available online at:
https'//deo nc aov/public-na-
That said newspaper was regularly issued and circulated
tices-heariraft. Printed copies
of the draft permit and related
on those dates.
documents may be reviewed at
the department's Winston.
SIGNED:
Salem Regional Office (450
West Hanes Mill Road, Suite
300. Winston-Salem. NC
710 To make an appoint-
27105).
merit to review the documents,
ment to
Classified Re p
please call Jenny Graznak, As.
sistant Regional Supervisor, at
336-776-9695. File materials
Subscribed to and sworn to me this 20th day of April 2023.
may not be removed from any
DWR office: copy machines are
available for use upon pay-
ment of the cost thereof to
DWR pursuant to G.S. 132 6.2.
Public comments on the draft
permit may be mailed to.
nn
Wastewater Permitting, Alin.
(6A.4"" '�.Ilb.w✓�,R
Asheboro -Asheboro WWTP
Barbara M Daniels, Notary Guilford, County, NC
Permit, 1617 Mail Service Cen-
ter, Raleigh, N.C.. 27699-1617,
and must be postmarked no
My commission expires: March 06, 2027
later than May 24. 2023. Public
comments may also be submit-
ted by email to publiccorn
ments0 cdenr oov Please in-
clude'Asheboro WWTP" in the
email subject line. Comments
will be accepted via email until
May 24, 2023, 5 p.m. All com-
70083249 70648070
menls will be considered in the
final determination regarding
permit issuance and permit pro -
_
WREN THEDFORD
visions.
NCDEQ-DWR-NPDES (ASH)
Public Hearing Details (IN -
PERSON) Date: Tuesday. May
1617 MAIL SERVICE CENTER y p 7,q� ,'
'., 23. 2023. at 6 p.m. to 8 p.m.
RALEIGH, NC 27699-1617 - . ``
Location: Corporate Training
? Center at the. Randolph Com�
,1 A
munity College. 413 Industrial
.z
Park Avenue, Asheboro, NC
C
27205 Register: Speaker regis-
tration opens at 5:30 p.m..
onsite via sign-up sheet.
i
11: 4/2012023

Coco, Nick A
From: Kirby, Ben
Sent: Tuesday, January 3, 2023 12:56 PM
To: Coco, Nick A; Hudson, Eric
Subject: RE: Draft Permit Asheboro WWTP, NPDES Permit Number NC0026123, SIC Code 4952
Follow Up Flag: Follow up
Flag Status: Flagged
Nick,
Our Office concurs with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
Thanks,
Ben Kirby, E.I. (he/him/his)
Assistant Regional Engineer, Winston-Salem Regional Office
Division of Water Resources, Public Water Supply Section
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
ben. kirbvCcDncdenr.gov
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
NORTH CAROLINAD_E
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Coco, Nick A <[e-mail]>
Sent: Wednesday, December 7, 2022 4:13 PM
To: Hudson, Eric <[e-mail]>; Kirby, Ben <[e-mail]>
Subject: Draft Permit Asheboro WWTP, NPDES Permit Number NC0026123, SIC Code 4952
Hi Eric and Ben,
Thank you again for your help in developing the contact list for utilities downstream of this facility. While this facility is
not discharging into a WS water, we have developed limits for one of the parameters, specifically 1,4-dioxane, with
consideration of the nearest downstream WS boundary.
Please see the following links to review the draft permit and cover letter and draft fact sheet for NPDES permit
NCO026123 for the Asheboro WWTP. I have also provided a link to the NPDES Standard Conditions for your reference.
You have a 30-day period ending on 1/13/2023 to comment, ask questions, or request an extension to review this draft
permit. Please contact me with any comments you might have.

Draft Permit: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2601378&dbid=0&repo=WaterResources
NPDES Standard Conditions: https://bit.IV/3k5NFaL
Draft Fact Sheet: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=2601402&dbid=0&repo=WaterResources
Thanks and have a nice day.
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ / Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
D- E
NORTH CAROLINA7d� Q
ki;
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.

DocuSign Envelope ID: 6772C75B-1EB4-40CD-99D4-F3F8627845AE
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Michael D. Rhoney, PE
Water Resources Director
City of Asheboro
P.O. Box 1106
146 N Church Street
Asheboro, North Carolina 27204
Dear Mr. Rhoney:
NORTH CAROLINA
Environmental Quality
July 3, 2023
Subject: Study Plan Approval
Silver Water -Effect Ratio (WER)
Permit NCO026123
Asheboro WWTP
Randolph County
A technical proposal for the development of a silver WER, submitted by BT Solutions, LLC on
behalf of the City of Asheboro, was received May 16, 2023, by the Division of Water Resources
(Division). Submittal of this WER study plan is in accordance with Special Condition A.(4.)
Schedule of Compliance for Total Silver Limitations, included in the draft permit NC0026123.
With revisions to the technical proposal received on June 30, 2023, the final study plan has been
reviewed and found to be satisfactory. Approval is hereby granted for the City to conduct a silver
WER in accordance with the technical proposal received on June 30, 2023.
Please note that NPDES permit NCO026123 for the Asheboro WWTP has not yet been re -issued,
and the City may consider deferring action on conducting the WER until issuance of the final
permit has occurred since we cannot determine the final NPDES permit wording until that action.
We do request at the conclusion of the WER that the consultant provide the WER checklist which
will expedite the overall staff review process.
The issuance of this Letter of Approval for the Study Plan does not guarantee approval of the final
WER itself, since EPA Region IV will review this as part of any future permit modification (if
needed).
If you have any questions concerning this letter, please contact Michael Montebello at (919) 707-
3624 or at michael.montebello&deq.nc.gov.
S1riCDocuuSigiied by: L J -'' "
AUK
C464531431644FE...
Michael Montebello, Branch Chief
NPDES Municipal Permitting Unit
Hardcopy: NPDES Files
Ecopy: DWR/Winston-Salem Regional Office
DWR/Aquatic Toxicology Branch
BT Solutions, LLC/Beth Thompson
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9���
gaper .mo F.o. wquay

Coco, Nick A
From: Grzyb, Julie
Sent: Wednesday, August 16, 2023 4:30 PM
To: Montebello, Michael J; Coco, Nick A
Subject: Fw: [External] 1,4 Dioxane Sampling Hardship
FYI -Julie
Julie A. Grzyb
Deputy Director, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone] 1 Cell: [phone]
[e-mail] please note new email address
D_E'QNURfr. ,AHOLINA
Department at Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties_
From: Michael Rhoney <[e-mail]>
Sent: Wednesday, August 16, 2023 2:33 PM
To: Grzyb, Julie <[e-mail]>
Subject: [External] 1,4 Dioxane Sampling Hardship
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Julie,
The City of Asheboro has incurred a significant increase in sampling costs for 1,4 Dioxane. This has been a burden for
our sampling budget and we would appreciate DEQ's consideration to reduce our sampling requirements for this
contaminant.
Thank you,
V , R&eery, ;V'5
Water Resources Director
Water Resources Division
336-626-1201, ext: 2358
www.asheboronc.gov

North Carolina
MAIN STREET
Community
Asheboro
All-Aoerin MY
tnc7l tL� nx: irk A.F
201
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Table 1. Project Information
❑ CHECK IF HQW OR ORW WQS
Facility Name
Asheboro WWTP
WWTP/WTP Class
Grade IV
NPDES Permit
NCO026123
Outfall
001
Flow, Qw (MGD)
9.000
Receiving Stream
Hasketts Creek
HUC Number
03030003
Stream Class
❑ Apply WS Hardness WQC
C
7Q10s (cfs)
0.00
7Q10w (cfs)
0.00
30Q2 (cfs)
0.20
QA (cfs)
12.00
1 Q10s (cfs)
MEL 0.00
Effluent Hardness
86.25 mg/L (Avg)
Upstream Hardness
51.93 mg/L (Avg)
Combined Hardness Chronic
86.25 mg/L
Combined Hardness Acute
86.25 mg/L
Data Source(s)
Effluent data from DMRs from January 2018 -Aug
2022, three PPAs and Hardness data provided by
❑ CHECK TO APPLY MODEL
the Permittee.
REQUIRED DATA ENTRY
Par01
Par02
Par03
Par04
Par05
Par06 E
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Table 2. Parameters of Concern
Name WQS Type Chronic Modifier Acute PQL Units
Arsenic
Aquactic Life
C
150
FW
340
ug/L
Arsenic
Human Health
Water Supply
C
10
HH/WS
N/A
ug/L
Beryllium
Aquatic Life
NC
6.5
FW
65
ug/L
Cadmium
Aquatic Life
NC
1.5031
FW
9.5406
ug/L
Chlorides
Aquatic Life
NC
230
FW
mg/L
Chlorinated Phenolic Compounds
Water Supply
NC
1
A
ug/L
Total Phenolic Compounds
Aquatic Life
NC
300
A
ug/L
Chromium III
Aquatic Life
NC
324.6023
FW
2495.4158
ug/L
Chromium VI
Aquatic Life
NC
11
FW
16
pg/L
Chromium, Total
Aquatic Life
NC
N/A
FW
N/A
pg/L
Copper
Aquatic Life
NC
22.7043
FW
33.6311
ug/L
Cyanide
Aquatic Life
NC
5
FW
22
10
ug/L
Fluoride
Aquatic Life
NC
1,800
FW
ug/L
Lead
Aquatic Life
NC
11.6442
FW
298.8096
ug/L
Mercury
Aquatic Life
NC
12
FW
0.5
-,^"
Molybdenum
Human Health
NC
2000
HH
ug/L
Nickel
Aquatic Life
NC
106.1413
FW
955.6324
pg/L
Nickel
Water Supply
NC
25.0000
WS
N/A
pg/L
Selenium
Aquatic Life
NC
5
FW
56
ug/L
Silver
Aquatic Life
NC
0.06
FW
2.4939
ug/L
Zinc
Aquatic Life
NC
361.8812
FW
358.9451
ug/L
Bromodichloromethane
Human Health
C
17
HH
pg/L
Dibromochloromethane
Human Health
C
21
HH
pg/L
Chloroform
Human Health
j C
j 2000
HH
j
pg/L
26123 FW RPA UPDATED, input
10/13/2022

REASONABLE POTENTIAL ANALYSIS
H1
I Effluent Hardness
Date
1 6/8/2017
2 7/12/2017
3 12/5/2019
4 12/12/2019
5 12/19/2019
6 12/23/2019
7 3/5/2020
8 3/12/2020
9 3/20/2020
10 3/30/2020
11 6/24/2021
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
Data
BDL=1/2DL
Results
99.8
99.8
Std Dev.
108
108
Mean
86
86
C.V.
76
76
n
58
58
10th Per value
94
94
Average Value
84
84
Max. Value
88.2
88.2
84.3
84.3
79.4
79.4
91
91
Use "PASTE SPECIAL
Values" then "COPY"
Maximum data
points = 58
13.0463
86.2455
0.1513
11
76.00 mg/L
86.25 mg/L
108.00 mg/L
H2
Date
1 8/29/2016
2 9/13/2016
3 10/19/2016
4 11 /2/2016
5 12/6/2016
6 1/11/2017
7 2/2/2017
8 3/7/2017
9 4/11/2017
10 5/10/2017
11 6/8/2017
12 7/12/2017
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
Upstream Hardness
Data
BDL=1/2DL
Results
106
106
Std Dev.
40
40
Mean
49
49
C.V.
69
69
n
28
28
10th Per value
73
73
Average Value
39
39
Max. Value
49
49
53
53
34
34
43.7
43.7
39.5
39.5
Use "PASTE SPECIAL
Values" then "COPY"
Maximum data
points = 58
21.5387
51.9333
0.4147
12
34.50 mg/L
51.93 mg/L
106.00 mg/L
26123 FW RPA UPDATED, data
- 1 - 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par01 & Par02
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Arsenic
Date
Data
BDL=1/2DL
1 /23/2018
<
2
1
2/14/2018
<
2
1
3/6/2018
4.2
4.2
4/18/2018
<
2
1
5/22/2018
<
2
1
6/5/2018
<
2
1
7/24/2018
<
2
1
8/15/2018
<
5
2.5
9/13/2018
<
5
2.5
10/17/2018
<
2
1
11 /6/2018
<
2
1
12/4/2018
<
2
1
1/10/2019
<
2
1
2/12/2019
<
2
1
3/5/2019
<
2
1
4/16/2019
<
2
1
5/22/2019
<
2
1
6/4/2019
<
2
1
7/25/2019
<
2
1
8/6/2019
<
2
1
9/10/2019
<
2
1
10/10/2019
<
2
1
11 /7/2019
<
2
1
12/5/2019
<
5
2.5
1 /8/2020
<
2
1
2/13/2020
<
2
1
3/5/2020
<
2
1
4/7/2020
<
2
1
5/20/2020
<
2
1
6/2/2020
<
2
1
7/14/2020
<
2
1
8/19/2020
<
2
1
9/15/2020
<
2
1
10/22/2020
<
2
1
11 /11 /2020
<
2
1
12/8/2020
<
2
1
1/13/2021
<
2
1
2/16/2021
<
2
1
3/2/2021
<
2
1
4/14/2021
<
2
1
5/21 /2021
<
2
1
6/24/2021
<
2
1
7/28/2021
<
2
1
8/19/2021
<
2
1
9/14/2021
<
2
1
10/27/2021
<
2
1
11/10/2021
<
2
1
12/7/2021
<
2
1
1/13/2022
<
2
1
2/17/2022
<
2
1
3/8/2022
<
2
1
4/13/2022
<
2
1
5/12/2022
<
2
1
6/7/2022
<
2
1
7/18/2022
<
2
1
8/11/2022
<
2
1
Results
Std Dev
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
Maximum data
points = 58
0.5382
1.1375
0.4731
56
1.01
4.2 ug/L
4.2 ug/L
-2-
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par03
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Use "PASTE SPECIAL
Beryllium Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
3/17/2016
<
1 0.5
Std Dev.
0.0000
12/5/2019
<
1 0.5
Mean
0.5000
3/5/2020
<
1 0.5
C.V. (default)
0.6000
6/24/2021
<
1 0.5
n
4
Mult Factor = 2.59
Max. Value 0.50 ug/L
Max. Pred Cw 1.30 ug/L
P a r04
Use "PASTE SPECIAL
Cadmium
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1 /23/2018
<
0.5
0.25
Std Dev.
0.0334
2
2/14/2018
<
0.5
0.25
Mean
0.2545
3
3/6/2018
<
0.5
0.25
C.V.
0.1313
4
4/18/2018
<
0.5
0.25
n
56
5
5/22/2018
<
0.5
0.25
6
6/5/2018
<
0.5
0.25
Mult Factor =
1.00
7
7/24/2018
<
0.5
0.25
Max. Value
0.500 ug/L
8
8/15/2018
<
0.5
0.25
Max. Pred Cw
0.500 ug/L
9
9/13/2018
<
0.5
0.25
10
10/17/2018
<
0.5
0.25
11
11 /6/2018
<
0.5
0.25
12
12/4/2018
<
0.5
0.25
13
1/10/2019
<
0.5
0.25
14
2/12/2019
<
0.5
0.25
15
3/5/2019
<
0.5
0.25
16
4/16/2019
<
0.5
0.25
17
5/22/2019
<
0.5
0.25
18
6/4/2019
<
0.5
0.25
19
7/25/2019
<
0.5
0.25
20
8/6/2019
<
0.5
0.25
21
9/10/2019
<
0.5
0.25
22
10/10/2019
<
0.5
0.25
23
11 /7/2019
<
0.5
0.25
24
12/5/2019
<
1
0.5
25
1 /8/2020
<
0.5
0.25
26
2/13/2020
<
0.5
0.25
27
3/5/2020
<
0.5
0.25
28
4/7/2020
<
0.5
0.25
29
5/20/2020
<
0.5
0.25
30
6/2/2020
<
0.5
0.25
31
7/14/2020
<
0.5
0.25
32
8/19/2020
<
0.5
0.25
33
9/15/2020
<
0.5
0.25
34
10/22/2020
<
0.5
0.25
35
11 /11 /2020
<
0.5
0.25
36
12/8/2020
<
0.5
0.25
37
1/13/2021
<
0.5
0.25
38
2/16/2021
<
0.5
0.25
39
3/2/2021
<
0.5
0.25
40
4/14/2021
<
0.5
0.25
41
5/21 /2021
<
0.5
0.25
42
6/24/2021
<
0.5
0.25
43
7/28/2021
<
0.5
0.25
44
8/19/2021
<
0.5
0.25
45
9/14/2021
<
0.5
0.25
46
10/27/2021
<
0.5
0.25
47
11/10/2021
<
0.5
0.25
48
12/7/2021
<
0.5
0.25
49
1/13/2022
<
0.5
0.25
50
2/17/2022
<
0.5
0.25
51
3/8/2022
<
0.5
0.25
52
4/13/2022
<
0.5
0.25
53
5/12/2022
<
0.5
0.25
54
6/7/2022
<
0.5
0.25
55
7/18/2022
<
0.5
0.25
56
8/11/2022
<
0.5
0.25
57
58
-3-
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par05
Chlorides
Use "PASTE
SPECIAL -Values"
then "COPY".
Par07
Use "PASTE
SPECIAL -
Values" then
"COPY".
Total Phenolic Compounds
Maximum data
Maximum data
points = 58
Date Data
BDL=1/2DL
Results
Date
Data
BDL=1/2DL
Results
points = 58
1
3/6/2018
105
105
Std Dev.
45.1468
1
6/24/2021
<
20
10
Std Dev.
3.1458
2
6/5/2018
154
154
Mean
160.9
2
3/17/2016
<
5
2.5
Mean
5.6250
3
9/13/2018
137
137
C.V.
0.2806
3
12/5/2019
<
10
5
C.V. (default)
0.6000
4
12/4/2018
137
137
n
26
4
3/5/2020
<
10
5
n
4
5
3/5/2019
71.5
71.5
5
6
6/4/2019
150
150
Mult Factor =
1.1
6
Mult Factor =
2.59
7
9/10/2019
178
178
Max. Value
247.0 mg/L
7
Max. Value
10.0 ug/L
8
12/5/2019
159
159
Max. Pred Cw
276.6 mg/L
8
Max. Pred Cw
25.9 ug/L
9
3/5/2020
182
182
9
10
4/7/2020
100
100
10
11
9/15/2020
247
247
11
12
12/8/2020
177
177
12
13
1 /13/2021
191
191
13
14
2/16/2021
83.2
83.2
14
15
3/2/2021
101
101
15
16
4/14/2021
197
197
16
17
5/21 /2021
200
200
17
18
6/24/2021
152
152
18
19
7/28/2021
180
180
19
20
8/19/2021
202
202
20
21
9/14/2021
223
223
21
22
10/27/2021
198
198
22
23
11 /10/2021
189
189
23
24
12/7/2021
212
212
24
25
3/8/2022
140
140
25
26
6/7/2022
118
118
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
26123 FW RPA UPDATED, data
-4- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par10
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Chromium, Total
Date
Data
BDL=1/2DL
1 /23/2018
<
5
2.5
2/14/2018
<
5
2.5
3/6/2018
<
5
2.5
4/18/2018
<
5
2.5
5/22/2018
<
5
2.5
6/5/2018
<
5
2.5
7/24/2018
<
5
2.5
8/15/2018
<
5
2.5
9/13/2018
10.7
10.7
10/17/2018
9.9
9.9
11 /6/2018
6.4
6.4
12/4/2018
<
5
2.5
1/10/2019
5.8
5.8
2/12/2019
<
5
2.5
3/5/2019
<
5
2.5
4/16/2019
<
5
2.5
5/22/2019
5.1
5.1
6/4/2019
<
5
2.5
7/25/2019
<
5
2.5
8/6/2019
<
5
2.5
9/10/2019
<
5
2.5
10/10/2019
5.4
5.4
11 /7/2019
<
5
2.5
12/5/2019
6
6
1 /8/2020
<
5
2.5
2/13/2020
<
5
2.5
3/5/2020
<
5
2.5
4/7/2020
<
5
2.5
5/20/2020
<
5
2.5
6/2/2020
<
5
2.5
7/14/2020
<
5
2.5
8/19/2020
<
5
2.5
9/15/2020
<
5
2.5
10/22/2020
<
5
2.5
11 /11 /2020
<
5
2.5
12/8/2020
<
5
2.5
1/13/2021
<
5
2.5
2/16/2021
<
5
2.5
3/2/2021
<
5
2.5
4/14/2021
<
5
2.5
5/21 /2021
<
5
2.5
6/24/2021
<
5
2.5
7/28/2021
<
5
2.5
8/19/2021
<
5
2.5
9/14/2021
<
5
2.5
10/27/2021
<
5
2.5
11/10/2021
<
5
2.5
12/7/2021
<
5
2.5
1/13/2022
<
5
2.5
2/17/2022
<
5
2.5
3/8/2022
<
5
2.5
4/13/2022
<
5
2.5
5/12/2022
<
5
2.5
6/7/2022
<
5
2.5
7/18/2022
<
5
2.5
8/11/2022
<
5
2.5
Results
Std Dev
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
Use "PASTE SPECIAL
Values" then "COPY"
Maximum data
points = 58
1.6920
3.0679
0.5515
56
1.01
10.7 pg/L
10.8 dig/L
Pal
Use "PASTE SPECIAL
Copper
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1 /23/2018
6.9
6.9
Std Dev.
1.5802
2
2/14/2018
6.6
6.6
Mean
6.4946
3
3/6/2018
8
8
C.V.
0.2433
4
4/18/2018
6.7
6.7
n
56
5
5/22/2018
5.4
5.4
6
6/5/2018
7.2
7.2
Mult Factor =
1.00
7
7/24/2018
5.8
5.8
Max. Value
11.80 ug/L
8
8/15/2018
6.2
6.2
Max. Pred Cw
11.80 ug/L
9
9/13/2018
7.5
7.5
10
10/17/2018
6.1
6.1
11
11 /6/2018
7.2
7.2
12
12/4/2018
7.4
7.4
13
1/10/2019
9.6
9.6
14
2/12/2019
6.5
6.5
15
3/5/2019
5.6
5.6
16
4/16/2019
3.5
3.5
17
5/22/2019
5.7
5.7
18
6/4/2019
5.9
5.9
19
7/25/2019
5
5
20
8/6/2019
6
6
21
9/10/2019
6.7
6.7
22
10/10/2019
9.5
9.5
23
11 /7/2019
5.4
5.4
24
12/5/2019
< 10
5
25
1 /8/2020
7.6
7.6
26
2/13/2020
5.6
5.6
27
3/5/2020
7
7
28
4/7/2020
5.6
5.6
29
5/20/2020
6.7
6.7
30
6/2/2020
10.4
10.4
31
7/14/2020
5.6
5.6
32
8/19/2020
5.6
5.6
33
9/15/2020
5.2
5.2
34
10/22/2020
5.4
5.4
35
11 /11 /2020
4.6
4.6
36
12/8/2020
5.2
5.2
37
1/13/2021
5.5
5.5
38
2/16/2021
3.7
3.7
39
3/2/2021
4.2
4.2
40
4/14/2021
6.1
6.1
41
5/21 /2021
7.7
7.7
42
6/24/2021
9
9
43
7/28/2021
7.7
7.7
44
8/19/2021
6.7
6.7
45
9/14/2021
7.9
7.9
46
10/27/2021
11.8
11.8
47
11/10/2021
6.9
6.9
48
12/7/2021
9.1
9.1
49
1/13/2022
7.3
7.3
50
2/17/2022
6.2
6.2
51
3/8/2022
5.4
5.4
52
4/13/2022
5
5
53
5/12/2022
6.1
6.1
54
6/7/2022
5.3
5.3
55
7/18/2022
6.2
6.2
56
8/11/2022
6
6
57
58
26123 FW RPA UPDATED, data
-5- 10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par12
Date
1 3/6/2018
2 6/5/2018
3 9/13/2018
4 12/4/2018
5 3/5/2019
6 6/4/2019
7 9/10/2019
8 12/5/2019
9 3/5/2020
10 4/7/2020
11 9/15/2020
12 12/8/2020
13 1 /13/2021
14 2/16/2021
15 3/2/2021
16 4/14/2021
17 5/21 /2021
18 6/24/2021
19 7/28/2021
20 8/19/2021
21 9/ 14/2021
22 10/27/2021
23 11 /10/2021
24 12/7/2021
25 3/8/2022
26 6/7/2022
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
Cyanide
Values" then "COPY"
Maximum data
points = 58
Data
BDL=1/2DL
Results
<
10
5
Std Dev.
0.0000
<
10
5
Mean
5.00
<
10
5
C.V.
0.0000
<
5
5
n
26
<
5
5
<
5
5
Mult Factor =
1.00
<
5
5
Max. Value
5.0 ug/L
<
5
5
Max. Pred Cw
5.0 ug/L
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
<
5
5
Par14
Use "PASTE SPECIAL
Lead
Values" then "COPY"
Maximum data
points = 58
Date
BDL=1/2DL
Results
1
1 /23/2018
<
2
1
Std Dev.
0.4316
2
2/14/2018
<
2
1
Mean
1.1339
3
3/6/2018
<
2
1
C.V.
0.3806
4
4/18/2018
<
2
1
n
56
5
5/22/2018
<
5
2.5
6
6/5/2018
<
2
1
Mult Factor =
1.01
7
7/24/2018
<
5
2.5
Max. Value
2.500 ug/L
8
8/15/2018
<
5
2.5
Max. Pred Cw
2.525 ug/L
9
9/13/2018
<
5
2.5
10
10/17/2018
<
2
1
11
11 /6/2018
<
2
1
12
12/4/2018
<
2
1
13
1/10/2019
<
2
1
14
2/12/2019
<
2
1
15
3/5/2019
<
2
1
16
4/16/2019
<
2
1
17
5/22/2019
<
2
1
18
6/4/2019
<
2
1
19
7/25/2019
<
2
1
20
8/6/2019
<
2
1
21
9/10/2019
<
2
1
22
10/10/2019
<
2
1
23
11 /7/2019
<
2
1
24
12/5/2019
<
5
2.5
25
1 /8/2020
<
2
1
26
2/13/2020
<
2
1
27
3/5/2020
<
2
1
28
4/7/2020
<
2
1
29
5/20/2020
<
2
1
30
6/2/2020
<
2
1
31
7/14/2020
<
2
1
32
8/19/2020
<
2
1
33
9/15/2020
<
2
1
34
10/22/2020
<
2
1
35
11 /11 /2020
<
2
1
36
12/8/2020
<
2
1
37
1/13/2021
<
2
1
38
2/16/2021
<
2
1
39
3/2/2021
<
2
1
40
4/14/2021
<
2
1
41
5/21/2021
<
2
1
42
6/24/2021
<
2
1
43
7/28/2021
<
2
1
44
8/19/2021
<
2
1
45
9/14/2021
<
2
1
46
10/27/2021
<
2
1
47
11/10/2021
<
2
1
48
12/7/2021
<
2
1
49
1/13/2022
<
2
1
50
2/17/2022
<
2
1
51
3/8/2022
<
2
1
52
4/13/2022
<
2
1
53
5/12/2022
<
2
1
54
6/7/2022
<
2
1
55
7/18/2022
<
2
1
56
8/11/2022
<
2
1
57
58
M
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par16
Use "PASTE SPECIAL
Molybdenum
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1/23/2018
35.9
35.9
Std Dev.
49.5015
2
2/14/2018
169
169
Mean
51.7125
3
3/6/2018
123
123
C.V.
0.9572
4
4/18/2018
21
21
n
56
5
5/22/2018
29.3
29.3
6
6/5/2018
67.4
67.4
Mult Factor =
1.02
7
7/24/2018
59.8
59.8
Max. Value
272.0 ug/L
8
8/15/2018
63.2
63.2
Max. Pred Cw
277.4 ug/L
9
9/13/2018
272
272
10
10/17/2018
59.9
59.9
11
11 /6/2018
37
37
12
12/4/2018
92.8
92.8
13
1/10/2019
27.1
27.1
14
2/12/2019
22.3
22.3
15
3/5/2019
<
10
5
16
4/16/2019
17.6
17.6
17
5/22/2019
108
108
18
6/4/2019
25.1
25.1
19
7/25/2019
30.3
30.3
20
8/6/2019
28.4
28.4
21
9/10/2019
38.2
38.2
22
10/10/2019
82
82
23
11 /7/2019
55.9
55.9
24
12/5/2019
<
50
25
25
1 /8/2020
37.2
37.2
26
2/13/2020
17.2
17.2
27
3/5/2020
14
14
28
4/7/2020
21.6
21.6
29
5/20/2020
126
126
30
6/2/2020
34.8
34.8
31
7/14/2020
43.7
43.7
32
8/19/2020
24
24
33
9/15/2020
159
159
34
10/22/2020
28
28
35
11 /11 /2020
15.8
15.8
36
12/8/2020
38.7
38.7
37
1 /13/2021
24.1
24.1
38
2/16/2021
<
10
5
39
3/2/2021
<
10
5
40
4/14/2021
17.8
17.8
41
5/21 /2021
22.1
22.1
42
6/24/2021
33
33
43
7/28/2021
22.1
22.1
44
8/19/2021
29.3
29.3
45
9/14/2021
32.7
32.7
46
10/27/2021
32.9
32.9
47
11 /10/2021
125
125
48
12/7/2021
47.4
47.4
49
1/13/2022
42.1
42.1
50
2/17/2022
30.3
30.3
51
3/8/2022
28.5
28.5
52
4/13/2022
43.2
43.2
53
5/12/2022
83.7
83.7
54
6/7/2022
151
151
55
7/18/2022
25
25
56
8/11/2022
40.5
40.5
57
58
Par17 & Par18
Use "PASTE SPECIAL
Nickel
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1 /23/2018
<
2
1
Std Dev.
4.2677
2
2/14/2018
2.3
2.3
Mean
3.5661
3
3/6/2018
2.2
2.2
C.V.
1.1967
4
4/18/2018
2.3
2.3
n
56
5
5/22/2018
<
2
1
6
6/5/2018
3.3
3.3
Mult Factor =
1.02
7
7/24/2018
<
5
2.5
Max. Value
33.0 pg/L
8
8/15/2018
<
5
2.5
Max. Pred Cw
33.7 dig/L
9
9/13/2018
33
33
10
10/17/2018
9
9
11
11 /6/2018
4.7
4.7
12
12/4/2018
3.8
3.8
13
1/10/2019
6.4
6.4
14
2/12/2019
6.3
6.3
15
3/5/2019
2.9
2.9
16
4/16/2019
2.3
2.3
17
5/22/2019
3.7
3.7
18
6/4/2019
3.1
3.1
19
7/25/2019
3.8
3.8
20
8/6/2019
3.7
3.7
21
9/10/2019
4.5
4.5
22
10/10/2019
3.9
3.9
23
11 /7/2019
3.5
3.5
24
12/5/2019
<
10
5
25
1 /8/2020
2.3
2.3
26
2/13/2020
2.5
2.5
27
3/5/2020
5
5
28
4/7/2020
2.8
2.8
29
5/20/2020
2.5
2.5
30
6/2/2020
2.8
2.8
31
7/14/2020
3.9
3.9
32
8/19/2020
2.9
2.9
33
9/15/2020
3.1
3.1
34
10/22/2020
4.7
4.7
35
11 /11 /2020
3.3
3.3
36
12/8/2020
<
2
1
37
1/13/2021
2.4
2.4
38
2/16/2021
2.1
2.1
39
3/2/2021
<
2
1
40
4/14/2021
2.4
2.4
41
5/21 /2021
2.8
2.8
42
6/24/2021
4
4
43
7/28/2021
3.6
3.6
44
8/19/2021
<
2
1
45
9/14/2021
2.9
2.9
46
10/27/2021
3.3
3.3
47
11/10/2021
2.8
2.8
48
12/7/2021
3
3
49
1/13/2022
2.6
2.6
50
2/17/2022
2.3
2.3
51
3/8/2022
<
2
1
52
4/13/2022
<
2
1
53
5/12/2022
2.2
2.2
54
6/7/2022
2.2
2.2
55
7/18/2022
2.6
2.6
56
8/11/2022
<
2
1
57
58
-7-
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par19
Date Data
1 7/25/2019
2 8/6/2019 <
3 9/10/2019
4 10/10/2019
5 11 /7/2019 <
6 1 /8/2020 <
7 2/13/2020 <
8 3/5/2020 <
9 4/7/2020
10 5/20/2020 <
11 6/2/2020 <
12 7/14/2020 <
13 8/19/2020 <
14 9/15/2020 <
15 10/22/2020 <
16 11 /11 /2020 <
17 12/8/2020 <
18 1/13/2021 <
19 2/16/2021 <
20 3/2/2021 <
21 4/ 14/2021
22 5/21 /2021
23 6/24/2021 <
24 7/28/2021 <
25 8/19/2021
26 9/14/2021
27 10/27/2021 <
28 11/10/2021 <
29 12/7/2021
30 1 /13/2022
31 2/17/2022 <
32 3/8/2022 <
33 4/13/2022
34 5/12/2022
35 6/7/2022
36 7/18/2022
37 8/11/2022
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Par20
Use "PASTE SPECIAL -
Selenium Values" then "COPY".
Maximum data points =
58
BDL=1/2DL
1.5 1.5
1 0.5
2.1 2.1
2.6 2.6
1 0.5
1 0.5
1 0.5
1 0.5
1.2 1.2
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1 0.5
1.2 1.2
1.4 1.4
1 0.5
1 0.5
2.1 2.1
1.4 1.4
1 0.5
1 0.5
2 2
1.9 1.9
1 0.5
1 0.5
1 1
2.1 2.1
1.6 1.6
1.3 1.3
1.5 1.5
Results
Std Dev.
0.6416
Mean
0.9703
C.V.
0.6612
n
37
Mult Factor = 1.14
Max. Value 2.6 ug/L
Max. Pred Cw 3.0 ug/L
Use"PASTE
SPECIAL -Values"
Silver then "COPY".
Maximum data points
= 58
Date
Data
BDL=1/2DL
Results
1
7/25/2019
<
1
0.5
Std Dev.
0.3797
2
8/6/2019
<
1
0.5
Mean
0.5973
3
9/10/2019
<
1
0.5
C.V.
0.6357
4
10/10/2019
<
1
0.5
n
37
5
11 /7/2019
<
1
0.5
6
1/8/2020
<
1
0.5
Mult Factor =
1.14
7
2/13/2020
<
1
0.5
Max. Value
2.600 ug/L
8
3/5/2020
<
1
0.5
Max. Pred Cw
2.964 ug/L
9
4/7/2020
<
1
0.5
10
5/20/2020
<
1
0.5
11
6/2/2020
<
1
0.5
12
7/14/2020
<
1
0.5
13
8/19/2020
<
1
0.5
14
9/15/2020
<
1
0.5
15
10/22/2020
<
1
0.5
16
11/11/2020
<
1
0.5
17
12/8/2020
<
1
0.5
18
1/13/2021
<
1
0.5
19
2/16/2021
<
1
0.5
20
3/2/2021
<
1
0.5
21
4/14/2021
<
1
0.5
22
5/21 /2021
<
1
0.5
23
6/24/2021
<
1
0.5
24
7/28/2021
1.2
1.2
25
8/19/2021
1.3
1.3
26
9/14/2021
<
1
0.5
27
10/27/2021
2.6
2.6
28
11/10/2021
<
1
0.5
29
12/7/2021
<
1
0.5
30
1/13/2022
<
1
0.5
31
2/17/2022
<
1
0.5
32
3/8/2022
<
1
0.5
33
4/13/2022
<
1
0.5
34
5/12/2022
<
1
0.5
35
6/7/2022
<
1
0.5
36
7/18/2022
<
1
0.5
37
8/11/2022
<
1
0.5
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par21
Zinc
Use "PASTE SPECIAL
Values" then "COPY"
Par22
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
1
1/23/2018
24.6
24.6
Std Dev.
17.1465
1
2
2/14/2018
18.5
18.5
Mean
21.6804
2
3
3/6/2018
33.8
33.8
C.V.
0.7909
3
4
4/18/2018
18.7
18.7
n
56
4
5
5/22/2018
20.4
20.4
5
6
6/5/2018
12.5
12.5
Mult Factor =
1.01
6
7
7/24/2018
<
20
10
Max. Value
100.0 ug/L
7
8
8/15/2018
<
20
10
Max. Pred Cw
101.0 ug/L
8
9
9/13/2018
<
20
10
9
10
10/17/2018
10.2
10.2
10
11
11 /6/2018
24.9
24.9
11
12
12/4/2018
56.7
56.7
12
13
1/10/2019
82.9
82.9
13
14
2/12/2019
53.1
53.1
14
15
3/5/2019
35.1
35.1
15
16
4/16/2019
20.5
20.5
16
17
5/22/2019
16.9
16.9
17
18
6/4/2019
<
20
10
18
19
7/25/2019
16.7
16.7
19
20
8/6/2019
25.7
25.7
20
21
9/10/2019
27.4
27.4
21
22
10/10/2019
25.2
25.2
22
23
11 /7/2019
17.8
17.8
23
24
12/5/2019
34
34
24
25
1 /8/2020
32.9
32.9
25
26
2/13/2020
22
22
26
27
3/5/2020
29
29
27
28
4/7/2020
13
13
28
29
5/20/2020
16.9
16.9
29
30
6/2/2020
24.8
24.8
30
31
7/14/2020
15.7
15.7
31
32
8/19/2020
13
13
32
33
9/15/2020
15.3
15.3
33
34
10/22/2020
20.2
20.2
34
35
11 /11 /2020
15.2
15.2
35
36
12/8/2020
<
10
5
36
37
1 /13/2021
11.3
11.3
37
38
2/16/2021
20.2
20.2
38
39
3/2/2021
11.7
11.7
39
40
4/14/2021
17
17
40
41
5/21 /2021
100
100
41
42
6/24/2021
18
18
42
43
7/28/2021
19.9
19.9
43
44
8/19/2021
10.7
10.7
44
45
9/14/2021
14.2
14.2
45
46
10/27/2021
17.8
17.8
46
47
11 /10/2021
16.1
16.1
47
48
12/7/2021
16.8
16.8
48
49
1/13/2022
36.9
36.9
49
50
2/17/2022
14.3
14.3
50
51
3/8/2022
11.1
11.1
51
52
4/13/2022
<
10
5
52
53
5/12/2022
11.2
11.2
53
54
6/7/2022
<
10
5
54
55
7/18/2022
<
10
5
55
56
8/11/2022
13.3
13.3
56
57
57
58
58
Use "PASTE SPECIAL
Bromodichloromethane
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
3/8/2018
6.3
6.3
Std Dev.
10.2278
6/5/2018
24.4
24.4
Mean
16.1456
9/13/2018
18.6
18.6
C.V.
0.6335
12/6/2018
< 5
2.5
n
18
3/7/2019
< 5
2.5
6/6/2019
20.6
20.6
Mult Factor =
1.44
9/12/2019
26.6
26.6
Max. Value
36.000000 pg/L
12/5/2019
8.94
8.94
Max. Pred Cw
51.840000 pg/L
3/5/2020
9.02
9.02
6/4/2020
19.4
19.4
9/30/2020
17.4
17.4
12/10/2020
11.7
11.7
3/4/2021
10.3
10.3
6/24/2021
26.9
26.9
9/30/2021
33.1
33.1
12/9/2021
10.7
10.7
3/10/2022
5.66
5.66
6/9/2022
36
36
M
26123 FW RPA UPDATED, data
10/13/2022

REASONABLE POTENTIAL ANALYSIS
Par23
use "PASTE Par24
SPECIAL -Values"
Dibromochloromethane then "COPY". Chloroform
Maximum data
points = 58
Date Data
1 3/8/2018 <
2 6/5/2018
3 9/13/2018 <
4 12/6/2018 <
5 3/7/2019 <
6 6/6/2019
7 9/12/2019
8 12/5/2019 <
9 3/5/2020 <
10 6/4/2020
11 9/30/2020
12 12/10/2020 <
13 3/4/2021 <
14 6/24/2021
15 9/30/2021
16 12/9/2021
17 3/10/2022 <
18 6/9/2022
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
5
2.5
Std Dev.
5.1615
1
3/17/2016
13.4
13.4
Std Dev.
7.4
7.4
Mean
6.6161
2
12/5/2019
19
19
Mean
5
2.5
C.V.
0.7801
3
3/5/2020
21.1
21.1
C.V. (default)
5
2.5
n
18
4
6/24/2021
33.4
33.4
n
5
2.5
5
6.26
6.26
Mult Factor = 1.54
6
13
13
Max. Value 17.200000 pg/L
7
5
2.5
Max. Pred Cw 26.488000 pg/L
8
5
2.5
9
10.1
10.1
10
5.55
5.55
11
5
2.5
12
5
2.5
13
12.2
12.2
14
16.6
16.6
15
8.28
8.28
16
5
2.5
17
17.2
17.2
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
Mult Factor =
Max. Value
Max. Pred Cw
Use"PASTE
SPECIAL -Values"
then "COPY".
Maximum data
points = 58
8.4346
21.7250
0.60
4
2.59
33.40 pg/L
86.51 pg/L
26123 FW RPA UPDATED, data
- 10 - 10/13/2022

Asheboro WWTP >
Outfall 001
NCO026123 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
MAXIMUM DATA POINTS = 58
Qw (MGD) =
9.0000
1Q10S (cfs) =
0.00
7Q10S (cfs) =
0.00
7QIOW (cfs) =
0.00
30Q2 (cfs) =
0.20
Avg. Stream Flow, QA (cfs) =
12.00
Receiving Stream: Hasketts Creek HUC 03030003
WWTP/WTP Class: Grade IV
IWC% @ 1Q10S =
100
IWC% @ 7Q I OS =
100
IWC% @ 7Q10W =
100
IWC% @ 30Q2 =
98.58657244
IW%C @ QA =
53.75722543
Stream Class: C
Qw = 9 MGD
COMBINED HARDNESS (mg/L)
Acute = 86.25 mg/L
Chronic = 86.25 mg/L
PARAMETER
NC STANDARDS OR EPA CRITERIA
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
J
D
Aplied
Chronic Acute
n # Det. Max Pred Cw Allowable Cw
Standa d
Acute (FW): 340.0
Arsenic
C
150 FW 340
ug/L
56 1
4.2
_____
Chronic (FW) 150.0
No value > Allowable Cw
Arsenic
C
10 HH/WS
ug/L
_____ _ _ _
Chronic (HH) 18.6
_ _ _ _ _ _ _ _ _ _ _ _ _
No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: 65.00
Beryllium
NC
6.5 FW 65
ug/L
4 0
1.30
Note: n < 9
C.V. (default)
Chronic: 6.50
No detects at < 1 ug/L. No monitoring or limits
Limited data set
NO DETECTS
Max MDL = 1
required.
Acute: 9.541
Cadmium
NC
1.5031 FW 9.5406
ug/L
56 0
0.500
Chronic: 1.503
No RP, Predicted Max < 50% of Allowable Cw - No
NO DETECTS
Max MDL - 1
Monitoring required
Acute: NO WQS
Chlorides
NC
230 FW
mg/L
26 26
276.6
Chronic: 230.0
RP shown; apply quarterly monitoring in conjunction
1 value(s) > Allowable Cw
with toxicity tests, per 15A NCAC 02B .0211(22)
Acute: NO WQS
Total Phenolic Compounds
NC
300 A
ug/L
4 0
25.9
_ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Note: n < 9
C.V. (default)
Chronic: 304.3
No detects at < 5, < 10 ug/L and < 20 ug/L. No
Limited data set
NO DETECTS
Max MDL = 20
monitoring or limits required.
Acute: 2,495.4
Chromium III
NC
324.6023 FW 2495.4158
µg/L
0 0
N/A
--Chronic: -----324.E---
---------------------------
Acute: 16.0
Chromium VI
NC
11 FW 16
µg/L
0 0
N/A
--Chronic: ----- 11.0 ---
---------------------------
Tot Cr value(s) > 5 but < Cr VI Allowable Cw
a: No monitoring required if all Total Chromium
Chromium, Total
NC
µg/L
56 7 10.8 Max reported value = 10.7
samples are < 5 pg/L or Pred. max for Total Cr is <
allowable Cw for Cr VI.
Acute: 33.63
Copper
NC
22.7043 FW 33.6311
ug/L
56 55
11.80
Chronic: 22.70
_ _
No RP, Predicted Max >_ 50% of Allowable Cw
No value > Allowable Cw
apply Quarterly Monitoring
26123 FW RPA UPDATED, rpa
Page 1 of 2 10/13/2022

Asheboro WWTP Outfall 001
NCO026123
Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators
5.0
NO DETECTS
N/A
2.525
NO DETECTS
277.4
33.7
3.0
2.964
101.0
51.84000
26.48800
86.50600
C.V. (default)
Acute: 22.0
Qw = 9 MGD
Chronic: 5.0 All results < 10 ug/L considered compliant. No
Max MDL = 10 monitoring or limits required.
Acute: NO WQS
--Chronic:----1--- --I ------
Acute: 298.810
Chronic: 11.644 No detects < 2 and < 5 ug/L. No monitoring or limits
Max MDL = 5 required.
Acute: NO WQS
Chronic: 2,000.0 No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw Monitoring required
Acute (FW): 955.6
Chronic (FW) 106.1
No -value > Allowable Cw ---
Chronic (WS) 25.0
1 value(s) > Allowable Cw
Acute: 56.0
----------------------------
No RP, Predicted Max < 50% of Allowable Cw - No
Monitoring required
----------------------------
Chronic: 5.0 No RP, Predicted Max >_ 50% of Allowable Cw
No value > Allowable Cw apply Quarterly Monitoring
Acute: 2.494
Chronic:-----0.060--- ---------------------------
RP shown - apply Monthly Monitoring with Limit
37 value(s) > Allowable Cw
Acute: 358.9
Chronic: 361.9 No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw Monitoring required
Acute: NO WQS
Chronic: 31.62366 [RP shown - apply Monthly Monitoring with Limit
2 value(s) > Allowable Cw
Acute: NO WQS
----------------------------------------------
Chronic: 39.06452 No RP, Predicted Max >_ 50% of Allowable Cw
No value > Allowable Cw apply Quarterly Monitoring
Acute: NO WQS
---------------------------
Chronic: 3720.43011 No RP, Predicted Max < 50% of Allowable Cw - No
No value > Allowable Cw Monitoring required
Page 2 of 2
26123 FW RPA UPDATED, rpa
10/13/2022

2018 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Proiect Information
Facility Name
WWTPIWTP Class
NPDES Permit
Outfall
Flow, Qw, (MGD)
Receiving Stream
Stream Class
HUC Number
7Q10s (cfs)
70110w (cfs)
30Q2 (cfs)
CIA (cfs)
1Q10s (cfs)
WS Barrier
Latitude
Longitude
Receiving Stream
Stream Class
7Q10s (cfs)
70110w (cfs)
30Q2 (cfs)
CIA (cfs)
1Q10s (cfs)
Data Source(s)
❑ CHECK IF HQW OR ORIN
Asheboro WWTP
Grade IV
NCO026123
001
9.000
Hasketts Creek
C
3030003
0.00
0.00
0.20
12.00
Gulf-Goldston Watershed
34.48437
-79.44746
Deep River
WS-V; HQW
N/A
N/A
N/A
846.00
1,4-dioxane data from July 2021 - September 2022.
CIA used was estimated by USGS for the
downstream WS-V boundary of Gulf-Goldston WS
watershed. 1,4-dioxane biodegradation negligible,
and concentration discharged assumed equivalent
direct discharge point and downstream WS; More
restrictive Cw allowable based on downstream WS-
V selected
❑ CHECK TO APPLY MODEL
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.
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Par23
Par24
Par25
Par26
Par27
Par28
Par29
Par30
Par31
Par32
Table 2. Parameters of Concern
Name Stream Class Type Chronic Modifier Acute PQL Units
1,4-Dioxane C C 80 HH 1 1 Ug/L
1,4-Dioxane WS C 0.35 WS 1 Ng/L
uva Ly t
� O
Asheboro i
WWTP
�p
OL - - Silk"
Asheboro
I
v r M
OW O
I
FiR
O O
Goldston-Gulf
WS-V boundary
Copy of 9595 GENERIC RPA2018_01 - 1,4-Dioxane, input
12/5/2022

REASONABLE POTENTIAL ANALYSIS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
1,4-Dioxane
Values" then "COPY"
Maximum data
points = 58
Date
Data
BDL=1/2DL
Results
7/8/2021
88.4
88.4
Std Dev.
123.1529
7/16/2021
153
153
Mean
83.7071
7/20/2021
34.2
34.2
C.V.
1.4712
7/23/2021
55.7
55.7
n
58
7/30/2021
115
115
8/6/2021
334.4
334.4
Mult Factor =
1.0000
8/13/2021
25.2
25.2
Max. Value
636.0 pg/L
8/20/2021
55.6
55.6
Max. Pred Cw
636.0 pg/L
8/27/2021
64.6
64.6
9/1/2021
58.9
58.9
9/10/2021
70.2
70.2
9/17/2021
63.9
63.9
10/1/2021
37.5
37.5
10/8/2021
44.5
44.5
10/15/2021
114
114
10/21 /2021
548
548
10/29/2021
636
636
11/19/2021
5.04
5.04
11 /22/2021
10.3
10.3
11 /5/2021
75.3
75.3
11/12/2021
3.82
3.82
11/19/2021
5.04
5.04
11 /22/2021
10.3
10.3
12/3/2021
59.7
59.7
12/10/2021
2.7
2.7
12/17/2021
11.3
11.3
12/21 /2021
2
2
1 /7/2022
102
102
1/14/2022
26.9
26.9
1 /20/2022
3.06
3.06
1 /28/2022
25.2
25.2
2/4/2022
74.7
74.7
2/11 /2022
107
107
2/18/2022
34.6
34.6
2/25/2022
133
133
3/4/2022
25
25
3/11 /2022
136
136
3/18/2022
44.3
44.3
3/25/2022
15.1
15.1
4/1/2022
46.3
46.3
4/8/2022
16.75
16.75
4/12/2022
28.7
28.7
4/22/2022
82.8
82.8
4/29/2022
11.3
11.3
5/6/2022
63.2
63.2
5/13/2022
22.8
22.8
5/20/2022
31.9
31.9
5/27/2022
135
135
6/3/2022
21.9
21.9
6/10/2022
48.5
48.5
6/17/2022
20
20
6/24/2022
144
144
7/8/2022
149
149
7/22/2022
449
449
8/5/2022
66.8
66.8
8/12/2022
33.8
33.8
9/16/2022
45.9
45.9
9/23/2022
25.9
25.9
Copy of 9595 GENERIC RPA2018_01 - 1,4-Dioxane, data
- 1 - 12/5/2022

Asheboro WWTP REASONABLE POTENTIAL ANALYSIS Outfall 001
NCO026123
Qw (MGD) =
9.0000
1Q10S (cfs) =
0.00
7QIOS (cfs) =
0.00
7Q 1 OW (cfs) =
0.00
30Q2 (cfs) =
0.20
Avg. Stream Flow,
12.00
QA (cfs) _
Hasketts
Receiving Stream:
Creek HUC
3030003
2018 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS
= 58
Qw (MGD) = 9.0000
WWTP/WTP Class:
Grade IV
1Q10S (cfs) = NO 1Q10S DATA
IWC% @ 1Q10S =
100
7Q10S (cfs) = NO 7Q10S DATA
IWC% @ 7Q10S =
100
7Q10W (cfs) = NO 7Q10w DATA
IW%C @ 7Q10W =
100
30Q2 (cfs) = NO 30Q2 DATA
IWC% @ 30Q2 =
98.5865724
Avg. Stream Flow, 846.00
IWC% @ QA =
53.7572254
QA (cfs) _
Receiving Stream: Deep River
HUC 3030003
Stream Class: C
Qw=9 MGD
WWTP/WTP Class: Grade IV
IWC% @ 1Q10S =
N/A
IWC% @ 7Q10S =
N/A
IW%C @ 7QIOW =
N/A
IWC% @ 30Q2 =
N/A
IWC% @ QA = 1.622187336
Stream Class: WS-V; HQW
PARAMETER
NC STANDARDS OR EPA CRITERIA
—j
Cn
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
Cl
�
Chronic Applied Standard Acute
n # Det. Max Pred Cw Allowable Cw
Acute: NO WQS
1,4-Dioxane
C
80 HH(Qavg)
1
µg/L
58 58
636.0
Chronic: 148.82
Less stringent than protection of
6 values > Allowable Cw
downstream water uses. Apply WS
Acute: NO WQS
1,4-Dioxane
C
0.35 WS(Qavg)
1
µg/L
58 58
636.0
Chronic: 21.58
_
RP shown apply limit with Monthly
45 values > Allowable Cw
Monitoring
Copy of 9595 GENERIC RPA2018_01 - 1,4-Dioxane, rpa
Page 1 of 1 12/5/2022

Reduction in Frequency Evalaution
Facility:
Asheboro WWTP
Permit No.
NC0026123
Review period
08/2018 - 07/2021
(use 3 yrs)
Approval Criteria: Y/N?
1. Not currently under SOC
Y
2. Not on EPA Quarterly noncompliance report
Y
3. Facility or employees convicted of CWA
violations
N
# of non
monthly Monthly
3-yr mean
# daily
# daily
Reduce
Data Review
Units
average
SOo/
(geo mean
< 50%?
200%
samples
<15?
200%
samples
< 20?
monthly
> 2?
#civil penalty
> 1?
Frequency?
average limit
limit
MA
for FC)
MA
>200%
WA
>200%
limit
asessment
(Yes/No )
violations
BOD (weighted)
mg/L
8.5
5.66667
2.8
1.8087015
Y
11.3
0
Y
0
N
0
N
Y
TSS
mg/L
45
30
15
0.6311432
Y
60
0
Y
0
N
0
N
Y
NH3 (weighted)
mg/L
4
i 1.333331
0.7
1 0.1313479
1 Y
1 2.67
1 3
Y
0
1 N
1 0
1 N
I Y
Fecal Coliform
#/100
400
1 200
1 1001
6.3818497
1 Y
800 1 0 Y
0
1 N
1 0
1 N
I Y

10/13/22 WQS = 12 ng/L
Facility Name Asheboro WWTP / NC0026123
/Permit No.
Total Mercury 1631E PQL = 0.5 ng/L
Date Modifier Data Entry Value
MERCURY WQBEL/TBEL EVALUATION V:2013-6
No Limit Required
MMP Required
7Q10s = 0.000 cfs WQBEL = 12.00 ng/L
Permitted Flow = 9.000 47 ng/L
1/11/18 < 1
0.5
2/8/18 3
3
3/8/18 1.1
1.1
4/5/18 1.2
1.2
5/3/18 2.8
2.8
6/7/18 1.6
1.6
7/12/18 1.6
1.6
8/9/18 1.2
1.2
9/13/18 3.5
3.5
10/4/18 1.8
1.8
11/8/18 1.7
1.7
12/6/18 < 1
0.5
1.7 ng/L - Annual Average for 2018
1/10/19 2.9
2.9
2/7/19 1.3
1.3
3/7/19 2.5
2.5
4/4/19 2.7
2.7
5/2/19 < 1
0.5
6/6/19 1.1
1.1
6/27/19 1.3
1.3
7/11/19 1.7
1.7
8/8/19 < 1
0.5
9/12/19 < 1
0.5
10/3/19 < 1
0.5
11/7/19 < 1
0.5
12/19/19 2.1
2.1
1.4 ng/L - Annual Average for 2019
1/9/20 1.7
1.7
2/6/20 2.3
2.3

3/5/20
2.3
2.3
4/9/20
1.5
1.5
5/7/20
<
1
0.5
6/4/20
3.3
3.3
7/9/20
2.6
2.6
8/6/20
<
1
0.5
9/17/20
1.4
1.4
10/8/20
<
1
0.5
11/5/20
1.1
1.1
12/10/20
<
1
0.5 1.5 ng/L - Annual Average for 2020
1/7/2 1
1.1
1.1
2/4/21
<
1
0.5
3/4/21
<
1
0.5
4/8/21
1.5
1.5
5/6/2 1
3.6
3.6
6/25/21
1.4
1.4
7/8/21
<
1
0.5
8/5/21
<
1
0.5
9/16/21
<
1
0.5
10/7/21
1.3
1.3
11/4/21
2.2
2.2
12/9/21
1.8
1.8 1.3 ng/L - Annual Average for 2021
1/13/22
1.4
1.4
2/3/22
1.3
1.3
3/10/22
1.8
1.8
4/7/22
<
1
0.5
5/5/22
4.6
4.6
6/9/22
<
1
0.5
7/7/22
<
1
0.5
8/4/22
1
1 1.5 ng/L - Annual Average for 2022

Asheboro WWTP / NCO026123
Mercury Data Statistics (Method 1631E)
2018
2019
2020
2021
2022
# of Samples
12
13
12
12
8
Annual Average, ng/L
1.7
1.4
1.5
1.3
1.5
Maximum Value, ng/L
3.50
2.90
3.30
3.60
4.60
TBEL, ng/L
47
WQBEL, ng/L
12.0

IWC Calculations
Facility: Asheboro WWTP
N C0026123
Prepared By: Nick Coco
Enter Design Flow (MGD): 9
Enter s7Q10 (cfs): 0
Enter w7Q10 (cfs): 0
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
0
s7Q10 (CFS)
0
DESIGN FLOW (MGD)
9
DESIGN FLOW (MGD)
9
DESIGN FLOW (CFS)
13.95
DESIGN FLOW (CFS)
13.95
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
Upstream Bkgd (ug/1)
0
Upstream Bkgd (mg/1)
0.22
IWC (%)
100.00
IWC (%)
100.00
Allowable Conc. (ug/1)
17
Allowable Conc. (mg/1)
1.0
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Fecal Coliform
w7Q10 (CFS)
0
Monthly Average Limit:
200/100mI DESIGN FLOW (MGD)
9
(If DF >331; Monitor)
DESIGN FLOW (CFS)
13.95
(If DF<331; Limit)
STREAM STD (MG/L)
1.8
Dilution Factor (DF)
1.00 Upstream Bkgd (mg/1)
0.22
IWC (%)
100.00
Allowable Conc. (mg/1)
1.8
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/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I
4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter)
5. BAT for Major Municipals: 1 mg/I (year-round)
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

NCO026123 Asheboro WWTP
BOD monthly removal rate
Month
January-18
February-18
March-18
April-18
May-18
June-18
July-18
August-18
September-18
October-18
November-18
December-18
January-19
February-19
March-19
April-19
May-19
June-19
July-19
August-19
September-19
October-19
November-19
December-19
January-20
February-20
March-20
April-20
May-20
June-20
RR (%)
97.82
97.96
97.92
98.69
99.04
99.27
99.44
99.22
98.97
98.98
98.59
98.36
98.63
98.20
98.16
98.90
99.19
99.16
99.26
99.32
99.40
99.33
99.14
98.80
98.48
97.82
98.35
98.74
98.73
99.14
Month
July-20
August-20
September-20
October-20
November-20
December-20
January-21
February-21
March-21
April-21
May-21
June-21
July-21
August-21
September-21
October-21
November-21
December-21
January-22
February-22
March-22
April-22
May-22
June-22
July-22
August-22
September-22
October-22
November-22
December-22
Overall BOD removal rate
RR (%)
99.30
99.25
99.34
99.23
99.13
98.63
98.92
98.40
98.50
98.61
98.77
99.14
99.25
99.29
99.26
99.26
99.33
99.09
98.34
98.88
98.44
98.92
99.20
99.36
99.63
99.53
98.89
10/13/2022
TSS monthly removal rate
Month
January-18
February-18
March-18
April-18
May-18
June-18
July-18
August-18
September-18
October-18
November-18
December-18
January-19
February-19
March-19
April-19
May-19
June-19
July-19
August-19
September-19
October-19
November-19
December-19
January-20
February-20
March-20
Apri I-20
May-20
June-20
RR (%)
96.47
97.29
97.50
98.24
98.71
99.07
99.43
99.30
98.20
98.02
97.53
96.89
97.09
97.45
97.45
98.31
99.03
99.16
99.25
99.35
99.36
99.24
99.11
97.42
96.59
96.13
97.04
97.57
97.33
98.36
Month
July-20
August-20
September-20
October-20
November-20
December-20
January-21
February-21
March-21
April-21
May-21
June-21
July-21
August-21
September-21
October-21
November-21
December-21
January-22
February-22
March-22
April-22
May-22
June-22
July-22
August-22
September-22
October-22
November-22
December-22
Overall TSS removal rate
RR (%)
99.02
99.04
98.89
99.01
99.01
98.44
98.73
97.50
97.74
97.96
97.72
98.60
98.75
99.22
99.03
98.79
98.20
97.81
96.50
98.15
96.85
98.36
98.79
99.27
99.44
99.44
98.21

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
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 IN 2 u 3 I NC0026123 111 121 22/05/10 I17 18 L D I 19 I s I 201
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 73 � I 74 79 I I I I I I I80
70 I I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 22/05/10
12/08/01
Asheboro WWTP
1032 Bonkemeyer Dr
Exit Time/Date
Permit Expiration Date
Asheboro NC 27203
12:OOPM 22/05/10
16/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
John N Ogburn,PO Box 1106 Asheboro NC 272041106/City
Manager/336-626-1213/3366261218 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Pretreatment
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
Patricia Lowery DWR/WSRO WQ/336-776-9691/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO026123 I11 12I 22/05/10 117 18 1 p I
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On May 10, 2022, a Pretreatment Compliance Inspection (PCI) was performed by Tricia Lowery of the
Winston-Salem Regional Office. Sarah Laughlin and Bobby Crandall was present for the inspection.
The purpose of this inspection was to determine the effectiveness of the Asheboro's pretreatment
program, which includes reviewing the files, POTW plant performance, industry monitoring data, and
adherence to the enforcement response plan (ERP).
Background
This is a 9.0 MGD permitted facility. The city has 14 Significant Industrial Users (SIUs), 7 of which are
categorical. The publicly owned treatment works (POTW) had no pretreatment related violations in
2021.
POTW Interview
There are no plant problems related to pretreatment issues. Weekly dioxane sampling with
DEQ-DWR is ongoing and conducted every Friday. No SIU's were SNC for 2021. The pretreatment
program has 33 dental offices and all in are compliance with program.
Pretreatment Program Elements Review
The Headworks Analysis (HWA) was last approved on 6/30/2017. The next HWA is due 6/1/2022.
The IWS was last approved on 5/8/2018. The next IWS is due 4/15/2023.
The Sewer Use Ordinance (SUO) was approved on 11/5/2012.
The Enforcement Response Plan (ERP) was submitted on 1/12/2020 and approved on 2/5/2020.
The Long -Term Monitoring Plan (LTMP) was submitted 2/18/2020 and approved on 5/7/2020.
LTMP File Review
The Long -Term Monitoring Plan (LTMP) is being conducted at the proper locations and frequencies
(2/year).
Industrial User Permit (IUP) File Review
A review of the file for Covanta (#5049) revealed that the monitoring data was well organized and
compliant.
A review of the file for Bossong (#0822) revealed that the monitoring data was well organized and
compliant.
A review of the file for Premier Power Coating (#3734) revealed that the monitoring data was well
organized and compliant.
The slug control plan for Covanta (#5049) was in good order.
The slug control plan for Bossong (#0822) was in good order.
The slug control plan for Premier Power Coating (#3734) was in good order.
Action Items
No other action items were noted.
Page#

Permit: NC0026123
Inspection Date: 05/10/2022
Owner -Facility: Asheboro WWTP
Inspection Type: Pretreatment Compliance
Yes No NA NE
Page#

A
B C D E F G H I J K L M
N O P
Pollutants of Concern (POC) Review Form
Version:2022.09.28
1
2
1. Facility's General Information
Date of (draft) Review
8/29/2022
c. POC review due to:
e. Contact Information
3
Date of (final) Review
8/12/2023
Municipal NPDES renewal
0
Regional Office (RO)
Winston-Salem
4
NPDES Permit Writer (pw)
Nick Coco
HWA-AT/LTMP Review
❑
RO PT Staff
Patricia Lowery
RO NPDES Staff
Alex Lowe
5
6
Perm ittee- Facility Name
Asheboro WWTP
New Industries
ElFacility
PT Staff, email
Sarah Laughlin, slaughlin(aDci.asheboro.nc.us
7
NPDES Permit Number
NCO026123
WWTP expansion
❑
f. Receiving Stream
8
NPDES Permit Effective Date
10/1/2023
Stream reclass./adjustment
❑
Outfall 1
9
Chemical Addendum Submittal Date
4/7/2022
Outfall relocation/adjustment
❑
Receiving Stream:
Hasketts Creek
QA, cfs:
12
10
NPDES Permit Public Notice Date
12/6/2022; Public Hearing on 5/23/2023
7Q10 update
❑
Stream Class
C
7Q10 (S), cfs:
0
11
eDMR data evaluated from:
1/1/2018
to
6/1/2022
Other POC review trigger, explain:
Oufall Lat.
34.46.00
Outfall Long.
79.47.06
12
a. WWTP Capacity Summary
Outfall II
13
Current Permitted Flow, mgd
Designed Flow,
9.0
Receiving Stream:
QA, cfs:
mgd
14
Permitted SIU Flow, mgd
u.112
d. IU Summary
Stream Class
7Q10, cfs:
15
b. PT Docs. Summary
# IUs
Oufall Lat.
Outfall Long.
16
IWS approval date
5/8/2018
# SIUs
Is there a PWS intake downstream of the Facility's Outfall(s)?
❑r YES ❑ NO
17
L/STMP approval date:
5/7/2020
# CIUs
Comments:
18
HWA-AT approval date
6/30/2017
# NSCIUs
The nearest downstream water supply (WS-V) boundary is located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles downstream
# IUs w/Local
14
Permits or Other
of the outfall
19
ITypes
20
2. Industrial Users' Information.
21
#
Industrial User (IU) Name
IU Activity
IU Non Conventional Pollutans & Toxic Pollutant
IUP Effective Date
1
Bossong Hoisery Mill Inc.
SIC 2253
pH, COD, Chromium
7/30/2022
22
i
2
Covanta Environmental Solutions
40 CFR 437
pH, COD, TKN, O&G, Antimony, Arsenic, Cadmium, Chromium, Cobalt, Copper, Lead, Mercury, Nickel, Silver, Tin, Thalium, Vanadium, Zinc,
7/30/2022
23
'E
Bis (2ethylhexyl) phthalate, Carbazole, o-Cresol, p-Cresol, n-Decane, Fluoranthene, n-Octadecane, 2,4,5-Trichlorophenol
iv
3
Energizer Manufacturing Plant 1
SIC 3692
pH, COD, TKN, Mercury, Nickel (plant responsible for washing of batteries and battery parts)
7/30/2022
24
d
w4
Energizer Manufacturing Plant 2
SIC 3692
Chromium, Cyanide, Manganese, Mercury, Nickel, Silver, Zinc (plant responsible for battery manufacturing)
7/30/2022
25
0-
z
5
Georgia-Pacific Corrugated LLC
SIC 2653
pH, COD
7/30/2022
26
6
Great Oak Landfill
40 CFR 403
pH, COD, TKN, Cyanide, Chloride, Antimony, Arsenic, Cadmium, Cobalt, Chromium, Copper, Lead, Mercury, Manganese, Molybdenum, Nickel,
6/22/2021
27
Selenium, Silver, Tin, Titanium, Vanadium, Zinc, various others (see IUP)
7
—ayser Roth
SIC 2252
pH, COD, Copper
7/30/2022
28
8
Matlab Plant 4
SIC 3479
pH, COD, Cadmium, Chromium, Copper, Cyanide, Lead, Nickel, Silver, Zinc, TTO
7/30/2022
29
9
Matlab Plant 5
SIC 3479
pH, COD, Cadmium, Chromium, Copper, Cyanide, Lead, Nickel, Silver, Zinc, TTO
9/30/2022
30
10
Matlab Plant 8
SIC 3479
pH, COD, Cadmium, Chromium, Copper, Cyanide, Lead, Nickel, Silver, Zinc, TTO
9/30/2022
31
11
MOM Brands
SIC 2043
pH, COD
7/30/2022
32
12
Premier Powder Coating
SIC 3479
pH, COD, Cadmium, Chromium, Copper, Cyanide, Lead, Nickel, Silver, Zinc, TTO
7/30/2022
33
13
Randolph Packing
SIC 2011
pH, COD, TKN, Zinc
7/30/2022
34
14
Starpet Inc.
40 CFR 414.4
pH, COD, Cyanide, Lead, Zinc, various others - note 1,4-Dioxane is not in the IUP, but is sampled
7/30/2022
35
Comment:
Recommend adding 1,4-Dioxane to Great Oak Landfill and Starpet pollutant list
40
41
3. Status of Pretreatment Program (check all that apply)
42
Status of Pretreatment Program (check all that apply)
43
❑
1) facility has no SIUs, does have Division approved Pretreatment Program that is INACTIVE
44
❑
2) facility has no SIUs, does not have Division approved Pretreatment Program
45
p
3) facility has SIUs and DWQ approved Pretreatment Program
46
p
3a) Full Program with LTMP
47
❑
3b) Modified Program with STMP
48
❑
4) additional conditions regarding Pretreatment attached or listed below
49
❑
5) facility's sludge is being land applied or composted
50
❑
6) facility's sludge is incinerated (add Beryllium and Mercury sampling according to § 503.43)
51
❑
7) facility's sludge is taken to a landfill, if yes which landfill:
52
❑
8) other
53
Sludge Disposal Plan:
Land Application
54
55
Sludge Permit No:
WQ0001684
56
Page 1 POC Review Form

A
B C D E F G H I I J I K I L M N O P
57
4. LTMP/STMP and HWA Review
58
PW: Find L/STMP document, HWA spreadsheet, DMR, previous and new NPDES permit for next section.
59
a
Cn Cn
c
U
a
Parameter of Concern
(POC) Check List
New
NPDES
POC
Previous
NPDES
POC
Required by
EPA PT(1)
POC due to
Sludge (2)
POC due to
SIU (3)
POTW
POC (4)
%
Removal
Rate
L/STMP
Effluent Freq.
NPDES
Effluent Freq.
PQLs review
Comment
60
PQL from
L/STMP, ug/I
Required PQL
per NPDES
permit
Recomm.
PQL, ug/I
61
❑�
Flow
❑J
ID❑✓
❑
Monthly
Continuous
62
❑✓
BOD
❑r
0
❑
Monthly
Daily
63
0
TSS
❑�
❑J
D
❑
Monthly
Daily
64
❑r
NH3
0
❑J
❑
Monthly
Daily
65
0
Arsenic
❑
❑
0
0
❑
Monthly
2.0
66
❑
Barium
❑
❑
❑
0
❑
Monthly
67
p
Beryllium(5)
❑
❑
0
❑
❑
Monthly
68
0
Cadmium(1)
❑
❑
0
0
0
❑
Monthly
0.5
69
0
Chromium(1)
❑
0
0
0
0
❑
Monthly
5.0
70
0
Copper(l)
❑
0
0
0
ID
❑
Monthly
Quarterly
2.0
71
0
Cyanide
❑
❑
❑
0
❑
Monthly
72
❑p
Lead(1)
❑
❑
0
0
0
❑
Monthly
2.0
73
p
Mercury(5)
❑
p
p
p
❑
Monthly
0.001
74
p
Molybdenum
❑
❑
p
❑
❑
Monthly
10.0
75
0
Nickel(1)
❑
❑
0
0
❑r
❑
Monthly
76
0
Selenium
❑✓
❑
0
0
❑
Monthly
Quarterly
1 ug/L
1.0
77
0
Silver
0
❑
❑
0
❑
Monthly
Monthly
1 ug/L
1.0
78
p
Zinc(1)
❑
❑
Monthly
10.0
79
0
Sludge Flow to Disposal
p
❑
❑
Monthly
80
p
% Solids to Disposal
p
❑
❑
Monthly
81
❑
Oil & Grease
❑
❑
Monthly
82
ITN
❑
❑
❑
❑
Monthly
83
❑
TP
❑
❑
❑
❑
Monthly
84
❑
PFAS 1633
0
❑
❑
❑
Monthly
Quarterly
85
❑
1,4 Dioxane
0
0
❑
❑
1/Week
1 ug/L
86
p
Manganese
❑
❑
❑
0
❑
Monthly
87
❑�
Chlorides
0
❑
❑
❑
Quarterly
88
❑
I
❑
❑
❑
89
❑
❑
❑
❑
❑
90
❑
❑
❑
❑
❑
91
Footnotes:
92
(1) Always in the LTMP/STMP due to EPA -PT requirement
93
(2) Only in LTMP/STMP if listed in sludge permit
94
(3) Only in LTMP/STMP while SIU still discharges to POTW
95
(4) Only in LTMP/STMP when pollutant is of concern to POTW
96
(5) In LTMP/STMP, if sewage sludge is incinerated
97
allillPlaaso
use blue font for the info updated by pw
98
Please use red font for POC that need to be added/modified in USTMP sampling plan
99
Please font for POC that be from LISTMP POG Iffistis
use orange and strikethrough may removed
100
Blue shaded cell (D60: H81): Parameters usually included under that POC list
=15.
Facility Summary/background information/NPDES-PT regulatory action:
Comments
POC to be added/modified in L/STMP:
i
F
101
102
103
ORC's comments on IU/POC:
104
POC submitted through Chemical
Addendum or Supplemental Chemical
Datasheet:
105
Additional pollutants added to L/STMP due
to POTW s concerns:
106
NPDES pw's comments on IU/POC:
107
6. Pretreatment updates in response to NPDES permit renewal
108
NPDES Permit Effective Date
10/1/2023
180 days after effective (date):
3/29/2024
Permit writer, please add list of required/recommended PT updates in NPDES permit cover letter.
Page 2 POC Review Form

Whole Effluent Toxicity Testing and Self Monitoring Summary
Arclin USA Inc.
NC0000892/001
County:
Chatham
Region:
RRO
Basin:
CPF07
Feb May Aug Nov
Ceri7dPF
Begin:
7/1/2013
chr lim: 0.39%
+
NonComp: Single
7Q10:
40.0
PF: 0.10
IWC:
0.39 Freq: Q
J
F M
A M
J
J
A
S
O
2018
-
Pass -
- Pass
-
-
Pass
Pass
-
-
2019
-
Pass -
- Pass
-
-
Pass
-
-
2020
-
Pass -
- Pass
-
-
Pass
-
-
2021
-
Pass -
- Pass
-
-
Pass
-
-
2022
-
Pass -
- Pass
-
-
-
-
-
Ardagh Glass
NCO083038/001
County:
Vance
Region:
RRO
Basin:
TAR02
Fthd24Ac
Begin:
5/1/2015
ANNUAL: 24hr LC50
NonComp:
7Q10:
0
PF: 0.50
IWC:
100.0 Freq: A
J
F M
A M
J
J
A
S
O
2018
H
2020
-
- -
- -
H
-
-
-
-
2021
-
- -
- -
H
-
-
-
-
2022
-
- -
- -
H
-
-
-
-
Asheboro WWTP
NCO026123/001
County:
Randolph
Region:
WSRO
Basin:
CPF09
Mar Jun Sep Dec
Ceri7dPF
Begin:
8/1/2012
chr lim: 90%
NonComp: Single
7Q10:
0.0
PF: 9.0
IWC:
100 Freq: Q
J
F M
A M
J
J
A
S
O
2018
-
- Pass
- -
Pass
-
-
>100(P) Pass
-
2019
-
- Pass
- -
Pass
-
-
Pass
-
2020
-
- Pass >100(P)
- -
Pass
-
-
Pass
-
2021
-
- Pass
- -
Pass >100(P)
-
-
Pass
-
2022
-
- Pass
- -
Pass
-
-
-
-
Asheville DeBruhl WTP
NCO056961/001
County:
Buncombe
Region:
ARO
Basin:
FRB02
Jan Apr Jul Oct
Ceri7dPF
Begin:
4/11/2017 chr monit: 29% (Grab
NonComp: Single
70.10:
1.1
PF: 0.1
IWC:
12.3 Freq: Q
J
F M
A M
J
J
A
S
O
2018
Pass
- -
Pass -
-
Pass
-
-
Pass
2019
Pass
- -
Pass -
-
Pass
-
-
Pass
2020
Pass
- -
Pass -
-
Pass
-
-
Pass
2021
Pass
- -
Pass -
-
Pass
-
-
Pass
2022
Pass
- -
Pass -
-
Pass
-
-
-
Asheville Northfork WTP NCO035807/001 County: Buncombe
Ceri7dPF Begin: 4/1/2017 chr Monit: 22% NonComp: Single
J F M A M
2018 Pass - - Pass -
2019 Pass - - Pass -
2020 Pass - - Pass -
2021 Pass - - Pass -
2022 Pass - - Pass -
SOC JOC:
N
Pass
Pass
Pass
Pass
SOC JOC:
N
SOC JOC:
N
SOC JOC:
N
Region: ARO Basin: FRB02 Jan Apr Jul Oct SOC JOC:
70.10: 1.7 PF: 0.8 IWC: 42.2 Freq: Q
J J A S O N
- Pass - - Pass -
Pass - - Pass -
- Pass - - Pass -
- Pass - - Pass -
Pass
C
C
D
Pass
Pass >100(P)
Pass
Pass
C
IU
LeEend: P= Fathead minnow (Pimohales oromelas). H=No Flow (facilitv is active). s = Split test between Certified Labs Page 5 of 117

NORTH CAROLINA 2022 INTEGRATED REPORT
Deep Cape Fear River Basin
AU Name AU Number Classification AU LengthArea AU Units
AU ID Description
DEEP RIVER 17-(10.5)b
4126 From US 220 business to Subbasin 03-06-08 and 03-06-09 boundary
2022 Water Quality Assessments
PARAMETER IR CATEGORY
Water Temperature (32°C, AL, LP&CP) 1
Dissolved Oxygen (4 mg/I, AL, FW) 1
pH (6 su, AL, FW) 1
pH (9.0, AL, FW) 1
Turbidity (50 NTU, AL, FW miles) 1
Chloride (230 mg/I, AL, FW) 3a
Flouride (1.8 mg/I, AL, FW) 3a
1,4-Dioxane in Water (80 µg/I, AL, FW) 3a
Fecal Coliform (GM 200/400, REC, FW) 3a
)EEP RIVER
4128 From Haskett Creek to Gabriels Creek
2022 Water Quality Assessments
PARAMETER
Water Temperature (322C, AL, LP&CP)
Dissolved Oxygen (4 mg/I, AL, FW)
pH (6 su, AL, FW)
pH (9.0, AL, FW)
Turbidity (50 NTU, AL, FW miles)
Fecal Coliform (GM 200/400, REC, FW)
Chlorophyll a (40 µg/I, AL, NC)
17-(10.5)d1 `
2.2 FW Miles
CRITERIA STATUS
Meeting Criteria
Meeting Criteria
Meeting Criteria
Meeting Criteria
Meeting Criteria
Data Inconclusive
Data Inconclusive
Data Inconclusive
Data Inconclusive
2.7 FW Miles
I:MKIN lcfe1.1t el1.1k14:I/_11142 r_Al01i
1
Meeting Criteria
1
Meeting Criteria
1
Meeting Criteria
1
Meeting Criteria
1
Meeting Criteria
3a
Data Inconclusive
5
Exceeding Criteria
6/7/2022 NC 2022 INTEGRATED REPORT -Category 5 Approved by EPA 4/30/2022 Page 108 of 1346

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
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 IN 1 2 u 3 I NCO026123 111 121 22/01/27 I17 18 LC] I 19 I s I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I n, I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:30AM 22/01/27
12/08/01
Asheboro WWTP
1032 Bonkemeyer Dr
Exit Time/Date
Permit Expiration Date
Asheboro NC 27203
12:10PM 22/01/27
16/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
John N Ogburn,PO Box 1106 Asheboro NC 272041106/City
Manager/336-626-1213/3366261218 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar 0 Records/Reports
Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Alex Lowe DWR/WSRO WQ/336-776-9689/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO026123 I11 12I 22/01 /27 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On January 27, 2022, Alex Lowe of the WSRO conducted a routine Compliance Evalauation
Inspection at the City of Asheboro WWTP. ORC Mike Wiseman was present throughout the
inspection.
In the interview with Mr. Wiseman, the state of the POTWs permit was discussed. A current permit is
in administrative review, but is awaiting the results of the Cape Fear study.
A review of three randomly chosen months of laboratory data and DMR submissions found all data to
be properly reported. The POTW permit is currently expired, and the renewal application is under
administrative review. It is not expected to be approved until the completion of the Cape Fear study
on emerging contaminants.
A tour of the facility with Mr. Wiseman demonstrated a well -maintained system, and no operational
issues were uncovered. With influent flows of only 33%-50% of maximum design rate, proper steps
are being made to ensure retention time and thorough treatment are being achieved.
This facility was found to be in permit compliance.
Page#

Permit: NCO026123
Inspection Date: 01/27/2022
Owner -Facility: Asheboro WWTP
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment: Permit awaiting results from the Cape Fear study. Permit renewal underway.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Yes No NA NE
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
El
El
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
Comment: All DMRs and lab data kept for at least five years (observed folders dated back to
2012). Random spot checks of DMRs and laboratory results for three months in 2021
demonstrates accurate reporting of effluent parameters.
Page# 3

Permit: NCO026123 Owner -Facility: Asheboro WWTP
Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Grit Removal
Yes
No
NA
NE
Type of grit removal
a.Manual
❑
b.Mechanical
Is the grit free of excessive organic matter?
0
❑
❑
❑
Is the grit free of excessive odor?
■
❑
❑
❑
# Is disposal of grit in compliance?
0
❑
❑
❑
Comment: Grit removal by vortex
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
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?
0
❑
❑
❑
Comment: Temperature of auto sampler kept below 6 C. Temperature reading
last calibrated
March 12, 2021.
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Yes No NA NE
❑ ❑ ❑
❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page# 4

Permit: NC0026123
Inspection Date: 01/27/2022
Owner -Facility: Asheboro WWTP
Inspection Type: Compliance Evaluation
Equalization Basins
Yes
No
NA
NE
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Are audible and visual alarms operable?
0
❑
❑
❑
# Is basin size/volume adequate?
0
❑
❑
❑
Comment:
Primary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
❑
❑
❑
Comment:
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
❑
❑
❑
Comment: Three final clarifiers on site, only two running to increase retention time.
Page# 5

Permit: NCO026123 Owner -Facility: Asheboro WWTP
Inspection Date: 01/27/2022 Inspection Type: Compliance Evaluation
Trickling Filter
Yes
No
NA
NE
Is the filter free of ponding?
0
❑
❑
❑
Is the filter free of leaks at the center column of filter's distribution arms?
0
❑
❑
❑
Is the distribution of flow even from the distribution arms?
0
❑
❑
❑
Is the filter free of uneven or discolored growth?
0
❑
❑
❑
Is the filter free of sloughing of excessive growth?
0
❑
❑
❑
Are the filter's distribution arms orifices free of clogging?
0
❑
❑
❑
Is the filter free of excessive filter flies, worms or snails?
0
❑
❑
❑
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
❑
❑
❑
Are surface aerators and mixers operational?
E
❑
❑
❑
Are the diffusers operational?
0
❑
❑
❑
Is the foam the proper color for the treatment process?
0
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
Comment: Three 40 HP blowers on site for each aeration tank. All in working order at time of
inspection.
Disinfection -Liquid
Yes
No
NA
NE
Is there adequate reserve supply of disinfectant?
❑
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
❑
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
❑
❑
❑
❑
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?
❑
❑
❑
❑
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑
Page# 6

Permit: NCO026123
Inspection Date: 01/27/2022
Effluent Pipe
Owner -Facility: Asheboro WWTP
Inspection Type: Compliance Evaluation
If effluent (diffuser pipes are required) are they operating properly?
Comment: Flow over steps to aerate. No residual foaming 150 feet downstream.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment:
Flow Measurement - Effluent
# 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?
Comment: Ultrasonic flow meter used as primary effluent flow recorder.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Yes No NA NE
■ ❑ ❑ ❑
Yes
No
NA
NE
■
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
Yes
No
NA
NE
❑
❑
❑
❑
❑
❑
Page# 7

9/8/2021
Mail - Perlmutter, Gary - Outlook
USGS response to DWR USGS Low Flows request # 2021-145 (dated 2021/08/13) for Deep River Moore County... RE: [EXTERNAL] Low -
flow request approval
Weaver, John C <[e-mail]>
Wed 9/8/2021 11:29 AM
To: Perlmutter, Gary <[e-mail]>
Cc: Hill, David A <[e-mail]>; Kebede, Adugna <[e-mail]>; Montebello, Michael J <[e-mail]>; Dowden, Doug
<[e-mail]>; Albertin, Klaus P <[e-mail]>; Weaver, John C <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam.
Gary,
In response to your inquiry about the low -flow characteristics for a location on the Deep River adjacent to the end of NC Secondary Road 1617 (Trivett Road) near
Glendon in northeast Moore County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (SAWSC, Raleigh office) does not indicate a previous low -flow determination
for the point of interest, identified by the adjusted lat/long coordinates (35.48437,-79.44746) associated with the email dated 08/13/2021 from the DWR USGS
Low Flow portal following your request submission.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at ungaged locations would be determined
by assessing a range in the low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby sites where estimates have previously been
determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina (https://streamstats.usga.ggy ss) indicates the drainage area for
the point of interest (StreamStats adjusted coordinates 35.48437,-79.44747 NAD83) is 853 sgmi, which confirms the drainage area submitted as part of the
request information.
For the record:
(1) The low -flow estimates provided below are patterned after an identical approach used earlier this year to respond (via emails dated February 23, 2021) to two
separate low -flow requests (#108 and #110) for the Deep River.
(2) The low -flow estimates provided below do not account for the presence of the upstream High Falls dam and the impounded reach on the Deep River
upstream from this dam. Please be aware the USGS techniques used to provide estimated low -flow discharges for streams and rivers are not applicable to
impounded reaches. The estimated low -flow discharges would not be meaningful for impounded reaches where the storage characteristics and circulation
patterns of the impoundment are additional components of the flow dynamics within these streams and rivers.
For streams in northern Moore County, low -flow characteristics published by the USGS are provided in the following reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow characteristics of streams in North Carolina" (Giese and
Mason, 1993). An online version of the report is available at httpjlpiLbs.usgs.gov/wsp/2403/r port.pd . The report provides the low -flow characteristics (based on
data through 1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sgmi and not considered or known to be affected by
regulation and/or diversions.
(2) The second is a basin -wide report for the Cape Fear River basin published in 2001. It is USGS Water -Resources Investigations Report 01-4094, "Low -flow
characteristics and discharge profiles for selected streams in the Cape Fear River Basin, North Carolina, through 1998 " (Weaver and Pope, 2001). An online version of
the report is available through httpl nc.water.usgs.gov/reports/wriOl4O94 . The report provides the low -flow characteristics (based on data through 1998) for
continuous -record gaging stations and partial -record sites within the Cape Fear River basin. The report also provides low -flow discharge profiles (7Q10, 30Q2, winter
7Q10, and 7Q2) for the Cape Fear River and selected tributaries within the basin.
(3) The third is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001, "Low -flow characteristics and flow -duration statistics
for selected USGS continuous -record streamgaging stations in North Carolina through 2012" (Weaver, 2015). The report is available online at
http.1pubs.usga.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration statistics for 266 active (as of 2012 water year) and
discontinued streamgages across the state where a minimum of 10 climatic years discharge records were available for flow analyses.
Low -flow characteristics estimated for point of interest:
The USGS SAWSC currently operates two streamgages on the Deep River having long-term continuous records of discharge. The upstream active streamgage is on the
Deep River at Ramseur in Randolph County (station id 02100500, drainage area 349 sgmi) with discharge records dating back to the 1923 water year. The downstream
active streamgage is on the Deep River at Moncure in Lee County (station id 02102000, drainage area 1,434 sqmi) with discharge records dating back to the 1930 water
year.
The USGS also operated a discontinued continuous -record streamgage from July 1993 through September 1996 on the Deep River near Glendon in Lee County (station
id 0210106600, drainage area 859 sgmi). Because of the short-term record available for this site, low -flow techniques applicable to continuous -record streamgages with
a minimum of 10 climatic years record cannot be applied to this streamgage. However, low -flow techniques applicable to partial -record sites are applicable to this
streamgage. A MOVE.1 analysis (Helsel and Hirsch, USGS Techniques and Methods 4-A3, published 2020) can be completed for a correlation between two streamgages,
in which discharge records at the short-term site are correlated with the discharge records at the long-term streamgage.
(a) Two MOVE.1 analyses were completed. The first analysis correlated the daily mean discharges for July 1993 through September 1996 between the Ramseur and
Glendon streamgages (correlation coefficient 0.9). The second analysis correlated the daily mean discharges for the same period between the Glendon and Moncure
streamgages (correlation coefficient 0.963).
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9/8/2021
Mail - Perlmutter, Gary - Outlook
(b) Using the published low -flow characteristics (Weaver, 2015) at the Ramseur and Moncure streamgages, each of the MOVE.1 equations were used to compute the
estimated low -flow characteristics for the discontinued Glendon streamgage. Using the respective drainage areas at the three streamgages, the equivalent low -flow
yields (cfsm) were then determined for the low -flow characteristics at the three streamgages. For the discontinued Glendon streamgage, the final provisional unit low -
flow yields were averaged from the two separate MOVE.1 analysis results.
(c) The unit low -flow yields for the point of interest were then pro -rated on the basis of drainage area between the average yields at the discontinued Glendon
streamgage and yields for the upstream Ramseur streamgage.
(d) The drainage area for the point of interest (853 sqmi) was then applied to pro -rated low -flow yields to determine the estimated low -flow discharges (in cubic feet per
second, or cfs). The resulting low -flow discharges estimated for the point of interest are as follows:
Annual 7Q10 discharge = 19.5 cfs (equivalent to 0.0228 cfs per sqmi)
Annual 30Q2 discharge = 78.2 cfs (equivalent to 0.0917 cfs per sqmi)
Winter 7Q10 discharge = 39.3 cfs (equivalent to 0.0461 cfs per sqmi)
Annual 7Q10 discharge = 50.0 cfs (equivalent to 0.0586 cfs per sqmi)
NOTE: Given the close proximity of the point of interest (853 sqmi) to the downstream discontinued continuous -record streamgage near Glendon (859 sqmi), the above
estimated low -flow characteristics are practically identical to the low -flow characteristics determined for the streamgage.
Reference table for above -described analysis steps:
USGS station
Drainage area
(sqmi)
7Q10
(cfs)
7Q10 (cfsm)
30Q2
(cfs)
30Q2
(cfsm)
W7Q10
(cfs)
W7Q10
(cfsm)
7Q2
(cfs)
7Q2
(cfsm)
Comment
02100500
349
13
0.0372
46
0.1318
26
0.0745
30
0.0860
USGS SIR 2015-5001 (Weave
Point of interest
853
19.5
0.0228
78.2
0.0917
39.3
0.0461
50.0
0.0586
Low -flow yields pro -rated by
0210106600
859
19.5
0.0227
80.4
0.0936
42.4
0.0494
49.8
0.0580
Based on MOVE.1 analysis u:
0210106600
859
19.4
0.0226
76.3
0.0888
36.2
0.0421
50.3
0.0586
Based on MOVE.1 analysis u:
Average
19.5
0.0226
78.4
0.0912
39.3
0.0458
50.1
0.0583
For the average annual discharge, an average unit flow was determined for the mean daily discharges published in Table 5 on page 77 of USGS SIR 2015-5001 for the six
sites within the Deep River basin (site index numbers 192, 193, 196, 197, 200, 202, and 203). The average unit flow was computed to be 0.9914 cfs per sqmi drainage
area.
Average annual discharge = 846 cfs (equivalent to 0.9914 cfs per sqmi)
Please note:
(1) The estimated flows are provided in units of cubic feet per second (cfs).
(2) The information provided in this message is based on a preliminary assessment and considered provisional, subject to revision pending collection of future
data and further analyses.
These provisional streamflow statistics are provided via the DWR USGS Low Flows cooperative agreement between the USGS and the N.C. Department of
Environmental Quality, Division of Water Resources.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email: [e-mail]
USGS South Atlantic Water Science Center Online: https://www.usgs.gov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]
From: Albertin, Klaus P <[e-mail]>
Sent: Friday, August 13, 2021 10:27 AM
To: Perlmutter, Gary <[e-mail]>
Cc: Albertin, Klaus P <[e-mail]>; Hill, David A <[e-mail]>; adugna.kebede@ncdenrgov; Weaver, John C <[e-mail]>; Montebello,
https://outlook.office365.com/mail/inbox/id/AAQkADRjNGZkNGYwLWNjOTctNGQ4MS1 hZDQ3LWJjMGMOYmRiN2M3NwAQADGLyKwk3UB4v%2FIR... 2/3

9/8/2021 Mail - Perlmutter, Gary - Outlook
Michael J <[e-mail]>; Dowden, Doug <[e-mail]>
Subject: [EXTERNAL] Low -flow request approval
This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding.
Your request has been approved and will be forwarded to USGS. A response from USGS usually takes 7 - 10 business days.
Request Flow Statistic Approval
Request ID: 145
Requestor: Gary Perlmutter
Requestor e-mail: g2ry.perlmutter(o)ncdenr.gov
Requestor Phone: [phone]
Local Government:
Public Water Supply:
Consultant:
Contact:
Reason: Permit
River/Stream: Deep River
Drainage Area (sq. mi.): 853
Latitude: 35.48437
Longitude:-79.44746
Other Information:
Statististics: [" 7Q10","30Q2","Average Annual"," 7Q10 - Winter"]
Approved by: Dowden, Doug
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Asheboro WWTP (NCO026123) Public Comments and Responses
Comments to the draft Asheboro WWTP NPDES permit (NCO026123) were received from the City of
Asheboro, dated 5/31/2018. Comments and responses are below:
• Comment: "The WWTP staff requested mass based limits for ammonia in lieu of concentration
based limits during the March 29, 2018 meeting at the WWTP [site visit]. Upon review of
historical data, mass based limits are attainable. What was the rationale for not using mass
based limits in the draft permit? Asheboro is requesting a three year compliance schedule to
research alternative treatment options that will allow for consistent compliance if mass based
limits are not allowed. "
Response: Concentration -based limits are in the permit because EPA water quality criteria for
ammonia (i.e., 1.0 mg/L summer, 1.8 mg/L winter) are expressed as concentrations, not mass, and
are based on concentration -based toxicity studies. An updated review of effluent data shows that
the Asheboro WWTP has not reported a weekly average or monthly average ammonia
concentration that is greater than the proposed limits since January 2018. As the facility is
consistently meeting the proposed limitations, a compliance schedule does not appear necessary
and has not been added to the permit.
• Comment: "Chloride has consistently been sampled in conjunction with Toxicity testing in
previous permit cycles. Asheboro has never failed toxicity based on the chronic results and has
had an excellent track record for passing toxicity testing. Explain what factors, data and
calculations the Reasonable Potential Analysis are based on and confirm how this number is
obtained. "
Response: The RPA was conducted on 15 sample concentrations ranging from 68 to 300 mg/L,
collected from March 2014 — December 2017. The RPA results showed that the chloride standard
of 230 mg/L could be violated with a maximum predicted value of 351 mg/L. However, since
Asheboro is passing toxicity tests, only monitoring is required. This is consistent with 15A
NCAC 02B .0211 (22): If chloride is determined by the waste load allocation to be exceeded in a
receiving water by a discharge under the specified 7Q 10 criterion for toxic substances, the
discharger shall monitor the chemical or biological effects of the discharge - Monitoring will be
maintained in conjunction with toxicity tests. Asheboro should use this permit cycle as an
opportunity to assess sources of chloride and how it can reduce this pollutant so that the allowable
discharge concentration can be achieved in the next permit cycle.
Comment: "Staff reviewed historical influent and effluent data for Cyanide collected since 2010.
During this time no samples ever resulted in above detect for the influent. However, a period of
seven days in September of 2015, three effluent samples resulted in a detection of cyanide. Upon
review of the lab bench sheets, the data indicates that there was an interference with the test
method in these samples and therefore these data points should have not been used or reported. A
copy of relevant bench sheets are attached with this correspondence. All samples collected from
March 2, 2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects
<O.Ol mg/L (one was <0.005mg/L). The maximum data point used to show reasonable potential
for cyanide should not be considered in light of this interference as it is not an accurate reflection
of Asheboro WWTP effluent. Asheboro requests the limit and monitoring requirements for
cyanide be removed. "
Response: A Reasonable Potential Analysis review has been conducted based on the last 4.5
years of effluent data (March 2018 — June 2022). Based on the reasonable potential analysis
(RPA) showing no reasonable potential to violate state water quality standards, total cyanide
limits and monitoring requirements have not been added to the permit.
Page 1 of 4

Asheboro WWTP (NC0026123) Public Comments and Responses
Comment: `Asheboro Staff is actively exploring alternatives in how to meet the new
boromodichloromethane limit. We would like to request a two year compliance schedule to
evaluate our disinfection process and determine how to effectively reduce our
bromodichloromethane concentrations but continue to properly disinfect the wastewater in order
to continue to protect the stream end environment. "
Response: The City informed the Division via email notification on 11/29/2022 that a
bromodichloromethane compliance schedule is no longer requested.
Comment: `Asheboro staff is aware of the concern associated with 1,4 dioxane and will be able
to comply with the terms of the three year compliance schedule. However, Asheboro is not
inclined to regulate an industry that may be discharging 1,4 dioxane based on the inconclusive
data regarding the health effects of this parameter and the lack of enforceable stream standards.
We feel identifying the sources of this contaminant is crucial. However, any sources found should
have ample opportunity to provide options of reducing or eliminating the contaminant while
properly budgeting funds which are anticipated to be substantial. Asheboro believes after the
sources are identified, then a set of standards should be developed and limits applied. Staff would
like an explanation of the legal basis and calculations for the 149 ,ug/L limit in this draft permit. "
Response:
Division regulations applicable to 1,4-Dioxane limitations:
15A NCAC 02B .0206(a)(4)(B) identifies that for the flow design criteria for effluent limitations,
the average annual flow for toxic substances shall be used to protect human health.
15A NCAC 02B .0208(a)(2)(B) identifies for carcinogens, an unacceptable exposed risk level is
1 X 10-6 or greater.
15A NCAC 02B .0216(4)(d) Fresh Surface Water Quality Standards for Class WS-IV Waters
identifies that no discharge of sewage "...shall be allowed that have an adverse effect on human
health or that are not treated in accordance with the permit or other requirements established by
the Division..."
The previously identified allowable discharge concentration of 149 µg/L for 1,4-Dioxane was
based on a Reasonable Potential Analysis for the human health criterion of 80 µg/L in non -water
supply waters. The non-WS criterion was based on a calculated 1 in 1,000,000 cancer risk from
fish consumption per 15A NCAC 02B .0208.
1,4-dioxane is completely miscible in water and resistant to biodegradation. It is assumed that
concentrations of 1,4-dioxane discharged from the WWTP will be equivalent at the direct
discharge to Hasketts Creek, a class C waterbody, and the nearest downstream water supply (WS-
V) boundary, located in the Deep River 1.0 mile upstream of Tysons Creek and 43.5 miles
downstream of the outfall. As such, in this reevaluation, allowable discharge concentrations were
calculated for both the direct discharge to Class C Hasketts Creek and for the nearest downstream
water supply (WS-V) boundary, and the more restrictive concentration was selected for
protection of downstream uses. The water supply boundary is for the Deep River (Gulf-
Goldston) water supply watershed, whose water supply intake is currently inactive. Each
allowable discharge concentration was calculated considering the applicable receiving stream's
Average Annual Flow (AAF), appropriate Instream Target Value (ITV) and the facility's
permitted design flow.
Page 2 of 4

Asheboro WWTP (NC0026123) Public Comments and Responses
For the direct discharge to Class C Hasketts Creek, an ITV of 80 µg/L for non -water supply
waters at an AAF of 12 cfs and a permitted design flow of 9.0 MGD (13.95 cfs) was considered.
This calculation yielded a chronic allowable discharge concentration of 149 µg/L. When
considering the downstream WS-V waters, a 1 X 10-6 risk level ITV of 0.35 µg/L for water supply
waters at an AAF of 846 cfs (calculation estimated by USGS for WS-V boundary of Gulf-
Goldston WS watershed) and a permitted design flow of 9.0 MGD (13.95 cfs) was considered.
This calculation yielded a chronic allowable concentration of 21.58 µg/L. The allowable
discharge determination based on direct discharge to Class C Hasketts Creek is insufficiently
protective of downstream water supply uses. As such, the chronic allowable discharge
concentration of 21.58 µg/L has been used in determination of permitting actions.
Based on a review of the effluent data, the WWTP demonstrates a reasonable potential to exceed
both the EPA drinking water heath advisory (HAL) of 35 µg/L and the state water supply
Instream Target Value (WS ITV) of 0.35 µg/L for 1,4-Dioxane at the nearest downstream water
supply boundary. As the reported effluent concentrations of 1,4-dioxane are greater than 35 µg/L,
the facility discharges to non-WS waters with downstream WS waters, and reasonable potential to
exceed applicable ITV at downstream WS boundary has been demonstrated. As such, weekly
monitoring and limits have been added to the permit. Recognizing that 1,4-Dioxane is an
emerging contaminant and industrial users are just now understanding its impact and use in
materials, a phased implementation compliance schedule has been included in the permit. Please
see the fact sheet for additional information regarding 1,4-dioxane permitting actions.
Comment: "Staff has discovered a NPDES permit issued to DAK Americas (permit # NC0003719
— included with this correspondence) dated March 20, 2018 in the Cape Fear River Basin —
direct discharge to the Cape Fear River. This industry has the potential to be a significant
discharger of 1,4 dioxane based on their manufacturing process as well as toxic review inventory
submitted annually to EPA. This industry is only required to monitor annually and report
according to the newly issued permit. This appears to be a discrepancy and Asheboro staff does
not understand the difference in permit requirements Staff feels if we are held to this standard
then it should be included in the reasonable potential analysis for all state issued permits and all
permit holders should be held to the same set of standards. "
Response: The DAK Americas permit has a monitoring only requirement for 1,4-Dioxane to
determine whether this facility discharges the contaminant in detectible amounts, given the
concern of 1,4-dioxane in the Cape Fear River basin as a whole. The only historical 1,4-Dioxane
data generated by the facility was in 2003, well before the implementation of EPA Test Method
164.1 in 2017, and under a process that has since changed. Asheboro has generated sufficient data
to perform an RPA.
• Comment: "Staff would like an explanation as to why the term for this permit is only four years.
NPDES permits are typically written for 5 year terms. It is understood that we have been
operating on an expired permit for some time but shortening the term of the new permit to four
years is a burden not only for city personnel bur also DEQ. "
Response: The permit term has been revised to be 5 years.
Page 3 of 4

Asheboro WWTP (NC0026123) Public Comments and Responses
Comments were received from Mick Noland (Fayetteville Public Works Commission, PWC), Jim
Fletchner (Cape Fear Public Utility Authority, CFPUA, Wilmington), Victor Czar (City of Sanford), and
Jeff Adkins (Town of Cary) via e-mail on June 8, 2018. All commenters represent municipalities with
water supply concerns of 1,4-Dioxane. Comments are summarized as follows:
• All commenters ask the Division to consider the designated uses of the river downstream in 1,4-
Dioxane limit development.
• PWC, CFPUA and Sanford representatives request that other sources of 1,4-Dioxane be
considered in developing limits.
• CFPUA cites the EPA health advisory for 1 in 10,000 cancer risk of 35 µg/L in drinking water.
• Sanford cites the water supply criterion of 0.35 µg/L and requests DEQ conduct an analysis to
determine if the 149 µg/L limit is protective of the 0.35 µg/L criterion at the WS-IV classified
water downstream at the confluence of Governors Creek with the Deep River.
• CFPUA requests the compliance schedule be reduced; PWC and Sanford request a 2 yr
compliance schedule
• PWC requests a public hearing
• PWC will consider legal action should DWR not consider downstream WS and other sources in
limits development
Response: Please see the response to the City of Asheboro's above comment and the revised Other
WQBEL Considerations section of the fact sheet, with pages 16 and 17 focusing on the 1,4-doxane
compliance schedule for more information.
Page 4 of 4

Coco, Nick A
From: Sarah Laughlin <[e-mail]>
Sent: Monday, December 5, 2022 1:06 PM
To: Coco, Nick A; mrhoney
Cc: Montebello, Michael J; Mike Wiseman; Judy Smith
Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro
WWTP Draft Courtesy Copy
Follow Up Flag: Follow up
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Hi Nick,
Thank you for taking time and meeting with me to discuss our permit further.
The City of Asheboro is requesting the full 5 year compliance schedule for 1,4 dioxane. We believe Industry
in Asheboro will need this time to investigate and install treatment units to reduce 1,4 dioxane discharges in
order to meet the final compliance limits.
Thank you,
Sarah W. Laughlin
Technical Services Manager
Water Resources Division
City of Asheboro
[phone] ext. 218
[e-mail]
Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed to third
parties.
From: Coco, Nick A [mailto:[e-mail]]
Sent: Monday, December 5, 2022 10:36 AM
To: Michael Rhoney <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>; Sarah Laughlin <[e-mail]>; Mike
Wiseman <[e-mail]>; Judy Smith <[e-mail]>
Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NC0026123 Asheboro WWTP Draft
Courtesy Copy
Hi Michael,
i

We understand your concerns and have added some language to the footnote to allow for the sampling to be handled
by the coalition (see below for footnote language). We do not have an issue with the coalition conducting the sampling,
so long as we are receiving at least 1/month data. Additionally, if the coalition does not conduct sampling for the
parameter, it will fall back on the City to resume sampling.
"Instream 1,4-dioxane sampling shall be performed on concurrent days with effluent 1,4-dioxane sampling. If the
Permittee is a member of the Monitoring Coalition Program, sampling for instream 1,4-dioxane may be waived as long
as the Monitoring Coalition samples 1,4-dioxane at the nearest upstream and downstream locations, at a minimum
frequency of monthly, and the Permittee has obtained approval from DWR - NPDES Permitting Unit that the upstream
and downstream stations being monitored by the Coalition are representative of the receiving stream for this discharge.
The Permittee is responsible for submitting instream 1,4-dioxane test results with its permit renewal application
package. If the Coalition terminates instream 1,4-dioxane sampling at either of the approved stations, the Permittee will
immediately notify the Division and resume sampling for instream 1,4-dioxane."
Do you have time today for a quick MS Teams call? This would only take 10-15 minutes and is regarding the 1,4-dioxane
compliance schedule.
Thanks,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ / Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
ID: A CP-
��E tj �
11-DW"ftmaof Em9raameMal4ua10
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Carolina Public Records Law and may be disclosed to third parties.
From: Michael Rhoney <[e-mail]>
Sent: Friday, December 2, 2022 11:02 AM
To: Coco, Nick A <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>; Sarah Laughlin <[e-mail]>; Mike
Wiseman <[e-mail]>; Judy Smith <[e-mail]>
Subject: RE: [External Sender] RE: [External Sender] [External] RE: [External Sender] NC0026123 Asheboro WWTP Draft
Courtesy Copy
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Nick,
Thank you for this response. We appreciate your cooperation as we continue this process. Your comments are
satisfactory. However, we still have some concern with the 1,4-dioxane sampling requirements. We understand the
importance of investigating background concentrations. Unless the samples are hydraulically paired, a grab sample on
the same day as the effluent is immaterial. The samples aren't associative without hydraulically paring them. We have
been completely receptive and cooperative with everything DEQ has requested of us concerning 1,4 but this sampling
places somewhat of a burden on us. We aren't currently staffed to do this sampling and the two bridge sites aren't safe
locations. The contract lab for the UCFRBA is already doing sampling at these sites and we would like to coordinate with
them to do this sampling while they are there.
You consideration of this request is greatly appreciated.
Thank you,
V . R6ae, y, P.5
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.gov
Asheboro
Whom CO
NATV 1" a Vk 'I L% Xl-
MAIN TR EET
Community
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From: Coco, Nick A [mailto:[e-mail]]
Sent: Thursday, December 1, 2022 3:04 PM
To: Michael Rhoney <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>; Sarah Laughlin <[e-mail]>; Mike
Wiseman <[e-mail]>; Judy Smith <[e-mail]>
Subject: [External Sender] RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft
Courtesy Copy
Hi Michael,
Again, thank you very much for taking the time to review the draft permit and submit these comments. Please see
below for responses to each:

1. The September 30 expiration is a remnant of the basinwide scheduling for NPDES permit renewals. I had it in as
a placeholder, but will remove it and just have Month xx, 2027 for now to avoid confusion. The term of the
permit is going to be 5 years.
2. That was an oversight on my part. I jumped the gun getting this out to you. Please see the revised version
attached, which includes the reduced frequency.
3. Upstream hardness has not been added to the permit, for the reason you had listed. I will revise the language
used in that email to remove reference to upstream hardness sampling when preparing the cover letter.
4. 1 will remove the compliance schedule for bromodichloromethane in the draft permit. Thank you for letting me
know.
5. The instream 1,4-dioxane data will be used to understand background concentrations. I have changed the
footnote language from "in conjunction with" to "on concurrent days with." The goal is to have the 2/month
instream samples be taken on days where effluent samples are taken. This does not have to be down to the
minute, but the concurrent data provides clearer conclusions. Please see response 1 for the 5-year term.
6. We will provide this as an attachment to the cover letter.
7. Permittees are responsible for tracking the Federal Register, but we will also be sending notifications to
permittees with this requirement.
8. 15A NCAC 02B .0211 (11) (b) states, "With the exception of mercury, aquatic life standards for metals listed in
this Sub -Item shall apply as a function of the pollutant's water effect ratio (WER). The WEIR shall be assigned a
value equal to one unless any person demonstrates to the Division's satisfaction in a permit proceeding that
another value is developed in accordance with the "Water Quality Standards Handbook: Second Edition"
published by the US Environmental Protection Agency (EPA-823-B-12-002), which is hereby incorporated by
reference, including subsequent amendments and editions, and can be obtained free of charge at
http://water.epa.gov/scitech/swguidance/standards/handbook/. Alternative site -specific standards may also be
developed when any person submits values that demonstrate to the Commission that they were derived in
accordance with the "Water Quality Standards Handbook: Second Edition, Recalculation Procedure or the
Resident Species Procedure", which is hereby incorporated by reference including subsequent amendments and
can be obtained free of charge at http://water.epa.gov/scitech/swguidance/standards/handbook/."
Additionally, as you had noted, 15A NCAC 02B .0211 (11) (c) (viii) [for chronic silver] as well as 15A NCAC 02B
.0211(11) (e) [for acute silver] incorporate the WEIR as a multiplicative factor when calculating the standards.
DWR is also willing to consider other methods to achieve compliance with the proposed silver limits.
Please confirm that the City believes a 5-year compliance schedule is necessary for achieving compliance with the
proposed 1,4-dioxane effluent limitations.
Please let me know if you would like to have a follow-up call to discuss any of these bullet items or would like further
clarification on anything related to the draft permit.
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ / Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617

ie D7:,..E
Oepe14r1MR al 61MM�unmoMal NUHIH��,Y)LIN Q
Ovai.ly
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From: Michael Rhoney <[e-mail]>
Sent: Tuesday, November 29, 2022 4:34 PM
To: Coco, Nick A <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>; Sarah Laughlin <[e-mail]>; Mike
Wiseman <[e-mail]>; Judy Smith <[e-mail]>
Subject: RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy
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Good afternoon,
The City of Asheboro NPDES Permit Comments/Concerns are itemized below:
1. Please verify that this permit will be for less than 5 years based on the September 30, 2027 expiration date.
2. It doesn't appear that we were granted Reduction of Monitoring Frequencies for BOD, TSS, Ammonia and Fecal
in NPDES permits for exceptionally performing facilities as requested. Was there an error in our request
submission or was this just overlooked and didn't get changed?
3. The email on 11/21/2022 states upstream hardness sampling is required but Asheboro did not see it in the
permit on A.(1.). Was it listed in another location? Asheboro has a 7Q10 of zero so upstream hardness testing is
not needed or relevant to our site.
4. We would like to request the Bromodichloromethane compliance schedule be removed. We feel confident we
have made enough internal operational changes since the last draft was published to meet the current limit and
a compliance schedule is no longer necessary.
S. 1,4 Dioxane instream sampling — What is the data collected being used for? We would like to have the effluent
and instream pairing requirement removed (footnote 13). This puts an undue hardship on our staff. Samples are
not hydraulically paired when collected together so Asheboro does not understand the reasoning for this
requirement. Please explain or remove the requirement for pairing. The 1,4 Dioxane final limit goes into effect
at the end of year 5 but our permit isn't good for 5 years. Is that acceptable or was it an oversight (See comment
1 on less than 5 year permit).
We would like NCDEQ to provide a list of Downstream Utilities and the ORC/Owner contact information for
A.(6.) (g) notification requirement.
7. A.(8.) PFAS Monitoring Requirement —Will NCDEQ send a letter to notify permit holders once the method is
approved or are we expected to track this internally and be aware.

8. According to 40 CFR 131.36, a WER does not change the Chronic Silver limit — See below. 15A NCAC 02B .0211
(11) (c) states chronic silver is WER time 0.06 ug/L. Can DEQ Staff confirm in writing that performing a WER will
result in multiplying 0.06 ug/L times WER to result in a new NPDES silver limit? We need to know what our
options are for a compliance schedule. Will DEQ consider other methods?
I will be glad to discuss any of these items with you as needed.
V . R&eery, ;V'F
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.gov
North camlina
MAM STREET
Community
Asheboro
ahurin My
\nll 6" < n, I f ., A h
1
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to third parties.
From: Coco, Nick A [mailto:[e-mail]]
Sent: Tuesday, November 29, 2022 2:11 PM
To: Michael Rhoney <[e-mail]>
Cc: Montebello, Michael J<[e-mail]>; Sarah Laughlin <[e-mail]>; Mike
Wiseman <[e-mail]>; Judy Smith <[e-mail]>
Subject: RE: [External Sender] [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy
Hi Michael,
Thank you very much for the update. I look forward to seeing your summary.
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ/ Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
**Email is preferred but 1 am available to talk by via Microsoft Teams**

Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
9f: . ^� I) IN �
I ite, t 1 oP E(mr(nrneMal Ouel+q'
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Carolina Public Records Law and may be disclosed to third parties.
From: Michael Rhoney <[e-mail]>
Sent: Tuesday, November 29, 2022 2:08 PM
To: Coco, Nick A <[e-mail]>; Sarah Laughlin <[e-mail]>; Mike Wiseman
<[e-mail]>; Judy Smith <][e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: [External] RE: [External Sender] NCO026123 Asheboro WWTP Draft Courtesy Copy
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Nick,
We finished our review yesterday. I hope to sit down this afternoon and summarize everything before the end of the
day.
Water Resources Director
Water Resources Division
336-626-1201, ext: 258
www.asheboronc.gov
Asheboro
Ail-Anarin City
UAL"'
North Carolina
MAIN STREET
Community

Email correspondence to and from this sender is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Coco, Nick A [mailto:[e-mail]]
Sent: Tuesday, November 29, 2022 1:42 PM
To: Michael Rhoney <[e-mail]>; Sarah Laughlin <[e-mail]>; Mike Wiseman
<[e-mail]>; Judy Smith <[e-mail]>
Cc: Montebello, Michael J <[e-mail]>
Subject: RE: [External Sender] NC0026123 Asheboro WWTP Draft Courtesy Copy
Hi all,
I just wanted to follow up on this to make sure that December 1 is still an attainable timeline for your review. With the
holiday, I'm sure many folks were out of town or at the very least off line. Do you need a little bit more time to conduct
your review and provide comments? If so, what would you say is a reasonable timeline for you?
Thanks in advance,
Nick Coco, PE (he/him/his)
Engineer Ill
NPDES Municipal Permitting Unit
NC DEQ / Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
ED:, E
14pi
0.4 ran N or
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From: Coco, Nick A
Sent: Monday, November 21, 2022 10:36 AM
To: Michael Rhoney <[e-mail]>; [e-mail]; [e-mail];
[e-mail]
Cc: Montebello, Michael J<[e-mail]>; Grzyb, Julie <[e-mail]>; Graznak, Jenny
<[e-mail]>; Snider, Lon <[e-mail]>
Subject: NC0026123 Asheboro WWTP Draft Courtesy Copy
Hi all,

As we discussed on our call last Thursday, please see attached for a courtesy copy of the draft version of NPDES permit
NC0026123 Asheboro WWTP. I've also listed below the changes being made to the permit, but please note that I am
basing the changes off of the current active permit and not that first draft. The summary of changes:
• Per the results of instream waste concentration (IWC)-based calculations for ammonia -nitrogen, ammonia
nitrogen limits have been revised [See A.(1.)].
• Based on the reasonable potential analysis (RPA) showing no reasonable potential to violate state water quality
standards, the limits and monitoring requirements for total chromium and total zinc have been removed from the
permit [See A.(1)].
• Based on the reasonable potential analysis (RPA) showing reasonable potential to violate state water quality
standards, total silver, bromodichloromethane, and 1,4-Dioxane limits and monitoring requirements have been added to
the permit [See A.(1)].
• Based on the reasonable potential analysis (RPA) predicting a maximum effluent total selenium concentration
that is greater than half of the allowable discharge concentration based on state water quality standards, quarterly
monitoring for total selenium has been added to the permit [See A.(1)].
• To provide an opportunity for the City to develop a plan to assess sources of total silver and
bromodichloromethane in order to come in compliance with the limits in Section A.(1.), schedules of compliance have
been added to the permit [See Special Conditions A.(4.) and A.(5.)].
• To provide an opportunity for the City and their industries to develop a plan to assess sources of and implement
technology to control discharges of 1,4-Dioxane in order to come in compliance with the limits in Section A.(1.), a
preliminary 5-year phased schedule of compliance has been added to the permit [See Special Condition A.(6.) Schedule
of Compliance for 1,4-Dioxane Limitations]. We do request that you confirm and provide additional information that the
proposed 1,4 dioxane compliance schedule is consistent with EPA memo (related to compliance schedules) from James
Hanlon (Office of Wastewater Management) dated May 10, 2007 (attached).
• Based on the Mercury TMDL evaluation showing no annual average mercury concentration exceeded the
WQBEL, and no individual mercury sample exceeded the TBEL, the limits and monitoring requirement for total mercury
have been removed from the permit [See A.(1)].
• Based on Mercury TMDL evaluation showing mercury values reported at levels > 1 ng/L and since the permitted
flow is greater than 2 MGD, Special Condition A.(7.) Mercury Minimization Plan (MMP) has been added to the permit.
• Based on review of instream conductivity indicating the facility effluent appears to influence downstream
conductivity levels, instream conductivity monitoring has been added to the permit [See A.(1.)]. The Permittees'
instream sampling requirement for this parameter is provisionally waived as long as the Permittee is a member of the
Upper Cape Fear River Basin Association.
• Based on resulting patterns indicating effluent impact on the receiving waterbodies and to assess background
concentrations of 1,4-dioxane to better analyze the discharge, instream monitoring for 1,4-Dioxane has been added to
the permit [See A.(1.)].
• A special condition to monitor effluent PFAS chemicals quarterly has been added to the permit, to be effective
six (6) months after EPA has a final wastewater method in 40 CFR136 method published in the Federal Register [See
Special Condition A.(8.) PFAS Monitoring Requirements].
• The Division is implementing dissolved metals standards in all permits, per the 2016 revisions to State water
quality standards. As such, the NPDES Permitting Unit will need site -specific effluent hardness data and instream
hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit
limitations. Effluent hardness and instream hardness sampling, upstream of the discharge, have been added to the
permit at a monitoring frequency of quarterly [See A.(1.)].
• Some of the wording has changed in Special Condition A.(2.), Chronic Toxicity Permit Limit, please review each
paragraph carefully.
• Special Condition A.(3.) has been modified to include the specific three years in which the Effluent Pollutant
Scan shall be performed (2024, 2025, and 2026). In addition, at the end of the Special Condition, 2nd species Toxicity
Testing Requirements for municipal permit renewals per Federal Regulations [40 CFR 122.21(j)(5)] have been added.
• A notation was made concerning the Electronic Reporting Rule — NPDES Electronic Reporting Rule — Phase 2
Extension. EPA extended the Phase 2 deadline to December 21, 2025.
9

• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The requirement to continue reporting discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit [See Special Condition
A.(10.)].
• Parameter codes have been added to the Effluent Limitations and Monitoring Requirements [ See A.(1.)].
• Regulatory citations have been added to the permit.
Please feel free to follow up with me with any questions. We are requesting that you submit any comments or provide
any supplemental material regarding this draft permit by December 1, 2022. 1 appreciate your time and look forward to
hearing from you after you have a chance to review.
Best,
Nick Coco, PE (he/him/his)
Engineer 111
NPDES Municipal Permitting Unit
NC DEQ / Division of Water Resources / Water Quality Permitting
Office: [phone]
[e-mail]
"Email is preferred but 1 am available to talk by via Microsoft Teams"
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
-E
NA
PF¢�P4fF•IH OR EgVJP011AFaMiI 41►Elltr
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10

Attachment A —Request for Missing Information
Table 2. EPA Application Form 2A Missing Information
1.1 Email address of facility contact [e-mail]
1.2 Applicant email address [e-mail]
1.3 Email address of the organization transporting the discharge for treatment prior to discharge N/A
1.4 Email address of the organization receiving the discharge for treatment prior to discharge N/A
1.5 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)? (Check all that apply. Consult
with your NPDES permitting authority to determine what information needs to be submitted and when.)
Discharges into marine waters (CWA Section Water quality related effluent limitation (CWA
301(h)) Section 302(b)(2))
Not applicable
1.6 Emall address of contractor responsible for operational or maintenance aspects of the treatment works
i
1.7 Indicate the number of SIUs and NSCIUs that discharge to the POTW.
Number of SIUs Number of CIUs
14 7
1.8 1 Certification Statement
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete, l am aware that
there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Name (print or type first and last name) I Official title
John N. Ogburn, III ' City Manager
Date signed„ )-0 2
r J
U

EPA Identifcation Number
NPDES Number
Facili Name Outfall Number
Asheboro-1 00,
Method Number (if
Estimated Concentzadon (If
Pollutant Re wired
CAS number
Applicable)
Reason Pollutant Believed Present in D(schar a
Known
c14the
an.40. During
EzterlficA'11prpcezy Di0.-, d byproduct Starp.t
l,4 prod as a
insta letl a 1,4 diozanetreatm antl itwas put in service
NA- See attached
6e varies.
1,4 Dip -
123A1-1
624.1
2yos,cem
November 20, 2020.
-atOaklandfill,lU-953, contains l,4 Diozane in Me discharge.
N. M1az been installed date. Great Oak iz Municipal S01id
datasummarysheet.
treatment t0 a
Waste Landfill.
'+PFAS M.-Not a Certified Metbedper40 CFR Port 136-40 CFR Part 136 does not list a PFAS MNhod M thi-1-1-
3lniluent Samples taken in July,
Augurt& September 2019. See
attached summary sheet
PFASby LCMSMS
tOak Landfill, IUP M-, Municpal 5o1id W.A. landfill.
Perfl.......-k and
335i)-1
C°mplian[wi[M1 Table B-15
Ashebowa<cepts Leachate. Landfills are known and suspected sources
]0.59 n8/L
of q5M 5.1 or latest
Version
ofa variery of PFPS comp0unds
PFPS by LCM-
Great Oak Landfill, IUP W953, Municipal Solid Waste landfill.
Ped........ ic acid
1763-23-1
Compliantwith Table 8-15
ASM1ebpro...piz Leachate. Landfills are known and suspected spur<es
192)ng/L
of OSM 5.1 or latest
ofa variery of PFAS compountls
-byLICM5M5
Great0ak LandfiILIUPW953, Municipal5olid Wart. Landfill.
Perfluowbutanoic acid
3)5-22-C
C°mplian[ witlh Table B-11
Asheboro accepts Leachate. Landfills are known and susp-dsources
ND
of 0SM 5.1 or latest
Version
of a variety of Pl- compounds
PFAS by LCMSMS
Great Oak Lantlfill,lUPp4953,M.,,MpaI5Iid Was-,Ifill.
Perfluorobutanesulfonic acid
3)5-)3-5
C°mplian[ with Table B-15
Asheborn... ph, -1,te. Landfills are known and suspected sources
ND
of OSM 5.1or latest
ofa vaderyof PFAS compounds
PFgS by LICM5M5
Great Oak Landfill, IUP W953, Municipal Solld W.A. Landfill.
oro P.Mud.canesulfonic acid
335-)) 3
C°m IiantwitM1Table B-IS
Asheboro accepts Leachate, tantlflls are known and suspected sources
e .13 ng/L
of M. 5.1 or latest
Version
ofa varlety of PFPS compounds
PFAS by LCMSMS
Great Oak Landfill, IUP W953, Municipal Solid Waste landfill.
Peril .... dlwnoi-dd
335-76-2
Compliant with Table B-15
Asheboro.-A,Leachate. Landfills are known and suspected sources
1.50 ng/L
of OSM 5.1 or latest
I
of a varieryof PFAS compounds
PFAS by LCM5M5
Great Oak Landfill, IUP W953, Municipal Solid W.A. Landfill.
P.munrodode-k and
30)-554
C°m lien[ witlh Table B-11
Asheboro awepts Le known and suspected sources
236 ng/L
of M. 5.1 or latest
Version
f.-i.tandfillsare
P
ofa varety of FPS compounds
PFPS by LCMSMS
Great Oak Landfill, IUP W953, Municipal Solid Waste landfill.
Pedb, oheptanesulfoni ad
3)592-8
C°mpli-ith Table B-15
Asheboro attepis Leachate. Landfills are known and suspected sources
0.68
of OSM 51 or latest
ofa variery of PFAS compountls
PFASby LICM5M5
Oak Landfill, IUP W953, Munlclpal Solid Waste Landfill.
PerfluoroM1eptanolc add
3)5-85-9
Com Item with Table B-"
CMS
Ashebpro accepts Leachate.tantlfills are known and suspected sources
3.52 ng/L
5.l or latest
Version
ofa varlety of PFPS compounds
PFPS by LCMSMS
Great Oak Landfill, IUP W953, Municipal Solid Waste landfill.
PeM-.hemnesulfoni dd
355-
Compliant with Table B-15
Asheboro...ph Le t.. Landfills are known and suspMed sources
ND
of OSM 5.1 or latest
I
of a varieryof Pl-compountls
PFgS by LCM5M5
Oak Landfill, IUP W953, Munlclpal Solid Waste Landfill.
P.rfluor.M1e ..k acid
307- 24b
C°m IiantwitM1Table B-IS
Asheboro a<ceprs Leachate. Landfills are known and suspened sources
11 .ss ng/L
of M. 5.1 or latest
Version
ofa lety of PFPS compounds
var
P-by LCMSMS
GreatOak-fill, IUP W953, Municipal Solid Waste landfill.
PeMuorononanesulf-ic acid
68259-124
C°mplian[ with Table B-15
ASM1eboro accepts Leachate. Landfills are known and suspected sources
0.73 nd/L
of OSM SA or latest
ofa variery of PFAS wmp-d,
PFASby LICM5M5
Dak Landfill, IUP W953, Munlclpal Solid Waste Landfill.
......nano
PeTlc acid
3) SAS-1
C°m IiantwitM1Table B-IS
kn
Asheboro -A,ts Leachate. -fill, are own and suspectetl source
12
. 9 ng/L
of QSM 5.1 or LateR
Version
ofa varlety of PFAS rompounds
PFPS by LCMSMS
GreatOak-fill, IUP W953, Munidpal5olid Waste landfill.
PeMuoropctanesulfonamide
)5491-6
Compliant with Table B-15
Asheboro accepts Leachate. Landfills are known and suspected sources
ND
of OSM 5.1 or latest
ofa variery of PFPS compountls
PFASby LICM5M5
tDak LandW9 fill, IUP 53, Munlclpal Solid Waste Landfill.
2-(N-Rhylp.M..roocta-.IMnamldo)ace-ld
2-1--
C°mpliantwith-le B-IS
Ashebowa<cepts Leachate. Lantlfills are known and suspected
1.3b ng/L
of QSM 5.l or latest
Version
of a varlety of Pi -compounds
24N-MMOWMuor-ulomid.) eicacd
2355A
PFPSbyCMSM
Co
mplamth Tab85AM1ebooeehte
GeOanll,IUPW53,Micip-lid Wrtdfill.
Lnfills e knwndpte
ND
oOMiezt
Version
of a variery of PFPS wmp-dz
PFASby LCMSMS
Daklandflll,IUPW953,Muoldpal Solid Waste Landfill.
Perfluoropentenesulfonic acid
2)06AIJ
Compliant witlh Table B-IS
of M5 5.1 or latest
Version
Ashebawta<cep6 -h...Lantlfillz are known and suspec[etl sources
ofa varieryof Pi- compounds
ND
PFPSby LCMSMS
Great Oak -fill, IUP W953, Municipal Solid Waste landfill.
Pemupr0pemana. add
2)0690-3
Compliant with Table 8-15
ASM1eboro a<cepu Leachate. Landfillsare known and suspected sources
8.6 ng/L
of OSM 5.1 or latest
ofa variery of PFAS compountls
PFASby LICM5M5
MkLandfill, IUP W953, Munlclpal Solid Waste Landfill.
Periluor-decanolcacid
3)6-06-
wit
C°m Iiant lh -IS
Table B
A shebpwat<cepts -AA,-AA,-fill,fills are own nd asuspectetl source
kn
3 .e ng/L
of QSM 5.1 or latest
Version
ofa varlety of PFAS compounds
P.Mu.-id.can°ic and
)262yy4-8
PFPSby LCMSMS
Compliant with Table B-15
Great Oak -fill, IUP W953, Municipal Solid W-landfill.
Asheboro a,,M Leachate. landilllsare known and sus petted souces
2.38 ng/L
of OSM5.l or latest
I
ofa varieryof PFPS compounds
PFASby LCM5M5
Great Dak landfill'UP.113, Munlclpal Solid Waste landfill.
Perfluor...deranoic acid
205884-8
C°mpliant wit lh Table B-IS
A.hebaro acceptsLeachate. Landfllz are known antl suspMed s0ur<es
1.68 ng/L
of mm 5., or latest
Version
ofa varlety of PFAS compounds
Gen-X
620310-3
PFPS by LCMSMS
Compliant with Table B-15
Great Oak Lantlfill,IUP-53, Municipal Solid Waste landfill.
Asheboro accepts Leachate. Landfills are known and suspected sources
ND
of OSM SA or latest
ofa varieryof PFPS compounds
PFAS- Others speclficte Landfill Leachate
Great Oak Landfill, IUP W953, Municipal Solid Waste landfill.
Asheboro accepts L 1,W.Landfills are known and suspected sources
Unknown
pf a varieryof PFPS compounds

Enter data ONLY in blue cells!
POTW Name: city of Asheboro WWTP NPDES #: I NCO026123
Influent Grab (ng/L)
CAS Number
Analyte Name
Acronym
7/10/2019
*
8/8/2019
*
9/5/2019
335-67-1
Perfluorooctanoic acid
PFOA
9.47
10.6
11.7
1763-23-1
Perfluorooctanesulfonic acid
PFOS
19.8
18.8
19.2
375-22-4
Perfluorobutanoic acid
PFBA
<2.54
U
ND
U
ND
U
375-73-5
Perfluorobutanesulfonic acid
PFBS
<2.54
U
ND
U
ND
U
335-77-3
Perfluorodecanesulfonic acid
PFDS
<2.54
U
ND
U
24.4
335-76-2
Perfluorodecanoic acid
PFDA
<2.54
U
ND
U
4.51
307-55-1
Perfluorododecanoic acid
PFDoA
<2.54
U
ND
U
7.07
375-92-8
Perfluoroheptanesulfonic acid
PFHpS
<2.54
U
ND
U
2.03
375-85-9
Perfluoroheptanoic acid
PFHpA
4.62
ND
U
5.95
355-46-4
Perfluorohexanesulfonic acid
PFHxS
<2.54
U
ND
U
ND
U
307-24-4
Perfluorohexanoic acid
PFHxA
8.74
B
13.5
12.4
68259-12-1
Perfluorononanesulfonic acid
PFNS
<2.54
U
ND
U
2.19
375-95-1
Perfluorononanoic acid
PFNA
<2.54
U
ND
U
3.87
754-91-6
Perfluorooctanesulfonamide
PFOSA
<2.57
U
ND
U
ND
U
2991-50-6
2-(N-Ethylperfluorooctanesulfonamido) acetic acid
N-EtFOSAA
<2.54
U
ND
U
4.09
2355-31-9
2-(N-Methylperfluorooctanesulfonamido) acetic acid
N-McFOSAA
<2.54
U
ND
U
ND
U
2706-91-4
Perfluoropentanesulfonic acid
PFPeS
<2.54
U
ND
U
ND
U
2706-90-3
Perfluoropentanoic acid
PFPeA
25.8
ND
U
ND
U
376-06-7
Perfluorotetradecanoic acid
PFTeA
<2.54
U
ND
U
11.4
72629-94-8
Perfluorotridecanoic acid
PFTriA
<2.54
U
ND
U
7.15
2058-94-8
Perfluoroundecanoic acid
PFUnA
<2.54
U
ND
U
5.04
62037-80-3
Gen-X
HFPO-DA
ND
U
ENTER OTHER PARAMETERS TESTED
ENTER OTHER PARAMETERS TESTED
ENTER OTHER PARAMETERS TESTED
ENTER OTHER PARAMETERS TESTED
Sum of PFOA and PFOS
29.27
29.4
30.9
Total
68.43
42.9
121

Asheboro WWTP Effluent Grab 1,4 Dioxane Data (ug/L)
Date
Research & Analytical
Laboratories, Inc. NC #34
Meritech Inc. NC
#165
Pace Analytical NC
#12
NC DEQ DWR
*Not Certified*
12/7/2017
98.7 *Not Certified*
89.0
1/11/2018
937
1590
2/1/2018
882
1140
3/1/2018
212
4/5/2018
397
5/9/2018
75.7
6/13/2018
77.7
7/17/2018
48.0
8/22/2018
764
9/11/2018
182
10/25/2018
31.6
11/8/2018
58.3
12/6/2018
217
1/9/2019
167
2/5/2019
613
3/13/2019
159
4/17/2019
228
5/8/2019
37.0
6/4/2019
46.5
7/10/2019
49.2
8/22/2019
423
9/4/2019
18.2
10/22/2019
184
11/19/2019
64.7
12/10/2019
200
1/16/2020
166
2/19/2020
208
3/3/2020
571
4/1/2020
102
5/6/2020
149
6/9/2020
79.3
7/16/2020
120
8/12/2020
232
9/2/2020
199
10/8/2020
<2.0
11/17/2020
72.6
110*
12/2/2020
<1.0
12/9/2020
<1.0
12/15/2020
1.23
3.3*
12/21/2020
<1.0
12/29/2020
6.12
1/7/2021
3.05

1/13/2021
3.19
3.6*
1/21/2021
4.06
1/27/2021
8.21
2/2/2021
4.01
2/10/2021
31.4
2/16/2021
20.5
46.0*
2/25/2021
32.9
3/2/2021
18.1
3/10/2021
93.8
3/16/2021
145
200*
3/25/2021
133
3/30/2021
316
4/7/2021
77.2
4/15/2021
58.3
4/22/2021
14.1
15.0*
4/28/2021
20.8
5/5/2021
4.86
5/13/2021
19.7
5/19/2021
18.3
5/24/2021
147
290*
6/2/2021
27.2
6/9/2021
26.6
6/17/2021
143
6/22/2021
88.8
130*
6/29/2021
35.9
7/8/2021
88.4
7/16/2021
153
240*
7/20/2021
34.2
7/23/2021
55.7
82.0*
7/30/2021
115
220*
8/6/2021
34.4
64.0*
8/13/2021
25.2
25.0*
8/20/2021
55.6
82.0*
8/27/2021
64.6
96.0*
9/1/2021
58.9
120*
9/10/2021
70.2
100*
9/17/2021
63.9
83.0*
9/24/2021
98.6
140*
10/1/2021
37.5
38.0*
10/8/2021
44.5
68.0*
10/15/2021
114
270*
10/21/2021
548
920*
10/29/2021
636
940*
11/5/2021
75.3
130*
11/12/2021
3.82
6.0*
11/19/2021
5.04
7.2*
11/22/2021
10.3

12/3/2021
59.7
65.0*
12/10/2021
2.7
4.1 *
12/17/2021
11.3
38.0*
12/21/2021
<2.0
1/7/2022
102
130*
1/14/2022
26.9
22.0*
1/20/2022
3.06
1/28/2022
25.2
22.0*
2/4/2022
74.7
110*
2/11/2022
107
180*
2/18/2022
34.6
74.0*
2/25/2022
133
190*
3/4/2022
25.0
33.0*
3/11/2022
136
190*
3/18/2022
44.3
Not Received
3/25/2022
15.1
Not Received
4/1/2022
Not Received
Not Received

DARSWEIL L. ROGERS, COMMISSIONER/_ FAYETTEVILLE PUBLIC WORKS COMMISSION
WADE R. FOWLER, JR., COMMISSIONER CCi S 955 OLD WILMINGTON RD
EVELYN 0. SHAW, COMMISSIONER R.O. BOX 1089
D. RALPH HUFF, III, COMMISSIONER H ME AWN UTILITY FAYETTEVILLE, NORTH CAROLINA 28302-1 D89
DAVID W. TREGO, CEO/GENERAL MANAGER TELEPHONE [phone]
W W W.FAYPWC.COM
June 8, 2018
VIA EMAIL: g_ary.perlmutterna,ncderingov
Mr. Gary Perlmutter
NCDEQ — Division of Water Resources
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: Fayetteville Public Works Commission Comments on Draft NPDES Permit for City of
Asheboro Wastewater Treatment Plant (NC0026123); Randolph County, NC
Dear Mr. Perlmutter:
The North Carolina Department of Environmental Quality — Division of Water Resources
(DWR) issued a public notice of the draft NPDES permit for the City of Asheboro's Wastewater
Treatment Plant (WWTP) on May 9, 2018 and the comment period is open through June 8, 2018.
Located within the Cape Fear River basin, this facility discharges to Hasketts Creek which is a
tributary of the Deep River. This WWTP has a pretreatment program for the applicable
industries that discharge to its collection system. Fayetteville Public Works Commission (PWC)
has a surface water intake on the Cape Fear River downstream of this discharge and is providing
comments on this draft permit based on protecting its and other water systems water supplies.
PWC has reviewed the draft permit considering the known levels of 1,4-dioxane, an emerging
contaminant, in the Cape Fear River. PWC is providing relevant background information and
presenting alternatives to the proposed permit limit for 1,4-dioxane. This is a very important
public health issue for water supplies in the Cape Fear River basin and we believe a public
hearing is appropriate to get additional public comment before issuance of the final NPDES
permit.
Background on 1,4 Dioxane
Monitoring data in the Cape Fear River watershed collected by both DWR and a researcher at
North Carolina State University (NCSU) has identified the presence of 1,4-dioxane. This
chemical is most often used as a stabilizer in chlorinated solvents, paint strippers, and waxes. It
is found as an impurity in antifreeze and aircraft deicing fluids, is a by-product in the
manufacturing of polyethylene terephthalate (PET) plastics, and may be present in manufactured
food additives, food packaging materials, and pesticides. It moves easily from soil to
groundwater, as it does not stick to soil particles but is soluble in water. Environmental
Protection Agency's (EPA) technical fact sheet for 1,4-Dioxane, dated November 2017, further
characterizes it as completely miscible in water, making it highly mobile and not readily
biodegradable in the water environment.
Described by the (EPA) as a "likely human carcinogen," this chemical compound is also
identified by the EPA as an emerging contaminant. The U.S. Department of Health and Human
Services also considers 1,4-dioxane as "reasonably anticipated to be a human carcinogen."
BUILDING COMMUNITY CONNECTIONS SINCE 1905
AN EQUAL EMPLOYMENT OPPORTUNITY EMPLOYER

Mr. Gary Perlmutter
Page 2
June 8, 2018
EPA's risk assessment resulted in a drinking water health advisory with an associated estimated
lifetime cancer risk of one in one million at a concentration of 1,4-dioxane of 0.35 µg/L. Human
exposure may occur through ingestion of contaminated food (including fish from contaminated
waterways) or water and through skin contact. Conventional WWTPs and water treatment plants
are not capable of removing this compound. With these characteristics, PWC is concerned with
how and where this compound enters the Cape Fear River watershed upstream of its drinking
water intake.
In accordance with the water quality standards regulations (15A NCAC 02B.0208), DWR
calculated protective values for 1,4 Dioxane (CAS # 123-91-1) are 0.35 ug/L in Water Supply
classified waters, and 80 ug/L in Class C waters. The calculation of 0.35 ug/L is protective of
consuming water and consuming fish (WS Classified waters). The 80 ug/L is based upon the
risk of consuming only potentially contaminated fish (Class C). These numbers are based upon
the carcinogenicity of the compound from information obtained from the US EPA IRIS
database.
1.4-Dioxane in the Cane Fear River
Monitoring of this compound in the Cape Fear continues to show its presence in both main
tributaries, the Deep and Haw Rivers, as well as in the Cape Fear River. DWR completed a study
from 2014 through 2016 on the Cape Fear River Basin and published results in February 2017.
Monitoring is continuing and so far, four primary sources were identified, with three identified as
municipal WWTPs. This further supports the premise that the municipal treatment facilities are
not removing 1,4-dioxane with current treatment practices, and sources are likely industrial
facilities discharging to the WWTPs. This study includes conclusions that further reductions will
be necessary to achieve federal and state health advisory levels in the Cape Fear River.
City of Asheboro WWTP Draft NPDES Permit
The City of Asheboro's draft NPDES permit includes a limit of 149 µg/L of 1,4-dioxane with a
compliance schedule of 3 years. Based on the information provided in the fact sheet for the draft
NPDES permit, PWC believes this limit is not sufficient to protect downstream water supplies.
Also, since downstream waters currently have 1,4-Dioxane levels above the water supply
criterion, we believe the compliance schedule is too slow . Table 1 includes the data and
parameters used by DEQ to arrive at a limit of 149 µg/L. Using the combined flows from the
discharge and the annual average streamflow as reported in the fact sheet as well as the instream
criteria of 80 µg /L, one can derive the calculated proposed permit of 149 µg/L. This calculation
was made under the assumption that all Hasketts Creek loading of 1,4-dioxane is entirely
attributed to the Asheboro WWTP and there are no upstream sources. However, such an
assumption seems to be inherently unreasonable in light of the information cited above.
Table 1
City of Asheboro Draft NPDES permit parameters
Parameter Units
Permitted discharge 9 MGD, converted to 14 cfs From fact sheet
Annual average streamflow 12 efs From fact sheet
Instream criteria 80 µg/L To be met in mixing zone

Mr. Gary Perlmutter
Page 3
June 8, 2018
Water Supply Watershed Considerations
PWC is concerned that the approach used above to calculate the draft permit limit for 1,4-
dioxane improperly considers only the Class C waters near the discharge and not the water
downstream classified for water supply (WS) (as required by 15A NCAC 02B .0203
PROTECTION OF WATERS DOWNSTREAM OF RECEIVING WATERS). These concerns
are outlined below for the Deep River water supplies as well as for PWC's water supply in the
Cape Fear River further downstream.
Deep River — The calculation of the Asheboro permit limit for 1,4-dioxane does not consider
downstream WS waters nor other sources of this contaminant in the Deep River watershed.
Hasketts Creek discharges into the Deep River and literature shows that 1,4-dioxane is not
readily biodegradable in the water environment. Thus, the mass discharged can be assumed to
move downstream with little or no losses through sedimentation or biodegradation. Sampling
conducted by NCSU has detected low levels of 1,4-dioxane in the Deep River upstream of the
confluence with Hasketts Creek. In addition, the water supply (WS) segment for former Gulf-
Goldston Sanitary District intake and Lee County/Sanford is located on the Deep River before its
confluence with the Haw River. At this location, the water supply criterion of 0.35 µg/L should
be met. Using watershed size and the USGS gage at Moncure (downstream of the Lee County
intake), it is estimated that the annual average stream flow is approximately 1,000 cfs. Using that
as a dilution factor, the loading from the Asheboro WWTP alone would produce an instream
concentration of 2.0 ug/L at the Gulf-Goldston and Lee County/Sanford (WS) segments. This
value is well above 0.35 µg/ and would be much higher during low flow conditions that
frequently occur.
PWC has estimated the permit limit that would be necessary to meet the WS criterion at Gulf-
Goldston. Using the estimated average annual stream flow of 1,000 cfs and a water supply
criterion of 0.35 µg/L, the permit limit from Asheboro WWTP would need to be less than 15
µg/L if the Asheboro WWTP is the only source of 1,4-dioxane considered. DWR should also
consider other sources of 1,4-dioxane which would lower this permit limit further.
Cape Fear River
PWC has also been conducting monthly monitoring for 1,4-dioxane upstream of its intake as
well as at its intake. Data collected since May 2014 show an average instream concentration of
2.5 µg/L, as shown in Table 2 (at end of letter). This value is also above the water supply
criterion of 0.35 µg/L. DWR monitoring results included in the 2-year report published in 2017
show similar levels, with most records between 2 and 4 µg/L. If Asheboro WWTP were the only
1,4-dioxane source at 149 µg/L at permitted flow contributing at PWC's intake, it is estimated
that the concentration would still be above the water supply criterion at about 0.45 jig/L. This
estimate was made using the average annual stream flow at Cape Fear River USGS gage
02104000 in Fayetteville. Under low flow conditions approaching the 7Q10 flow, the
concentration would be above 4 ug/L at Asheboro's permitted flow and above 2 ug/L if they
were discharging at 50 percent of their permitted flow. Clearly, DWR needs to consider
downstream WS waters in calculating permit limitations for dischargers. Efforts are needed
throughout the Cape Fear River basin to reduce discharges of 1,4-dioxane to receiving streams.
Request for Public Hearina
We believe the issue of 1,4-dioxane has been flying under the radar because of other emerging
contaminant issues in the Cape Fear River and that many people are unaware of concerns over
this contaminant. Since Asheboro is the first of several NPDES permits in the river basin that
will have limitations for 1,4-dioxane, we believe DWR should conduct a public hearing to fully
inform the public and get public and water utility concerns over their approach to regulating this
contaminant.

Mr. Gary Perlmutter
Page 4
June 8, 2018
Concludine Comments
PWC appreciates your consideration of our requests for protection of, the Cape Fear River as a
water supply source for PWC and many other communities in the Cape Fear River basin, through
continued efforts to reduce 1,4-dioxane entering in the watershed. Clearly, the proposed permit
limit included in Asheboro WWTP's draft NPDES permit is not low enough to protect
downstream water supplies and should be reconsidered. Treatment technologies including
oxidation approaches can be used by either the Asheboro WWTP or the industrial facilities
discharging into the Asheboro WWTP to reduce 1,4-dioxane. We believe further efforts to
inform the public and get input on this contaminant is necessary.
Even with continued dilution downstream in the Cape Fear River, 1,4-dioxane inputs from the
Deep River and Haw River are resulting in concentrations higher than the 0.35 µg/L water
supply criterion at PWC's intake. PWC believes the situation in the river basin and the rules
require that as other NPDES permits are renewed in the watershed, additional WWTPs will
receive limits for 1,4-dioxane such that the combined discharges will not result in levels that are
higher than the criterion at classified water supply segments. We also believe that an appropriate
compliance schedule for meeting these requirements is 2 years, rather than the 3 years proposed
in the Asheboro draft NPDES permit since current levels well exceed the 0.35 ug/L water supply
criterion. We believe expedient actions are needed to reduce 1,4-dioxane levels sufficiently to
protect human health for drinking water supplies and that compliance can reasonably be
achieved within 2 years. The cost of compliance should be borne by either Asheboro or the
industries that discharge into the Asheboro WWTP rather than the innocent downstream users..
If DWR does not begin to consider downstream water supply uses as well as the multiple sources
of this pollutant in watershed in the development of NPDES permit limits, PWC will consider
administrative and legal appeals to protect its water supply. If you have any questions or require
further information concerning this letter please feel free to contact Mick Noland at (910) 223-
4733 and [e-mail].
Respectfully submitted,
Fayetteville Public Works Commission
AP *&—V
Mick Noland
Chief Operations Officer
Water Resources Division
Cc: Linda Culpepper
Shelia Holman

Table 2
Data Collected by Fayetteville
PWC
P.O. Hoffer
WTF Intake
OWL)
5/13/14
3.90
6/12/14
2.90
7/10/14
5.70
8/4/14
3.80
9/4/14
2.10
10/23/14
2.50
11/12/14
9.60
12/9/14
2.40
1/13/15
2.10
2/11/15
1.80
3/17/15
1.60
4/7/15
2.40
5/13/15
4.50
6/16/15
2.20
7/15/15
1.50
8/18/15
2.50
9/22/15
4.80
10/28/15
2.30
11/11/15
0.99
12/28/15
0.28
1/11/16
1.30
2/24/16
1.50
3/16/16
1.20
4/13/16
1.40
5/11/16
3.90
Table 2
Data Collected by Fayetteville
PWC
P.O. Hoffer
WTF Intake
(µFA)
6/14/16
1.80
7/20/16
2.90
8/23/16
0.59
9/20/16
1.50
10/26/16
0.67
11/28/16
1.40
12/27/16
1.20
1/26/17
5.00
2/22/17
4.80
3/16/17
1.90
4/5/17
2.30
5/3/17
0.81
6/20/17
2.20
7/13/17
0.76
8/15/17
0.66
9/19/17
3.00
10/12/17
2.30
11/14/17
2.50
12/11/17
2.40
1/10/18
5.40
2/21/18
3.90
3/13/18
1.70
4/11/18
1.60
Note: Data collected by
Fayetteville PWC

Water Resources Division
146 N Church Street
PO Box no6
Asheboro, NC 27204-iio6
May 31, 2018
CITY OF
AHI:RORO
S
NORTH CAR O L I NA
Mr. Gary Perlmutter
NCDEQ — Division of Water Resources
Water Quality Permitting Unit
1617 Mail Services Center
Raleigh, NC 27699-1617
Re: Comments for Draft Permit NCO026123
Dear Mr. Perlmutter:
Tel: 336-626-i201 Ext. 258
Fax: 336-626-i2M
RECEIVED/D NR/DVIW
JUN 0 7 2018
Water Resources
Permitting Section
Thank you for your work in preparation of the above referenced permit. City of Asheboro
Wastewater Treatment personnel have some questions and concerns regarding monitored
contaminants and limits listed in the draft permit. Asheboro would like some modifications to the
draft permit before final issuance. The following notes and requests should be considered before
issuing the final NPDES permit.
The WWTP staff requested mass based limits for ammonia in lieu of concentration based limits
during the March 29, 2018 meeting at the WWTP. Upon review of historical data, mass based
limits are attainable. What was the rationale for not using mass based limits in the draft permit?
Asheboro is requesting a three year compliance schedule to research alternative treatment options
that will allow for consistent compliance if mass based limits are not allowed.
Chloride has consistently been sampled in conjunction with Toxicity testing in previous permit
cycles. Asheboro has never failed toxicity based on the chloride results and has had an excellent
track record for passing toxicity testing. Explain what factors, data and calculations the Reasonable
Potential Analysis are based on and confirm how this number is obtained.
Staff reviewed historical influent and effluent data for Cyanide collected since 2010. During this
time no samples ever resulted in above detect for the influent. However, a period of seven days in
September of 2015, three effluent samples resulted in a detection of cyanide. Upon review of the
lab bench sheets, the data indicates that there was an interference with the test method in these
samples and therefore these data points should have not been used or reported. A copy of the
relevant bench sheets are attached with this correspondence. All samples collected from March 2,
2010 to June 4, 2015 and after September 22, 2015 have been recorded as non -detects <0.0lmg/L
(one was <0.005mg/L). The maximum data point used to show reasonable potential for cyanide
should not be considered in light of this interference as it is not an accurate reflection of Asheboro
WWTP effluent. Asheboro requests the limit and monitoring requirements for cyanide be
removed.
Asheboro Staff is actively exploring alternatives in how to meet the new bromodichloromethane
limit. We would like to request a two year compliance schedule to evaluate our disinfection process
Home of the NC Zoological Park

NC 0026123 Draft Permit Comments
5/31/2018
Page 2 of 2
and determine how to effectively reduce our bromodichloromethane concentrations but continue
to properly disinfect the wastewater in order to continue to protect the stream and environment.
Asheboro staff is aware of the concern associated with 1,4 dioxane and will be able to comply with
the terms of the three year compliance schedule. However, Asheboro is not inclined to regulate an
industry that may be discharging 1,4 dioxane based on the inconclusive data regarding the health
effects of this parameter and the lack of enforceable stream standards. We feel identifying the
sources of this contaminant is crucial. However, any sources found should have ample opportunity
to provide options for reducing or eliminating the contaminant while properly budgeting funds
which are anticipated to be substantial. Asheboro believes after the sources are identified, then a
set of standards should be developed and limits applied. Staff would like an explanation of the
legal basis and calculations for the 149 ug/L limit in this draft permit.
Staff has discovered a NPDES permit issued to DAK Americas (permit # NC0003719 — included
with this correspondence) dated March 20, 2018 in the Cape Fear River Basin — direct discharge
to the Cape Fear River. This industry has the potential to be a significant discharger of 1,4 dioxane
based on their manufacturing process as well as toxic review inventory submitted annually to EPA.
This industry is only required to monitor annually and report according to the newly issued permit.
This appears to be a discrepancy and Asheboro staff does not understand the difference in permit
requirements. Staff feels if we are held to this standard then it should be included in the reasonable
potential analysis for all state issued permits and all permit holders should be held to the same set
of standards.
Staff would like an explanation as to why the term for this permit is only four years. NPDES
permits are typically written for 5 year terms. It is understood that we have been operating on an
expired permit for some time but shortening the term of the new permit to four years is a burden
not only for city personnel but also DEQ.
Please carefully consider all of the above comments before issuing a final permit. Written
clarification on all questions posed in this correspondence is requested. I will be glad to discuss
any of these concerns with you and appreciate your prompt and thorough response to this matter.
Respectfully,
i
4
V
Michael D. Rhoney, PE
Water Resources Director
Enclosures
eCopy: Mr. Gary Perlmutter
Ms. Julie Grzyb
Mr. Jeff Poupart
Mr. John N. Ogburn, III
CITY OF
AsHmoju
WATER RESOURCES

Asheboro WWfPCyanide
Date
Influent Effluent
3/2/2010
kS° �;, tjVjj <0.01
3/4/2010
<0.01
6/8/2010
<0.01 <O 01
9/14/2010
<0.01 <0.01
2/17
1 6/7/20111 <0.011 <0.011
7/14/2011 <O.01 <0.01
9/22/2011
<0.01
<0.01
10/4/2011
<0.01
<0.01
11/15/2011
<0.01
<0.01
12/6/2011
<0.01
<0.01
6/12/2012
<0.01
<0.01
9/11/2012
<0.01
<0.01
12/4/2012
<0.01
<0.01
3/5/2013
<0.01
<0.01
6/4/2013
<0.01
<0.01
9/17/2023
<0.01
<0.01
12/12/2013
<0.01
<0.01
3/4/2014
<0.01
<0.01
6/19/2014
<0.01
<0.01
9/9/2014
<0.01
<0.01
12/4/2014
<0.01
<0.01
6/2/2015 <0.0I <0.01
6/4/2015 "pjl� `
<0.005
9/15/2015 <0.01
0.018 SWAUIW
9/18/2015 y+,�r
0.012 � Data
9/21/201.5 }�,'O
0.017 '"L"'
<0.01
<0.01
5/5/2016 <0.01 <0.01
6/14/2016 <0.01 <0.01
7/24/2016 <0.01 <0.01
11/2/2016
<0.01 I
<0.01
12/6/2016
<0.01
<0.01
3/7/2017
<0.01
<0.01
6/8/2017
<0.01
<0.01
1 12/5/20171 <O.Olf <0.011
1 3/6/20181 <0.01I <0.011

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P.O. Box 3729
Sanford, NC 27331-3729
June 8, 2018
Julie A. Grzyb
1634 Mail Service Center
Raleigh, NC 27699-1634
Dear Ms. Gryzb,
C JAir
r ��o
[phone]
c�aRrsREo'�}A FAX: [phone]
Email: [e-mail]
Kifv of unfor.b
Victor I. Czar, P.E.
Public Works Director
The following is a statement of our concerns regarding the pending issuance of a discharge permit to the
City of Asheboro, North Carolina.
We received the Asheboro permit that is going to public notice on May 9th, 2019. As we understand it,
the 1,4-dioxane limit of 149 ug/L is based on the 80 ug/L water quality criteria for Class C waters and the
instream dilution factor to which they are entitled. We feel it's important to review this limit to make
sure it is protective of downstream water uses. 15A NCAC 02B .0203 states "Water quality based
effluent limitations or management practices for direct or indirect discharges of waste or for other
sources of water pollution will be developed by the Division such that the water quality standards and
best usage of receiving waters and all downstream waters will not be impaired." In reviewing the NC
Surface Water Classifications map it appears there is a WS1 and WS IV classification just downstream of
the confluence of the Deep River and Sig Governors Creek, where the criteria for water supplies is 0.35
ug/L. As such, we feel DEQ should conduct some type of analysis to determine if the 149 ug/L limit is
protective of the 0.35 ug/L criteria at the downstream water supplies.
In developing permit limits to reduce 1,4-Dioxane in the Asheboro discharge, the Division of Water
Resources (DWR) does not appear to have considered downstream water supply use in the river basin.
Thus, the permit limit for 1,4-Dioxane appears to be at least 10 times higher than it should be to protect
downstream water supplies. The calculation of the permit limit also did not consider other sources of
1,4-Dioxane in the river basin. Asheboro's NPDES permit is the first of several to be issued this summer
in the river basin that will address 1,4-Dioxane levels. We believe it is important that DWR address this
issue comprehensively with the perspective of water supply use throughout the Cape Fear River basin,
and not just based on contaminant concerns near the point of discharge. Additionally, since the known
sources of Dioxane have been aware of this problem for a number of years, the City of Sanford believes
that compliance should be achieved in two years given the exposure of citizens located downstream
that are drinking the water.

Thank you for your time concerning this matter. We look forward to your consideration.
Sincerely,; "
Victor I. Czar, P.E.
Director of Public Works
Sanford, NC
VC/vrc
Cc: Jessica C. Godreau

Perlmutter, Gary__
From:
Jeff Adkins <[e-mail]>
Sent:
Friday, June 08, 2018 9:36 AM
To:
Perlmutter, Gary
Cc:
Jamie Revels
Subject:
[External] Comments on Draft NPDES Permit for City of Asheboro's Wastewater
Treatment Plant
Mr. Perlmutter,
On behalf of the Town of Cary, I am submitting comment on the Division of Water Resources' (DWR) Draft NPDES permit
for the City of Asheboro's Wastewater Treatment Plant. A public notice of the draft NPDES permit was posted May 9,
2018. The Town is interested in protecting water supplies which utilize the Cape Fear River and its tributaries. Cary has
reviewed the draft permit considering the known levels of 1,4-dioxane, a contaminant of emerging concern, in the Cape
Fear River. While Cary's water supply is Jordan Lake (Haw River Basin) and Asheboro's discharge does not directly impact
the Town's water supply, adequate treatment for 1,4-dioxane is a very important public health issue for water supplies
in the Cape Fear River basin, and the approach taken for Asheboro is likely to influence permit limits established for
other discharges which would be upstream of Jordan Lake as well.
DWR completed a study from 2014 through 2016 on the Cape Fear River Basin including monitoring for 1,4-Dioxane; the
results were published in February 2017. Monitoring is continuing and so far, four primary sources were identified, with
three identified as municipal WWTPs. It appears that municipal treatment facilities are not capable of removing 1,4-
dioxane with current treatment practices, and sources are likely industrial facilities discharging to the WWTPs. This study
includes conclusions that further reductions will be necessary to achieve federal and state health advisory levels in the
Cape Fear River.
One of the sources of 1,4-Dioxane in the Deep, Haw and Cape Fear Rivers is the City of Asheboro's wastewater
treatment plant (WWTP) discharge into a tributary of the Deep River. We ask that DWR consider downstream water use
in the river basin in developing permit limits to reduce 1,4-Dioxane in the Asheboro discharge. Asheboro's NPDES permit
is the first of several to be issued this summer in the river basin that will address 1,4-Dioxane levels. We believe it is
important that DWR address this issue comprehensively with the perspective of water supply use throughout the Cape
Fear River basin, and not just based on contaminant concerns near the point of discharge.
We appreciate DWR's efforts to ensure applications for NPDES discharge permits protect downstream water use and
public health, and encourage you to further consider the appropriate limits to place on 1,4-Dioxane for this and similar
discharge permits. Please feel free to contact me if you need additional information.
Best Regards,
Jeff Adkins
C. Jeff Adkins, PE
Water Resources Manager
TOWN Of CARY
PO Sox 8005 1 Cory, NC 27512-8005

316 N. Academy Street Cary, NC 2
Office: [phone] Mobile: [phone]
Email: ieff.adkins0Wtownofcary.or
E-mail sent to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties.

Perlmutter, Gar
L.
From: Jim Flechtner <[e-mail]>
Sent: Friday, June 08, 2018 12:07 PM
To: Perlmutter, Gary
Cc: Beth Eckert; Lindsey Hallock; Carel Vandermeyden; Frank Styers; Peg Hall Williams
Subject: [External] Draft Permit Comment
Mr. Perlmutter,
Cape Fear Public Utility Authority (CFPUA) provides drinking water to approximately 200,000 people in the City of
Wilmington and greater New Hanover County. We maintain and operate three drinking water systems, and our largest
system uses the Cape Fear River as its source water. After reviewing the City of Asheboro's draft NPDES permit, we have
concerns regarding the draft 1,4 Dioxane permit limit of 149 ug/L and its potential to impact our community's drinking
water supply.
The EPA has established a lifetime drinking water health advisory level for this compound of 200 ug/L and a health
advisory for one in ten thousand cancer risk at 35 ug/L. While health advisory levels are non -enforceable, they are
meant to provide public water suppliers with necessary guidance to ensure they are protecting public health to the best
of their ability.
Many water treatment plants are not able to remove 1,4 Dioxane. Others, such as our Sweeney Water Treatment Plant,
remove approximately 66% (on average) of the concentration that enters our intake at Lock & Dam #1. As a result, many
of the public drinking water intakes downstream of this segment of the basin will have the potential to be impacted by
the discharge of this compound.
in developing permit limits for 1,4-Dioxane in the City of Asheboro discharge, we ask that the Division of Water
Resources (DWR) consider both the designated uses of the river downstream of this discharge location and other
sources of this compound that may be affecting levels in the River. Treating for these compounds at the source, in a
manner consistent with existing drinking water health advisory levels, will minimize impacts to downstream
communities that may otherwise be required to install or increase treatment at the cost of their communities to ensure
protection of public health.
Additionally, because the existence of 1,4 Dioxane in wastewater discharge has been recognized for several years, we
request the draft compliance timeline of three years should be reduced to ensure downstream exposure to this
compound is minimized as quickly as possible.
Asheboro's NPDES permit is the first of several that may be issued this summer that will address 1,4-Dioxane levels. We
appreciate the efforts of DWR to communicate with other users of the River, and to issue limits for compounds such as
1,4-dioxane. CFPUA believes it is important to address this issue comprehensively by considering water supply uses
throughout the Cape Fear River Basin.
Regards,
James R. Flechtner, PE
Executive Director

Cape Fear Public Utility Authority
910-332-6669

PUBLIC NC IFICATIOM
NONE — No SIU's in SNC
SIU's with NO VIOLATIONS
12 SIU's were violation free in 2020.
® Bossong, Energizer Plant 1, Energizer Plant 2, Georgia Pacific,
Kayser Roth, MAS, Matlab #4, Matlab #8, Premier Powder
Coating, Starpet and Wells Hosiery.
CONSENT ORDERS AND COMPLIANCE SCHEDULES
No consent orders or compliance schedules
A i u C AND CONSTRUCTION INFORMA i it.
The city of Asheboro received an email on April 15, 2019 from
Starpet (#2228) requesting an Authorization to Construct for the
installation of a pretreatment system to remove 1,4 Dioxane. The
Authorization to Construct was signed and issued April 15th 2019.
Starpet was authorized to install a prebuilt KOCH Modular System
consisting of a 72' stripper column along with a reboiler, shell and
tube condenser and heat exchanger. The tower arrived at the
facility on January 14112020. Due to COVID 19 and the weather,
the pretreatment system began 24 hour operation on November
20th.
SIU'S WITH MISSING DATt
None
NON-SIU SNC
• None
• 3 permitted Non-SIU's
Dental Amal am Rule
Total number of dental offices — 28 with 100% compliance.
7